United States        Office of
Environmental Protection   Emergency and
Agency           Remedial Response
                               EPA/ROD/R03-91/137
                               June 1991
Superfund
Record of Decision:
William  Dick Lagoons, PA

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50272-101
REPORT DOCUMENTATION i. REPORT NO. 2.
PAGE EPA/ROD/R03-91/137
4. TWe *nd SubtWe '
SUPERFUND RECORD OF DECISION
William Dick Lagoons, PA
First Remedial Action
r. Authors)
8. Performing Orgainlzation Nuna end Addre**
12. Sponsoring Organization Nwne and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Redpienr* Accession No.
5. Report Date
06/28/91
6.
8. Peffoimlng Organization Rapt No.
10. Pro|ect/Taak/Work Ural No.
1 1. Coninct(C) or GrtmjG) No.
(C)
(G)
13. Type of ReportA Period Covered
800/000
14.
 IS. Supplementary Note*
 16. Abstract (Limit: 200 word*)
   The 4.4-acfe William Dick Lagoons  site is a chemical wastewater disposal site in West
   Cain Township,  Chester County, Pennsylvania.  Land use in  the  area is predominantly
   residential and agricultural, with adjacent woodlands.  An estimated 30 residences
   located within  1,000 feet of the site use private wells for their drinking water
   supply.   Two other Superfund sites are near the site:  the Blosenski Landfill located
   1.7 miles southeast; and the Welsh Landfill, 5 miles to the northwest.  Originally,
   the site  consisted of three unlined earthern lagoons or ponds  covering 2.2 acres and
   an associated borrow area.  From the 1950's to 1970, Mr. William Dick used the
   lagoons to dispose of wastewater left from cleaning the interiors of chemical and
   petroleum tank  trailers owned primarily by Chemical Leaman Tank Lines, (CLTL), and
   residual  chemical products.  In 1970,  the State ordered the lagoons closed after 37
   wild geese descended into the lagoons,  and were coated with waste.  Later in 1970,
   vandalism caused the release of an estimated 300,000 gallons of wastewater into Birch
   Run, a  tributary of the West Branch of Brandywine Creek.   As a result of this
   discharge,  more than 2,600 fish died,  and water supplies that  used Brandywine Creek
   as a water source were closed.  In 1971,  William Dick and  CLTL began lagoon closure

   (See Attached Page)
 17. Document Andysl* a Descriptor*
   Record of Decision - William Dick Lagoons, PA
   First  Remedial Action
   Contaminated Medium:  gw
   Key  Contaminants:  VOCs  (benzene,  PCE, TCE), other  organics (phenols), metals

   b. Identifiera/Opan-Ended Term*
   e. COSATI Held/Group
18. Av*il*bilty Statement
10. Security CtM* (Thi* Report)
None
20. Security Class (Thte P*ge)
None
21. No. of Pages
124
22. Price
(See AKSI-239.18)
                                     See Inatructione on Henna.
OPTIONAL FORM 272 (4-77)
(Formerly NT1S-35)
Department of Commerce
         . 7

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EPA/ROD/R03-91/137
William Dick Lagoons, PA      .-•
First Remedial Action                       '

Abstract (Continued)

as part of a State agreement.  Activities during 1971 included the addition of alum to
the wastewater, spray irrigation of the treated wastewater into the woods, and covering
and revegetating lagoons with soil.  During 1985, site studies identified numerous
organic compounds in soil samples, two spring-fed water supplies, and five wells.  In
1988, EPA required CLTL to fence around the site, conduct yearly monitoring of
residential wells, and install point-of-entry treatment systems for selected private
wells.  In 1990 and 1991, sampling revealed TCE arid other contaminants in 30 to 40
private wells.  As a result, CLTL installed point-of-entry carbon filtration units in 12
of the 30 to 40 homes where contamination in well water exceeded MCLs.  This Record of
Decision (ROD) provides an interim remedy and addresses contaminated residential water .
as Operable Unit 1  (OU1) and ground water as OU2.  A future ROD will address source
control and will provide a remedy for the cleanup of contaminated soil.  The primary
contaminants of concern affecting the ground water are VOCs including benzene, PCE, and
TCE; other organics including phenols; and metals.

The selected remedial action for this site includes providing an alternate water supply
to affected residences by extending the City of Coatesville Authority's water line;
installing a water storage tank near the site to provide storage and pressure feed for
the water line connections; monitoring nearby springs; collecting hydrogeologic data;
conducting initial pumping and onsite treatment of the contaminated ground water plume
using treatment components that will be selected during interim remedial design, which
are expected to include chemical precipitation and one of more of the following:
granular activated carbon, chemical oxidation, and air stripping, with possible emission
controls; discharging the treated water onsite to surface water; installing monitoring
and recovery wells to further characterize the entire plume; and implementing
institutional controls including ground water use restrictions.  The estimated present
worth cost for this remedial action ranges from $5,991,000 to $7,028,000, which includes
an annual O&M cost of $305,000 to $330,000 for years 0-5, and $21,000 to 46,000 for
years 6-30.

PERFORMANCE STANDARDS OR GOALS:  For OU2, EPA is invoking a waiver for Federal and state
ground water clean-up standards because the remedial action is an interim measure.
Chemical-specific ground water clean-up goals will be set in the final remedy.

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                        RECORD OP DECISION


                     WILLIAM DICK LAGOONS SITE

                            DECLARATION
8ITB NAME-AND LOCATION

William Dick Lagoons  Site
West Cain Township, Chester County, Pennsylvania


STATEMENT OP BASIS AND PURPOSE

This decision document presents the selected remedial action for the
William Dick  Lagoons Site in West  Cain Township,  Chester County,
which  was  chosen  in accordance  with  the  requirements of  the
Comprehensive Environmental  Response,  Compensation, and Liability
Act of  1980 (CERCLA), as amended by the Super fund Amendments and
Reauthorization Act of 1986  (SARA) and, to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP).  This decision document explains the  factual and legal basis
for selecting the remedy for this site.

The Commonwealth  of  Pennsylvania agrees with the selected remedy.
The  information  supporting  this  remedial  action  decision  is
contained in the Administrative Record for this site.
ASSESSMENT OP THE SITE

Pursuant to duly delegated authority,  and pursuant to Section 106
of CERCLA, 42 U.S.C Section 9606, I hereby determine that actual or
threatened  releases of  hazardous  substances  from this  site,  as
discussed in  the Summary  of  Sit* Risks section  set  forth in the
attached Record of Decision (ROD), if not addressed by implementing
the response action selected  in this ROD, may present an  imminent
and  substantial  threat  to  public   health,   welfare,   or  the
environment.
DESCRIPTION OF THE SELECTED REMEDY

Three  operable units  have been identified  at the  William Dick
Lagoons Site. These operable units include:

     . Alternate Water Supply -  Operable Unit 1
     . Groundwater - Operable Unit 2
     . Source Control - Operable Unit 3

EPA is deferring selection of a remedy for Source Control - Operable
Unit 3 and will address this unit in a subsequent Record of Decision
(ROD).    The  Source  Control  ROD  will   present  a   decision  on
remediation of the contaminated  soils at the site.

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In this ROD, the Environmental Protection Agency  (EPA) has selected
remedies for Operable Units 1 and 2.  The major components of each
are as follows:

     ALTERNATE WATER SUPPLY

     1. The City of Coatesville Authority (CCA) water line will be
     extended  from its  current location  on  State  Route  340  to
     service impacted or potentially impacted residents located near
     the William Dick Lagoons Site.

     2. The pump station located on Route 340 near Sandy Hill Road
     will be upgraded to meet additional pumping  needs, and a water
     storage tank will be installed near the site.

     3.  As  available,  through   appropriate  legal  authority,
     institutional  controls  will be  implemented to:  (a)  address
     water supply issues for newly constructed  homes near the site,
     and  (b)  protect the  health of  those residents choosing to
     maintain the use of private wells.
     GROUNDWATER

This remedy is considered an interim action  for groundwater cleanup
because  final  groundwater cleanup levels cannot  be determined at
this time.  The primary objectives of the remedy are to minimize the
migration of groundwater contaminants,  to initiate the reduction of
toxicity, mobility  and volume of groundwater contaminants,  and to
collect  data  on aquifer  and contaminant response to remediation
measures.  A final  action addressing groundwater will be selected
in a later ROD after the data gathered  during the  implementation of
the interim action are evaluated.

     The interim remedy contains the following major components:

     1. Further study will be performed to adequately define site
     hydrogeologic   conditions.     This  work  will  include  the
     installation and sampling of monitoring wells, collection of
     water level measurements,  and performance of aquifer tests.

     2.  Groundwater  extraction wells  will be   installed  at and
     surrounding the site. Groundwater  will  be pumped to a treatment
     plant  designed  and   constructed   to  remove  site-related
     contaminants.   The actual treatment components of the plant
     will be determined during the initial  phases of this remedy.

     3. Treated groundwater will be discharged to a nearby stream.

     4. Groundwater monitoring of selected wells will be  performed.

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 DECLARATION OF STATUTORY DETBRMZNATION8

 The selected  remedies  are protective  of human  health  and the
 environment,  are cost-effective, and  comply  with  the Federal and
 State  requirements  that are  legally  applicable  or  relevant and
 appropriate to the remedial action (referred to as  ARARs)  except to
 the extent  that such requirements are waived.   For  Operable Unit 2,
 a  waiver  is  invoked  for  Federal  and State  groundwater  cleanup
 standards per  the the  justification  requirements of CERCLA Section
 121 (d) (4) (A) .  This section of the Act permits use of a waiver when
 the proposed remedial action is an interim measure which is expected
 to  be  followed by a complete measure that will attain all  ARARs.


 The remedy  for Operable Unit 1 does not satisfy  the  statutory
 preference  for treatment as a principal element because EPA believes
 that  treatment  of  private well  water  at  this  site  is  not  a
 practicable solution as a long-term remedy. Provision of  regulated
 public  water,  from  a source unaffected by the site, was  deemed to
 be  a  more  effective and permanent  solution.  Treatment of site
 groundwater will  occur under the selected remedy for Operable
 Unit 2.

 The remedy  for Operable Unit 2 satisfies the statutory preference
 for remedies that employ treatment that reduce toxicity,  mobility,
 or  volume to the  maximum extent practicable.   The remedy  is  not a
 permanent solution, however, as existing hydrogeologic data are not
 adequate to make an informed  decision on a  final remedy  at this
 time.   The  remedy may  utilize  alternative  treatment of groundwater
 depending on the results of treatability work  during initial phases
 of  this remedy.

 For Operable Unit 1,  the five-year review required under Section 121
 (c) of  CERCLA, 42 U.S.C. Section 9621 (c) , will not apply to this
 action  since the remedy will not result  in  hazardous substances
 remaining onsite  above health-based  levels.

 For Operable Unit 2, the selected remedy is an interim action for
 addressing the contaminated groundwater plume  at the site.  For this
 reason, a final remedy will be  selected for this unit in the future.
 EPA estimates that a final ROD for groundwater can  be  issued within
 five yearsr after commencement  of  the  Operable   Unit 2  remedial
 action^- however, the Agency will conduct a five- year  revieir should
 the final ROD  not be issued within this time  frame.
   .
Edwin B. Erickson                          Date:
Regional Administrator
EPA Region III

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                                         William Dick Lagoons ROD


                        RECORD OF DECISION
               WILLIAM DICK LAQOON8 SDPERFTOD SITE


I. Sit* Location  and  Description

The William Dick  Lagoons Site  (the site) is located in West Cain
Township, Chester County, Pennsylvania approximately 3.5 miles
south-southeast of the Village of Honey Brook.  The 4.4 acre site
is located within a larger 105-acre parcel of land and is
situated in a rural wooded setting on the crest of a small ridge
known as the Baron Hills.  It is accessible via Telegraph Road,
at approximately  2,500 feet west of North Sandy Hill Road.  The
nearest residence is  located roughly 300 feet to the north and
approximately thirty  homes are within 1000 feet of the Site.
Figures l and 5 provide a perspective of the site setting in
relation to residential proximity.

The site currently appears as a sparsely vegetated field behind
several residences located on the south side of Telegraph Road.
The site is obscured  from view by both the surrounding trees and
its position at the crest of a hill.  Land use surrounding the
site is primarily residential, with a generally spars* population
density.  Housing development in the area is progressing
relatively quickly and several new homes have been built since
the commencement  of site remedial investigative activities.  The
majority of the residences are single family dwellings with
private wells and onsite septic systems. Several trailer parks
and a campground  exist within the vicinity of the site and two
separate automobile junkyards are located just north of the site.
Much of the area  extending outward from the near-site residences
is actively farmed.   Important crops include corn, wheat, oats,
soy beans and hay.  Dairy cattle are also raised within the
surrounding countryside.

Two other Superfund sites are located within five miles of the
site.  The Blosenski  Landfill is located approximately 1.7 miles
to the southeast  and  the Welsh Road Landfill is roughly 5
miles to th* northwest.


II. Site. History  and  Enforcement Activities	
Waste disposal activities at the Site were initiated by its
former owner, Mr. William Dick, in the late 1950s through May
1970.  Originally, the Site consisted of three unlined earthen
lagoons or ponds that were used for the disposal of wastewater.
The lagoons covered approximately 2.2 acres of the 4.4 acre Site;
the remaining 2.2 acres served as a borrow area for soil used to
construct the compacted earthen ridges or berms around the
perimeter of the lagoons (See Figure 2).

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                                         William Dick Lagoons ROD
 Principally,  the  lagoons were used to dispose of final rinse
 waters  from the interior cleaning of tank trailers owned by
 Chemical  Leaman Tank Lines  Inc.  (CLTL).  However, it has been
 reported  that minor amounts of residual chemical products were
 occasionally  disposed of in the  lagoons.  The tank trailers were
 used  for  transporting petroleum  products, latex, rhoplex, and
 resins.   Following  the rinsing and cleaning of the tank trailers
 at  Chemical Leaman's Downingtown, Pennsylvania facility, the
 rinse water was delivered to the lagoons by tanker approximately
 every three days  for disposal.

 On  April  26,  1970,  37 wild  geese were shot at the site by the
 district  game protector for humane reasons.  The birds' feathers
 were  coated with  waste after the birds descended onto the
 lagoons.   In  May  1970,  the  Pennsylvania Department of Health
 (PADH)  ordered the  lagoons  closed.  On June 7, 1970, vandals
 allegedly caused  a  breach in the berm of the second lagoon,
 resulting in  the  release of an estimated 300,000 gallons of
 wastewater that moved into  Birch Run, a tributary of the West
 Branch  of Brandywine Creek.  The discharge caused the death of
 more  than 2,600 fish and the closure of public water supplies
 which used the creek as a water  source as far downstream as
 Wilmington, Delaware.

 In  early  1971, per  agreement with PADH, CLTL and William Dick
 began work to close the lagoons.   This activity included the
 addition  of alum  to the lagoon wastewater, and spray irrigation
 of  the  "treated"  wastewater into the woods adjacent to the
 lagoons.   Settled residue remaining in the bottom of the lagoons
 was buried by pushing the earthen berms into the lagoons.  The
 lagoons were  completely filled in with soil and a vegetative
 cover planted on  the surface.

 In  April  1985, under the authority of the Comprehensive
 Environmental Response, Compensation, and Liability Act  (CERCLA)
 of  1980,  an EPA contractor  performed a site sampling inspection
 of  the former lagoon site and collected well water samples from
 several surrounding residences.  This inspection was conducted in
 response  to a 1981  CERCLA notification to EPA by CLTL which
 indicated that the  former lagoons may contain hazardous
 substance*.   During the inspection, elevated levels of numerous
 organic compounds were detected  in the soil samples collected
 from  the  former lagoon area.  A  few site-related compounds also
were  found in two residential wells.  In May 1987, additional
 sampling  of 28 residential  wells by EPA's Technical Assistance
Team  (TAT)  found  trichloroethene (TCE) to be the most prevalent
organic compound, at the highest concentration, in groundwater.
This volatile organic compound (VOC), a suspected carcinogen and
common industrial solvent,  was detected in two spring-fed water
supplies  and  five wells.  Following the completion of these

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                                 3        William Dick Lagoons ROD

 follow-up evaluations,  the  site  was  listed in July 1987 on the
 National  Priorities List (NPL) of hazardous waste sites eligible
 for  cleanup under Superfund.

 As part of "an immediate action to minimize public exposure to
 site-related contaminants,  CLTL  and  EPA entered into negotiations
 in July 1987 to limit access to  the  area of the former lagoons,
 conduct more extensive  sampling  of residential wells, and supply
 point-of-entry water treatment units to homes with unacceptable
 levels of contaminants  in well water.  In September' 1987, CLTL
 contracted with the Environmental Resources Management Group
 (ERM) for this work.    On January 27, 1988, EPA and CLTL entered
 into an Administrative  Order on  Consent ("1988 Removal Order")
 which required CLTL to  install a fence around the site, conduct
 at least  yearly monitoring  of residential wells (more frequent
 monitoring in some cases),  and install point-of-entry treatment
 systems for home well water exceeding Maximum Contaminant Levels
 (MCLs).   The fence was  installed at  the site in February 1988.
 The  sampling and treatment  unit  provision requirements of the
 Consent Order continue  to be in  effect.

 As a result of CLTL's three initial  sampling events in 1987, TCE
 was  detected at 23 of the 58 locations sampled.  As of October
 1990, approximately 130 home wells had been sampled. Of the 130
 home wells sampled,  30  to 40 are believed to contain site-related
 contamination,  the primary  contaminant being TCE.  Twelve of the
 30 to 40  homes have been found to have levels of TCE
 contamination above EPA's MCL of 5 ppb.  Trace concentrations of
 a few additional contaminants believed to be site-related have
 been found in limited homeowner  wells, although none exceed MCLs.
 These additional compounds  include chloroform, 1,2-
 dichloroethane,  chlorobenzene,   1,4- 1,3- and 1,2-
 dichlorobenzene,  1,1- and 1,2- dichlorethene, styrene, toluene,
 1,1,1-trichloroethane,  tetrachloroethene, and di-n-butyl
 phthalate.    During a sampling event in March of 1991, the
 compound  bis (2-ethylhexyl) phthalate  was found in one well at a
 level exceeding the proposed MCL of  4 ppb (because this compound
 has  appeared in laboratory  "blank" samples, its possible presence
 in several additional wells exceeding the MCL cannot be
 confirmed.);   This March 1991 occurrence marks the first time
 that a compound other than  TCE,  determined to be site-related,
 has  been  detected in a  homeowner well above a proposed or final
MCL. (The.affected well water is treated via carbon filtration.)

 CLTL has  supplied bottled water  to all homes  (approximately 34)
 in which  TCE levels between 0 to 5 parts per billion  (ppb) were
detected  in residential wells.   The  company has supplied bottled
water under its own initiative;  CLTL is not required to do so by
 EPA.  To  date,  CLTL has installed point-of-entry carbon
 filtration units in the twelve homes where TCE concentrations in
well water exceed EPA's MCL of 5 ppb.

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                                4        William Dick Lagoons ROD

On September 14, 1988, CLTL and EPA signed a second
Administrative Order on Consent, requiring that a Remedial
Investigation/Feasibility Study (RI/FS) be conducted.  CLTL again
obtained the services of ERM for this work.  The RI began in
December 1988 and progressed throughout the Spring and Summer of
1989.  Based upon both EPA- and ERM- identified data gaps, a
second shorter phase of RI work was initiated in October 1989.
An interim RI report was submitted to EPA in December 1989.
After EPA comments, a more detailed draft RI report, along with a
draft FS report and Risk Assessment (RA), were submitted for EPA
review on March 8, 1990.  Following receipt of EPA comments, a
Preliminary Final RI/RA/FS was submitted on September 6, 1990.
(The RI, RA and FS reports are described as "preliminary final11
until minor changes in language and/or emphasis are incorporated
per EPA direction.  Any changes to be made to the RI/FS/RA
documents which have a bearing on EPA's decision on a remedial
action have already been considered and documented in the
Administrative Record for this site.)

On September 24, 1990, EPA informed the Rohm & Haas Company of
Philadelphia, Pennsylvania of its potential responsibility
regarding contamination at the site.  This notification was based
on information received on the company's past involvement at the
site through interviews with former CLTL employees.


III. COMMUNITY RELATIONS HISTORY

In order to keep the community aware of ongoing actions,
understand residents' concerns, and address public involvement
requirements under CERCLA, EPA instituted several measures to
contact and correspond with site residents.  Following is a
listing of the community relations efforts conducted by EPA:

     Summer 1987 - meeting held with approximately 35
     residents at a local resident's home to discuss the
     initial sampling results of private wells;

     February 1988 - meeting held at Wagontown Fire Hall
     with approximately 25 residents to discuss upcoming
     RI/FS work at the site and to explain the Superfund
     process;
     February 1988 to March 1990 - this period was mainly
     devoted to telephone contact with individual residents
     concerning ongoing RI/FS work and the collection and
     analysis of residential well samples;

     March 1990 - "at home" interviews conducted with
     approximately 15 residents to gauge community interest,
     concerns, and opinions;

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                                5        William Dick Lagoons ROD

     June  1990  - completion of a Community Relations Plan
      (CLP) the  goal of which is to establish and maintain
     open  communication among Federal, State, and local
     officials, and the residents of the site area; issued
     two fact sheets to residents on the site mailing list
     explaining the Superfund remedial process and
     procedures for obtaining a Technical Assistance Grant
      (TAG);

     July  1990  - issued a fact sheet to mailing list site
     residents  and government officials describing the RI/FS
     results and upcoming actions;

     July  1990  - held public meeting with approximately 85
     residents  to explain the RI/FS results, risk posed by
     the site,  future site actions, and the pros and cons of
     the potential remedial alternatives for an alternate
     water supply; solicited public comment on the
     residents' preference for alternate water;

     December 1990 - issued fact sheet informing residents
     that  the Proposed Remedial Action Plan (PRAP) will be
     issued in  January 1991;

     January 1991 - issued the PRAP for the site via press
     release, newspaper publication, and direct mailing to
     all individuals on the site mailing list; announced
     public meeting in February;

     February 1991 - held public meeting with approximately
     70 interested individuals to present EPA's rationale
     for the proposed remedial alternatives presented in the
     PRAP; solicited comments on the PRAP;

     February 1991 - conducted a telephone survey to reach
     50 residents residing within the groundwater
     contaminant plume to determine their preference for an
     alternate  water supply and their position on EPA's
     proposed remedy for alternate water.


In addition, EPA has frequently placed copies of RI/FS technical
reports for-pubtic review at the West Ca-ln Township Building and
has continually updated the Administrative Record placed at this
location.

Based on public comments received to date, community concerns
principally relate to the contamination of private well water,
the nature of the final remedy for this problem, and the time
required for completion of the remedy.  Individuals have also
expressed an interest in the type of remedy to clean up soils
at the site.  At the February 14, 1991 public meeting, residents

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                                6        William Dick Lagoons ROD

expressed a strong desire to have the site responsible party
compensate residents for any future water cost, whatever the
chosen remedy.  During the PRAP public comment period, several
residents expressed a desire to have the site returned as near
as possible to its original uncontaminated state.  EPA's response
to all comments received during the PRAP public comment period
appear in .the Responsiveness Summary at the end of this ROD.


XV. SCOPE AND ROLE OP RESPONSE ACTION

   Based on the results of the Preliminary Final RX/FS, EPA has
decided that remediation of the entire site can best be
approached by considering the site as consisting of three
separate "units".  These units include:

  (1) Residential Water Use (i.e. Alternate Water Supply)
       - involves a remedy to protect residents from contaminated
         private well water

  (2) Groundwater
       - involves a remedy to remediate all or portions of the
         contaminated groundwater aquifer

  (3) Source Control
       - involves a remedy to clean up contaminated soils at the
         site; contaminated soil is the media considered to be
         the "principal threat" at the site per the definiton of
         principal threat in the NCP. (See 40 C.F.R. Section
         300.430 (a)(1)(iii).)


At this time, EPA has decided to defer selection of the remedy
for Unit 3 - Source Control for the following reasons:

     (A)  unresolved technical questions regarding the
     appropriateness of the soil leaching model used to
     calculate the type of protective cover needed at the
     sit* following completion of EPA's proposed remedy of
     Thermal Desorption;

     (B)  unresolved technical questions concerning soil
     cleanup -criteria at the site as it involves the
     identification and concentration of contaminants to be
     included in the established cleanup levels.  In
     addition, concerns regarding the ability of EPA's
     proposed remedy to meet the cleanup criteria proposed
     in the Preliminary Final FS;

     (C)  State concerns regarding attainment of State
     groundwater ARARs using EPA's proposed remedy;

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                                7        William Dick Lagoons ROD

      (D) recent evaluation and discussion on the potential
     usefulness and appropriateness of a Treatability Study
     before a source control remedy is selected.

In contrast to the approach presented in the Preliminary Final
FS, EPA has chosen to evaluate the two remaining units
independently against the nine criteria required under the
Superfund program  (See Figure 3).  This approach differs from
that presented in the Preliminary Final FS which evaluated each
of the units against EPA's three screening criteria'
 (Effectiveness, Implementability and Cost) before developing
site-wide alternatives for nine-criteria evaluation.  Although
the method presented in the FS is in accordance with EPA
guidance, the Agency has decided to perform a complete evaluation
of individual units in this ROD to present a clearer view of why
each proposed unit remedial alternative was chosen.


     Regarding Unit (2) Groundwater. the Agency does not believe
that sufficient information exists at this time to  conclude that
the groundwater can be practicably restored to its  beneficial use
as a drinking water source within the areas of contamination.
This belief is based on the site area's complex hydrogeology and
the relatively high levels of contamination found in the deep
fractured aquifer directly below or immediately surrounding the
former lagoons.  For this reason, EPA is proposing  an interim
remedial action for the Groundwater unit which will obtain
information about the response of the aquifer to remediation
measures in order to define final cleanup goals.  This interim
remedy will also initiate the reduction of toxicity, mobility and
volume of contaminants as well as limit contaminant migration.
After a period of approximately five years of interim remedy
operation, EPA will select a final remedy for groundwater cleanup
in a subsequent ROD.

     EPA has also chosen to revise or add to the number of unit
alternatives screened or evaluated in the Preliminary Final FS.
Specifically, the Agency has added an alternative for the
Groundwater Unit which calls for pump and treat at  and adjacent
to the sit* only.  EPA believes this alternative warrants final
consideration.  The Agency has chosen to delete, in contrast to
the Preliminary Final FS, the specific type of treatment
technologies to- be employed for groundwater remediation?  EPA
believes that a decision on the type of groundwater treatment at
this stage is premature and will best be determined during
remedial design following the performance of treatability
studies.  EPA has also deleted Spring Water Treatment of the
Gregor property spring as a remedial option.  The Agency believes
that the spring is most efficiently addressed by an interim
groundwater remedy which will attempt to remediate  water
discharging at the spring.

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                                8        William Dick Lagoons ROD

     Finally, in contrast to the Preliminary Final FS, the Agency
does not view the discharge of treated groundwater as a separate
unit requiring detailed evaluation.  Treated groundwater is
generated as a result of a selected remedy at a site and is not
an existing condition necessitating a cleanup option.  Although
the detailed evaluation in the Preliminary Final FS is
appreciated, the Agency believes that only one discharge
alternative, Stream Discharge, is applicable for this site.  The
rationale for this decision can be obtained from the discussion
presented in the Preliminary Final FS as well as in the
Responsiveness Summary.


V. SUMMARY OF SITE CHARACTERISTICS

The major findings of the Preliminary Final RI report are
summarized below.  A detailed discussion of all site conditions
can be found in the Preliminary Final RI.


   Geology and Qroundvater:

          The site is located in the Honeybrook Uplift in an
          outcrop belt of a geological structure known as the
          Chickies Formation. It is situated on the crest of
          the Baron Hills Anticline in a fault block bounded
          by two normal faults to the north and south.  (The
          Chickies is a white to light grey quartzite
          with interbedded phyllitic beds.)  The site is
          located on a groundwater divide.  The bedrock
          beneath the lagoons is highly weathered and forms a
          thick saprolite up to 100 feet thick.  Although
          laboratory analysis indicates that the saprolite
          material is of low permeability, contaminants have
          migrated to the groundwater table (approximately 50
          feet below the surface) through joints and fractures
          in the saprolite.

          Groundwater at the site, as determined by monitoring
          well sampling, is contaminated primarily by VOCs
          and, to a lesser extent in frequency and
          concentration, semi-VOCs.   Again, TCE is the
    -  -    predominant VOC (average concentration - 1200-ppb,
          maximum concentration - 16,000 ppb)  and phenol is
          the predominant semi-VOC (average -800 ppb, maximum
          » 14,000 ppb).  Other compounds found less
          frequently and/or in lower concentrations include
          chloroform, benzene, acetone, 2-methylphenol, 4-
          methylphenol, isophorone and other organic
          compounds.  Vinyl chloride, a contaminant of
          specific concern from a human health standpoint, was
          detected on only one occasion in one monitoring well

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                      9        William Dick Lagoons ROD

during  post-RI/FS sampling.  To date, three to four
rounds  of monitoring well samples have been
collected,  dependent on well location.  See Table 1
for  a listing of maximum and average groundwater
concentrations in onsite monitoring wells.

'By far, the highest groundwater concentrations of
organic chemicals are found in two of the twelve
monitoring  wells installed at the site, wells MW-5
and  MW-7.   In addition, the seven deeper monitoring
wells (110  to 397 feet deep) are generally more
contaminated  than the six shallow wells (70 to 80
feet deep).   All wells were installed in bedrock
(See Figure 4).  At well MW-20, the southwest corner
of the  site,  groundwater was found to be
contaminated  down to a depth of 397 feet.
The groundwater surrounding the Site utilized by
residents  is  also characterized by low-level TCE
concentrations.  Of the approximately 130
residential wells sampled to date (See figure 5),
roughly 30 to 40 appear to have some site-related
contamination.  Of these 30 to 40, eleven have
concentrations of TCE in the 5 to 15 ppb range  (the
drinking standard is 5 ppb) and one well contains
TCE at levels from 20 to 280 ppb, dependent on the
sampling season.  Many of the residential wells
identified during commencement of the Consent Order
with CLTL  have been sampled a total of nine times to
date.  Homes  within a predetermined radius of the
site are sampled at least once a year; those homes
found to have a detectable level of TCE are sampled
twice a year.  Due to the number of homes within the
predetermined radius of the site (1 mile south, 1/2
mile north) the sampling schedule is set up so that
samples are collected from 20 to 25 home wells every
quarter of the year.

The results of the RZ and three years of residential
sampling data indicate that TCE levels are not
significantly increasing at the boundary of the
contaminant plume where residential wells are—
generally  located.  Based on this information, the
boundary of the groundwater area affected by site-
related contaminants has been relatively well-
defined (See  figure 6), although additional
characterization work is needed.

The regional  groundwater flow at the Site appears to
be toward  the southeast.  Three significant bedrock
fracture features (two of which are faults) are

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soil:
                             10        William Dick Lagoons ROD

       believed to exist in the vicinity of the site.   Each
       appears to provide pathways for contaminant
       migration to vary from the overall southeasterly
       flow direction and two may serve to partially block
       the flow of groundwater beyond the fractures.
       However, it seems that intersecting smaller
       •fractures act as conduits for groundwater
       contamination to migrate beyond the three larger
       fractures, resulting in a rather complex flow
       pattern.

       Additional groundwater monitoring wells are needed
       and further studies are necessary to confirm the
       theory that groundwater flow is controlled by site
       geologic fractures, to determine the extent of
       groundwater flow to the north, and to determine the
       severity of contamination in the area generally
       south of the site.
       Soils in the former lagoon are contaminated by
       volatile organic compounds (VOCs),  principally
       trichloroethene (TCE), which was used at one time to
       clean out chemical tank trailers disposing material
       at the site, and semi-VOCs, which appear to be
       primarily associated with fuel oil residues.  Other
       than TCE, compounds found at significant levels in
       site soils are 2-butanone, toluene, styrene,
       xylenes, ethylbenzene, chlorobenzene, and
       tetrachloroethene (all VOCs); and several semi-
       VOCs, especially phenol, 1,2,4-trichlorobenzene,
       naphthalene and bis(2-ethylhexyl)  phthalate.  The
       pesticide ODE was also found in concentrations
       suggesting that it was disposed of at the site.
       Table 2 presents a listing of average and maximum
       soil contaminants.

       Soils are heavily contaminated from a depth of about
       on* foot below the surface down to approximately 20
       feet, depending on site location.   Former lagoon /I
       Is- most heavily contaminated, with- concentrations-
       decreasing as one moves across the site to former
       lagoon #2 and lagoon #3 (See Figures 2 and 7).
       Because groundwater is contaminated, and the water
       table lies at approximately 50 feet below the site,
       low-level subsurface soil contamination exists as
       deep as 50 feet although a significant drop-off in
       levels occurs after approximately 20 feet (See
       Figure a and 9).  Contamination of soils at and
       below the surface appears to be confined to the area

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Air:
                             11       William Dick Lagoons ROD

       of the  three former  lagoons.

       As a  result of the reported occasional burning of
       floating oils on the surface of the lagoons, the RI
       included an analyses for dioxins in the soil
        (dioxins can be created from the burning of
       chlorinated phenols  and hydrocarbons).  Although
       dioxins were detected in the parts per trillion
        (ppt) range (See Table 3), the levels do not present
       an unacceptable risk and will not require
       remediation.  EPA generally considers the potential
       need  for remediation of dioxins when levels are
       found to exist in the ppb range or higher.

       Based on the results of RCRA Subtitle C 40 CFR
       Section 261.24 Toxicity Characteristic Leaching
       Procedure (TCLP) analyses of three of six soil
       boring  samples, the  soil/waste mixture at the site
       would be classified  as characteristic hazardous
       waste under RCRA.  In addition, based on EPA's
       understanding of the nature of the operations
       leading to  the generation of waste materials
       disposed of at the site, EPA Region III has
       interpreted RCRA's Land Disposal Restrictions (LDR)
       of November 8, 1984  to suggest that the soil/waste
       mixture also would be classified as a land disposal
       restricted  hazardous waste under the RCRA program.
       The waste disposed at the site is considered by the
       Agency  to be F001-F005 waste.

       The former  spray irrigation and berm borrow areas
       (See  Figure 7) only  have minor levels of organic
       contamination which  is not expected to present a
       direct  contact risk. (See Table 4 for spray
       irrigation  area sampling results.)

       The site does not appear to have caused inorganic
       contamination of site soils, although levels were
       occasionally above background concentrations.  This
       finding is  in agreement with our understanding that
       organic chemical rinsewaters and wastes were
       disposed of at the site.
       The site does not negatively affect air quality
       based on real-time air monitoring  results collected
       during boring and well installation activities as
       well as air dispersion modeling  conducted for the
       Risk Assessment.

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                                12       William Dick Lagoons ROD
    Surface Water and Sediments:

           Surface water  and  sediment  samples were collected
           from fifteen stations  in three streams surrounding
          ' the site.   These streams include the West Branch of
           Brandywine Creek,  Birch Run and Indian Spring Run
           (See Figure 10).   Based on  sampling results, the
           streams do not appear  to be affected by site-related
           contaminants  (See  Tables S  and 6).  Although a few
           site-related compounds were discovered in sediments,
           the data do not indicate a  contaminant distribution
           pattern with respect to dilution or accretion of
           concentrations associated with increasing distance
           from the site  or tributary  headwaters.  The
           contaminants are spatially  variable and their
           presence in the streams may be due to other sources.
           In  addition, the compound levels found have not been
           shown nor  are  expected to cause an adverse impact.


    Ecological Assessmentt

           Analyses of surface water and sediment samples
           during the RI  did  not  indicate that aquatic
           environmental  receptors have been exposed to site-
           related contamination.  Further, the habitat
           assessment, both of aquatic and terrestrial species
           surrounding the site,  did not identify any
           potentially adverse effects of site-related
           contamination  to the well-being of flora and fauna.

           The only areas visibly affected by contamination are
           the immediate  area of  the former lagoons and former
           berm borrow area.  Vegetation directly in these
           locations  is very  sparse, consisting of hardy,
           pioneer species.

           No  wetland areas exist onsite.  Narrow fringe,
           forested wetlands  along the various streams adjacent
           to  and downgradient of the  site do not appear to be
           affected by- site contaminants.   	


VI. SUMMARY Or 8ZTB  RISKS

A Baseline Risk Assessment (RA)  was performed for the site in
accordance with EPA  guidelines.   The RA provides an estimation
of risk to public health and the environment posed by the site if
no remedial actions  were taken.  It involves assessing the
toxicity or degree of hazard posed by substances found at the

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                                13       William Dick Lagoons ROD

site by considering the levels at which these substances are
present.  The RA also entails describing the exposure routes by
which humans and the environment could come into contact with
these substances.

When estimating an individual's exposure to site substances,
conservative assumptions regarding such factors as length of the
exposure period, frequency of exposure, amount of skin exposed
and/or quantity of substance ingested are purposely used to
ensure that the risk is not underestimated.  After -evaluation of
the site data, an assessment of toxicological information and
potential exposure is performed, followed by calculations of the
risks posed.  Separate calculations are made for those substances
that can cause cancer and for those that can cause other, non-
carcinogenic health effects.  Risks to both childen and adults
are presented.  General conclusions of the RA pertaining to
public health impact are presented in Sections A through D below.
A) ^yp^^'ninant Identification

The initial phase of the RA involves reviewing all RI data and
identifying the chemicals of potential concern found in all
exposure media at the site for further risk evaluation.  The
exposure media includes onsite soil, groundwater, surface water,
springvater, fugitive dust and air emissions, and deer which
might graze at.the site.  Identified chemicals are primarily
chosen based on their relatively high toxicity, mobility,
persistence and prevalence when compared to all contaminants
present at the site.  The chosen chemicals also provide a
representative analyses of the potential risks at the site.
Arithmetic average and maximum concentration levels of the chosen
contaminants are utilized to develop most probable and maximum
exposure scenarios in a later phase of the RA.  A listing of the
identified chemicals of concern or "indicator* chemicals appears
in Table 7.  Based on RI data, the selected chemicals represent
99% of the risk associated with each exposure scenario for each
medium.  Sources of uncertainty in selecting the indicator
chemical* are discussed in the RA.
B)
The next step in conducting the RA is an exposure assessment.
The objectives of this task are to identify potential exposures
associated with the chemicals of concern at the site and to
estimate the magnitude of these exposures.

Based on the site's environmental setting, this RA has  identified
five potential populations who could be exposed to site

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                                14       William Dick Lagoons ROD

 contaminants.   It should be noted that actual exposure by these
 groups is severely limited  however, due to controls implemented
 at the site to date.  Following  is a listing of the potentially
 exposed populations,  which  shall  be referred to as "potential
 exposure pathways".   Rationale  for their selection appears in
 Table  8:

           Use  of  groundwater (via private well) as a residential
           water supply  by residents living in the area of
           estimated site-related  impact.  Exposure includes
           dermal  contact with and ingestion of groundwater as
           well as inhalation of volatile organic chemicals
           released during showering and other activities.

           Dermal  contact with and incidental ingestion of
           contaminated  onsite soils by a casual trespasser.

           Ingestion of  venison  from deer that may graze onsite.

           Inhalation  of volatile  organic chemicals and fugitive
           dust released from on-site soils, and


           Recreational  use  of the ponds fed by spring #48 (a.k.a.
           the  Baldwin Campground  spring).  Exposure includes
           dermal  contact with and incidental ingestion of water,
           as well as  inhalation of volatiles released from the
           water.

           Hypothetical  residential use of groundwater from the
           onsite  monitoring wells installed during RI field work.


When calculating  the  risks  associated with each of these
pathways,  the  RA  considers  three  age groups as potentially
exposed:  adults,  children ages  6  to 12, and children ages 2 to 6
 (See Table 9 for  additional information on exposure duration.)

Actual quantification of potential exposure involves estimating
exposure point concentrations and calculating potential intakes
for eachexposure pathway identified above.  Exposure point
concentrations (the contaminant concentration at which the
resident  is-exposed)-were based on the-arithmetic average and
maximum values for each indicator chemical found in each medium
at the site.   To  determine  the  concentration of VOCs released
from onsite soils and the pond  fed by Spring #48, and to
determine the  concentrations in fugitive dust released from
onsite soils,  air screening models were utilized.  When
estimating VOC concentrations released during showering with
private residential well water, an inhalation dose equivalent to
that experienced  via  ingestion  of such water was assumed.
Summaries  of the  average and maximum exposure point

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                                15       William Dick Lagoons ROD

concentrations  appear  in Appendix A of this ROD.

In the calculation of  potential intakes  (how much and for how
long one  is exposed to the exposure point concentrations), the
characteristics of the various exposure pathways must be defined.
Important parameters include the frequency, duration, and degree
of exposure as  well as physiologic characteristics of the exposed
population, such  as body weight and skin surface area. Estimates
of these  parameters are based on EPA guidelines, recommendations
found in  the current literature, and professional judgment. The
exposure  assumptions used in calculating the potential intakes
appear in Table 9.

Several assumptions must be made regarding both the nature and
extent of contamination present at the site as well as the
behavior  and characteristics of the populations potentially
exposed to the  contamination.  Some of these assumptions include
use of the following:

     . monitoring data to represent exposure concentrations
       across a medium,

     . screening  level models to represent exposure
       concentrations  across a medium,

     . single values for exposure parameters to characterize the
       behavior of an  entire population over an extended period
       of time, and

     . the intake calculations for the deer ingestion scenario,
       which should be considered semi-quantitative in light of
       the numerous assumptions required.
C)
Toxicitv AflflASBBftnfc Suanu
This task requires the assessment of the intrinsic toxicological
properties of the chemicals of potential concern.  Both
carcinogenic and non-carcinogenic effects from the indicator
chemical* mast be presented.  A summary of toxicological
information on all indicator compounds assessed for the site
appears in Table 10.  This table identifies those compounds which
are-considered-potential-carcinogens and-those-identified for
non-carcinogenic effects.  In some cases, compounds are evaluated
for both types of effect. In reviewing Table 10, several terms or
acronyms require definiton.

Cancer Potency Factors  (CPTa) have been developed by EPA's
Carcinogenic Risk Assessment Verification Endeavor  (CRAVE)for
estimating excess lifetime cancer risks associated with exposure
to potentially carcinogenic chemicals.  CPFs, expressed in units
of (mg/kg-day)  , are  multiplied by the estimated  intake of a

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                                16       William  Dick Lagoons ROD

 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.   CPFs are derived  from the  results of human
 epidemiolpgical studies or chronic animal bioassays to which
 animal-to-human extrapolation and uncertainty factors have been
 applied.

 Reference doses fRfDsl  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.   RfDs are derived  from human
 epidemiological studies or animal studies to which uncertainty
 factors have been applied (e.g..  to  account for the use of animal
 data to predict effects on humans).  These uncertainty factors
 help insure that the RfDs will not underestimate  the  potential
 for adverse noncarcinogenic effects  to occur.

 Carcinogenic Class refers to  EPA's weight-of-evidence system for
 classifying chemicals  suspected of being human  carcinogens.
 Substances are classified based on their epidemiological
 association with human cancer, induction of cancer in multiple
 species of test animals,  or induction of cancer in one species.
 Following is a brief description  of  the  classes appearing on
 Table 10:   Group A - human carcinogen, Group Bl - Probable human
 carcinogen based on limited human data,  Group B2  - Probable human
 carcinogen based on sufficient evidence  in animals but little or
 no  evidence in humans,  Group  C -  Possible human carcinogen, Group
 D - Not classified as  to human carcinogenicity, Group E -
 Evidence  of noncarcinogenicity for humans.

 D)  Risk Characterisation

 The final task of the  RA is to integrate the results  of the
 Exposure Assessment and Toxicity  Assessment to  quantitatively
 estimate the-potential  risk associated with the six exposure-
 pathways previously identified.   Both carcinogenic and
 noncarcinogenic effects will  be considered.

     Carcinogenic risk  - Carcinogenic risk is calculated by
multiplying the daily  intake  of each chemical,  averaged over the
years of exposure,  by  the appropriate CPF.  Results are presented
 in probabilities expressed in scientific notation.  For instance,
 a result of 1E-04  (IxlO*4) indicates, as  a plausible upper bound,
that an individual  has  a one  in ten  thousand chance of developing

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                                17       William Dick Lagoons ROD

cancer as a result  of  site-related exposure to that chemical
under the specific  exposure conditions at the site.  This
estimate is often expressed as the incremental or excess
individual cancer risk associated with exposure to a chemical.

The risk associated with exposure to a set of chemicals is
estimated'by adding the risks associated with exposure to each
chemical.  Several  of  the exposure scenarios at the site may
involve more than one  route of exposure.  A summary of the
results of the calculations for each age group under each
exposure scenario,  as  well as a lifetime exposure scenario
(calculated by adding  the risk for each age group), is presented
in Table XI.  This  table also provides a summation of risk
associated with simultaneous exposure under mutiple scenarios.
Based on EPA policy, a risk exceeding the range of 1E-04 to 1E-
06 is generally considered as exceeding the acceptable risk
level.

    Noncarcinoaenic Risk - Noncarcinogenic risk is determined by
calculating the Hazard Index (HI).  This number is found by
dividing the daily  intake by the appropriate RfD.  The HI
provides an estimation of the potential for toxic effects to
devlop as a result  of  exposure to a chemical or set of chemicals
under the assumed conditions of exposure.

The calculation of  the HI asssumes that there is a threshold
exposure, below which  no toxic effects are expected to occur.
Therefore, a HI less than one indicates that no toxic effects are
expected to occur as a result of a given exposure, while a HI of
greater than one indicates that there is a potential for an
individual to experience adverse health effects as a result of a
given exposure. Noncarcinogenic risk associated with exposure to
a set of chemicals  is  conservatively estimated by adding the
risks associated with  exposure to each chemical.  A summary of
the results of the  HI  calculations for each age group under each
exposure scenario,  including a lifetime exposure scenario,
appears in Table 12.   As indicated in the carcinogenic risk
section, a multiple exposure summation also appears in this
table.
              Risks- •
During the RI, an ecological investigation of the surrounding
site area was conducted to assess site-related impacts to the
local flora and fauna.  The objectives of this work were to:

     1) characterize the terrestrial and wetland communities of
     the site and surrounding area,

     2) identify the macroinvertebrate communities of the

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                                18        William Dick Lagoons ROD

      dovngradient tributaries,

      3)  assess any site-related impacts on these various
      ecological communities.

 Utilizing the data obtained from the above tasks,  an ecological
 assessment of the site was conducted in a methodology similar to
 that described above for public health impact.   After completion
 of the Exposure Assessment and Toxicity Assessment phases of  the
 total ecological assessment,  it was determined  that RI analytical
 results of surrounding stream samples did not indicate an
 exposure of aquatic ecological receptors to site-related
 contaminants.  In fact, the macroinvertbrate community in the
 streams surrounding the site were found to be diverse and
 healthy.

 The only terrestrial receptors experiencing site-related impact
 would be those trespassing or residing directly on the 2.2 acre
 former lagoon area.  The chain link fence around the site and the
 lack of an adequate food supply onsite acts to  prevent
 surrounding wildlife from coming into direct contact with site
 soils.  The vegetation surrounding the site appears quite
 healthy, and is not measurably affected by the  site.  Wildlife
 residing around the site is not expected to be  impacted by the
 site contamination based on evaluation of the RI data, lack of
 access to the site, and the RA analysis of potential exposure to
 grazing deer. Due to past onsite dumping activities, onsite
 vegetation is quite sparse, resulting in the one measurable
 effect of the site to the local ecology.

 Finally, although fringe,  forested wetlands exist along the
 streams  surrounding the site, they are determined not to be
 impacted based on both visual inspection and the analytical
 results  of stream surface water and sediment samples.  Based  on
 consultation with the appropriate State and Federal agencies, no
 threatened or endangered species are known to exist in the site
 area,  save the occasional transient species.

 Significant flonge  of Uncertaint
The RA for the site is based on conservative assumptions
regarding exposure and toxicity.  In making estimates of potential
-exposure- and -resultant -intake,  an effort was made to select
parameters that overestimate actual exposures,  so that the
resulting estimates of potential risk also overestimates the
actual risk associated with site-related exposures.   Included
among  the conservative assumptions utilized are:
                                                        \

     - the assumption that an individual may be exposed to any of
     these exposure conditions over the course of a  lifetime,

     - the assumption that an individual may be chronically

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                               19        William Dick Lagoons ROD

     exposed to concentrations of contaminants approaching the
     values used in the RA,

     - the assumption that an individual may be simultaneously
     exposed to multiple pathways of exposure over the period of
     a lifetime,

     - deliberate overestimation of toxicity indices where
     questions exist about the actual toxicity or carcinogenicity
     of a substance or group of substances.  (One exception to
     this conservative methodology is the RA's assumption that
     the risk associated with exposure to more than one toxicant
     is additive.  In some cases, depending on the chemicals,
     risk may be greater than additive.)

Several limitations of the RA should also be noted:

     - analytical results from only five surface soil samples
     were available to evaluate the exposure pathways associated
     with dermal contact, contaminant air releases/fugitive dust
     emissions, and ingestion of venison associated with deer
     grazing onsite;

     - the method utilized during the RI to identify the depth
     interval of soil borings for sample analyses may or may not
     have excluded samples with higher concentrations of
     semivolatile organic compounds:

     - the sampling data utilized in the RA for exposure via use
     of residential well water is solely comprised of volatile
     organic analytical results,  per the residential well
     sampling requirements in the EPA/CLTL Consent Order.  For
     this reason, exposure and significance of such exposure of
     residents to other chemicals associated with site soils,
     such as semivolatile compounds and tentatively identified
     compounds (TZCs), is uncertain, albeit unlikely.  Results
     from the one round of sampling of residential wells for
     semivolatile organic analyses were not used based on the
     limited data set for these compounds.

     - regarding exposure assumptions, the use of monitoring
     data, single concentration values, and screening level
     models (especially-in the air and grazing deer exposure -
     scenarios) all present a measure of uncertainty when
     estimating one's exposure to site contaminants.

     - the RA is based on conditions of no action at the site.
     Protective measures instituted at the site, including the
     installation of a fence around the site and provision of
     point-of-entry carbon treatment units to homes with well
     water exceeding MCLs, results in risks considerably lower
     than that predicted in this RA.

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                                20       William Dick Lagoons ROD
Conclusions of the Risk Assessment

.  The results of the calculations performed in the RA using the
aforementioned exposure routes indicate that the estimate of most
probable risk associated with all routes of exposure, except the
Hypothetical Residential Use of Monitoring Well (or "Onsite")
Groundwater, is within EPA's range of acceptable risk.  The
estimate of maxJP^P or worst case risk exceeds EPA's range for
two exposure routes; (1) the Hypothetical Residential Use of
Onsite Groundvater and (2) the more realistic and actual
Residential Use of Offsite Groundwater.

Following is a condensed table of the lifetime carcinogenic risks
calculated for each exposure scenario:
   Exposure Route               Most Probable       Worst Case

   Residential Use of
   Offsite Groundwater          1 x 10*5             3  x 10"**
   Contact and Ingestion
   of Onsite Soils              9 x 10'6             2 x 10*5
   Deer Meat Ingestion          5 x 10*'             1  x 10'5

   Recreational Use of
   Spring Water at Campground   3 x 10              3  x 10

   Inhalation of Dust and
   Vapor from Onsite Soils      5 x 10*6             1  x 10"5
   TOTAIi OF ALL "CURRENT"       3 X 10"5             4  X 10"**
   EXPOSURES
   Hypothetical Residential
   Use of Monitoring Well
   Groundwater                  1 x 10"3*            2  x 10"**

   * outside of EPA's acceptable risk range

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                                21       William Dick Lagoons ROD


It  is  important to note that the RA principally evaluated the
risk posed by the site under current conditions.  Due to a lack
of  sufficient hydrogeologic data, the RA was not designed to
predict the  future risk associated with residential water use if
the relatively highly contaminated groundwater below the site
were to migrate to residential wells.  The exposure route
Hypothetical Residential Use of Monitoring Well Groundwater gives
an  indication of the carcinogenic risk which would 'be posed by
use of groundwater directly below and adjacent to the site. When
and if this  contaminated groundwater, at or near to the
concentration levels found below the site, could reach
residential  wells has not been determined at this point.  Using a
conservative approach to public health protection one would
assume that  groundwater contaminant concentrations approaching
those  levels below the site would ultimately reach residential
wells  if either the pollutant source or contaminated groundwater
is  not contained or remediated.

    In  addition to carcinogenic risks, the RA calculated risks to
humans of contracting non-carcinogenic health effects from
substances associated with the site using the same identified
exposure routes.  The results of these calculations for non-
carcinogenic health effects were below the EPA guideline of l . 0
for children and adults for all exposure scenarios except both
the most probable and maximum Hypothetical Use of Onsite
Groundwater  scenarios.  These results suggest that exposure to
non-carcinogenic chemicals at the site is not anticipated to
result in adverse health effects under the current .conditions of
exposure.  As stated above, however, it implies that groundwater
contaminants found at levels directly below and adjacent to the
site could pose non-carcinogenic health effects to users.
Therefore,, if groundwater contaminant concentrations at or
approaching  these levels were to migrate to residences, non-
carcinogenic health effects would be expected.

    For the two groundwater exposure scenarios exceeding EPA 's
carcinogenic and noncarcinogenic guidelines (Residential Use of
Of f site and  Onsite Groundwater) , TCE is the contaminant which
poses  the greatest carcinogenic risk and chloroform and
tetrachloroethene pose the greatest noncarcinogenic risk.
*-  Under th* scenario Hypothetical -Residential Use of- Monitor ing-
Well Groundwater, it should be emphasized that no one is
currently using this water.  This scenario presents the risk
which could be posed if the site were left unaddreseed and the
contaminant plume continued to spread.

   It is somewhat reassuring to note that three years of
residential well data indicate that residential well
concentrations are not significantly rising and site  groundwater
contaminant transport seems to be in "steady-state".  Despite

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                                22       William Dick Lagoons ROD

 this apparent condition,  several  factors suggest that future site
 groundwater conditions  are  uncertain, warranting careful
 evaluation of future residential  exposure to groundwater
 contamination.   These factors  include:  (1) the complex
 hydrogeology of the site  area,  (2)  limited knowledge of
 groundwater contaminant concentrations  and flow patterns between
 the site 'and residential  wells,  (3) close proximity of homes to
 the site,  and (4)  based on  the heterogenous and relatively
 unknown types of waste  disposed of  in the former lagoons, the
 possibility,  although not considered likely, that compounds of an
 unknown nature may be present  or  migrating to homeowner wells.

    From an environmental  risk  perspective, analyses of surface
 water and  sediment samples  near the William Dick Lagoons Site do
 not indicate that  these media  are currently measurably affected
 by  site-related contamination.  Further, except for that of the
 immediate  area of  the former lagoons, the assessment made of the
 local environment  did not identify  any  potentially adverse
 effects of site-related contamination to the wellbeing of plants
 and animals.   Thus,  it  appears that the Site has had no
 persistent adverse effect upon the  surrounding ecosystem.

 EPA has determined that 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.


 VII.  DESCRIPTION OF REMEDIAL ALTERNATIVES

 The Preliminary Final FS  discusses  the  alternatives evaluated for
 the site and provides supporting  information leading to
 alternative selection by  EPA.  The  Preliminary Final FS includes
 consideration of all EPA  comments on the Draft FS.  As mentioned,
 it  is  identified as a preliminary document since EPA is
 conducting one  final review.   Any paper revisions to the
 Preliminary Final  FS will not  affect EPA's alternative selection
 process, since the  rationale for these changes has already been
 incorporated into  the Administrative Record.

As  indicated in the section of this ROD entitled Scope and Role
 of  Remedial Agtiony this  document addresses remedial action for
two of three  units at the site.   Specifically, this ROD presents
a remedial decision for Unit l-Alternate Water Supply, and Unit 2
 -Groundwater.   The decision on Unit 3-Source Control, will be
deferred to a later date, as previously indicated.  Remedial
objectives for  the Unit l and  2 alternatives focus on the
elimination of  unacceptable human or environmental health risk
and the reduction  of contaminant  concentrations in groundwater to
meet ARARs and/or  risk-based levels.

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                                23       William Dick Lagoons ROD

 Section 121 of CERCLA requires that the selected remedial
 alternative to address contamination at a Superfund Site be
 protective of  human health and the environment, comply with ARARs
 or  justify a waiver,  be cost effective, utilize permanent
 solutions  and  alternative technologies to the maximum extent
 practicable, and   satisfy the preference for treatment as a
 component  of the remedial action or explain why the preference is
 not satisfied.

 The alternatives evaluated in this ROD for Units 1 and 2 appear
 below.   As discussed previously, the method and detail of
 alternative evaluation differs from that presented in the
 Preliminary Final FS and several changes to the alternatives
 presented  in the FS have been made.


 ALTERNATE  WATER SUPPLY - UNIT l!

      AWS  1: No Action

      Estimated Capital Cost:  $0
      Estimated Annual Operation 6 Maintenance  (O&M): $0
      Estimated Present Worth: $0
      Estimated Time to Complete: Immediate

             - costs of existing requirements under the 1988
                Removal Order not included

 The Superfund  program requires that the No Action alternative be
 evaluated  for  each site unit in order to establish a baseline for
 comparison.  Under this alternative, EPA would take no remedial
 action  at  the  site to prevent residential exposure to
 contaminated groundwater.  However, CLTL would continue the  .
 provision  of point of entry systems (i.e. granular activated
 carbon  (GAG) units)  and sampling of residential wells (and
 springs) as required under the 1988 Removal Order signed with
 EPA.  A five year review of this remedy would be conducted in
 accordance; with Section I21(c) of CERCLA.

 Protection of  public health and compliance with ARARs is
 potentially jeopardized under this scenario since the existing
 Removal Order was established as a temporary measure and may not
 contain a-sufficient monitoring schedule to ensure that- -
 contaminants have not migrated to wells between individual
monitoring events.   A resident(s) could be exposed to.
 contaminants above MCLs until such time as scheduled monitoring
 determines the  presence of contaminants in his/her individual
well.   Operation and maintenance of the point of entry systems
 and monitoring  of homes not supplied with point of entry systems
must be performed with committed and persistent application  for
this remedy to  be effective.  Compliance with ARARs will require
that spent carbon or regeneration waste from used systems will be

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                                24       William Dick Lagoons ROD

 disposed of  in accordance with the Resource Conservation and
 Recovery Act,  42  U.S.C.  Section  6901 et seq.   (RCRA) and State
 hazardous waste disposal requirements.

 The remedy meets  the  statutory requirement for treatment (at the
 residential  well  itself) but  is  not a permanent remedy since
 occasiona-1 replacement of the carbon in the point of entry
 systems  will be needed on an  approximately two to three year
 basis.

 This alternative  would prove  to  be difficult to implement if a
 pump and treat remedy is selected for Operable Unit 2.  The
 installation and  operation of recovery wells to collect and treat
 groundwater  for Operable Unit 2  could act to draw contaminants
 into home wells since the complex site hydrogeology might prevent
 the adequate institution of preventative measures to prevent this
 event.   In addition,  the continued use of individual residential
 wells could  act as a  deterrent to the adequate collection of
 contaminated groundwater by the  recovery wells since the home
 wells might  act to draw  groundwater away from the recovery wells.
      AWS2: Institutional Controls

      Estimated Capital Cost:     $10,000
      Estimated Annual O&M Cost:  $2000

      Estimated Present Worth  :   $30,600
      Estimated Time to Complete:  1 to 2 Years

            - costs of existing requirements under the
              1988 Removal Order not included.  Costs
              include personnel or man-hour expenditures for
              establishing and administering institutional
              controls.

Under this alternative, the existing Removal Order of 1988 would
remain in effect.  In addition, the alternative would include the
imposition of institutional controls such as deed, zoning, and/or
ownership restrictions to prevent residential use of contaminated
groundwater by individuals moving into the area of the
contaminated groundwater plume.  For example, a deed restriction/
notice or property transfer advisory could be instituted for the
sale of property within the area of the contaminated plume.

The Chester County Health Department (CCHD) has already
established an internal mechanism whereby all new private wells
drilled in Chester County must first obtain a permit from CCHD
before drilling commences.  For any prospective wells to be
drilled within the area of the contaminant plume surrounding the
Site, the resident is required to perform sampling and analyses

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                                25       William Dick Lagoons ROD

 of the well water  immediately after well construction and on a
 yearly basis thereafter.  Should the well water sample results
 indicate  a contaminant(s) above drinking water standards,
 treatment of the water must be in place prior to granting of
 approval  of private well use (See Appendix C).  EPA would provide
 information to  CCHD to enforce this requirement at the site
 should it* be necessary.  Existing well owners are entitled to
 periodic  sampling  and provision of a point of entry treatment
 system  (if needed) by CLTL as a result of the 1988 Removal Order
 between EPA and CLTL.

 A five year review of this remedy would be conducted per Section
 121(c) of CERCLA.  The potential for protection of public health
 and compliance  with ARARs is slightly higher under this
 alternative due to the emphasis placed on institutional controls.
 Compliance with the statutory requirements of treatment
 preference, and utilization of a permanent remedy/alternative
 treatment technology whenever-practicable, is identical to that
 of AWS1.  Should a pump and treat remedy for Operable Unit 2
 be selected, the same potential problems are associated with this
 remedy as identified for AWS1.
      AWS 3: Point of Entry Systems with Institutional Controls

      Estimated Capital Cost:     $0
      Estimated Annual O&M Cost:  $16,000 to $74,500
      Estimated Present Worth:    $720,000 to $1,158,000
      Estimated Time to
      Install/Complete:           Several Weeks after MCL
                                  Exceedance

          - range in costs based on present and future case
            scenarios.  Costs include those associated with
            existing 1988 Removal Order plus additional
            monitoring requirements.

The monitoring of residential well water (and springs) and
provision and monitoring of point of entry systems would continue
as currently provided under the 1988 Removal Order.  However,
because the- Removal Order requirements were originally envisioned
as a temporary measure, and this decision contemplates a final
remedy, EPA would institute steps to increase the frequency and
potentially the scope of monitoring above that currently provided
by CLTL.  Currently, the frequency of monitoring for this
alternative is expected to be that appearing on pages 3-13 and
3-14 of the Preliminary Final FS.  The scope of monitoring would
increase if the Agency determines that homes located outside of
the current sampling radii (1/2 mile north and 1 mile south of
the former lagoons) require periodic monitoring.  This would be
determined when planning for and/or during the additional

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                                26       William Dick Lagoons ROD

 hydrogeologic work scheduled  for  Operable Unit 2.  Such efforts
 would continue until  the  contaminated groundwater is restored to
 its  beneficial use.   The  institutional controls discussed under
 AWS2 would  also be a  component of this alternative.

 This alternative has  a greater propensity than AWS1 and AWS2 for
 meeting  the statutory requirements to protect public health and
 comply with ARARs  due to  the  increased scope and frequency of
 monitoring  for this option.   Compliance will require vigorous
 efforts  to  ensure  that point  of entry units are properly
 monitored and maintained  including the proper disposal of
 contaminated carbon from  spent units.

 A five year review of this remedy would be conducted per Section
 121(c) of CERCLA.   Compliance with the statutory requirements of
 treatment preference, and utilization of a permanent
 remedy/alternative treatment  technology whenever practicable, is
 identical to that  of  AWS1 and AWS2.  Should a pump and treat
 remedy for  Operable Unit  2 be selected, the potential
 incompatability problems  identified for AWS1 and AWS2 also apply
 to this  alternative.
      AWS 4: Extension of the Coatesville Water Line with
             Institutional Controls

      Estimated Capital Cost:     $1,631,000 to $2,187,000
      Estimated Annual O&M Cost:  $21,000 to $46,000
      Estimated Present Worth:    $2,034,000 to $3,071,000
      Estimated Time to
      Install/Complete:            2+ Years

             - range in costs based on current uncertainty
               regarding length of water line extension and the
               identification of all residents to be serviced.

This alternative addresses residential water use by extending the
City of Coatesvill* Authority's (CCA) water line from  its current
location at the intersection of Cof froath Road and North Sandy
Hill Roadv  Public water from the City of Coatesville's intakes
on Birch Run, Rode Run, and/or Octoraro creek, after treatment,
would b* supplied to affected and potentially affected site
residents (i.e. homes located within the site groundwater
contaminant plume).  A water storage tank would be installed at a
location near the site to provide storage and pressure feed for
water line connections.

EPA will work with the appropriate local authorities to develop
and/or enforce institutional controls in an attempt to ensure
that current and future residents within the contaminated
groundwater plume either obtain their water from the newly
installed water line, or, should they decline to connect, that

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                                27       William Dick Lagoons ROD

 their groundvater well be periodically analyzed for site
 contaminants.   Several existing rules and regulations of the
 Chester County Health Department  (CCHD) apply to this situation:

      - Section 501.14 of the Rules and Regulations of the CCHD
      requires- that no individual water supply well may be used,
      constructed or maintained where a public water supply pipe
      is within 150 feet of the structure to be served by water
      (provided the structure is located within the/franchise area
      of the  water supplier.)

      - The CCHD interprets Section 501.3.1. of the CCHD Rules and
      Regulations to require that all residents connecting to a
      public  water supply must "abandon" their private well.
      Abandonment of a well requires filling and sealing of the
      well as defined in Section 501.9 of the CCHD Rules and
      Regulations.

      - Section 501.13.2.3.3. of the CCHD Rules and Regulations
      grants  CCHD the authority to require owners of newly drilled
      private wells to analyze the well water for harmful
      substances which the CCHD suspects are present.  The
      CCHD has  established an internal mechanism whereby all new
      private well drillers in Chester County must first obtain a
      permit  from CCHD before drilling commences.  For all new
      wells drilled within the area of the contaminant plume
      surrounding the Site, the resident is required to perform
      sampling  and analyses of the well water immediately after
      well construction and on a yearly basis thereafter.  Should
      the well  water sample results indicate a contaminant(s)
      above drinking water standards, treatment of the water must
      be in place prior to granting of approval of private well
      use (See  Appendix C).

If continued us* of a well by a non-connecting resident is
determined to  present an unacceptable environmental or public
health impact,  EPA may initiate efforts to close the well under
its CERCLA Section 106 authority.  To determine the risk posed by
exposure, to  well water by any individual within the groundwater
contaminant  plum* who declines to connect to the water line and
maintain* and  continues to use a private well, EPA may attempt to
require periodic monitoring of the well water by the resident
through cooperative enforcement efforts with the CCHD.  Section
501.13.2.3.3.  of the CCHD Rules and Regulations may provide a
mechanism for  this action via application to existing well
owners.  If  necessary,  monitoring could be conducted by EPA.

Based  on existing data, it is anticipated that the line would be
extended up  North Sandy Hill Road toward the site and would
extend westward to service affected or potentially affected
residents on Telegraph Road.  At this time, it is not known if
the water line would be extended to service residents on Hill

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                                28       William Dick Lagoons ROD

 Road or residents living northeast  of the  site near the
 intersection of North Sandy  Hill  Road and  Telegraph Roads.  A
 determination of all  residents who  will be offered the
 opportunity to connect to the line  will be decided during water
 line design and following completion of additional hydrogeologic
 study scheduled to commence  during  mid-1991  (see the discussion
 of  alternatives for Unit 2).  One of the major tasks of the
 additional  hydrogeologic work will  be to make a definitive
 determination on the  extent  of the  plume and thus determine which
 residents will be eligible for water line  connection.

 Current data indicates that  approximately  50 residential
 locations lie within  the estimated  groundwater plume area (as
 identified  in the RI).  The additional hydrogeologic work in 1991
 may indicate that a significantly larger number of residents may
 be  affected or potentially affected by 'site groundwater
 contamination.   It is expected that water  line design will
 commence as additional hydrogeologic work  proceeds.

        A representative portion of  existing residential locations
 beyond the  reach of the proposed  line would undergo periodic
 sampling of private wells if there  is concern that the
 groundwater contaminant plume could migrate and impact such wells
 during the  period of  the remediation activity selected for
 Operable Unit 2.   If  such residences were  to warrant connection
 to  the CCA  water supply in the future, EPA would take appropriate
         actions to extend the line.  Nearby springs will also be
 monitored under this  alternative.

 This  alternative meets all of the statutory requirements of
 Section 121 of  CERCLA.   The Coatesville water supply is in
 compliance  with ARARs under the Safe Drinking Water Act and 25 PA
 Code  Chapter 109.   It is a permanent alternate water supply
 remedy.  The statutory preference for treatment under CERCLA will
 be met by the groundwater remedy  selected  for Unit 2.   Although
 the estimated cost is higher than the other alternatives, the
 cost  is  not excessively elevated  in view of the permanence and
 reliability of  the remedy and the elimination of the long-term .
 need  for; future operation and maintenance.

 Concerning  this alternative's protection of public health, an
 added  carcinogenic risk occurs as a result of exposure to
 trihalomethanes in the City of Coatesville Authority's  (CCA)
water  supply.   These  compounds (chloroform, bromodichloromethane,
 chlorodibromomethane,  and bromoform as identified by State law
 for monitoring  purposes)  are created as a  result of the
chlorination of surface waters containing  natural organic
precursor substances  such as humic  acid, fulvic acid, and plant
extractives.

Based on a  limited data base, the calculated current risk
associated with trihalomethanes in  the CCA water supply is

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                                29       William Dick Lagoons ROD

 approximately equal  to that of the current risk from the use of
 residential well water contaminated with site-related chemicals.
 Specifically,  the  current average case total carcinogenic risk
 posed  by  the  ingestion and inhalation of site-related groundwater
 compounds,  using data  collected from the 1988 Removal Order
 requirements,  is calculated to be 7.58E-05 (or 1 additional
 cancer per  13193 exposed individuals).  The current worst-case
 risk is calculated to  be 2.92E-04 (or 1 additional cancer per
 3425 individuals).

 The current average  case total carcinogenic risk posed by the
 ingestion and inhalation of trihalomethanes in the CCA water
 supply, using quarterly monitoring data obtained from Coatesville
 for the period of  March 1990 to March 1991, is calculated to be
 1.05E-04  (or  1 additional cancer per 9488 individuals).  The
 current worst-case risk is calculated to be 1.6E-04 (or 1
 additional  cancer  per  6097 individuals).

 Although  the  current risk scenarios described above are roughly
 equal, it is  important to note that the CCA water supply has been
 in compliance with all drinking water standards for
 trihalomethanes  (i^fij.,  a Maximum Contaminant Level (MCL) of 100
 ppb for Total Trihalomethanes) at least over the last three
 years.  In  addition, EPA'a Drinking Hater Program is scheduled to
 propose new national standards for trihalomethanes in June of
 1993,  with  promulgation of such standards scheduled for June of
 1995.  Current indications are that the trihalomethane standards
 will be set at a lower level, thus reducing the carcinogenic risk
 posed  by  these compounds.  If the standard is reduced, the CCA
 will be required to  comply with the new standard within a few
 years  of  promulgation.  Finally, the CCA has expressed a desire
 to reduce trihalomethane levels as evidenced by its intention,
 expressed to  EPA in  April of 1991, to convert its disinfection
 system from chlorination to chlorine dioxide treatment.  However,
 toxicity  concerns  regarding chlorine dioxide treatment residuals
 caused the  CCA to  postpone its plans for disinfection conversion.

 EPA also  considered  the risk, again utilizing a limited data
 base,  associated with  the presence of natural radioactive
 substance*  fi.e..  radon, radium, and uranium) in residential
wells  located near the site.  These substances appear in elevated
 levels in site groundwater as a result of the geochemical
 characteristics  of the Chickies rock formation, where the site
 lies.  (Due  to its  use  of surface water as a source of drinking
water, the  CCA water supply does not contain elevated levels of
radioactive substances.)

The Agency  has limited authority, under CERCLA  (SSS. CERCLA
 Sections  104  (a)(3)  and (4)), to take a remedial action to
address a release  or a threatened release of a naturally-
occurring substance  in its unaltered form, or altered solely
through naturally  occcuring processes or phenomena, from a

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                                30       William Dick Lagoons ROD

location where  it is naturally found.  However, when risk results
from both natural and man-made sources, the Agency considers it
appropriate to  evaluate the overall risk associated with the use
of water from each source.  Such  an analysis presents a complete
picture of the  health risk associated with each water supply
alternative.
An assessment performed for exposure to the natural radioactive
substances in site groundwater found that provision of
Coatesville water to site residents would actually reduce the
risk of added cancer since it would eliminate the natural but
rather significant risk posed by  exposure to radionuclides in
site groundwater.  The current average carcinogenic risk
associated with exposure to radionuclides in groundwater (not
including the risk posed by site-related compounds), utilizing
data collected  by the US Geological Survey and ERM during 1988,
is calculated to be 7.07E-04 (or  1 additional cancer per 1,400
exposed persons).  The current worst-case carcinogenic risk
associated with this exposure is  calculated to be 2.7E-03 (or 1
additional cancer per 370 exposed individuals).  These calculated
risks are substantially higher than the risks posed by either
site-related chemicals in groundwater or trihalomethanes in the
City water supply.

A complete evaluation of the risks from all three exposure
scenarios appears in Appendix B of this ROD.

          Note:  Under alternative AWS 4, the campground and
          trailer park located approximately 3/4 mile and 1/2
          mile  southwest of the site would not receive public
          water due to: (1) their remote location from the
          remaining affected residences, (2) the considerable
          cost  (roughly $360,000) associated with the extension
          of a water line several thousand feet to service only a
          few residents, and (3)  the lack of contaminants found
          in their well water to  date.  Instead, this remedy
          would provide a point of entry system with applicable
          monitoring, similar to  that which is currently performed.
      AWS 5: Private Water Company With Institutional Controls

      Estimated Capital Cost:     $1,190,000 to $1,748,000
      Estimated Annual O&M Cost:  $21,000 to $23,100
      Estimated Present Worth:    $1,706,000 to $2,298,000
      Estimated Time to
      Install/Complete:           2+ Years
                                                        N.
          - range in costs based on current uncertainty regarding
           length of water service line and the identification of
           all residents serviced.

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                                31       William Dick Lagoons ROD

     This alternative  involves installation of a high capacity
water supply well(s) in an uncontaminated groundwater location
near the site to be utilized by residents within the contaminated
groundwater plume.  The water would be treated at an onsite
treatment plant and distributed to residents for household use.
Water quality and operation procedures would be required to meet
all Federal and Pennsylvania standards for a public water supply.
The well and treatment plant would be maintained by a licensed
operator.

As in AWS 4, institutional controls would be implemented
(see the earlier discusion on existing CCHD regulations) in an
attempt to ensure that all current or future residents residing
in the groundwater contaminant plume be required to connect to
this water supply well treatment system. Should a resident within
the plume decline to connect and instead maintains a private
well, EPA may work with the CCHD to develop institutional
controls to require periodic monitoring of the private well water
by the owner to determine the level of site contaminants.  EPA
could monitor the well water if determined to be necessary.  The
Agency would take efforts to close the well if the well water is
determined to pose an  unnaceptable risk to health or the
environment.

The identification of  all residents to be offered an opportunity
to connect to this system would be determined during remedial
design and completion  of the additional hydrogeologic
investigation as discussed under AWS4.  Limited monitoring of
nearby springs and residential wells located outside the well
system connection area also would occur.

This alternative could meet all of the statutory requirements of
CERCLA Section 121 if  designed and operated properly.  However, a
significant concern exists regarding the inability to adequately
ensure the existence of a long-term operator for a new water
supply system. (CERCLA does not permit EPA to expend Superfund
monies to operate and  maintain a water treatment plant.)  In
addition, the type and cost of treatment which would be required
at the groundwater supply well is uncertain at this time.  Based
on the geochemical characteristics of the hydrogeology of the
area, treatment for radioactive substances may be necessary if
levels in the well water exceed drinking water standards.

     Note 1:  Under alternative AWS 5, the campground and trailer
     park located approximately 3/4 mile and 1/2 mile southwest
     of the site would not receive public water due to:  (1) their
     remote location from the remaining affected residences,  (2)
     the considerable  cost (roughly $360,000) associated with the
     extension of a water line several thousand feet to service
     only a few residents, and (3) the lack of contaminants found
     in their well water to date.  Instead, this remedy would
     provide a point of entry system with applicable monitoring,

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                                32       William Dick Lagoons ROD

      similar to that which  is currently performed.



GROUNDWATER - UNIT  2   (INTERIM REMEDY)

Scope of Groundwater Remedy

As previously indicated, the remedy for this unit is an interim
measure based on the lack of sufficient data to predict the
response of the aquifer to  pumping and thereby establish cleanup
levels and timeframes.  The goal of the selected interim remedy
will  be the collection of hydrogeologic data and commencement of
an initial pump and treat system geared toward (1) initiation of
the reduction of groundwater contaminant toxicity, mobility, and
volume, and (2) the collection of data on aquifer and contaminant
response to remediation measures.

The ultimate goal for remediation will be determined in a final
ROD for groundwater at the  site, which shall be prepared after
evaluating data generated during the interim action.  EPA
estimates that a final ROD  will be prepared within five years of
interim remedy implementation.  It is possible that sufficient
data may be obtained before that time to enable selection of a
final remedy.  The  interim  action will continue until the
selected final groundwater  remedial action is chosen or
implemented.  The extraction and treatment operation of the
interim remedy may  become a major component of the final remedy.

EPA has decided that specification of the type of groundwater
treatment technologies to be utilized at the site is premature at
this time.  The specific type of technologies will be determined
during interim remedial design and are expected to consist of
chemical precipitation and  one or more of the following: granular
activated carbon (GAG), chemical oxidation, and air stripping
with possible emissions controls.  Data presented in the
Preliminary Final FS indicates that the cost of all possible
combinations of these technologies which could be utilized at the
site are within the range of fifteen percent from one alternative
to the next.  The differences among the alternatives presented
below primarily focus on the scope of the interim remedy in
addressing- all or portions  of the contaminant plume.
      GWS i: No Action

      Estimated Capital Cost:     $0
      Estimated Annual O&M Cost:  $0
      Estimated Present Worth:    $0
      Estimated Time to Install/Complete: Immediate

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                                33       William Dick Lagoons ROD

 The  Superfund  program requires that the No Action alternative be
 evaluated  for  each  site unit in order to establish a baseline for
 comparison.  Under  this alternative, EPA would take no action at
 the  site to  attempt to cleanup the contaminated groundwater.  The
 contaminated groundwater plume could increase in volume and
 severity .and might  well affect additional residential wells and
 migrate to ecological receptors.  Unless an alternate water
 supply is  provided,  residents would be exposed to varying levels
 of contaminants.  At least initially, 12 residential wells will
 have contaminants in excess of MCLs.  A five year review of this
 action would be performed under CERCLA Section 121(c) since
 wastes would be left onsite above health based levels.

 This remedy  would not meet the statutory requirements to protect
 human health or the environment and does not satisfy the
 preference for treatment nor utilize permanent
 solutions/alternative technologies whenever practicable.  Since
 no action  is taken,  ARARs do not apply.


     GWS 2:  Additional Hydrogeologic Study/Pumping Wells
             (At/Adjacent to Former Lagoons) With
             Groundwater Treatment, Stream Discharge

      Estimated Capital Cost:  $1,078,000
      Estimated Annual O&M:    $166,700
      Estimated Present Worth: $2,289,000
      Estimated Time to
      Install/Complete:        2+ Years/5+ Years

           (costs assume 5 years of groundwater pump and treat)


     This  interim alternative initially calls for the collection
of additional  hydrogeologic data followed by pumping and treating
from the contaminated portion of the aquifer directly below
and/or adjacent to  the former lagoons.

Monitoring wells would first be installed and aquifer tests
conducted  to better define site hydrogeologic conditions;
including  flow patterns, contaminant extent and aquifer
inhomogeneities.  Following this work, an interim groundwater
remedy for the highly contaminated portion of the aquifer would
be designed  and installed.  Wells would be located below or
adjacent to  the site and possibly in the nearby bedrock fractures
which may  carry the majority of contaminated groundwater from the
site.  The intent of this conceptual design would be to capture
groundwater  moving  under the former lagoon area to limit the
migration  of contaminants in the aquifer currently used by nearby
residents. (The costs for this conceptual recovery system design
appear in  Appendix  E of the Preliminary Final FS as the 8 well
recovery system under Alternatives GW7 and Dl.  Costs for

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                                34       William Dick Lagoons ROD

 additional hydrogeologic  work  are based on the Geraghty & Miller
 proposal o£ December 12,  1990.)

      The groundwater recovery  system  and hydrogeologic
 characterization under  this  alternative would not attempt to
 gather data regarding,  nor attempt to determine the potential for
 remediation of,  the  remainder  of the  plume.  This option assumes
 that,  as the contaminated upgradient  groundwater is cleaned,
 contaminated water near residential wells should improve in
 quality over time.   Verification of this scenario or a time frame
 for  this improvement cannot  be provided with current
 hydrogeologic data.

 The  captured groundwater  would be piped to an onsite treatment
 plant,  specific  components of  which will be developed during
 remedial design.  The plant  is expected to include chemical
 precipitation and one or  more  of the  following technologies:  air
 stripping,  granular  activated  carbon  absorption and chemical
 oxidation.   Appropriate emissions controls will be required as
 needed to meet State and  Federal air  emissions standards.
 Residuals generated  during water or air treatment will be
 disposed offsite or  regenerated as required by regulations under
 RCRA and 25 PA Code  Sections 75.260.1 through 75.270.4. Following
 treatment,  groundwater  is expected to be discharged to Indian
 Spring Run located north  of  the site.  Discharge water will be
 required to meet effluent limitations and water quality criteria
 requirements set by  the Pennsylvania  DER under 25 PA Code
 Chapters 92 and  93.

 This alternative, in conjunction with an action-oriented remedy
 for  Unit 1,  would provide a  measure of protection to human health
 and  the environment  by  beginning to reduce the toxicity, volume,
 and  mobility of  contaminants and may  serve to impede the flow of
 contaminants to  residential  wells and ecological receptors.
 However,  it is not intended  to reduce contaminant levels
 throughout the plume and  its interim  nature does not ensure that
 pumping and treating will continue until complete remediation. It
 will result in the collection  of data needed to determine a final
 remedy  OIL remediating all or at least portions of the aquifer.
 The  remedy does  not  set specific cleanup standards but it will
 attempt tov determine whether or not State and Federal groundwater
 standards can be met. Due to the remedy's interim nature, state
 and  Federal groundwater,  chemical-specific cleanup ARARs  (i.e.,
 "background"  water quality for the State and drinking water
 standards  or MCLs for Federal) will not and need not be attained
per the ARAR waiver  provisions of Section 121(d)(4)(A) of CERCLA.
However, all regulated  activities associated with the operation
of the pump and  treat system will comply with state and Federal
ARARs.

The remedy  does  not  meet  the statutory permanency requirement
based on its  interim nature.   This situation is justified since

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                                35       William Dick Lagoons ROD

 adequate  data  is  lacking to make a decision on a permanent
 remedy. The statutory  preference for treatment will be met.


     GWS  3:  Additional Hydrogeologic Study/Pumping Wells
             (At/Adjacent to and Within the Plume) With
             Groundwater Treatment, Stream Discharge


       Estimated Capital Cost:  $2,232,000
       Estimated Annual O&M:    $284,000
       Estimated Present Worth: $3,957,000
       Estimated Time to
       Install/Complete:        2+ Years/5+ Years
           (costs  assume 5 years of groundwater pump and treat)

 This interim alternative is similar to option GWS 2 except that
 the intent of  both hydrogeologic data collection and the pump and
 treat  system is to determine the potential for and feasibility of
 capturing and  treating the entire contaminated groundvater plume.
 Monitoring wells  will  also be placed in an attempt to further
 characterize the  plume and to obtain sufficient data to determine
 the extent of  site-related groundwater contamination.
 Specifically,  wells will be placed to determine if the site  (l)
 is impacting or may impact groundwater located beyond the major
 fault  located  approximately 1/2 mile south of the site and (2) is
 impacting or may  impact groundwater utilized by residents located
 north  and northeast of the site along Telegraph Road, upper North
 Sandy  Hill Road and Hill Road east and west of North Sandy Hill
 Road.

 This remedy generally  entails the installation of several
 recovery  and/or monitoring wells located at a distance from the
 site to observe how large portions of the contaminant plume will
 respond to recovery operations and to determine the
 practicability of addressing this entire plume in a final
 decision  for the  site. (The estimated costs for this conceptual
 recovery  system design are based on the 47 well recovery system
 for Alternatives  GW7 and Dl appearing in Appendix E of the
 Preliminary Final FS.  Estimated costs presented herein are  lower
 than those appearing in the Preliminary Final FS document since
 EPA believes that the  stated goals of this interim remedy do not
 suggest the installation of 47 wells.  A total of 15 recovery
wells was used for costing purposes for this interim remedy
 although  the actual number of wells installed must await the
 results of the initial hydrogeologic data. The actual recovery
well number may be more or less than 15.  The cost for the
 additional hydrogeologic work required in this remedy is based on
the Geraghty & Miller  proposal of December 12, 1990.)

Although  installation  of recovery and monitoring wells is
 expected  to  occur in a staged approach, the intent of the remedy

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                                36       William Dick Lagoons ROD

is to determine the practicability of remediating the entire
contaminant plume, not simply the groundwater contamination
nearest the former lagoons,  if the collection and evaluation of
data during the interim remedy suggests to EPA that remediation
of the entire contaminated plume is impracticable, the final ROD
will indicate which areas of the plume will require remediation
and to what contaminant levels remediation will be attempted.

Similar to AWS 2, and in conjunction with an action-oriented
remedy for Unit 1, this alternative provides a measure of
protection to public health and the environment by beginning to
reduce the toxicity, mobility, and volume of contaminants and it
may serve to impede the flow of contaminants to residential wells
and ecological receptors. Because the scope of this remedy is
broader than AWS 2 in that it attempts to determine the potential
for cleanup of the entire contaminated -plume, the extent of
contaminant reduction should be greater.  This remedy also does
not set cleanup standards although the action has greater
potential for determining whether or not and at what cost Federal
and State groundwater standards can be met throughout the entire
plume.  This alternative does not ensure that pumping and
treating of the aquifer will continue until complete remediation
but it will collect the information necessary to make a well-
informed decision on such action.  Waiver of groundwater cleanup
ARARs is justified and would be invoked based on the interim
nature of the remedy and the provisions of Section 121(d)(4)(A)
of CERCLA.  ARARs will be attained for all regulated activities
associated with the operation of the pump and treat system.

     Noter  Both Alternatives GWS 2 and GWS 3 will require
     monitoring of the macroinvertebrate community at Stations 1
     and 2 on Indian Spring Run and Stations 5, 6 and 7 on Birch
     Run as identified in the ecological assessment portion of
     the RI.  Although the potential is considered minimal, this
     activity will be conducted to ensure that the pumping of
     groundwater does not result in hastening of the movement of
     groundwater contaminants into nearby streams. Such
     monitoring will include the EFT ratio (for ephemeroptera,
     plecoptera, and tricoptera) as found in EPA's Ba&id
     Bioaaaeaament Protocols for Use in Streams and Rivers.
     Benthic Macroinvertebrates and Fish. (EPA/444/4-89-001, May
     1989).  If the monitoring program indicates a decline in
     numbers,  diversity, abundance, or EPT ratio, chronic
     toxicity testing of surface waters and sediments should be
     incorporated.  (Additional monitoring requirements for the
     stream selected for discharge of treated groundwater will be
     determined by the State of Pennsylvania during issuance of a
     National Pollutant Discharge Elimination System (NPDES)
     permit.)

     As the frequency, duration and specific details of the
     monitoring program will be determined during design of the

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                                37       William Dick Lagoons ROD

      pump and treat  system, adequate cost figures cannot be made
      at this time  and  do not appear in the cost figures for
      Alternatives  GWS  2 and GWS 3.  However, it is roughly
      estimated that  costs of the  EPT ratio work will not exceed
      $10,000 per year.
VIII. COMPARATIVE ANALYSIS 07 THE ALTERNATIVES:

Each of the remedial alternatives under both site units has been
evaluated with respect to the nine evaluation criteria in the
National Contingency Plan, 40 CFR Part 300.430(e)(9).  A
description of these criteria appears in Figure 3.  The actual
evaluation of the criteria for each unit appears in Tables A
and B.
IZ. SELECTED REMEDY:

Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments, the
remedial alternatives selected for implementation at the William
Dick Lagoons Site are Alternative AWS4, Extension of the
Coatesville Water Line W/Institutional Controls and Alternative
GW83, Additional Hydrogeologio Study/Pumping Wells (At/Adjacent
to and within the Plume) with Groundvater Treatment, Stream
Discharge.

The goal of the selected remedy for Operable Unit 1, the
Alternate Water Supply, is to provide a proven, protective and
permanent water supply for the affected and potentially affected
residents surrounding the site. An additional goal is to attempt
to adequately meet the statutory preferences under CERCLA
described in Section X of this ROD.  The chosen remedy was
especially selected to eliminate risk associated with potential
future site exposure scenarios.

The primary goal of the chosen remedy for Operable Unit 2,
Groundwater, is to collect the necessary data to make a final
decision on the feasibility of complete groundwater restoration
and to commence work to reduce the mobility, toxicity and volume
of groundwater contamination.  An additional goal of the initial
hydrogeologic study portion of the remedy is to determine which
residents, based on potential groundwater impact from the site,
will require connection to the water line extension chosen for
Operable Unit 1.

The components of each remedy have been discussed throughout this
document. A breakdown of the capital, operation and maintenance,
and present worth costs associated with the two remedies can be
found in Tables 13 and 14.

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Fable A
Operable Unit 1
Alternate Water Supply
Evaluation Criteria
Overs* Protocttvanees to
HaaMhandEnvlrwuMnl
1 e.

LOCIQ Ttnn EftocttvMMM
Reduction of Toxtdty,
MoMltyandVoluiM
Sttort TMaV EffecUwnoM
ImplMainlibiHy
COSt
(Estimated to be 30% to +60%
Stats/Community
Acceptance

Alternative AWS 1 • No Action
(1988 Removal Order Remain* In Effect)
Limited protecton aince existing 1068 Removal
Order wil remain in place. Monitoring schedule may
not be adequate to determine contaminant exposure
to residents not receiving a point of entry (POE) unit
ARARa under the Safe Water Drinking Act (SDWA)
A 25 PA Code Chapter 109 may be violated on
disposal of keatment unit residuals requires
compsance wMi RCRA Subtitle C A 25 PA Code
Chapters 7S.21 to 75.38.
Point of entry systems only effective tor one to three
years. Replacement of the units nil be needed as
unto wi require continuous, efficient monitoring to
ensure exposure prevention.
Reduction In toxksty as a result ol treatment at He
homowel. MobUHy and volume reduction would not
be accomplished. Some concern regarding
contaminant •breaUhrough* Irom home freatmenl
urdta espadaly given Imited monitoring.
Low risk la workers associated with water
monitoring and changeover of home treatment units
containing contaminanted carbon.

instasalkm of home treatment units is relallvely easy
& Inexpensive. Concerns exist regardtogOAM
of tw units A continual samplng of numerous home
welt by araaponsMe entity for 20+yrs. EPA not
permitted to conduct OAM. Institutional controls
Implementation somewhat questionable.
Capitol Costa: $0 *
Operafon A Maintenance (OAM): $0 •
Present Worth: *0 •
Not recommended by state. Community members
preferring point-of-use treatment would be expected
to prater AWS 3.
Alternative AWS 2 - Institutional Controls
(1088 Removal Order Remains In Effect)
Slightly increased protection since 1088 Removal
Order remains in effect and institutional controls
would be implemented to aid in protection of future
residents moving into the site area.
ARARs under ttie SOWA A 25 PA Code Chapter 109
may be violated on occasion due to limited monitoring
schedule. Otlsite disposal of treatment unit residuals
requires compliance with RCRA Subtitle C & 25 PA
Code Chapters 75.21 to 75.38.
Point of entry systems only effective tor one to three
years. Replacement of the units will be needed as
determined by residential monitoring. Homes without
units will require continuous, efficient monitoring to
ensure exposure prevention.
Reduction in toxicity as a result of treatment at the
homewel. Mobltty and volume reduction would not
be accomplished. Some concern regarding
contaminant •breakthrough* from home treatment
units.
Low risk to workers associated with water
monitoring end changeover of home treatment units •
containing contaminanted carbon.
Implementation can be almost immediate since
installation ol home treatment units is relatively easy
& inexpensive. Concerns exist regarding OAM ol the
units & continual sampling of numerous home wells by
a responsible entity for 20+ yrs. EPA not permitted
to conduct O&M. Institutional controls implementa-
tion A enforcement somewhat questionable.
CC: $10.000*
OAM: $2.000 *
PW:f30.600*
Not recommended by state. Community members
preferring point-of-use treatment would be expected
to prefer AWS 3.
• Does not Include co»U associated with 1088 Removal Order requirement*.

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Table A {contj
Operable Unit 1
Alternate Water Supply
Evaluation Criteria
Overal ProtecUvenes* to
HeaMh and Environment




Compaanca wtth ARAfto


Long Term Eriecttvenea*

R^rtiirtbin nl Tnvlrltw
MobHtty and Volume

SllOft Toilet EneCtlVOfieee







Cost
(Estimated to be -30% to +50%
ol actual cost)
State/Community
Acceptance



Alternative AWS 3 •
Pomt of Entry Syatem
w/lnatConlrola
Due to increased monitoring, expected greater pro-
tection to homeowner* w/ POE ayttemt

HTOvmaa monHorwig m concur JMI eneciwiy. ntm-
fthto OftM lor 20 yW Of toAQBf It a major concern.
ly monitored tar ?0» yra to determine H exposure ex-
it*, fnsthueunaf control* heto protect new residents.
Due to InoreMed monitoring. 80WA » 26 PA
(Virte tt^t^t Ifltt ftmtJ^t wMi at MM m^rhviti*

homea piovidad traebnent unto era monitored
and maintained OHstodtepOMloftMkTwnl
unit residuate require* comptance wit* RCRA
Subtid* C * 25 PA Code Chapter* 75.21 to 75.38.
Point of entry ay alama only effective tor one to throe
yeara. Replacement of 0w unto wM be needed aa
untta wH require continuous. eOktont monitoring to
ensure exposure prevention.
n«wtir*««« >» fc»lrfev •« • m
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Operable Unit 2
Qroundwater (Interim Remedy)
Evaluation Criteria
                                          ANmatwGWSI-
                                                           AttomaHveGWS2-
                                              Addl Hydrogwtogic Study/Pumping WeHa
                                                      (at/adjacent to fontiM- lagoona)
                                                     ml Groundwater (QW) Treatment,
                                                            Slraam Dtecharae
                                                                                      Alternative GWS 3-
                                                                        Ado"! Hydrogeotoglc Sludy/Pumplng Walla
                                                                            (at, adjacent to, and removed from former
                                                                                  lagoona) w/ GW Treatment,
                                                                                       Spring Dtschsrae
       Pfotectlvefiose to
flaatln MM| Eitirlrofiiitofit
Wll not ba protective to environment since ground-
watof cootamlinK oanoentaliona may Increase.
Sortaco water bodes * aquatic Ha could ba affected
Unprotectrve of human healm H residents continue to
contact. Ingest, andtor Inhale contaminant* In
                           Environment receive* fmitod protection since highly
                           contaminated graundwator near tfte aite is captured
                           andteated. Portion ol contaminated plume removed
                           from site continues to discharge to surface water until
                           contaminants are reduced by natural dilution.
                           Residents receive tote reduction In risk since most
                           residents use the contaminated portion of
                           groundwater which is not addressed by this remedy.
                           Interim remedy would not be geared toward
                           determining if groundwater used by residents can be
                           actively, practicably treated.	
                                              Environment receives greater protection since a
                                              larger area of contaminated groundwater is captured
                                              & treated.  Contaminant levels in groundwater
                                              discharging to surface water bodies should be
                                              reduced. Most residential wells will continue to
                                              receive contaminated groundwater until a final
                                              remedy is selected. (Provision of an alternate water
                                              supply undar OU1 wil prevent exposure). Interim
                                              remedy goal is to determine if total area of
                                              groundwater contamination can be actively and
                                              practicably treated.	
Compliance with ARARs
No further evatuatic
                            is not protective.
tquirad since attemativa
Comptance with Federal and State groundwater
cleanup standards is beyond the scope of this interim
action.  Groundwater ARARs are being waived per
the justification requirements of CERCLA Section
121(dX4XA).  Al other pertinent Federal and State
ARARs*. Inckxfing wastewater discharge, treatment
residual disposal, and air emission standards, wV be
met Remedy ultimately is not directed toward
meeting EPA goal of restoring entire contaminated
ptume to its beneftdal use
Compliance with Federal and State groundwater
standards is beyond the scope ol this interim
remedial action. Groundwater ARARs are being
waived per the justification requirements of CERCLA
121(dM4KA).  All other pertinent Federal and State
ARARs*. Including wastewater discharge, treatment
residual disposal, and air emissions standards, will bt
met. Remedy ultimately is directed toward meeting
EPA goal of restoring the entire contaminated plume
to its beneficial use.    	
Long Tera Elfocttveneta
No further evaluation require) since alternative
ts not protective.
                           Criterion Is not appHcabte since this it an interim.
                           short-term remedy.  However, tils attemativa wil ba
                           effective in beginning to reduce polutant
                           concentrations in a heavily contaminated portion of
                           theaquifier.  The •offste* or downgradnnt portion of
                           the aquifier wl benefit from polutant reduction in Ms
                                              Criterion is not applicable since this is an interim
                                              short-term remedy. However, fcis alternative will be
                                              effective for beginning to reduce plume-wide
                                              contamination and determining Vie practicability of
                                              remediating all such groundwater contamination.
                                                                          upgradtent area (i.e. water lowing into the
                                                                          downgradtentarea is expected to have tower
                                                                          contaminant concenfrations.)	
* For a complete description of State laws applicable, relevant and approve to ttwse remedial alternatives.
  see the •Compliance witi ARARs' section In lie ROD.

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Tabte B (fiont)


Operabto Unit 2
Qroundwater (Interim Remedy)
Evaluation Criteria
Reduction of TojrJdry,

Implemontabilrly
COM
(Estimated to bo -30% to *60%

AMVMtfwOWSI-
No Acton
No further evaluation reiftarod tine* aftemaliva
Is not protective.
to lurtw evaluation raojuired since alternative
te not protective.
Itbi tvrttar •ii^i^fain mn^Ml >Wa •frmnallim
te not protective.
No further evaluation required ilnoo alternative
is not prolKtfvo.

tend protective.
Alternative GWS 2-
Addl Hydragootoglc Study/Pumping Write
(•Vod|acont to fornior lagoons)
«tf Groundwatar (OW) TiMtaMnt,
Slraom Dtodwrao
Mobttty and vohmo of oontuniMnto In groundwater
wil bo reduced In to area of Ihe oxkacten welto at
•ndad)ac0nltojh»site. Toxfcityolgroundwatorte
raduoad u • mud of tM kMfenanl technologies
employed. Mnorlranctor of contaminants to sludges

treatment process.
Minimal risk associated witi t>e bnplomentelion of
this remedy beyond ttsl normally experienced
during conskuceon work Minor contact with
contaminated water by workers Is possible. Air
as necessary to prevent risk to community.
Work te considered easily impfementable as tie
technologios omptoyod are conventional and well
developed. Interim nature of the remedy does not
require compliance wttt specific groundwater cleanup
goals. Assuming no unusual circumstances, design
and start-up of me pump and treat portion of tie
raawwfc* •hnidrt IMWM ^tfiln 9 119 wajv* fW RfVI
signature. AoVMonal hydrogeologic work can
begin within 6 months of ROD signature.
CC. $1.078.000
(MM: $166.700
PW: $2.289,000
Not acceptable to State. Mmbnal expression of
community interest in groundwater remedy.
Alternative GWS 3-
Add'l Hydrogeotoglc Study/Pumping WeHs
(at, ad|acent to, and removed from former
lagoons) */ GW Treatment,
Spring Discharge
Mobility and volume of contaminants reduced in a
wider area as a result of extraction wels placed
beyond locations adjacent to lagoons. Toxtctty ol the
groundwater te reduced as a result of the treatment
technologies employed. Slightly larger transfer of
contaminants to sludges anoYor carbon material as a
result of probable larger amount of groundwater
underooina treatment
Same as GWS 2.
Same as GWS 2 except time frame may be longer
due to expected larger size of the recovery
operation.
CC: $2.232.000
OAM: $284.000
PW: ^3. 957.000
Acceptable to State as an interim remedy only
Minimal expression of community interest in
oroundwater remedy.

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                                38       William Dick  Lagoons ROD


 Current data gaps regarding the extent  of the groundvater
 contaminant plume preclude  an exact delineation  of the water line
 configuration and residents to be serviced.  This information
 will be obtained following  completion of the hydrogeologic study
 planned for Operable  Unit 2,  the groundwater remedy.   The current
 draft plan for the hydrogeologic study  consists  of the
 installation of 10 to 17 monitoring wells with subsequent
 sampling,  water level monitoring,  and aquifer testing.

 Although cost estimating needs required selection of a specific
 groundwater treatment technology (i.e., pumping  wells, iron
 precipitation,  air stripping with emissions controls,  chemical
 oxidation,  stream discharge),  the actual type of treatment will
 be  selected after the ROD pending treatability studies.  The
 actual number of recovery wells to be installed  and volume of
 groundwater to be treated will be determined after the initial
 hydrogeologic study (for costing purposes, 15 wells were
 selected,  pumping at  a rate of 8  gallons per minute).   The
 number of  wells may be augmented  during the life of the interim
 remedy as  the work is expected to take  place in  an iterative
 fashion, reactive to  continuing data collection  efforts.


 Z.  STATUTORY DETERMINATIONS

 Section 121 of  CERCLA establishes several requirements and
 preferences when selecting  remedial actions at Superfund sites:

      (1) the selected remedy should be  protective of human health
      and the environment;

      (2) it should attain ARARs (or adequately explain the
      rationale  for invoking a waiver);

      (3) it should be cost-effective;

      (4) it should utilize  permanent solutions and alternative .
      treatment  technologies or resource recovery technologies to
      th« maximum extent practicable;

      (5) it is  preferable that the remedy permanently  and
      significantly reduce the toxicity, mobility, or volume of
      hazardous  substances.
Following is a discussion of how the selected  remedy for each
unit satisfies the above statutory requirements:

Protection <      '   ealth and the
   Alternate Water Supply - Extension of the  City of Coatesville

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                                39       William Dick Lagoons ROD

Authority  (CCA)  water  line with institutional controls was
selected primarily to:  (1) eliminate the current risk associated
with  the use of  contaminated groundwater, and  (2) eliminate the
potential  future risk  associated with the migration of site
groundwater  contaminants to residential wells.

The Agency also  has chosen the water line extension since it is a
permanent  and regulated remedy not subject to the constant
monitoring of individual home wells for an unspecified period of
time.   It  provides a more manageable water supply in that the
specific types of chemicals disposed of at the William Dick
Lagoons Site are basically unknown.  Such a scenario presents
risks associated with  the inability, due to analytical
limitations,  to  identify all site-related chemicals potentially
in groundwater and available for human or environmental exposure.
Alternative  AWS  4 also prevents any future exposure risk to
residents  should contaminated groundwater directly below the site
migrate to residential wells.• This possibility is a significant
concern since:

      (1) groundwater directly below the site presents relatively
      high  risks  (maximum carcinogenic risk • 2.0E-02 or 2 cancers
      per 100  individuals exposed, average carcinogenic risk -
      l.OE-03  or  1 cancer per 1000 individuals exposed, maximum
      noncarcinogenic Hazard Index - 30, average noncarcinogenic
      Hazard  Index - 2  (a Hazard Index above l suggests the
      potential for toxic effects),

      (2) several residential homes exist within 500 feet of the
      site  and over 70  residences are within 1/2 mile of the site,

      (3) details of groundwater contaminant flow, direction of
     groundwater flow,  and the proximity of elevated
     concentrations of  contaminants to residential wells are not
     well  known  at this point,

      (4) the  technical  feasibility of fully remediating the
     groundwater contaminant plume at this site is questionable
     due. to the  complex hydrogeology of the area.  A decision on
     whether  or  not such action can occur may require five years
     or sore> of  groundwater study and partial groundwater pumping
     and treating,  and

      (5) the  remedy selected for Operable Unit 2 will require the
     pumping  of  groundwater from several recovery wells.  It is
     possible that the  active pumping of these wells, along with
     the active  pumping of surrounding residential wells, could
     result in the migration of contaminants into home wells.
Based on the assessment presented in Appendix B  and discussed

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                                40       William Dick Lagoons ROD

 earlier in -the description of  remedial alternative AWS4, the
 Agency acknowledges that  a current carcinogenic risk exists as a
 result of the presence of trihalomethanes  in the CCA water
 supply.   In fact,  the risk currently posed by use of CCA water,
 in comparison to the use  of untreated groundwater contaminated
 with site-related compounds, is approximately equal.  However, it
 is important to note that EPA  utilized the standard assumed
 exposure period of a lifetime  or  70 years  when calculating the
 carcinogenic risk posed by each water source.  Because the Agency
 currently is scheduled to propose and promulgate new standards
 for trihalomethanes in 1993 and 1995, respectively, and such
 standards are currently expected  to be lowered, it is possible
 that CCA water users will not  be  exposed to existing
 trihalomethane levels for more than 6 to 8 years (possibly less
 if CCA voluntarily acts to reduce trihalomethane levels sooner) .
 A  decrease in the period  of exposure would serve to substantially
 reduce the carcinogenic risk associated with this remedy.

 Although not a basis for  undertaking remedial action at
 this site,  Alternative AWS 4 also provides an incidental benefit
 in that  it will eliminate the  residential  use of groundwater
 contaminated with naturally occuring radioactive substances.
 Because  such risk is significant, AWS4 will incidentally result
 in greater protection of  public health.  Appendix B discusses
 this risk scenario further.

 It should be noted that the risk  incurred  by consumers of both
 groundwater and public water does not end  with the contaminants
 referred to above.   There are  many additional chemical and
 bacterial waterborne health threats which  are generically
 associated with water bodies and  have little relation to the
 site.  A regulated public water supply can best address the
 majority of  these potential waterborne contaminants via the
 relatively stringent monitoring requirements of over 100
 substances  (both chemical and  biological)  as imposed by the
 Commonwealth of Pennsylvania via  Chapter 109 of Title 25 of the
 Pennsylvania Code.   Many  of the substances monitored in a public
water  supply will  not be  addressed via the continued use of
 private  wells.   Only contaminants known to be associated with
 the  sit* will be monitored. (See  Appendix  D for a discussion of
this issuer and related matters concerning  alternate water
Should such measures be needed, institutional controls will  be
established, as legally available, to assist in protecting public
health and the environment from the use of well water by
residents not selected or not choosing to connect to  the water
line.

(A more detailed discussion of institutional controls appears in
Section VIZ. Description of Remedial Alternatives)

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                                41       William Dick Lagoons ROD

Finally, there are no unacceptable short-term risks associated
with the implementation of this remedy.  No cross media impacts
are expected.  In fact, this remedy avoids the effects of
potential cross-media impacts to residential water use that might
occur during the implementation of pump and treat measures under
the Unit 2 remedy.


   Groundvater -   Selected Alternative GWS 3 is an interim
groundwater remedy which will be designed to collect sufficient
additional data and commence an initial pump and treat action to
enable EPA to make a final decision on groundwater remediation
within approximately five years.  This interim remedy, although
not intended to clean groundwater to background quality or risk-
based levels, will provide a measure of protection by reducing
the mobility, toxicity, and volume of groundwater contaminants.
The remedy may result in a mitigation of contaminant flow to
residential wells although containment of the groundwater plume
is not a primary goal of this activity.

Any potential unacceptable short-term risks associated with this
remedy will be controlled via proper implementation.  Any
potential cross media effects, including reduction in the
availability of residential well water or augmentation of
contaminant migration from the site to private wells, will be
addressed during design and operation.  Potential impacts to
stream ecology will be evaluated via the macroinvertebrate
monitoring program identified in the selected alternative.


Compliance With ARXRa

.   The following ARARs, expressed as chemical-, location-, and
action-specific (as well as To-Be-Considered Materials), are
identified for the two selected remedies:

Alternate Water Supply - all of the ARARs identified for the
selected, remedy for this Unit are expected to be met:

     (1} Chemical-Specific

          (a) Maximum Contaminant Levels (MCLs) and monitoring
          requirements promulgated under the Safe Drinking Water
          Act (SDWA), 40 CFR Parts 141 and 143 are applicable to
          the water to be supplied to the residents since the
          chosen remedy obtains water from a regulated public
          water supply;

          (b) Pennsylvania State Law requirements established in
          25 PA Code Chapter 109 are applicable as they apply to
          standards set for drinking water systems and drinking
          water quality.

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                                42       William  Dick  Lagoons ROD
      (2)  Action-Specific

           (a)  25  PA Code  Chapter  102 requirements concerning the
           control of soil erosion and sedimentation from earth-
          . moving  activities  are applicable;

           (b)  OSHA standards for  worker protection, 29 CFR Parts
           1904, 1910,  and 1926 are applicable.


      (3)  Location-Specific

           (a)  Depending on the location of the proposed water
           tank, 40 CFR Part  6, Appendix A as it pertains to
           provisions for  carrying out Executive Order 11990
           (Protection of  Wetlands) may be applicable.


      4) To-Be-Considered  Material:

           (a)  Section 501.14 of the Rules and Regulations of the
           Chester County  Health Department  (CCHD) requires that
           no individual water supply well be used, constructed or
          maintained where a public water supply pipe is within
           150  feet of the structure to be served by water.
           Section 501.13.2.3.3. of the CCHD Rules and Regulations
           grants  CCHD the authority to require new well drillers
           to analyze well water for harmful substances which the
          CCHD suspects are  present.  The CCHD interprets Section
           501.3.1 of the  CCHD Rules and Regulations to require
          that all residents connecting to a public water supply
          must "abandon"  their private well.  Abandonment of a
          well requires filling and sealing of the well as
          defined in Section 501.9 of the CCHD Rules and
          Regulations.  Depending on the configuration of the
          water line and/or  the development of new housing within
          the  site area,  these requirements would be applicable.
           (b) Page 3-13 of the Guidance Doci^?nt  f°r  Providing
          Alternate Water Supplies. OSWER Directive 9355.3-03,
          EPA/540/6-87/006, February 1988, strongly encourages
          connection to existing water supplies when  considering
          actions for alternate water supply provision.  The
          selected remedy follows this recommendation.

  Groundwater - the following identified ARARs for the chosen
remedy GWS 3 are described in terms of compliance capability:

     1) Chemical-specific

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                                43        William Dick Lagoons ROD

           (a) MCLs promulgated under SDWA 40 CFR Sections 141 and
           143 are relevant and appropriate in terms of attaining
           these criteria to restore the Class II aquifer to its
           beneficial use as a drinking water source:

         •(b) 25 PA Code Sections 75.264.90 - 75.264.100,
           particularly 25 PA Code Sections 75.264.97(i),(j) and
           75.264.100(a)(9), maintain that all groundvater
           containing hazardous substances must be restored to
           "background" quality.  EPA recognizes this requirement
           as an ARAR for remediation of groundwater at Superfund
           sites.

Note; EPA  is waiving the requirement to comply with the above two
ARARs based on the interim nature of the selected remedy, in
accordance with CERCLA Section 121(d)(4)(A).  This interim remedy
will attempt to obtain sufficient data to support selection of a
remedy meeting all ARARs in a subsequent ROD.

All of the remaining ARARs for this remedy are expected to be
complied with:

     2) Action-specific

           (a) Since the site groundwater is contaminated by the
           leaching of RCRA-listed waste, the groundwater
           treatment plant will be designed and operated in
           accordance with relevant and appropriate RCRA Subtitle
           C miscellaneous treatment unit standards (40 CFR
           Section 264, Subpart X) and/or tank system standards
           (40 CFR Part 264, Subpart J), as appropriate.  The
           groundwater will be managed in accordance with the
           "Contained-In Interpretation" (EPA OSW Memorandum of
          November 13, 1986, M. Williams, Director of Ofice of
           Solid Waste to P. Tobin, Director of Waste Management
          Division, Region 4);

           (b) The potential use of a carbon adsorption system to
          treat groundwater and/or emissions from air stripping
          processes will result in the generation of spent carbon
          or liquid regeneration waste. These wastes are expected
          to be characteristic wastes under RCRA as well as
           listed RCRA wastes as a result of the Derived-from Rule
           found at 40 CFR 261.3(c)(2).  These wastes will require
          treatment and/or disposal.  The following ARARs are
          therefore applicable:

                    - RCRA Subtititle C 40 CFR Part 261 for the
                    listing and identification of characteristic
                    hazardous wastes.  RCRA Subtitle C 40 CFR
                    Parts 262 and 263 and Department of
                    Transportation regulations at 49 CFR Parts

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                      44       William Dick Lagoons ROD

           171-179  for the generation and transportation
           of hazardous wastes. RCRA Subtitle C 40 CFR
           Part 264 for the management of hazardous
           wastes.  RCRA Subpart C 40 CFR Part 268 which
           establishes Land Disposal Restrictions for
           the management of hazardous waste.

           - 25 PA  Code Sections 75.259 through
           75.270.42 which establish State requirements
           for the  generation, transportation, storage
           and treatment of hazardous wastes are also
           applicable. Specifically, 25 PA Code Section
           75.262 requirements for generators of
           hazardous wastes, 25 PA Code Section 75.263
           requirements for the transportation of
           hazardous wastes, and 25 PA Code Section
           75.264 requirements for the treatment,
           storage  and disposal of hazardous wastes.

 (c) Use of chemical precipitation to remove iron and
manganese  is expected to result in the generation of
non-hazardous sludges requiring storage, transportation
and disposal.  The following ARAR is therefore
applicable:

     - 25  PA Code  Chapter 299 sets forth provisions for
     the collection, storage and transportation of
     residual waste. Dependent on the type of disposal
     chosen, one or more of the following apply: 25 PA
     Code  Chapters 287, 288, 289, 291 and 297.

If the iron and manganese sludge should fail the
toxicity characteristic leaching procedure (TCLP) test
established under 40 CFR Section 261.3, requirements
for the generation, storage, transportation and
disposal of the sludge under 40 CFR Sections 262-264
the Land Disposal Restrictions of Section 268 would be
applicable.  In addition, 25 PA Code Sections 75.259 .
through 75.270.42, establishing requirements for the
generation, storage, transportation and treatment of
hazardous  wastes, also would be applicable.
Specifically,  25 PA Code Section 75.262 requirements
for generators of hazardous wastes, 25 PA Code Section
75.263 requirements for the transportation of hazardous
wastes, and 25 PA Code Section 75.264 requirements for
the treatment, storage and disposal of hazardous
wastes.

(d) The Pennsylvania National Pollutant Discharge
Elimination System (NPDES) requirements established
under 25 PA Code Chapter 92, the Pennsylvania water
quality criteria established under 25 PA Code Chapter

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                      45       William Oick Lagoons ROD

93, and the wastewater treatment requirements for all
dischargers under 25 PA Code Chapter 95 are applicable
for the discharge of treated groundwater to Indian
Spring Run (or other appropriate local stream.)  Indian
Spring Run is classified by FADER as a cold water
fishery.  It is not certain, at this point, if the
discharge will occur "offsite" or "onsite";

(e) 25 PA Code Chapter 102 requirements concerning the
control of soil erosion and sedimentation from earth-
moving activities are applicable during the
construction of treatment facilities;

(f) The Fish and Wildlife Coordination Act (16 USC
Section 661, et seq.) sets requirements to protect fish
and wildlife as a result of control or structural
modification of a natural stream or water body.  This
law is applicable to the proposed discharge of treated
groundwater to Indian Spring Run;

(g) The following ARARs apply for air emissions from
groundwater treatment units:

     - National Ambient Air Quality Standards  (NAAQS)
     under the Clean Air Act (40 CFR Part 50) for the
     release of volatile organic emissions from the air
     strippers (the site lies within an ozone non-
     attainment area);

     - RCRA Subtitle C 40 CFR Section 264 Subparts AA
     and BB for the release of emissions from treatment
     units;

     - 25 PA Code Section 127.1 requires control of the
     emissions to the maximum extent practicable and
     consistent with the best available technology,
     unless found to be exempt under 25 PA Code Section
     127.14.  In addition, 25 PA Code Section 127.11
     requires plan approval by the Department of
     Environmental Resources.

     - all air contamination sources must comply with
     the eaission limitations, work practices, and
     other applicable requirements contained in 25 PA
     Code Chapters 121, 122, 123, 124, 129, and 135,
     specifically section 123.31 which prohibits
     malodors from crossing the property line and
     Section 123.41 which prohibits visible emissions
     beyond a prescribed level;

(h) OSHA standards for worker protection, 29 CFR Parts
1904,  1910, and 1926, and the requirements of  40 CFR

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                           46       William Dick Lagoons ROD

     Section 300.150 are applicable.


3) Location Specific

     a) 40 CFR Section 6-302 calls for action to avoid
     adverse affects, minimize potential harm, and preserve
     and enhance wetlands to the extent possible.
     25 PA Code Chapter 105 sets forth provisions for the
     regulation and supervision of dams, reservoirs, water
     obstructions, encroachments, and wetlands.  These ARARs
     are applicable to the discharge point for treated
     groundwater due to the presence of fringe, forested
     wetlands.

     b) Section 404 of the Clean Water Act (40 CFR Part 230)
     establishes requirements regarding the discharge of
     dredge and fill material into wetlands.  It is relevant
     and appropriate to the construction and bedding of a
     treated groundwater discharge pipe if it traverses the
     fringe wetlands to the receiving stream.

     c) Executive Order 11990 (Protection of Wetlands) which
     calls for action to protect and preserve wetlands to
     the extent practicable is applicable.


4) To-Be-Considered (TBC)  Material:

     a) Substantive requirements for well drilling,
     groundwater pump tests and discharges as found in the
     Pennsylvania DER's Bureau of Water Quality Management
     ARARs document are expected to be complied with.

     b) EPA's Groundwater Protection Strategy (August 1984)
     was created to protect groundwaters for their highest
     current or potential form of use.  Since the aquifer at
     the William Dick Lagoons Site is classified as a Class
     II groundwater, the strategy recommends cleanup to
     background or drinking water levels.  This TBC will not
     b« complied with under the scope of this interim
     remedy.   However,  the remedy is designed to ultimately
     determine the technical feasibility of returning the
     groundwater to its intended use.


     c) The intent of Recommendation 1 in OSWER Directive
     9355.4-03,  Considerations in Groundwater Remediation at
     Superfund Sites.  October 18, 1989, has been followed
     via selection of the interim remedy for groundwater in
     this ROD.

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                                47       William Dick Lagoons ROD

          d) The  "Off-Site Policy", Revised Procedures for
          Planning  and  Implementing Off-Site Response Actions.
          OSWER Directive 9834.11, November 13, 1987, is expected
          to be adhered to when disposing of wastes generated
          during  the remedial action.
Cost Effectiveness

EPA believes that the two selected remedies are cost effective in
that they provide overall effectiveness in proportion to their
costs.  Although each remedy is the highest in cost of the
associated alternatives evaluated, the Agency believes that the
chosen remedies provide the best balance of tradeoffs among all
nine evaluation criteria.  The permanency and regulated status of
the selected alternative for Unit 1 was regarded as an important
factor in its selection over other alternatives.  Selection of
the Unit 2 remedy was primarily based on its stated goal of
gathering data and commencing remedial operations to ultimately
determine the potential for total contaminant plume remediation
(per the intent of Section 121 of CERCLA).

The estimated present worth costs associated with EPA's water
supply selection are roughly $1.3 to $2 million in excess of the
point-of-entry system remedy strongly recommended by a site
responsible party.  The Agency believes these added costs are
warranted when considering the extensive oversight and monitoring
which would be needed for 30+ years of individual point-of-entry
system use.  In addition, the potential for human error and
negligence under such a scenario is an unquantified cost which
the Agency chooses not to ignore.

Regarding contaminated groundwater, the responsible party
recommended the continuation of further study.  Although the
Agency decision for Unit 2 also includes additional study, it
provides for immediate follow-up by an active pump and treat
system which will begin partial groundwater cleanup and provide
adequate data to determine the best means of remediating the
entire contaminant plume.  Such action is consistent with recent
EPA guidance on groundwater remediation efforts (see
Considerations in Groundwater Remediation at Suoerfund Sites.
OSWER Directive 9355.4-03, October 18, 1989) as well as the goal
of CERCLA to expeditiously commence the cleanup of Superfund
sites nationwide.  The difference in cost between the responsible
party's proposal to continue further study and the EPA decision
is estimated at approximately $3.3 million.  As stated above, the
Agency believes this additional cost is justified.

As a comparison to what the remedy may have cost, the Agency
originally considered making a final groundwater decision for the
site which was estimated to require 55 pumping wells at a present

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                                48       William Dick Lagoons ROD

 worth cost of from $6.8  to  $8.2 million.  This decision would
 have attempted to remediate the entire groundwater plume in
 accordance with the intent  of CERCLA to restore groundwater to
 its original use.   However,  EPA chose not to consider nor select
 this option since it was determined that data gaps regarding site
 hydrogeology precluded consideration of such an approach at this
 time.   The cost estimate for such a remedy and the time estimate
 for groundwater restoration would have been extremely
 speculative.


 Preference for Treatment as a Principal Element

 The selected remedy for  the water supply alternative does not
 entail treatment of the  contaminated water; such action will best
 be  addressed via the interim and  final remedies for the
 groundwater unit.   The remedy includes the provision of a source
 of  water unaffected by the  site,  which the Agency believes is a
 more effective remedy than  individual household treatment.  The
 unselected alternative of point-of-entry systems at each affected
 household  would entail treatment, but at a location and manner
 which poses significant  questions regarding long term operation
 and management.

 The selected remedy for  the groundwater unit satisfies the
 preference for treatment in that  a pump and treat operation will
 commence in the aid- to  later phase of this remedy.  The interim
 nature of  the remedy does not ensure that treatment of the entire
 groundwater plume will be performed, but it will assist in
 achieving  this goal in a final ROD, if determined to be
 technically feasible.


 Utilisation of Permanent Solutions and Alternative TreatB^n^
 Technologies  to the Mmclmw    eat Practicable
EPA has determined that the selected remedies represent the
maximum extent to which permanent solutions and alternative
treatment technologies can be utilized while providing the best
balance among the evaluation criteria.  The nature of the
environmental problems to be addressed serve to limit the ability
to select from numerous alternative treatment technologies in
this cas*.  However, it is possible that the treatment scheme
chosen during design to cleanse groundwater may include the use
of an alternative treatment technology.

A major reason for EPA's selection of the Coatesville water line
as the chosen alternate water supply is its status as a,
regulated, permanent water source.  Extension of public water
will eliminate the need, under the point-of-entry scenario, for
extensive and rigorous monitoring fi.e. . sampling and analyses)
of questionable effectiveness for more than 100 residential wells

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                                49        William Dick Lagoons ROD

over an unknown period of time.  (The 100 residences includes
both those provided with point-of-entry systems and those
residing in the plume who must continually have the well
monitored.)  Concerns regarding the identity of the company or
regulatory authority to operate and maintain the systems, as well
as manage the monitoring program, also will be eliminated.  The
line extension would eliminate the need to replace home treatment
units every one to three years.  It is preferred over the private
water company since all future operation and maintenance can be
addressed by an existing operator,  its permanency is practically
assured, and the minimal additional residual waste generated as a
result of processing a slightly larger quantity of water can
easily be assimilated by the existing treatment plant.

As previously discussed, although the water line option will
exclude the risk presented by the potential migration of site-
related groundwater contaminants to residential wells, it
presents an expected short period of carcinogenic risk associated
with trihalomethanes in the city water supply.  This option
continues to be preferred, however, based on:

     (1) the permanance of the water supply and its compliance
     with State and Federal standards;

     (2) the generally lower carcinogenic risk posed by the use
     of city water when compared to the potential future risk
     posed by migration of site contaminated groundwater to
     residential wells (see the discussion under Section Z.
     statutory Determinations - Protection of Human Health and
     the Environment);

     (3) concerns regarding the unknown materials disposed of at
     the site as it involves the potential leaching of these
     chemicals to groundwater. Sampling of home wells under the
     point-of-entry scenario cannot adequately address unknown
     chemicals;

     (4) EPA'a intent to officially revise the drinking water
     standard for trihalomethanes in 1995.  Current indications
     are that the Agency will reduce the permissable
     concentration of trihalomethanes in public water supplies;

     (5) several issues raised regarding the effectiveness of
     point-of-entry systems, including:

          a)  published reports that bacteria buildup in GAG
          systems are a potential health problem.  These reports
          suggest additional monitoring of the systems for
         . bacteria or, if necessary, the placement of UV lights
          after the installed system.  If enacted, such action
          would add to both the oversight and operation and
          maintenance burden;

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                                50       William  Dick Lagoons ROD


           b)  concerns raised by an  EPA researcher that backwash
           water associated with system operation  may contain
           contaminants.   Backwash water  is routinely discharged
           to  septic  systems  and can ultimately  leach down to
           groundwater.   Again,  monitoring of this water may be
           necessary  as a minimum measure.  The  same researcher
           expressed  concerns that systems undergoing backwash may
           result in  reconfiguration of unit carbon, thus making
           contaminant breakthrough  to water consumers more likely
           and rather unpredictable  for monitoring to detect.

           c)  concerns regarding the permanency  and reliability of
           the entity responsible for operation  and maintenance of
           the units  over a potential 30+ year time frame.

      (7)  since a pump and treat remedy has been proposed for
      Operable Unit 2,  the potential exists for  migration of
      contaminants to home wells as  a result of  the concomitant
      pumping  of remedial action recovery wells  and residential
      wells in a rather complex  and  somewhat poorly understood
      hydrogeologic system.

      (8)  the  following incidental benefits: (a) the significant
      carcinogenic risk associated with the presence of naturally
      occuring radioactive substances in  private well water will
      be eliminated and,  (b)  the water supply of connected
      residences will be  monitored for over 100  contaminants, some
      unrelated, to the site.   This relatively large scale
      protective measure  will not occur under the  point-of-entry
      monitoring program.

Regarding groundwater remediation,  the two action-oriented
alternatives  merely  differ in the scope  of the  action to be
implemented.   Where  Alternative GW2 merely attempts to determine
if the most contaminated portion of the  aquifer nearest the
former lagoons can be remediated, the intent of the chosen
interim remedy is to collect data and begin actions needed to  .
restore the entire contaminated groundwater area. As stated, the
prospect* for the practicability of this goal are unknown at this
time  and  * final decision on the scope of groundwater remediation
will  be mad*  at the  latter stages of this interim action.

EPA considered proposing total  groundwater remediation as a final
remedy in this decision  document.   Although such  a remedy is
generally the goal of groundwater cleanups under  CERCLA, the
Agency realized that current data was insufficient to pursue such
an option and that such  a decision  would be premature at this
point.

At the public meeting on February 14, 1991 announcing EPA's
proposed  decision on the site,  a large majority of residents

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                                51       William Dick Lagoons ROD

expressed dissatisfaction with EPA's proposal to extend the CCA
water  line.   Several  residents indicated that "the water tastes
bad" and expressed  the opinion that they did not move out to the
area to drink "city"  water.  Most of these residents, however,
appeared to be unhappy with the thought of paying a relatively
high monthly  water  bill since EPA could not gaurantee that
affected residents  would be reimbursed for the cost of their well
installation  or have  all or a portion of their monthly water bill
paid for by a site  responsible party.

Since  EPA was unsure  of the overall public sentiment as a result
of this meeting and an earlier public informational meeting in
August 1990,  the Agency decided to conduct a telephone survey of
residents whose well  water was known to be impacted by site
groundwater contamination.  The telephone survey was conducted
during the week of  February 25 and reached 27 of 50 residences
identified for contact. Survey results indicated that 20 of the
27 residences did not approve of the water line even if all costs
of installation were  paid by EPA  (or a responsible party) but
monthly water bill  costs were incurred by the resident.  However,
10 of  the 20  non-approving residents would accept the water line
if some co-payment  of monthly water bill costs were made or if
the costs associated  with earlier private well installation were
reimbursed to the resident.

Only 3 of 27  residents approved of installation of a community
water well to be operated by a private company.  Apparently, the
major concern with  this option (again assuming that all hook-ups
costs to the  distribution system were not paid by the homeowner)
involved the  unknown  costs of monthly water bills and the
identity of the long  term well and treatment plant operator.

Concerning continuation of the current point-of-entry system
procedures (with more frequent monitoring), 12 of 27 residents
approved and  15 of  27 residents disapproved.  The rationale for
each individual response on this issue was not determined as part
of the survey.

During th« public comment period on the Proposed Plan, an allied
group of homeowners indicated that they did approve of the water
line alternative if the site responsible party is ordered to pay
monthly residential water bills.  A local chapter of the sierra
Club suggested the  installation of water conservation devices in
homes connected to  the line to help defray water bill costs and
conserve water. The principal site responsible party strongly
objects to EPA's reasoning for the water line and recommends
continuation  of point-of-entry systems.  The Commonwealth of
Pennsylvania  agrees with the water line alternative.

The groundwater proposal for the site did not generate as much
comment as the remedy for alternate water.  At the public
meeting, most questions were concerned with descriptive

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                                52       William  Dick Lagoons ROD

 information on site hydrogeology.   During  the comment period, one
 resident suggested reccommendations for  implementing a pumping
 strategy at the site which the Agency will take into
 consideration.   The principal site  responsible party suggested
 foregoing the pump and treat portion of  the  interim remedy until
 further hydrogeologic study is complete.   A  local chapter of the
 Sierra Club questioned EPA's proposal to discharge treated
 groundwater to a nearby stream.  The Commonwealth of Pennsylvania
 accepts the interim groundwater remedy but is watchful regarding
 the  future decision on a final groundwater cleanup as it relates
 to compliance with State groundwater cleanup goals.
 All  of the above public comments have been evaluated by EPA
 before choosing the selected remedies. As  indicated above, and in
 Section III Community Relations History, the public opinion on
 the  alternate water supply remedy was carefully evaluated and
 sought out.   A response to each public •comment or recommendation
 during the public meeting and comment period appears in the
 Responsiveness Summary at the end of this  ROD.

 The  Proposed Plan for the site also included a remedy for cleanup
 of site soils.   This remedy was identified as Unit 3 - Source
 Control in the Proposed Plan.  Several comments were made on
 EPA's  proposed alternative of Thermal Desorption  with a
 Protective Cover.   The allied group of homeowners suggested
 incineration of site soils as the most appropriate remedy.  A
 company involved in unrelated cleanup negotiations with the
 principal  site responsible party also believes that incineration
 is the best remedy.   At this point  in time,  subject to further
 evaluation and study,  the Commonwealth of  Pennsylvania believes
 that incineration of site soils is  the best  approach. The
 rationale  for the above recommendations  center on several issues,
 namely:  concern that thermal desorption  will create more toxic
 and mobile chemicals as a result of oxidation reactions, concern
 that the thermal desorption/protective cover remedy will not
 restore the property to its former  precontaminated beneficial use
 as well as incineration might, and  concern that the thermal
 desorption/protective cover remedy  will  not  adequately mitigate
 contaminant leaching to comply with State  groundwater ARARs.
 The principal site responsible party believes that the
 alternative Vacuum Extraction with  Protective Cover, as discussed
 in the Proposed Plan,  should be further  evaluated via a pilot
 study  as an appropriate alternative for  the  site.

Because of the  above public comments, as well as  the rationale
presented  in Section XV.  Scope and  Role  of Response Action, EPA
has decided  to  defer its decision on the Source Control remedy.

DOCDMEKTATION OF SIGNIFICANT CHANGES

The major  revision to the selected  remedy  since the issuance of
the Proposed Plan  is that of deferring selection  of a remedy for
Unit 3  - Source Control.   As mentioned,  EPA  proposed a remedy of

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                                53        William Dick Lagoons ROD

Thermal Desorption with Protective Cover.  The reasons for
deferring selection of a remedy for Unit 3 are discussed in
Section IV. Scope and Role of Response Action of this ROD.  EPA
expects to select a final remedy for Unit 3 within twelve months
of this ROD.

Minor revisions since Proposed Plan issuance include the
following:

     - the description of alternatives AWS1 and AWS2 has been
     revised to reflect the continuation of the 1988 Removal
     Order and its requirements;

     - a component has been added to the Groundwater remedy
     which requires ecological monitoring of selected locations
     of nearby streams to determine any changes in stream quality
     or macroinvertebrate diversity;

     - estimations of time needed to complete each remedial
     alternative for each unit have been revised slightly in some
     cases per additional evaluation;

     - the titles of groundwater remedies GWS2 and GWS3 have been
     revised to more accurately indicate the importance of the
     initial hydrogeologic study work

     - minor changes have been made to the tables discussing the
     nine evaluation criteria to more accurately reflect EPA's
     analysis..

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WILLIAM DICK LAGOONS
 RECORD OF DECISION

 TABLES  1  through 14

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                                             TABLE  1
                                      GROUND WATER QUALITY
                                     WILLIAM DICK LAGOONS SITE
 Compound  -

 VOLATILES (ng/l)

 methylene  chloride
 acetone
 carOon  disulfide
 1,2-dichloroethene.  (total)
 chloroform
 1.2-dichloroethane
 2-butanone
 1.2-dichloropropane
 mchioroethene
 benzene
 4-metnyl-2-pantanone
 tetrachloroethene
 toluene
 chlorobenzene
 ethytbenzene
 total xylenes

 SEMIVOLAT1LES (ng/l)

 phenol
 bis (2-chloroethyl)  ether
 2-chlorophenol
 benzyl  alcohol
 2-methylphenol
 4-methylphenol
 isophorone
 2.4-dimethylphenol
 benzole  acid
 2.4-dichloropheno4
 1,2.4-tnchlorob«nzene
 naphthalene
4-chloro-3-methylphenol
2-methylnapthalene
dimethyl  phthalate
diethyl  phthalate
bis(2-ethylhexyl)phthalate
  Mexlmum       Average         Average
Concentration   Maximum*     Concentration
  Frequency
of  Detection"
36
960
32J
210
560
120
350
17J
16.000
180
220
320
510
32J
46J
160
36
480
17J
153J
487
102J
207
9J
14.000
170J
105J
250J
430
19J
27J
127J
3
39
4
20
39
1 1
16
<1
1.200
1 4
13
19
35
2
2
12
1 of ::
4 Of 13
6 of 13
3 of 13
8 of 13
3 of 13
3 of 13
1 of 13
9 of 13
5 of 13
3 of 13
2 of 13
3 of 13
2 of 13
2 of 13
3 of '3
14.000
24
41
19
300
560
250
70
480J
46
3J
58
21
6J
7J
4
170
10.300
17
1 4
17
21 7J
397J
247
23
413J
30
1J
35
7
3J
5J
3J
96J
818
2
1
1
18
32
28
2
32
3
<1
3
<1
<1
<1
<1
23
                                                    of 13
                                                    of 13
                                                    of 13
                                                    of 13
                                                    of 13
                                                    of 13
                                                    of 13
                                                  2 of 13
                                                  3 of 1-3
                                                    of 13
                                                    of 13
                                                    of 13
                                                    of 13
                                                    of 13
                                                    of 13
                                                  2 of 13
                                                  7 of 13
                                       Page 1 of 2

-------
                                        GROUND WATER QUAUTY
                                      WILLJAM DICK LAGOONS SITE

Compound
METALS (dissolved) (jig/1)
aluminum
barium
beryllium
calcium
cobalt
copper
iron
lead
magnesium
manganese
potassium
selenium
sodium
zinc
CONVENTIONAL PARAMETERS
biochemical oxygen
demand (BOO) .
total dissolved solids (IDS)
nitrate
alkalinity (as CaC03)
chloride
nardness (as CaCO3)
total organic carbon (TOG)
pH'"
Maximum
Concentration

1.430
83.7
1.6
5.280
20.8
14.4
20.200
1
4.260 '
863
8.520
2.4
32.500
61.2
(mg/l)
91

560
3.1
20
20
64
52

Average
Maximum*

1,430
83.7
1.6
5.280
20.8
14.4
19.300
1
4.260
863
4,260
2.4
32.500
61.2

91

560
3.1
20
20
64
52

Average
Concentration

164
25.7
0.1
1.875
3.3
3.9
4.870
0.27
1.705
193
426
0.2
3.182
61.2

<15

<85
<1.3
8.2
<5
22
<8.4
5.6
Frequency
of Detection"

3 of '2
12 of -2
i of 12
9 of 3
4 OM2
2 of 5
11 of :-•
4 OM '
3 of i
11 of 12
1 oMO
1 of 12 ' '
7 of 12
1 of 1

12 of "2

12 of '2
12 of 12
12 of '2
12 of 12
12 of 12
12 of 12

    Average maximum concentration is  calculated when the maximum
    concentration, is reported  for a well from which two or more samples
    were taken.  It ia the average of the reported  concentrations from  this  well.

• '  Out of a maximum of 13 wells for organics and 12 wells for metals;
    excludes from  me total sample count those sample  in which the anaiyte
    was detected in the blank.

' * ' From pump test on MW-20. October/November 1989.

Note:   Pesticides/PCBs not detected in any wells.

J -  Estimated  concentration
                                        Page 2 of 2

-------
                            TABLE 2
                                      "i




                     LAGOON AND BERM AREA SOIL QUALITY

                         WILLIAM OICK LAGOONS SITE
Compound
   Average     Maximum   Frequency of

Concentration Concentration  Detection*
VOLATILES (pg/kg)
1,1-dichloroethane
1 ,2-dichloroethene, (total)
chloroform
1,2-dichloroethane
2-butanone
1,1.1-trichloroethane
1 ,2-dichloropropane
trichtoroethene
benzene
4-methyl-2-pentanone
tetrachloroethene
toluene
chtorobenzene
ethylbenzene
styrene
total xylenes
SEMIVOLATILES (ng/kg)
phenol
1 ,4-dichlorobenzene
1.2-dichlorobenzene
2-methylphenol
4-methylphenol
nitrobenzene
isophorone
2.4-dimethyfphenol
benzoie add
2,4-dichlorophenol
1 ,2.4-trichlorobenzene
naphthalene
4-chloroaniline
hexachlorobutadiene
4-chloro-3-methy (phenol
2-methylnaphthalene
2.4.5-trichlorophenol
2-chloronapnthalene

137
3.120
179
741
12.040
<1
<1
3.634.600
233
106
3.790
118,100
4.320
16,800
11.700
258,200

15.100
99
990
1,650
2.480
63
1.390
1.010
41
1,810
63,600
88,700
4.830
67
133
21,000
8
31

3.700
48,000
4.100
15,000
325.000J
5J
U
93.000.000
5.500J
2.800J
73.500J
2.500,000
64,000
200.000
217,500
5.500.000

350.000J
2.200J
7.200J
36.000J
44.000J
3.400J
31.000J
20.000J
900J
38.000J
1.300.000J
1.500.000J
130.000J
1.800J
3.300J
220.000J
210J
1.700J

' 1 of 27
5 of 27
4 of 27
4 of 27
1 of 27
1 of 27
1 of 27
12 Of 27
2 Of 24
2 of 27
8 of 27
12 of 27
12 of 27
14 of 27
4 of 27
12 Of 26

10 of 27
4 of 27
10 of 27
5 Of 27
8 Of 27
1 of 27
2 of 27
3 of 27
2 of 27
6 of 27
15 of 27
15 Of 27
2 of 27
1 of 27
3 Of 27
15 of 27
1 of 27
1 of 27
                            Page 1 of 3

-------
                     LAGOON AND BERM AREA SOIL QUALITY
                         WILLIAM DICK LAGOONS SITE
Compound
   Average     Maximum   Frequency of
Concentration Concentration  Detection*
SEMIVOLATILLS (cont'd) (ng/kg)
dimethyl phthalate
acenaphthylene
acanapthene
dibenzofuran
diethyl phthalate
fluorene
N-nitrosodiphenylamine
pentachlorophenol
phenanthrene
anthracene
di-n-butylphthalate
fluoranthene
pyrene
butylbenzylphthalate
benzo (a) anthracene
chrysene
bis(2-ethyihexyi)phthaiate
di-n-octylphthalate
benzo(b and/or k)fluoranthene
benzo(a)pyrene
indeno(! ,2.3.c,d)pyrene
dibenzo(a.h)anthracene
benzo(g,h,i)peryiene
PESTICIDES/PCBs (tig/kg)
heptachlor epoxide
4.4-.ODE
METALS (mg/kg)
aluminum
arsenic
barium
beryllium
cadmium
calcium ,•
chromium

1 1
740
3,970
3,570
83
4.240
734
2
16.500
1.830
5.910
8,360
6.020
11,300
1.860
2.130
169.000
4.720
3.540
1.250
300
81
300

6
34.300

8.040
5.2
81
0.09
0.04
2.190
39

590J
7.000J
47.000J
36.000J
1.400J
41.000J.
5.300J
54J
280.000J
13.000J
32.000J
200.000J
120.000J
78.000J
30.000J
29.000J
1.200.000J
29.000J
54.000J
26.000J
7.600J
2.700J
8.000J

150
220.000

15.100
14J
672J
0.51
1.1J
11,100
349J

- 1 of 27
8 of 27
13 of 27
13 of 27
2 of 27
13 Of 27
5 of 27
1 of 27
16 Of 27
16 of 27
14 of 27
16 of 27
16 of 27
15 Of 27
13 Of 27
16 of 27
22 Of 27
15 of 27
15 Of 27
11 Of 27
5 Of 27
3 of 27
5 Of 27

1 Of 27
17 of 27

27 of 27
27 of 27
27 of 27
1 of 6
1 of 26
6 of 6
26 of 27
                            Page 2 of 3

-------
                       LAGOON AND BERM AREA SOIL QUALITY
                           WILLIAM DICK LAGOONS SITE
Compound
   Average     Maximum    Frequency of
Concentration Concentration  Detection*
METALS' (cont'd) (mg/kg)

cobalt
copper
iron
lead
magnesium
manganese
mercury
nickel
potassium
silver
sodium
vanadium
zinc
     1.4
     19
    7,960
     24
     916
     64
     0.01
     5.4
     '628
     0.1
     38
     13
     52
  4.1
  40J
18,000
 269J
 5.080
  160
  2.3
  14
 3.070
  1.7
  644
  28J
 253J
 5 of 6
 7 of 8
27 of 27
27 of 27
18 of 18
23 Of 23
 3  Of 27
17 of 27
 4  of 17
 2  Of 27
 1  Of 17
27 of 27
23 of 23
J -  estimated concentration
* excludes from the total sample count those samples in which analyte
  was detected in the blank.
                              Page 3 of 3

-------
                                    TABLE
                                    Dioxin Data Summary
                                 William Dick Lagoons  Sit*
                            West Cain Township. Chester  County
EHM T.R. No.
Sample Location
Sample Date
units

2.3.7.8-TCOO
other TCDO
2.3.7.8-TCDF
other TCOF
2.3.7.8-PCOD
other PCOO
2,3,7.8-PCOF
other PCOF
2.3.7,8-HxCOO
other HxCDO
2.3.7.8-HxCDF
otherHxCDF
2.3.7,8-HoCOD
other HoCDD
2.3.7.8-HoCOF
other HpCOF
OCOO
OCOF
2.3.7.8 TCDD equivalents

23297
0-Backqround
1 0/1 1/89
uq/Kq










0.006



0.05


5.9

uq/Kg
0.007
23298
0-9 (2-*)
1 0/11/89
uq/Kq




0.06












3.8

uq/Kq
0.0044
23301
0-4 (0-2)
10/1 1/89
uq/Kq


0.18
0.01
0.19

0.01
0.006
0.024
0.05
0.27
0.03
0.03
0.37
0.42
0.08
0.01
4.1
0.18
uq/Kq
0.0248
23299
0-6 (2-4)
10/1 1/89
uq/Kq




0.035






0.095



0.26


2.4
uq/Kq
0.0145
* These results am approximate only; matrix  interference) would not allow
accurate  quantitation.
Concentration* not detected at or above the method  detection  limit have not been reported.

-------
                           TABLE  4


            FORMER SPRAY IRRIGATION AREA SOIL QUALITY
                    WILLIAM DICK LAGOONS SITE
Compound
  Average      Maximum    Frequency of
Concentration  Concentration    Detection
VOLAT1LES

SEMIVOLATILES
benzole acid
4-chloro-3-methylphenol
pyrene
bis(2-ethylhexyl)pntnalate

PESTICIDES/PCBs

METALS (mg/kg)

aluminum
arsenic
barium
beryllium
chromium
cobalt
iron
lead
magnesium
manganese
mercury
potassium
sodium
vanadium
zinc
45
6
23
20
360J
50J
180J
160J
1 of 8
1 of 8
1 of 8
1 of 8
   10.645
14.500
8 of 8
2.2
39
0.32
10
2.7
7.856
8.6
730
121
0.1
748
254
15.5
31
3.5
46
0.58
20
4.3
11.700
15
1.260
291
0.65
2.170
1.070
21
38
8 of 8
8 Of 8
6 of 8
8 of 8
7 of 8
8 Of 8
8 of 8
8 of 8
8 of 8
1 of 8
4 of 8
2 of 8
8 of 8
8 of 8
J - estimated concentration
NO • not detected

-------
                              TABLE  5
                         SURFACE WATER QUALITY
                       WILLIAM DICK LAGOONS SITE
                                Maximum       Average      Frequency
Compound	   Concentration  Concentration  of  Detection'

VOLATILES                                                    N 0

SEMIVOLAT1LES                                                N 0

PESTIClOES/PCBs                        .                      NO

METALS  (dissolved) (u.g/L)

aluminum                          119            32          8 of 15
barium                             58            31          15 of 15
calcium                           18200          7515         15 of 15
iron                               117            46          14 of 14
lead                                2             0.5          7 of 15
magnesium                         7730          5400          3 of 3
manganese                          37            14          13 of 15
nickel                              82             5           1 of 15
zinc                                37            37           2 of 2

•  • Total number of samples excludes samples in which the
     analyte was detected in the blank.
NO •  Not detected

-------
                             TABLE  6


                       STREAM SEDIMENT QUALITY
                      WILLIAM DICK LAGOONS SITE
                               Maximum       Average       Frequency
Compound	     Concentration   Concentration  of Detection1

VOLATILES  (tig/kg)

chloroform                        2J              1           10 of 15
toluene                           5J             0.3           1  of 15

SEMIVOLATILES

benzoic acid                       82J             5           1 of 15
phenanthrene                 •      73 J             5           1 of 15
fluorantnene                       67J             5           1 of 15
pyrene                            65 J             4           1 of 15
bis(2-ethylhexyl)pnthalate           95J            13          3 of 15

PESTICIOES/PCBS                                               MD

METALS (mg/kg)

aluminum                       8.630J          3,374         15 of 15
arsenic                           5.8J            1.4          10 of 15
barium                            107            32          15 of 15
beryllium                         0.69           0.21           6 of 15
calcium                          3.320           884          15  of 15
chromium                         29             11          13  of 15
copper                            36             12           1  of 3
iron                             15.900J         7,034         15  of 15
lead      .                         21              8           15  of 15
magnesium                       1.990           618          13  of 15
manganese                       1.300J           276          15  of 15
potassium                        2.380           273           2 of 15
selenium?                        0.79J           0.08          2 of 15
vanadium                         119            19          14 of 15
zinc                               119J            34          15  of 15
  * Total number of samples excludes samples in which  the analyte
   was detected in the blank.
J - estimated  value

-------
                               TABLE  7


                   SUMMARY OP CHEMICALS OF CONCERN
                             IN EACH MEDIUM
Off-Site Ground Water

1.2-dlchloroethene (total)
   1.2-dlchloroethane
      chloroform
  1.1.1-trtchloroethane
    tnchloroethene
   tetrachloroethene
    chlorobenzene
  dichlorobenzend 1.2)
  dlchlorobenzenei 1.4)
   1.1 -dlchloroethene
   1.1 •dichloroethane
          Soil

       chloroform
     tnchloroethene
    tetrachloroethene
     chlorobenzene
  1.2.4-tnchlorobenzene .
      naphthalene
     phenanthrene
      fluoranthene  •
bls(2-ethylhexyl)phthalate
       •4.4'-DDE
      acenapthene
        fluorene
benzo(a)pyrene equivalent
       anthracene
   heptachlor epoxlde
   2.4-dichlorophenol
        arsenic
        barium
       chromium
       manganese
       vanadium
 Qn-Slte Ground Water

       chloroform
   1.2-dlchloroethane
     tnchloroethene
        benzene
   tetrachloroethene
 bis(2-chloroethyl)ether
        barium
       beryllium
       manganese
bis(2-ethylhexyl)phthalate
         phenol
 1.2-dichloroethene (total)
     chlorobenzene
4-methylphenol (p-cresol)
   2.4-dlchlorophenol

-------
         TABLE  8
Exposure and Migration Pathways
       William Dick Lagoons
Madia
Ground water
Surface water
Sediments
Air
Surface •ell
D*M meal
(novation
Source
Contaminated eoayieechale
Discharge of
contaminated ground water
Discharge of
contaminated ground water
Contaminated Ml • dual
Contaminated aoil
Contaminated soft1
water
Exposure Point
drinking water aquifer
Indian Spring Run.
Birch Run
Indian Spring Run.
Birch Run
MB
On tile
Ofl the
Exposure
Route
Dermal contact
Ingeslion
Inhalation while showering
Qarmal contact
Ingeslion-waler
Ingestion-lish
Dermal contact
Food chain btoaccumulation
Inhalation of fugitive dust
Inhalation of volatiles
Dermal contact
Incidental ingeslion
Ingestion
Selected lor
Analysis •
yes • residential wells nearby
yes - residential wells nearby
yes - residential wells nearby
No • no significant contaminants detected
No • no significant contaminants delected
No - no significant contaminants detected
No • no significant contaminants detected
No-no significant contaminants detected
Yea
Yes
Yes
Yes
Yes

-------
                                   TABLE  9
               •TANOARO 'ARAMrriM* VON CALCULATION Of DOSAOI AND IHTAK1
                                WUJAM OICX LAOOONS SfTt
-
Avaraga Body Watgm
A»iraga SUn Surfcc* Araa
Avoraga N». Yn Exposur* m 70 yoar Ufoomt
Acnvmr cHARAcnmrnc*
RUOWMTUL UW Of OJROUNO WAT1R
Amount-or wiior ftgessM Oauy
Ptreantaga el Mtar from homo supply
P*re*ntag* of Skin Surtic* Aroa
immofsod Wfiilo Snowortng/Batning
Duraoon el Oarma) Exposur*
SOH.OCM6URI
Amount or Soil lng**M IneManWly
Poreamago or Skin Ar*a ConojctM By
Soil Contact
Skin ADsorpaon Ret* or Compounds
in Soil
Froquoney or Sod Contact
Amount of Vamaon ingoswd
Frequency or mga*tton
innatanon Raia
Aoaorpian Raw of innalia Air
Ouraoon of Expoaur* (Mr Mil)
Fraquancy ol Exposure (for MEI)
SWMMMB
r»or eana^a or $wn Araa Carnaaad
F,epu*K, or »-««*, E~,
MATaffflAL TttAftAfTTWlWTWal
Dual Aenararw
M Man maa
M-n-R-^^n

(a)
(S)
(d)

(&.«)
<•)
(Q)
(d)
. Mas Q.  IM«.  Tisattti impicanoni at aj.7>siuatft>e«oda»ruo p dtexm (TCOO)
                          sar. Journal ol Toxicotogy and EiMiuHmonoa Haam i4:47-tj.

-------
    TABLE  10
 MA
  0
  .MA
  A
  MA
  1A
  MA
  0
 HA
 MA
 e
 o
 o
 o
 MA
 0
 33
 MA
 MA
 MA
 MA
 MA
 MA
 MA
 MA
 MA
 MA
 n
 MA
 MA
 n
 MA
 MA
 0
 MA
 MA
 MA
 MA
 MA
 HA
 MA
  A
 MA
  A
  MA
  D
  MA
  MA
  0
  MA
  MA
  .MA
  MA
  0
  MA
  M
  MA
ou/KMir
OU/HCAtr
  H«AJT
              room
POOR QUALITY
   ORIGINAL

-------
                                                                                        TABLE  11
                                        •GMHART or CABcafoocmc Rax
                                               WUUm Dick LtgooM
      POPULATIOH}              Malt               Child S-ia             Child 1-S	Ufatim*

POTENTIAL EXPOSGBE SCSXABKM OHDEB CVBBCHT CONDITION*
Ofl-SlU Croud Wtttt         7E-06  • 2E-O4         2C-06  •  4E-05        2E-O6  -  SE-O5         IE-OS - 3E-O4
Oa-SIU Soil*                5E-O6 -  IE-03         3E-06  •  6E-06        2E-06  •  6E-06         9E-O6  • 2E-OS
O*tr M«*t iBgMtiaa          4E-06 • 9E-06         9E-07  -  2E-06        6E-O7  -  IE-OS-        SE-06 - IE-05
                           4E-O6 - IE-OS         6E-07  -  2E-O6        4E-07  -  IE-OS         SE-O6 -  IE-OS
lUcntdankl UM of
Spria«*4«                  3E-08 - 3E-08         4E-09  •  SE-09           MA  -  MA           3E-O8  - 3E-08
Totml                       2C-OS • 2*O4         6E-M  - SB4S        SB4«  -  ««-O»        3B4»  -  3C-04


HTPOTKCTICAL EZPOCOXB KX1CAIUO OHDCX TUTVH* (ISC CONDITIONS
Hypothetical UM of
Oa-SIU Oronad Wator         IE-O3  • IE-OS          3E-O4  - 3E-03        3E-04  •  3E-03        IE-O3   •  3E-02
NOTE: USEPAg«i4ottBMf«r««alwdMofcaielaaff«iatlakiao«ify«ttffMnat«afMe«pUbtoflakbotWMa 1 E-« «ad 11-4.
          llea isdleau —**«..»~i po»Mrttl rUk« wUck «MO*4 tkU gatdoHa^

-------
                                                                     TABLE   1  2
                          tCKMAKT OF KOHCJ
                             Adult
                                                OHM 6-13
pomnut BSOMKC •CKNARIO* ORDER cuuzirr coiaxTtom
Off-WU Or*od W«U»         3E-03 . 1E-01         1E-03  -  3E-01
                                                                   2E-02  • 3E-01
                         2E-02 • 5E-02
                                              1E-01  -  3E-01
                                                                   1E-01  • 3E-01
                          4E-03 • 1E-01
                                              9E-03  -  3E-01
8E-02  -  3E-01
                         3E-03 • 8E-03
                                              4E-03  .  IE-OS
3E-03  •  1E-02
                         6E-06   7E-06
                                              9E-06  •  IE-OS
  MA • NA
Tottl
                                                                   3B-01  •  OBXI1
           AL EXKMUBX •CENAJUO UMDCB rOTCU OBC COM

                          4E-01 • 6E*00        1E«00
                                                                  2E«00
ItOTB: OUPA gold«llaM far •*mhud«« of MaMnteopale kuud tadkM
Huvd tadlcM vktek «e»»4 1.0 tedieat* tkst tkM* to tfe« poUMUl for td
with th« 4«ftM4 uporar* MwUdau.  Buw«tadl«M (TMttr tka 1.0 «•
                                                                • «alM «T 1.0 far teurprtudon.
                                                               kMltk «fr«et* M

-------
           Estimated

Capital Cost:

ITEM

Water Line
Distribution
System

Service
connections

water Storage Tank

Pump Station w/new
pump
       TABLE  13
Costs for Extension of Water Line
  QUANTITY

  14750 to 19950
  linear feet at
  $50/ft.

  80 homes at
  $2000/home

  1 at 250,000 gals.

  1 at 200 hp
                        Total Direct
                        Construction  Cost
                        (TDCC)

                        Engineering,
                        Legal,  Health,  and
                        Safety at  25% of
                        TDCC

                        Contingency at  30%
                        of  TDCC
COST


$737,500 to
$997,500
$160,000



$250,000

$4,000
                          $1,051,900 to
                          $1,411,500
                          $262,975  to
                          $352,875
                          $315,570  to
                          $423,450
                        Estimated  Total
                        Installed  Cost
                          $1,630,445  to
                          $2,187,825
operation and
Maintenance Costa:

Monthly water
bills minus
private well
operation, site
monitoring
                          $21,000  to $46,000
                          (Annual  O&M for  30
                          years)
                        Total  Present
                        Worth
                        (assuming 5%
                        discount rate)
                          $2,034,000
                          to $3,071,000
                          (rounded).

-------
                             TABLE 14
              ESTIMATED COSTS FOR GROUNDWATER REMEDY
 (Note: Costs are estimates based on scaled down version of
Alternative GW-7 appearing in the Preliminary FS.  Treatment
units presented below are used for cost estimating purposes only,
The actual treatment units employed at the site may vary.)
Capital Costs:

ITEM

Hydrogeologic
Study  (11
monitoring wells,
sampling, aquifer
tests)

Recovery Wells

Piping

Tee Connections

Well Pumps

Sumps

Sump Pump System

Equalization Tank


Equalization Tank
Pump System

Iron Precipitation
System

Process Pump

Building-
Oxidation/Air
Stripping System
QUANTITY
15 at $12,000 each

4800 ft at $15/ft

15 at $26/ft

15 at $3000 each

2 at $2.200 each

2 at $15,000 each

1 - 10,000 gallon
tank
2 at $5,000 each

1100 sq ft at
$50/sg ft
COST

$700,000
$180,000

$72,000

$390

$45,000

$4,400

$30,000

$25,000


$15,000


$300,000


$10,000

$55,000


$200,000
                        Total  Direct
                        Construction Cost
                        (TDCC)
                        $937,000
                        (rounded)

-------
                                                           Page 2
                             TABLE 14
              ESTIMATED COSTS FOR GRODNDWATER REMEDY

                        Engineering,            $234,000
                        Legal,  Health &
                        Safety,
                        Construction
                        Management
                        (ELHSCM)  at 25%

                        Contingency at 30%      $281,000
Discharge to            5280  feet               $80,000
Surface Waters          discharge  line  at
                        $lO/ft  (plus
                        contingency and
                        ELHSCM)
                        Estimated  Total         $2,232,000
                        Installed  Cost
Operation & Maintenance Costs:

Includes sludge disposal, sludge              $284,000
transportation, iron precipitation         (Annual O&M for 5 yrs)
and oxidation/air stripping operation,
pump maintenance, equipment maintenance,
discharge line maintenance and labor for
an estimated 5 years.  (Contingency and
ELHSCM included.)

                       Total Present Worth*    $3,957,000
                       (5% Discount Rate)
  Cost  associated with ecological monitoring not included.

-------
WILLIAM DICK LAGOONS
  RECORD OF  DECISION

 FIGURES 1 through  10

-------
                        Site Location Map
                       William Dick Lagoons Site
                         Wtst Cain Township
                    Chester County, Pennsylvania
                       SITE
Sourc* USOS Topographic Ouadrmto. T4 ICmM S«iM.

-------
                                                     FIGURE   2
                                                                                     Chester County
           Approximate Loc*||M of
     Security Fence liMUtof In 1*7
                  r»nur I^MM N». I
                                                                          f ormur Lagoom No. 3
                                                                                                      Spray Irrigation
                                             Lagoon Bum Borrow ATM
                                                                                                         0  -   50

                                                                                                        Scale in Feel
             Oiarakf/Oito: E Knoplle 10/89
OMctrtt»/0«U: J LaRegina
110-15-07-02
                       :  P. Orabowskl 12/12/89
                                                          E. Boibely 12/12/09

-------
       •IE NINE REMEDIATION
      EVALUATION CRITERIA
                FIGURE 3
THRESHOLD
 CRITERIA
                      OVERALL PROTECTION OF
                      HUMAN HEALTH AND THE
                          ENVIRONMENT
                         COMPLIANCE WITH
                             ARARS
 PRIMARY
BALANCING
 CRITERIA
                          LONG-TERM
                       EFFECTIVENESS AND
                          PERMANANCE
REDUCTION OF TOXICITY,
 MOBILITY, OR VOLUME
 THROUGH TREATMENT
                     SHORT-TERM EFFECTIVENESS
                        IMPtEMENTABIUTY

                            COST
MODIFYm
 CRITERIA
                        STATE ACCEPTANCE
                      COMMUN rnr ACCEPTANCE

-------
                                FIGURE  4
                      Monitoring Well Locations
                          William Dick Lagoons Site
                     West Cain Township, Chester County
                                     u i.i
	
                                    ^•
 I
 •
  •
  I
  I
 100
 100   200  300 4QQI
Scai* in Fe«
         LeGEND
  MW-1 ^ Monitoring Well Nest
   BC-iO Rock Coring Location
 4-
MW-110
MW-12S
WM
  110-15-07-02
    Dmm oy / OM: D.GrabOwaki 11/15/89
                      D.
   CBtckMttv/o«K E-Boibely 11/15/89

-------
    William Dick Lagoons Site
    Surrounding Water Supplies
    Sampled to Date
                                              Approximate Location
                                               otFonmrUgoons
Source: The ERM Group
     Preliminary Final RI/FS September 6.1990

-------
                                         FIGURE  e
                                Area of Site Related Impact
                                William Dick Lagoons Site
                                        Tpwnship,
                                                   *** hnpacw by Sitt-fltlated Ccnraminant;
                                                      i
                                                   RttidmtiH Samoting Location
                          /0«r 0. Qrttowtki 3/7/90
i





-------
                                      :           FIGURE  7   ———	

                                         Soil Sampling Locations
              - "*••               Former Lagoon and Spray Irrigation Areas
                        William Dick Lagoons Site, West Cain Township, Chester County
           ^P kV*fMvMyeT^MaWlVl  .1J.' • '^i''*(^ *{ -                     ^

            Former Lagoon Af*e)
                                                                         .\p-ie* wpiajr inigaiion Area-,
                                                                         irf--t--7---n
                                                                                                           100
                                                                                                  HA-2*
                                                                                                     f
                                                                                                     I

                                                                                       LEGEND
                                                                                HAOA  Hand Auger Samplng Location

                                                                                 B-1«  Sol Boring Sampling Location

                                                                                 D-9*  OloidRSamplkig Location

                                                                                OC-10  GC Fingerprinting SampSng Location

                                                                                       Shafcw Vadose Zone Samptng Location

                                                                                       Approximate Ptrimrtw
                                                                                       Fence Location

                                                                                       Approximate Former Lagoon
                                                                                       Location
WOI
  110-1507-02
Dram kf / Date: D. Grabowski 12/12/69
             HJ»| / Date: P. Grabowski 2/19/90
OttffcH if / Dale:  E. Borbely 12/12/89
                             Oertel >|/Dele:  E. Borbely 2/19/90
                                                                      Metis:

-------
                    FIGURE 8
     Total VOCs and Trichloroethene
          Detected in On-Site Soils
 William Dick Lagoons Site, West Cain Township,
                   Chester County
                             W
                                          B-4
                                         • SV-4         »B-3
                                      739*10 (0-Z)  0.002/NO(4-T)
                                      1202(14-181
                w8V<
              6.991/3.800 (2-41
              0.734)005(19 21-)
„„.„   w	    •B-1V8V-13.>B.12
NO   IOI.436V93.000 »329/'«»(44»l 2/|.$ (0-21
(2-41     (2-41    0.27/0.1(49-511             0.13/0.12(49-511
     0.100.16(49-511
                                                                                                      • B-2
                                                                                              0.090/0.009(8-10')
                                              •B-s
                                            74/48(2-41
                                                                         B-11
                                                                       • SV-11
                                                                     1.663/1.200 (2-4*)
LEGEND
Boring Location
                                                                                                0.03/0.002(37-39')
         SoU Boring Number
        Shallow Vadose Zone
        Boring Number
                       0.007ya005(2-«1)  *«» C"l  O.OOS0.005 (2^'J
                                                                                                         • B-16
                                                                                                         NO (2-4')
                                                                    NO (2-41  O.OOS0.005(021
 739*10 Tola) VOC/TCE In mg/kg
        SoH Boring
        TotaJ VOC/TCE In mg*g •
        Shalow Vadote Zone Boring
                                                                                         •B-22
                                                                                           MD(0-21
        Sample Depth

        Not Delected
                                                                         •B-26
                                                                          NO (2-4-)
           Scale in Feel
woi
  110 1507-02
              Diawaky/Dalt: D. Grabowski 10/89
              Ht»lirt>»/D»U: E.McAIHster 3.690
                                      Cktckitf ky/Date: J LaRegina 10/89
                                      Ctortrt >y / Dm:  E Borbely 3.6.90

-------
                                         FIGURE 0
                             Total TCL Semivolatile Compounds
                                   Detected in On-Site Soils
                    William Dick Lagoons Site, West Cain Township, Chester County
     LEGEND
  •  Boring Location

 B4  SoU Boring Number

SV-6  ShatowVadose ZOM Boring
4363 TolalSVOC In mp/kg. SoU Boring
                                                                                 • 82
                                                                                £5(8-10-)
                          • B-7
                         159(0-21
                                    • 8V-6
                                    4397(2
                                    29(19-211
  B-9
 • SV-9
 695(24)   B-e«
NO (37-39')  101(46-)
30 Total SVOC In mg/fcg- Shadow
VadoM Zone Boring
(2-41 Sample Depth
AD Not Detected .
50 	 0 SO IJO
Scale in Feel
•Of
110 1507-02
•B-22 /
• 8-24 •8-23 NO (0-27 /
*
• B-27 9B-28 K l_
^' I^'O J ** |c*^ 1 Aim* fi«i f

Di* m If / Oito: E Knoplle 10/89 CtockH fc»/ Date: J LaRegina 10/89 "*•* IJirT^l
RnlMtfU/Oilr E. MeAUWer 36.90 OMtkHli /Dale 'E Bo'bely 3690 *^\B

-------

"• Ml \".W/f FIGURE 10
-\ " " V ,7
•^ -c&P^V Surface Waler and Sediment Sampling Locations
il\yv V'- >- i William Dick Lagoons Site, West Cain Township, Chester County
$v^jr~-'^
\
4^
• r>:^
, i •••"'•
f . - /H i II a x v.
.(.»;••*•—•* >
\ " ::-•

/I^SITE ^^y^by-^xA'
'^\?\,\\iv«ssas
M ^ i^S-^v gc '^, %^7^
fi/  i» .Al'i*•"» ^ /« V ' M«V^" J^^^XV evTl
"-  l?»  " y^--^? / *-./ Ji   \\v\\V^-v^i//)l ( \ ^ffl


 •%v?\ ••.rWv-.^^ >  ^N;// 'fi
                           ***•&&&$.
                           wSSS
110 IS 0701
      * b| / Bate: U OiabowsKI 3///90
     UMtkt< kf / Date E Iktilraly 2/26/90
    Cfc*cte< >t / Palt M Slieeluc 3/7/90
                                Dltt

-------
 WILLIAM DICK LAGOONS
  RECORD OF DECISION

APPENDICES A through D

-------
                                APPENDIX A
SUMMARY TABLES: INTAKE CALCULATIONS

-------
                                             PoUa
                                                               IM ExUlUg Cmullllan*
                                                         M4 Cakuhlc* l*Uku r«t Ofl-Slu Cnmad Water
                                                       WUMMiDtck Uf«Mu
                                                                    A*«m(«
                                                                                                      wa CkfMilc
                                                                                                   DaMr Uukc*
                                                                                                    ItMlPraWblc
                   l.3-4tehlorocthene(lo«aU
                                                                   27OE03
                                                                   200E03
                                                                   370E03
                                                                   7.00E03
                                                                   2HOEOI
                                                                   5.00EO3
                                                                   I.IDE 02
                                                  32OE03
                                                   I.DOE 03
                                                   I.20E03
                 I60E04
                 I HOE 04
                 360E04
                 2.6OEO4
                 947E03
                 2.IOE04
                 227E04
                 I60EO4
                 2.SOE04
                 I 73E04
                 2 IOC 04
                 I.I6K07
                 860EOH
                 I ME 07
                 3OIK 07
                 I20EOS
                 2 I5E07
                 4 73E 07
                                                                                                     I3BE07
                                                                                                     7.74E08
                                                                                                     &.I6EO8
                 7.74KOU
                 I.SSK OH
                 D I2K IIH
                 407E07
                 0.03E 09
                 0 76E 09
                 (i.MHE 119
                 I.OHE Ott
                 7 44E 09
                 UO3EO9
   b^MUon        1 J dkUondhciM lloul)
                      .1-lrtctiknicltMnc
                                 1 .41
                                                                   2.70E03
                                                                   200E03
                                                                   37OEO3
                                                                   700E03
                                                                   280EOI
                                                                   s.ooe-03
                                                                   I IOEO2
                                                                   230E03
                                                                   320E03
                                                                   i.aoe-03
                                                                   I.20E03
                 I6OEO4
                 I HOE 04
                 360E04
                 260E04
                 9.47E03
                 2IOE04
                 227E04
                 IGOEO4
                 2.SOE04
                 I.73E04
                 3IOE04
                 S78E05
                 428EOS
                 7.92E OS
                 I.SOE04
                 S.90EO3
                 I.O7E04
                 2.3SE04
                 4.92EOS
                 68SEOS
                 30SE-OS
                 2.S7EOS
                 3.42E06
                 385E06
                 770EOK
                 556E06
                 2.03E04
                 4.49E06
                 4.86E06
                 3.42EOK
                 S.3SE06
                 3.7OE06
                 44UE06
08
3030
oo
 J*'~  >—
MuUOan Ouilf^    1 J <*eMororthcn* (loUB
                   I.I.I trtctilanxltnnc
                   MracMoraclhene
                   cfakmbcmrne
                   1,2-dlchlofabeiucnc
                   1.4 dtchtoroberuriK
                   I.I dtchtoroclbcnc
                   I.I dlchluniclluiic
2.70E03
2.OUE03
370E03
700E03
2.80EOI
S.OOEO3
I.IOE02
                                                                       •: 0:1
                                                                     w»: on
                                                                     71if  0:1
I.60EO4
I.HOEO4
3.6OE04
260E04
A.47C03
2 IOE04
227EIM
I.6OE-O4
a sot 04
I 7.1K 04
2.IOEIM
S70EOS
4.28E-OS
792EOS
ISOE04
S98E03
I07E-04
2 :iSE 04
4 !«K 05
li HSK OS
342E06
GIHSt 06
7.70E06
5.56E06
2 03E 04
449E06
4H4iKO«
:i.4-2K 00
h :«SK (Mi
:t /OK «Ni
4 4UK (Mi
                                                                                                                                              3-
                                                                                                                                              t)

-------
                                           PMeMtol bpMMc* for B«Ulla( Coarfllloat
                           E>p*wu« MM CMMOtnllMM *•* C*knlMe4 tatak<* f«« Off Slu Cram* W.lci
                                                    WUUMl
                                                                 Avcrag*
                                                                                     i Cknalc
                                                                                  UyU
                                                                             HM| PtobaMc
                                                                              Daily iBtakc •
                  IJ-dfcMoroethcneltoUll
                  IJ^tehtorocUunt
                             2.70EO3
                             3 DUE 03
                             3.70EOCI
                             7 OOE 03
                             3 HOE 01
                             & OOE 03
                             I IOE02
                             230E03
                             3.3OE-O3
                             I WE 03
                 I GOE 04
                 IHOEO4
                 36UE04
                 2.60E04
                 047EO3
                 3 IOEO4
                 237E04
                 I GOt 04
                 2 50t 04
                 I 73E04
                 2.IOEO4
                 I 6IE07
                 I !9tO7
                 22IEO7
                 4 I7EO7
                 I 67E OS
                 29BE07
                 H SHE 07
                 I 37t 07
                 I 9IE O7
                 I07E07
                 7 IStOB
                 9 541: 09
                 I07KOH
                 2 I5EOH
                 ISStOM
                 5 ME O7
                 I 2SEIM
                 I 3SK OH
                 9 54K OM
                 I 49t OH
                 IO:IEOM
                 I 2SEOH
                  l.l.l-lrtcblonicllianc
                  UfcMoraeilicnt
                  UiracManxthcot
                             3.7OEO3
                             3.OOEO3
                             3 TOE 03
                             7 OOE 03
                             2 HOE 01
                             SOOEO3
                              I IOE02
                             230EO3
                             32OEO3
                              I.WE 03
                              I30E03
                 I GOEO4
                 I HOE 04
                 3.60E04
                 2.GOEO4
                 947E0.1
                 2IOE04
                 3.37E04
                 I60E04
                 3.SOE04
                 I 73E04
                 3 IOE04
                 I 40EO4
                 I04E04
                 I 92EO4
                 364EO4
                 I 46EO2
                 2 G(lt 04
                 S72E04
                 I 20E04
                 I66E04
                 936E05
                 624EOS
                 H.-I2KOK
                 » 36K OB
                 I M7t O5
                 I :»StOS
                 4.U2E04
                 I UUt OS
                 I IHEO5
                 H.32K-Ob
                 i:mtos
                 9 OUt 06
                 IU9tOS
litiilttttm Ourt^
1.3 (McMorocUicnc (lota*
1.3 «cUMOcltune
                   I.I.I UtcMafoclliMK
                  IctracHococlhcne
                  dtdilofabcnicnc4l.2l
                  dfcMorabciucncll.41
                   l.l-dkMtinwlhciic
                   I.TdlcMuiDeUuiic
3. TOE 03
2 OOE 03
370E03
7 OOE 03
280EOI
S OOE 03
I IOEIKI
230E03
320KIKI
I Hilt IKI
|.20t Ifl
I.GOE04
I HOE 04
3.GOEO4
3.GOEO4
047E03
2.IOE04
2.37E-04
I.60EO4
2.SOE04
I 73E04
2.IOE04
I 40E04
I04EO4
I 92E 04
364E04
I46E03
2.60E04
S.72E04
I 20E04
I b«it 04
9 :ttiC OS
li 24t OS
                                                                                I B7t OS
                                                                                I :i5t 05
                                                                                492EO4
                                                                                I OUt 05
                                                                                I IHEOS
                                                                                H.32E 06
                                                                                I :Mlt OS
                                                                                •ItNIK OK
                                                                                   It Ob
                                                                                                                                              *

-------
                PMcalUI EIPOTIUC* fw RcUllaf Caadllleni
Fipaaata M>| CMKCBU alia** a*4 Calculate* lalahca f»f OM-SUe Croa*4 Water
                                Dtefc IH«»"
»••»!•« ; dM*k»laf
BttyMWp • /. CaMCMa)
OcnMlOMlKl U-ctehlwoclhefWlioua
IJ-AcMonwUiMe
iMimifciia
l.l.l-McMaroeUiMW
Mdttotacltenc
MncUgtacUwne
iMiinlmiBia
IJ-OtMuiubuutnc
M-«d*Nol)eiurne
1.1-dfcfaBMoclheiw
I.I dkUorodhanc
litgcMlan 1.3 dlcMoroclhcnc llonO
1.2-dfcMacoclhanr
chtacafarn
I.I.I Utctoluralhane
.t— «-»^k— —.•--_-
™T" 1 til*"1*! TIT"*
MfwUpractbcnc

It .^fMointiciiMHf


ft I^CB^B^B^B^B^^B^tftaMBV
tabalaOaaCH*** 1 J-dkMMwUicnc luull
Shmak^ l.3-4kMo»«(UMnc
-i-l-^—-*... ^_
OMMWOnB
l.l.l-MdilQmlhanc
»_»-A-»^_^-» 	
Ifiniill infrr**
MntNnmOwnr
B^BaV^n^BBin^v***
1 .3-dtcMofnticiucne
1.4-dKMarabaucne
1.1-aacManeUwnc
l.l'dtchloroclhaiic
Maslavam
C««ciat>atUa
IM-I
370E03
3OOE03
3 TOE 03
7.ODE03
3HOEOI
SOOEO3
1 IOE02
3.30E03
32OEO3
1 HOE 03
I20E03
270EU3
300E03
370E03
700EO3
3 HOE 01
SOOEO3
I.IOE02
330E03
3.2OE-O3
I.80E03
1 JOE 03
3 TOE 03
3 ODE 03
3 TOE 03
7.0OEO3
SHOE 01
S ODE 03
I.IOEOa
330E03
320E03
IHOK o:l
1 20EUI
A*cia|«
Ca»t»alimlUa
IP*.)
I60E04
1 HOC 04
3.GOE04
2.fiOEO4
947E03
3.IOE04
227E04
I60E04
3SOEIM
1 73E 1*4
3 IOE04
1 bOE m
1 HOE 04
36OEO4
260EO4
047EO3
3. IOC 04
327E04
lfiO£O4
3.SOC-O4
I73E04
a.lOK-04
I6UEO4
1. HOE 04
3.60E04
3JOEO4
947E03
a.ioeiM
327EO4
|.fiOE04
3.SOE04
I.73E04
3.IOE04
•UitamiB Caraalc
Dally blakca
Ia^/«a/«af|
1 94E07
1 44E07
2 WiK O7
S 04E 07
202EOS
3.GOE07
7 92E 07
1 .bbE O7
2 :IOE 07
1 :iOE07
U.64E OH
2S4E04
1 HHEIM
34HE04
6 SHE 04
263E03
4.7OE-O4
I.O3E03
3.I6E04
3.OIC-04
I69C04
I.I3C04
3S4E04
IHHE04
3.48E-04
fi.SOEO4
363E02
4 TOE 04
I03E03
3.I6E04
3.OIE-O4
I.GUE04
i.i:u:o4
MMlPteWMe
Dally lnUk»
lmt/tt/4.,t
I.ISEOH
I.3OE OH
2 S!IK OH
1 tl'/E OH
6H2E O7
1 SIKOH
1 6. IK IIH
1 IbK IIH
1 HUE IIH
1 2SE OH
1 SIE OH
I SUE 05
1 GUE OS
33HEOS
244EOS
H90E04
1 U7E 06
2.I.1EOS
1 SUE OS
2.3SE-OS
1 &3E OS
I97EOS
I.SOEOS
I6UEOS
33BEOS
344EOS
8.WIE04
I97EO5
2.I3KOS
i sot; os
2 35E OS
I.KIC 05
1 .!I/E OS
                                                                                                         ff

-------
                                         Potential BBpoaurca lot Emitting Conditions
                                  iui« Point Coaceoualloaa and Calculated Intake* for Spring f 48
                                                   William Dick Lagoona
                                                         Adult*
            Of
                                              Average
                                           Concentration
                                 Marimuni Chronic
                                   Dally InUhea
                                  Jnig/kf/da»)
                                  Moal Provable
                                  Dally laUkea
    Dermal Contact
1.2-dlchtonwthane
chlorafarai
lilchlprocihuic
3.20E-O4
3.IOEO4
68Ot:O3
I.QOEO4
I 5OEO4
207E09
2UOK09
4 4ttK 08
I 23KOU
969K 10
2 9IE OH
  Inddcnud IngnUon   1.2-dlchlDracUiBne
                      chtorofona
                      Irtchloraclbenc
                           3.20E 04
                           3.IOE04
                           6.90E03
                   I.OOi:O4
                   I 50K04
                   4 SOt 03
                   I.I4KOH
                   I.IOKO8
                  2.46E07
                  676EOO
                  534KOi»
                   I oOE O7
      IntiBtallon'
l.2-dlchloroeUHUM
chlorofcinn
Ulchloraethcnc
I.07E04
a.eoc-os
2.I4E03
I07K04
9.90E05
2.I4E03
632KOH
5.H5EOB
I.26IC06
632EOH
5.85K OM
I.26IC06
• - The njudmum oonccntimUon detccUd In sample* collected from Spring 148 were used an Input to Ihe box model for calculation of I he unibk-nt
   •Jr concnetmion.
                                                                                                                                     o
                                                                                                                                     t>

-------
                                        PolcolUI Ecpoaiuca for Eilallng Condition*
                            Bxpociuc Poiat Concentrations and Calculated Intake* (or Spring 148
                                                  WtUUn Dick Ugooa*
                                                      Child 6-1 3
     Boot* Of
                         Concentration
                   Average
                Concentration
              HaximiuB Chrooic
                Dally Uukea
                                                                                                     Moal Probabk
                                                                                                     Dally loiakca
  Dermal Contact
l.a^dlcfatoracthane
duMOlMBI
trtcbtomtticm
3.20E04
3.IOEO4
6.90EO3
I.BOEO4
I50E04
4SOC03
                                                                                     2.HHK09
                                                                                     279E09
                                                                                     62IKOO
                                                                                                        I.3SK 0
-------
                    (• •**•*•-! '•"
                                                       0*117
 (m
4 l
a.ioc»oa
V30C-00
«.40t-00
;  IJE-OO
I  I4EXJJ
I  Z
I
3S6E-OI
rooc-aa
3.00*41
1.30*41
1.00*41
1.10*41
3.36 MO
4.00*40
i.soe-oi
9.90*40
140WOI
2.44E-00
i.ooe*oo
9 ME 01
54§E01
J. 14E.OO
Jttt^B
                  i ior.oi
 i.art or
 1 MEOS
 I.43C-07
 I.GCB-OT
4.42EO*
3.20C-0*
6.7M-07
3 Ml 07
S.9M-0*
3.7KO*
160C07
ZMC-07
I.MC-07
I.O4C07
1.9OCM
HT107
1.041 OT
i.rx-o*
9.07C-0*
4.16C-OS
348C07
G.ME-O8
12
X17C-4S
xaoc-o*
9.34C-07
                                                        «.(lt-0f
                                                        XI7C4*
a.uc-0*
O.MC-0*
5.zoe-o»
XJTCO*
I.42B-0*
S.UK-0*
i.sa-or
J.4IC-O*
                                                        1.MC-OT
                                                        Ult-Ot
                  1 ME.OJ
                  I 23G>00
l.XMt
1.IOB4I
ijocoi
9.90*40
1.40*41
                  9MKOI
                  344KU3
                  2.I1C-09
                  9.1K.OI
I
                   X29C07
                   3.J4I09
                   JOIF.07
                   1.SIK07
                   9.1K-0*
                   I. IOC 08
                   I.42KO*
                   r IJS07
                   : JOE-OS
                   I 2IEOS
                   1.4W07
                   a.oac-0?
                   194K07
                   x tie or
                   I.23CO*
                   32IE07
                   7071 OT
                   3.6K-OS
                   1916-05
                   • 7TCO«
                   I.ISCO*
                   I.J9K05
                   &UC-0*
                   itrt-at
                   7.HC-0*
                   I.99C-0*
                   1 I4C-07
                   IMC -07
                   9.041-0*
                   4MC-0*
                   iasc-07
                   t.JiC-07
                   1.10C-07
                   3.43C-0*
                   1.0OC-4M
                   i.in-07
                   1.42C-O7
                   I.I6C-0*
                   a.oic-0*
                   l.UC-0*
                   7.«7C-07
                  I.3MMM
                  S.73C.OO
                  «.ME«OI
                  13U*OO
                  244C4O
                  9JKOI
                  S.4M-09
                  IMMO
                  6.MOOI
                  i4or«oi
                  *.M«M>t
                   a.OK-13
                    I.4IC-0*
                    i.«a>-u
                   «.otc-o»
                   zia-oa
                   4.4IC-0*
                   S.T4K07
                   I»7t07
                   9.74X04
                    I.JOK-M
                   X3IC-OT
                   Z43C-07
                    1 I»C07
                   •.«••«
                    4.9IC-IJ
                    1.CW-II
                    IMX-OT
                    i.aoc-ii
                    4.o«c-o*
                    107C-1I
                    I.4IC-II
                    1.11C-11
                    i.«7c-ia
                    XMC-IO
                    14K-13
                    l.TJCfli
                    4.49C-04
                                                         i.a«c-o7
                                                         7.MC-OS
                    S34C-O7
                    uic-o*
                    4.4IC-0*
                    XltC-CS
                    1.7W-U
                   • l.UC-07
                    170K-II
                    I.07C-0*
                    uat-ta
                    9.40C-U
                    l.OK-ll
          POOR QUALITY
                ORIGINAL

-------
4.IOMO
                  I.I3C>00
                                     6.MW-07
                                     940C-09
i TOMB
                  i aac-oo
                  I.J9C-00
                                     snc-or
                                     3 10C-06
                                     4.oac-4>I
l.lOfeOI
4.(
I30C-OI
8.TMWB
                  300IWM
                  9.MKOI
                  )4«tCQ
                  I \4KWJO
                  «.atc^»
                  3.1 1 wa
a.io««oi
                  O.OOCrfll
                  I.40K«OI
                  (.S04UOI
1.8K-M
111108
auto*
xtacos
j. i IE o«
l.92t-0*
I.I1C-0*
4.99K-0*
3.0CO*
J.ICI-0*
I.90C-0*
9MCOS
4.UCO*
J.MCM
ritc-os
urtor
rsic-o*
1.49C-OT
1.93C-O7
l.OIC-OB
1.14C-0*
i.nc-os
9.MC-OV
xait-os
zuc-oa
&MC-OT
a.MC-07
S.MI-07
XMC-OT
l.SSK-0*
•.O4C-OT
irrt-o«
urc-oi
(.•7C-0*
1.94K-OB
14 IK-OB
4.10
4.10l>4«
                  U3K«40
IJOtXtt
                  3.3MMI
                  4.oac*oi
                  S.TMMO
                  341IUOO
                                      I.47C-II
                                      Mac-M
                                      IMC-11
                                      I.MS-0*
                                      S.IK-03
                    4.0K-I3
                    CMC- 10
                    4.IK-W
                    l.OTt-09
                    II4C-0*
                    s.oac-07
                    l.tK-OT
LOObOl
t.ll
                  xoo»%ao
                  9MOI
 IJOfrOI
•4
 1.*
                  1.40CWII
                  l.90t>OI
                                      I J9C-0*
                                      32K^M
                                      1.3K07
                                      IME-OT
                                      XMC-OT
                                      tIM-OT
                                      I. lit- II
                                      •.MB-11
                                      O.IK-OT
                                      XOCK-IO
                                      9.IIC-0*
                                      4.HK II
                                      1.40C-II
                                                         I.J4E-
                    1.
                    1271-01
                    4JM-U
                    Xllt-ll
                    »r**-OT
                    UIC-II
                        'r\\
                    U7I-II
                    IMC-II
               POOR  QUn
                    ORIGINA

-------
                                                           («»MIBM (•> u*
                                                  of
                                                                    •I
  DcmmlCoM
                                               4 loe-oo
                                               e.ioc>OO
                                    3.9KOT
                                    3.UC-09
                                    4IIC-OT
                                    1.9CC-OT
                                    I.49C-OS
                                    i rseos
                                               3.ooc>oB
                                                                1.03»>01
                                               1. 101*01
                                               S.MbOO
                                               4.00MO
                                               130COI
9 MK-OI
5 <«e MI
2 UE^X)
                                    I. I4C-06
                                    iOIC-08
                                    I.93C09
                                    • 74SOT
                                    961107
                                    4.6IC-O7
                                    3.90C-07
                                    l.llK-41
                                    t.MC-07
                                    i as-o*
9.MC-0*
I.OM-OB
I.IWC-CT
i.3it-ar
9.UC-M
1.93C-W
a.oic-07
X9W-0?
•.MC-0*
                                                                                                      i we -or
                                               }.4ICoO>
                                                                «.aot>oi
                                                                I 40E-OI
                   3.0K-06
                   140B-06
                   i tuca*
                   1311 OS
ITSC07
1.A4I-0*
4.79C-0*
l.fTX-OT
S.4K-OT
I.MC-OS
•.03C-M
s.7-rt-o»
I.73CM
74JCO*
INI «1iii»l
                                               4.IOI.OO
                                               <4oc>ao
                                               l.lDfeOI
                                                                344BMJO
                                                                3.0WWO
                                                                9MCOI
                                                i sot 01
                                               3.UMI
                                               i.
                                                                S.9MMI
                   19K-0*
                   roac-o*
                   i.oreo*
                   • 14109
                   99K06
                   I3SK06
                   8JJICO*
                   I.IOB-O4
                   I.OOICO4
                   47W-0*
                   JITBO*
                   3S710«
                   I.9K-0*
                   ritc-M
                   43K-0*
                   6.TIC-M
                   J.22C-04
                   l.CTC-04
                   TMI-O8
                   I OIB-09
                   I.31E04
                                                      S.94COB
                                                      S.UC-07
                                                      O.UC-47
                                                       I.70C-Q6
                                                       I.9M-OS
                                                      X74C-OI
                                                       1 WC-0*
                                                      49M06
                                                      4.1K-0*
                                                       i.utoe
                                                       i.irc-o*
                                                      9.9M-07
                                                      4.74C-OT
                                                      xaac-o*
                                                       I.MC-O*
                                                       l.OIC-O*
                                                       4.40C-OS
                                                       1181-06
                                                       6.71C-M
                                                       4.07T-OB
                                               4.
                                               •.I
                   I.13X-II
                   3.10C-O*
                   J.S4M1
                   t.nc-o*
                   4.
                   t.a
                   i.
                                                                1.49CWM
                                                       6.2M-10
                                                       rtwc-il
                                                       ).79C-Ot
                                                       9.73C-4M
                                                       1 .94(41
                                                       int-or
                                                       1.8K-OT
                                                       S.MC-04
I.10MI
SJ
4<
                                                                 t.m-oi
                                                                                   XMK-O*
                                                                                   4 CM -or
                                                                                   S.3H-OT
                                                                                   IMK-O?
                                                                                    I.HK-OT
                                      \.14t-OTT
                                      9«
                                      4.T7K-W
                                                                 I40»>OI
                   t.SIC-11
                   1SIC-OT
                   itw-te
                   t.««4M
                   4.9K-II
                   1.0K-II
                   O.MK-II
                                                                                                            l
                                                       l.MB-ll
                                                       10O-II
                                                       XXC-tl
                                                                        POOR QUALITY
                                                                              ORIGINAL

-------
  Deer Meet Intake
WIUiaiB Dick LacM
|CfemlcaJ«l
r«»i««a
r^
dilofiDfonn
Irichloroelhene
IcUachfefotihcne
cMoroberacne
1 .3.4 Utchlorotoenzene
naphthalene
phenunlhrene
•uornnlhene
Uaf2 rthyiheiyllphlhalale
4.4 DDE
acenaphihene
Buotene
bennfalpyrene equivalent
anthracene
heptachlor epiulde
a.4 dlcMorophenol
araenfc
barium
chromium
•Mngmeat
Mnadlum
dnc
3J.7.STCDD eq*valenl
MMtalM.
b»-l
4.IO£«00
6.ioE»oa
s.aoe«oo
6.40B*OO
I7oe»oa
aooe*oa
a.60E«OI
i.3oe*oi
a.30E«oa
a.aOEtOa
I.OOEtOI
I.IOKtOI
ft.3S£«OO
400E.OO
I.50KOI
tf.90C*00
i.4oe»oi
6.72K«O2
3.49E*O2
|.60E*O2
a.ioe«oi
2.S3E«O2
a-ase-os
Avwaga
V'1,,^1
i.ia£«oo
l^4R«03
iaae*oo
l.99e«00
3.96E*OI
4.ooe*oi
S.73E«OO
3.43E«00
l.03E««a
&ME«OI
a.36E«00
a.44E*00
a.ooe«oo
9.H9e«l
s.4ne-oa
a.i«c*oo
6.a«e«oo
a.iiE*oa
a.i«E»oi
6.60E«OI
I.40E*OI
&9oe«oi
IJOC-46

(Hg/«l/fc«/«J
saiEtoo
I.63E»00
i.aae»oo
e lattoo
6IHE»00
420EOI
4.aoeoi
4.aOEOI
lOW 04
34HCai
4.20COI
420EOI
420COI
4.aoe-oi
I07K>00
a tee 01
iser.too
a.7se-oi
a.4ae-oi
a ME 01
i.ooe-oa
449KOI
a.38G*00
— •••— *.—*
Cmu
4.3 IE 02
383e»OO
264K02
1 45KOI
385K.OO
3H2KOI
4U7KO2
2 49E 02
92IK02
»OHK02
I.UIKO2
2 IOK 02
1 02K 02
765KO;i
6.-ISK04
:i I7K02
H 42K O2
9..14i:OI
4.45KOI
2.IOEOI
9 I6E 03
5. IOE 01
2O3E07
™ HI ••^•-•.^•^
Ca>e |n|
1 IBE-02 :
7.77K-OI 1
S.H4K-03
3 I4KO2 •
H.05KOI &
7.70K02
1 IOK 02
65SK01
4 I2K02
:i69K02
4 SI K 03
4 66K 0:i
3 82K Oil
IHHKO:I
2 :i2K 04
7 nno:i
375K02
2.93K Ol
1 I7KOI
8.6HGO2
6 IOE 03
I.7IC4I
I.I7E-07 i
••
BTF
l/«l/lf*7jl
t 3OK 06
J03KOG
OOK 05
• 00f:,00
•OOK. 00
1 HHKOI
MHICOI
HHK Ol
.O2KiO2
2451: 01
1 HHi: 0|
I HHI: oi
I HHI : o i
i HHI: 01
1 2»iK05
2.0OK 05 '
I9UK02
1 50K;Ob
1 4UKOI
I60K06
I5IKO5
1 OOK 06
t.4Hf:«OI
- .1.
kJ^K*
HUB
MAXIMUM
9U2KOH
23 IK 05
264KO7
1 :»OK,00
347K.OI
7 IUK O2
U :I5K 01
4 I>7K O:i
i» IMK.OO
2 22K 02
:l 5!IK 0.1
3>I5K 03
1 «2K 0:i
1 44K03
H OOK Oil
b:i4KO7
4 IHKOri
1 40KOU
662E O2
3 36K O7
2.-IOK07
5 IOK 07
S03C06
fc«— _»
••€••
AVERAGE
27IKOH
469K06
5H4KOH
2.H2KOI
725K>00
1 45K02
2 Otii: 03
1 23K 03
4 20K.OO
!i on: (i:t
H 4HK 
-------
                                                                            Deer M«*l InUk*
                                                                                  Uck Ugoo»
                                                                                                           Heal
                                                                                  Cm
                                                                                                                       Meal
                                                                                                                     AVERAGE
                                                                                                                                 MAXUIUM
                                                                                                                    Intaka
                                                                                                                   AVERAGE
chloroform
trtchtoroelhene
leUachloroelhene
chlorobtmene
1.2.4 Irtchlorobentene
4.IOE*OO
6IOE*02
590E«00
6.40E«OO
                                          i.iaB«oo
                                                        a.8IE*00
phenanlhrenr
•uoranlhene
Maia-clhyihuyllphlhawle
4.4 DOE
acenaphthene
Duorenc
benaolalpyrene equtvalenl
anthracene
hepiachlar epoxlde
2.4-dtehkMophenal
•raenlc
barium
chrooiturn
                           a.ooe«oa
                           a.60E«OI
                           |.30E«OI
               4.036*01
               &73E*00
               3.43E*O0
               l.03E«Oa
6 I8E«00
6.I8E*OO
4.20EOI
4.20E-OI
420COI
                           a.aoEtoa
                           |.OOE*OI
                           I.IOKtOI
                           S.3SC«00
                           4.00E«OO
                           I.90E-OI
                           WSOEtOO
                           |.40E«OI
                           672E«02
                           3.49E*O3
               a.44E*00
               a.oo£«oo
               98UE-OI
               3.14E*OO
               «24E*00
                           a.ioe«oi
                           a.S3E*oa
a J.7.MCDD equivalent
                                          «.«oe«oi
                                          i.4oe«oi
                                          aso£*oi
                                          I JOE-OS
3.4BE-03
4.20EOI
4.20K-OI
4.20KOI
420KOI
I.07E*OO
8.16K 01
I.S6E»00
2.7SE-OI
243EOI
2ME-OI
I.OOE-02
449E-OI
2.38£«OO
4.3IE-02
3.82E«OO
2.64E-02
I 4SEOI
385E«00
382E-OI
4.97KO2
2.49K02
92IE02
90HK02

2 I0f:02
I .O2K O2
765KOTI
6 35*: 04
:i I7K-O2
8.42EO2
934E-OI
44SKOI
a.lOEOI
9.I6E-O3
5.IOE-OI
a.03C07
I
7.77E-OI
584K4KI
3.I4E42
80SEOI
7.70K02
I.IOK-02
4 I2K02
.•I69K02
45IKAI
4 66K O!l
I 89KO.-I
2 :i2E 04
7.13K Oil
37SK42
293E4)!
I.I7E4II
868E4>2
6.IOE-03
I.7IE-OI
230KO6
6.03K06
IOOEO5
9OOC»OO
9OOK»OO
 I HHKOI

 I O2K.O7
 2 4f*: 01
 I HHK 01
 I HHK 01
 I HHK Ol
 I HHK 01
 I 2tiK Oft
 2 OOK OS
 496K02
 I 5OK«ti
 I 49KOI
 I60EOK
 2SIEOS
 IOOKO6
 2.48E«OI
992E OH
2:ilKO5
2U4K07
I rtOKiOO
.T47K«OI
7 I9K 02
a :i5»: 0:1
4 «7K 0:1
9:i9K>00
2 22K 02
:i 59K 0:1
:i usi-: 0:1
i tKtK <>:»
I 44K 0:1
H OOK «l
6,:i4K 07

I 4OKOU
662EO2
3 36K O7
2.TOEO7
5 IOE 07
S.03E06
2.7IK OH
469KO6
SH4KOH
282KOI
725K.OO
I 45K02
2 OliK 0.1

4 2OK.OO
}»O:IK 0:1
8 4HK 04
H 76K O4
7 lt*KO4
2 92K Oil
   IK 07
   liK 0:1
  4OK 07
  74K02
                                                                                            5.-IK07
                                                                                            7IE07
                                                                                          2.891: OS
I.47K II
3 42K 09

I MIK04
5 I IK O.'l
I OUK O5

6 92K 07
I :i9KO:i
:i 29K 06
5 :i2K 07
f> HCK 07
2H!>K07
2 i:iK 07
I I9K 12
939K II
b I-JK07
2 OMK to
9.8IKO6
49BK II
340K II
756K II
7.45E IO
4.02E-I2
6 {MEMO
8fi5K 12
4.I8KOS
I07KO:I
2 I4K OB
:i 05K O7
IH2KO7
6 22K 04
I :i4K Uti
I 2CK 07
I :ioi; o7
I (M)K O7
S27KOH

2 I IK II
2 76K07
G5IK II
25HKOti
2OBK II
2 27K 11
2 S4K 11
428K 10


-------
 Deer Meal Intake
WUIlaai Uck Lagoosa
U^BflBMaMeat
IwVBMW
chlorofarm
Utchtoroethene
letrachflaraethene
cMorakenicne
1.2.4-trtchlorobefuene
naphthalene
phenamlhrene
Buoranlhene
bMa^thylhexyHprtthatale
4.4' DdE
acenaplMhene
fluorene
bennMpyrene equivalent
anthracene
heptachlor cporide
a.4-dkhlorophenol
araenlc
bartum
chromium
manganeae
vanadium
ant
OJ.7.8-TCDD equivalent
cJlatattaMMaj
IppaaJ
4.IOE«OO
e.ioe«oa
ssoe«oo
• 40£«OO
i.7oe«o9
a.ooEtoa
a.6oe«oi
i.3oe*oi
a.30E*oa
a.aoe«oa
IOOE*OI
I.IOEtOI
5.3SE«00
4.00E«00
I.90E-OI
9.50E*OO
|.40E«OI
6.72C«O2
3.49E*O2
i.aoe«oa
a.ioe«oi
a 53£«O2
a.26£-OS
cJawMlMi
.-• ij,^
i.iac«oo
i^tt*o>
i^aE*oo
I.39B«00
3.BOE*OI
4.00£tOI
&73E*OO
3.43E«00
l.03B«l
42OEOI
I.OBEO4
34BK OCI
4.aOKOI
4.2OE Ol
42OKOI
420KOI
I07K»00
H.I6EOI
IS6K«00
2.7SC-OI
343EOI
2&4EOI
IOOE42
449E-OI
23fiE*00

C-aaa
43IE02
3.H2E*OO
264E02
I4SKOI
3H5K.OO
3.H2E-OI
497K02
249E02
9 21 E 02
9OHKO2
I91K02
2 IOK O2
I02K02
76S»:u3
6..-ISE04
3 I7E02
B42K02
934EOI
4.4SEOI
2.IOE-OI
9.I6E-03
S.IOE-01
2O3E07

Ca»e
I.I8E-02
7.77E-OI
S.84E-03
3.I4E-02
HOSKOI
770E02
1 IOK 02
6.SSE03
4.I2E02
3 69K 02
4SIK03
4.66K03
:IH2KO!I
1 H9K O:i
2 32K 04
7.I3K03
375K02
2.90EOI
I.I7EOI
8.68E02
6 IOE03
I.7IE4I
1 I7E-07
BIT

2.30E06
fi.aiE-OS
1 OOK 05
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4 96K-O2
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1 49K 01
|.60»:06
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2.4BKtOI
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MAXIMUM
992KOH
23IK05
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i :HM-:«OO
347KIOI
7 I9KO2
9.3SE O-'l
4 67K O3
939K>OO
222K02
:» «»•: 03
:i u5i-: at
i >»2K 0:1
i 44K 0:1
H OOK Oil
• G 34K O7
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I40K06
662EO2
3.:i6EO7
2.30E 07
5 IOK 07
50.IE06
••«••
••«••>
AVERAGE
27IKOH
4.69KO6
5H4KOH
2H2EOI
725K.OO
I.45K02
2WiKo:i
1 2:iKo:i
4 20K>OO
9 O:IK o.i
H 4HK O4
H 7liK 01
7 I'lK (M
:i rxii: 04
2!ttK Oil
4:11: 07
M*iK 0:1
4 40K 07
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39K07
.KIK07
7IKO7
2.H9KO(i
latake
MAXIMUM
1 XIK II
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4 U5K 03
9 ttSK 06
1 2SK OG
6 27K 07
1 26K 03
2>K1KOI>
4 KIK O7
S. 'I IK 07
2 5HK 07
i 
-------
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-------
                                 r!»•••«• Mai C*ac«alnlUM Mid Calculated telahc* for On-Stic Ground Walci
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                                                        56OE-OI
                                                        i.aoe-01
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                                                        S.60EOI
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 I HOE 01

2 IOKOI
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-------
                                >•»•••>« Mat CmwutntUM «*4 Calculate* l»t*k«« r«t On-SIU Cioiui4 Valet
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                                  •.111-07            30M07              J.47C-07

-------
                                                       APPENDIX  B
                                                                t of
               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                Region  III
                           841 Chestnut Building
                          Philadelphia, PA  19107
SUBJECT: Drinking Water Comparison                      Date:  July  2*,  1=?9M
         William Dick Lagoons

   From: Dawn A. loven, lexicologist
         Technical Support Section (3HW15)

     To: Jack Kelly,  RPM
         SE PA Remedial Section (3HW21)

     BacKground

          To aid in  the determination of an  appropriate  remedy  at  the
     William Dick Lagoons site, viable drinking water alternatives  for
     area residents were evaluated for potential toxicological  impacts.
     That  is,  the health  risks  posed by  the  various potable  supply
     options were assessed and compared.   The potable water alternatives
     examined include:

     1.  untreated ground water, which  is  contaminated with site-related
     volatile organic, compounds (VOCs),

     2.   the municipal  water supply, which  contains trihalomethane  oy-
     products as a result of the mandatory  disinfection process, and

     3.   ground water,  which contains elevated  levels of  naturally
     occurring radionuclides.   (It  should  be noted  that  treatment of
     VQC-contaminated ground water by granulated activated carbon units
     at  the wellhead  is not  expected to significantly reduce the levels
     of  radioisotopes at the tap.)

     Assumptions
          In  performing  the risk calculations for each of the foregoing
     exposure scenarios, several  assumptions were made:

     1.   For each contaminant, both an average and  a maximum (worst-
     case)  concentration was used.

     a.   For residential wells, VOC  levels  were calculated based upon
     raw water sampling  results obtained from 9/87 through 9/89.  Non-
     detects   and  detectable  quantities  qualified  with  a   "B"  code
     (indicating blank contamination) were excluded from concentration
     computations.

     b.    With  regard  to  the municipal  water  supply, only  results
     generated'  by  Cedar  Grove  Environmental   Analytical  Labs  (2/89
     through  4/9O)  were assessed.   Results  produced  by  PA DER for the
     City of  Coatesville Authority  were discarded,  since the units of
     concentration  in these data  summary tables were unclear.

-------
                                                           A of
 c.  For the determination of radionuclide levels, all  USGS sampling
 data (6/88, 8/38, unknown dates) and ERtt sampling data (i/38, 2/88)
 were utilized,  irrespective of wnether samples  were  collected
 pre-,  mid- or post-treatment.

 2.   Risk  calculations  for each  contaminant were  conducted  for
 adults  weighing  70  kg,  who ingest 2 liters of  contaminated water
 each day  for 70  years.

 3.    Following   the completion  of  each  chemical-specifie  risk
 calculation, the  total  risk for eacn exposure scena-rio  (untreated
 ground  water,   municipal  water,  and  ground  water   containing
 radionuclides)  was  estimated.   This method  of  quantitative risk
 assessment  assumes   that  similar   risks   (carcinogenic   vs.
 noncarcinogenic)  are additive.

 Comparative Risk

     As indicated on the attached worksheet, the total carcinogenic
 risks  associated  with  consumption  of   untreated   ground  water
 (average  = 3.79E-O5, or  l additional  cancer  per 26,400 exposed
 individuals; worst-case =  1.46E—O4,  or   1  additional cancer per
 6,80O  exposed individuals) and  municipal water (average = 4.7SE-
 O5, or  1  additional cancer per 20,900 exposed individuals; worst-
 case  =  S.99E-OS,  or   1   additional  cancer  per 16,700  exposed
 individuals) are'- virtual ly  identical.  It should be noted, however,.
 that an  additional  risk of similar  magnitude  may be elicited by
 exposure to VOCs via the inhalation pathway.  Exposure through this
 route during typical household water usage (showering,  laundering,
 etc.) may  serve  to  double  the risk posed  by consumption alone.

     Clearly,  the  most  significant risk  of  the  three exposure
 scenarios  is contributed  by ground water  containing naturally
 occurring  radionuclides (radium,  radon,  and uranium).   Radium,
 radon and uranium are classified as Group A - Human Carcinogens by
 the EPA.*  The  primary route of exposure  to radium and  uranium in
drinking  water   is  via ingestion,  while  radon,  being  a vapor,
generally  follows an inhalation pathway.

     Bas«d  upon  carcinogenicity   information  provided  in  the
September 3O, 1986 issue of the Federal Register for radium-226 and
natural uranium, lifetime oncogenic risks in the 10**  (1/1,000,000)
 rang* »rm incurred  at respective  levels  of  O.I and   0.7 pCi/1 in
drinking Mater.   Therefore, given  the reported levels of radium and
uranium in sampled  ground water,  the  elevated individual cancer
risks related to ingestion of ground water  are  1.47E-04 (average)
and 3.86E-04  (worst-case)  for radium  and 5.24E-06  (average) and
 1.43E-OS  (worst-case) for  uranium.

-------
                               -3-          •

     The  carcinogenic  risk  associated with  exposure  to radon in
ground water  was  calculated  by  a different method than that used"
to assess radium- and uranium-related risks.  £ relationship exists
between the concentration of radon in water  and tne concentration
of >-adon in the atmosphere.   It is generally assumed that for every
1OOOO pCi of radon per  liter  of water, 1 pCi cf radon diffuses into
1 liter of air  (Telecon with Bill Belanger).  Consequently, since
2220 pCi/1  (average)  and 9200  pCi/1  (worst-case)  of  radon were
reported in sampled homewells, it is estimated that O.222 pCi/1 and
0.920  pCi/1,  respectively,   of  this  radionuclide  are  present in
household  air.   Further, since  0.0004  pCi/1 of  radon  in  air is
estimated to elicit a 10"* cancer risk (Telecon with Bill  Belanger),
the elevated  individual  carcinogenic risks associated with 0.222
and 0.92O pCi/1 of radon are 5.55E-04 and  2.3OE-O3, respectively.

     The combined carcinogenic risk  from  exposure  to radionuclides
in ground water is 7.O7E-O4  (average),-or  1  additional  cancer per
1,400 exposed  persons,  and  2.7E-O3  (worst-case),  or 1  additional
cancer per 370 exposed individuals.  While these carcinogenic risks
are  greater  than  those usually   considered    "acceptable"  at
Super-fund  hazardous waste  sites,  it  must be  stressed that the
reported  radionuclides  are  naturally  occurring and that similar
risk levels are not uncommon in other geographic  areas  containing
radionuclides  in ground water.

     With regard  to noncarcinogenic  risks, none of the foregoing
exposure scenarios  (untreated ground water, municipal  water, and
ground  water   containing  radionuclides)   appears   to  represent   a
health threat.  (Please refer to attached  worksheet.)
References

1.  Federal  Register, Part vl.  40 CFR Part 141,  Tuesday,  September
30.1986.

-------
GENERAL EXH)SIIRK ASSUMPTIONS
Adult mass (kg):
Length of Lifeline (years):
Length of adult's exposure (yearn):
VO.OO AD MASS
70.00 I.IKK
70.00 YRS.BXP All
Water Conaime-l OAK:
•i. (Wi I* INK


Pollutant
. 1-Dlchloroethylene
,2-Dichloroethylenft (Iran
. 1-Dtchloroft thane
,2-Dlchloroethane
Chloroform
, 1 ,2-Trlchloroethane
. 1 . 1-Trlchloroethane
Bromodlchloromethane
1 ,3-Dlchloropropene
Trichloroethylene (TCE)
Tetrachlqroethylene (PCB)
Toluene
Chloro benzene
1 ,4-Dichlorobenzene
1,3-Dichlorobenzone
1 ,2-Dlchlorobenzene
Xylene (Mixed)
Styrene
nOSB-RBSPONSB INFORMATION:

Oral RfD: Inhaled Rfb:
(mg/kg/d) (•f/kg/d)
9.001-03
2.001-02
1.008-01 1.008-01
1.008-02
4.008-03 6.308+00
9.001-02
2.008-02
3.008-04

1.008-02
3.008-01 1.508+00
2.008-02 5.708-03

8.908-02
9.008-02
2.008+00 4.008-01
2.008-01

Ch lorof or* 1 . 008-02
BroBodlchlnromethane 2.008-02
Chlorodlbromomsthane 2.008-02

Radium 226. 228
Radon 222
Uranium (soluble salts) 3.008-03

Ambient concentrations 'represent average values.


Or«l Inhaled
Potency Potency
Factor: factor:
()/( mg/kg/<1 )) ( I/ (mg/kg/d))
6.008-01 1.208+00
9.108-02
9.108-02 9.108-02
6.108-03 8.108-02
5.708-02 5.708-02

1.308-01
1.808-01
1.108-02 1.708-02
5.108-02 3.308-03


2.408-02



3.008-02
DRINKING HATER
Ambient
Cone.
(ug/1)
1.098+00
1.558+00
8.078-01
9.808-01
9.208-01
2.908 01
1. 658+00
5.608-01
6.608-01
.668+01
.608+00
.268+00
. 168+00
.418+00
.438-01
.008+00
.068+00
6.238-01

6.108-03 8.108-02 4. 718+01
1.308-01 9.868+00
8.40802 1.238+00

1.478+01
2.228+03
3.678+00




(Cancer)
Lifetime
Intake
mg/kg/d
3.108-05
4.438-05
2.318-05
2.808-05
2.638-05
8.298-06
.718-05
.578-05
.898-05
.448-04
.288-05
3. 608-05
1 . 198-04
4.208-05
1.278-05
2.868-05
3.038-05
1.78B-05

1.358-03
2.628-04
3.518-05

NA
NA
1.058-04




(Non-cancer)
Chronic
Intake
•g/kg/d
3. 108-05
4.438-05
2.318-05
2.808-05
2.638-05
8.298-06
.718 05
.578-05
.898-05
.448-04
.288-05
.608-05
.198-04
.208-05
.278-05
2.868-05
3.038-05
1.78B-05
TOTAL:
1.358-03
2.828-04
3.518-05
TOTAL:
NA
NA
1.0f.B 04
TOTAL:



Upper Bound
Lifetime
Cancer Risk
1.868-05
0.008+00
2.108-06
2.558-06
1.608-07
4.72E-07
O.OOKtOO
2.048-06
3.39E-06
4.898-06
2. 188-06
O.OOEtOO
0.008*00
1.0 IB -06
O.OOKiOO
0.008 UN)
O.OOKiOO
5.:j4B 07
3. 798 -Oh
8.20E-06
3.66E-05
2.95B-06
4.788-05
1.478 04
5.558 04
5.248-06
7. 078-04



Hazard Index
(Intake/HfD)
3.44K-03
2.218-03
2.318-04
0.008+00
2.638-03
2.078-03
5. 248-04
7.868-04
6.298-02
0.008+00
4.288-03
1. 208-04
5.94B-03
O.OOB«OU
1 . 4^-04
3.178 04
1.51K-05
H. 908 -05
8.5VK-02
1.358-01
1.418-02
1. 768-03
1.508-01
NA
NA
3.508-02
3.508-02



























Please note that the ambient concentrations for radii* and radon are reported In units of pCi/1. ^
NA = not applicable. Please refer to the attached memo

for risk estimates.







t>
-I
                                                                                                                                                        a

                                                                                                                                                       -O
                                                                                                                                                          OB

-------
GENERAL EXPOSURE ASSUMPTIONS
Adult MSB (kg):
Length of Lifetime (years):
Length of adult's exposure (years):


Pollutant
, 1-Dlchloroethylene
,2-Dlchloroethylene (tran
, 1-Dichloroethane
. 2-Dtchloroe thane
Jhloroform
,1,2-Trlchloroethane
, 1 , l-Trlchloroethaiw
Bromodichlorome thane
1 . 3-Dlchloropropene
Trichloroethylene (TCB)
Tetrachloroethylene (PCB)
Toluene
Chlorobenzene
1 , 4-Dlchlorobenzene
1 .3-Dlchlorobenzene
1 . 2-Dichlorobenzene
Xylene (mixed)
Styrene
UOSB-REUPONKB

Oral RfD:
< mg/kg/d)
9.001-03
2.001-02
1.001-01
1.008-02
4.001-03
9.008-02
2.008-02
3.001-04

1.008-02
3.008-01
2.001-02

8.908-02
9.008-02
2.008*00
2.008-01

Chloroform 1.008-02
Bromodichlorome thane 2.008-02
Oilorodlbromomethane 2.001-02

Radium 226. 228
Radon 222
Uranium (soluble salts) 3.008-03

70 00 AD MA*>r>
TO.'OO LIKE Watpr i:°n3"n*d
70.00 YK!'._BXI>..An
INFORMATION:

Oral Inhaled
Inhaled RfD: Potency latency
(mf/kg/d) Factor: Factor:
(l/(mg/kg/d» (l/(mg/kg/d)»
6.008-01 1.208*00
1.008-01 9.108-02
9.108-02 9.108-02
6.108-03 8. 108-02
6.308*00 6.708-02 5.708-02
1.308-01
1.808-01
1 . 108-02 1 . 708-02
5.108-02 3.308-03
1.508*00
5.708*03
2.408-02


4.008-01
3.008-02
DRINKING WATER
Ambient
Cone.
dig/1)
1.808*00
2.708*00
1.208*00
2.008*00
3.708*00
3.308-01
7.008*00
5. 508-01
1.008*00
2.608*02
5.008*00
1.808*00
1 . 108*01
3.208*00
1.008*00
2.308*00
1.708*00
1.508*00

6.108-03 8.108-02 6.778*01
1.308-01 1.188*01
8.408-02 1.808*00

3.868*01
9.208*03
1.008*01


(l/d):



(Cancer)
Lifetime
Intake
Mg/kg/d
5. 148-05
7.718-05
3.438-05
5.718-05
1.068-04
9.438-06
2.008-04
1.578-05
2.868-05
8.008-03
1.43B-04
5.148-05
3.1 48-04
9.148-05
2.868-05
6.57B-05
4. 868-05
4.29B-05

1.938-03
3.378-04
5.148-05

NA
NA
2.668-04


'.I. IKI



(Non-cancer)
Chronic
Intake
mg/kg/d
5. 148-05
7.718-05
3.438-05
5.718-05
1.068-04
9.438-06
2.008-04
1.57B-05
2.868-05
8.00K 03
1.438 04
5.14B-05
3. 148-04
9. 148 05
2.868-05
6.57E-05
4.868-05
4.298-05
TOTAL:
1.938-03
3.378-04
5. 148-05
TOTAL:
NA
NA
2.66E-04
TOTAL:

MINK



Upper Round
Lifetime
Cancer Risk
3.098-05
O.OOB*00
3. 12B-06
5.20E-06
6.45B-07
5. 378 -07
0.008*00
2.04B-06
5.148-06
8. 808 -05
7.29E-06
O.OOE*OO
O.OOEiOO
2.19B-06
O.OOE*IM)
0.008*00
O.OOBtOO
1.29B-06
1.46E-04
1 . 18B-05
4.388-05
4.32E-06
5.99B-05
3.HKB 04
2.30E-03
1.438-05
2.70B-03





Hazard Index
(Inl.nhe/RfD)
5.718-03
3.868-03
3.438-04
0.008*00
1.068-02
2.368-03
2.228 03
7.868-04
9.52B-02
O.OOStOO
1.43E-02
1.718-04
1.578 02
0. 008*00
3.21E-04
7.308-04
2. 438-05
2.14804
1.53E-01
1.938 01
1 . 69B- 02
2. 578-03
2 138-01
NA
NA
9.528-02
9.52E-02
Ambient concentrations .represent worst-case values.
Please note that the ambient concentrations for radium and radon are reported in units of pCi/1.
NA = not applicable.  Please refer to the attached memo for risk estimates.
                                                                                                                                                       0  a-

-------
                                                                   8
             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             REGION III
                          841 ChMtnut BulMIng
                      Philadelphia, Pennsylvania  19107


SUBJECT:   Coatesville Water Supply              DATE: May 13, 1991

FROM:   J^CTack Kelly, RPM

TO:       Dawn Ioven, lexicologist
     Dawn,

     Enclosed are the  additional lab reports presenting
trihalomethane results for the City of.Coatesville Authority
(CCA) water supply.  The  enclosed analytical reports from Cedar
Grove Laboratories are for quarterly samples taken from 3/1/90 to
3/21/91.  The individual  sample results for the Coatesville
Treatment Plant water  customers include the following dates:
3/1/90, 5/2/90, 9/24/90,  12/12/90 and 3/13/91.   The individual
results for the Octoraro  Treatment Plant water customers include
the following: 4/5/90,  5/2/90,  9/24/90, 12/12/90 and 3/21/91.  I
believe that your July 24,  1990 assessment only evaluated
sampling results taken on 12/12/89,  2/22/90 and 3/1/90 for each
plant's water distribution customers.  For your information, I
have been informed that the residents around the William Dick
Site essentially would obtain water from both plants if they were
to be connected to the CCA system.

     Please review the attached and get back to me to discuss an
approach to update your earlier risk assessment.  Please do so
within a few days if possible.

                                  Thanks1

-------
               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                Region III
                           841 Chestnut Building
                          Philadelphia, PA  191O7
SUBJECT: Evaluation of Trihalomethanes                   Date:  May  28,  1991
         William Dick Lagoons

   From: Dawn A. loven,  lexicologist
         Technical  Support Section  (3HW15)

     To: Jack Kelly, RPM
         SE PA Remedial  Section  (3HW21)

     Background

          To aid in the determination of an appropriate  remedy  at  the
     William Dick  Lagoons site, the  potential toxicological  impacts
     posed by consumption of water from the City of Coatsville Authority
     (CCA) were evaluated.  The CCA is  a municipal water supplier which,
     by law, disinfects potable water  prior  to distribution.   As  a
     result of  the  disinfection  process  currently  utilized  by the CCA,
     several unavoidable trihalomethane by-products are  introduced to
     the  drinking   water  supply.   A conservative  estimate  of  the
     potential   health  risks   associated   with  exposure   to   these
     trihalomethane by-products  is  provided  below.

     Assumptions

          In performing  the risk calculations, several assumptions were
     made:

     1.   For each  trihalomethane contaminant,  both  an average  and  a
     maximum (worst-case)  concentration  was  used.

     2.  A series of sampling results  (3/90  through 3/91) generated by
     Cedar  Grove Environmental  Analytical  Labs were  assessed.   The
     analyzed samples were collected from various points along the CCA
     distribution route.

     3.   Risk  calculations  for each contaminant  were  conducted  for
     adults weighing 7O kg, who ingest 2  liters of contaminated water
     each day for 7O years.

     4.   Following  the  completion  of  each   chemical-specific  risk
     calculation, the totaJ risk under each  exposure scenario (average
     and worst-case) was estimated.   This method  of  quantitative risk
     assessment  assumes   that   similar   risks   (carcinogenic   vs.
     noncarcinogenic) are additive.

-------
                                                           * of 
-------
6ENERAL EIPOSURE ASSUMPTIONS
Adult MSS (kg):
Length of Lifetiie (years):
Length of adult's eiposur* (yiars)i
70.00 AD BASS
70.00 LIFE
70.00 VRS.EIP.AO
Mater Consumed  |l/d):
2.00 DRINK





Pollutant
Chlorofori
Broiodichloroiethane
Chloroditaroioiethane
DOSE-RESPONSE


Oral MDi
lig/U/dl

l.OOE-02
2.00E-02
2.00E-02
INFORMATION:


Inhaled RfD:
lM/kg/d)






Oral
Potency
Factor:
(1/l.g/
6.
1.
8.





kg/d)|
10E-03
30E-0)
40E-02


Inhaled
Potency
Factor:
(1/Ug/kg/dl)
8.10E-02



DRINKIN6 NATER

Aibient
Cone.
lug/1)
3.17E+01
1.08E*01
1.50E»00


(Cancer)
Lifetiie
Intake
•g/kg/d
1.48E-03
3.09E-04
4.29E-05


(Non-cancer)
Chronic
Intake
•g/kg/d
1.4BE-03
3.09E-04
4.29E-OS



Upper Bound
Litetiie
Cancer Risk
9.01E-06
4.01E-05
3.60E-04




Hazard Inden
(Intake/RfD)
1.48E-OI
1.54E-02
2.14E-03
                                                                                                                     TOTAL>
                                                                               5.27E-05
                                                            1.65E-01
Aibient concentrations represent average values.





Pollutant
Chlorofon
Broiodichloroiethane
Chlorodibroioiethane

DOSE-RESPONSE INFQRHATIONi


Oral RfDi Inhaled RfD:
(•g/kg/d) Ug/kg/d)

l.OOE-02
2.00E-02
2.00E-02



Oral
Potency
Factor:
(l/Ug/kg/d)|
A.IOE-03
1.30E-01
B.40E-02



Inhaled
Potency
Factor:
(1/Ug/kg/dl)
B.10E-02




DRINKING NATER

Aabient
Cone.
(ug/1)
9.10E»01
1.47E*01
1.90E»00



(Cancer)
Lifetiie
Intake
•g/kg/d
2.60E-03
4.77E-04
5.43E-OS



(Non-cancer)
Chronic
Intake
•g/kg/d
2.60E-03
4.77E-04
5.43E-05
TOTAL:



Upper Bound
Lifetiie
Cancer Risk
1.59E-05
6.20E-05
4.56E-04
8.24E-05




Hi.'ird Index
(Intake/RfDI
2.&OE-01
2.39E-02
2.71E-03
2.87E-01
                                                                                                                                                              CP
Aibient concentrations represent uniui values.

-------
                                                       APPENDIX C


                                                           I of 3
             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                              Region III
                          841 Chestnut Building
                       Philadelphia. Pennsylvania 19107
MEMORANDUM

TO:    Jack Kelly                                    MAR 141391
       Eastern PA Remedial Section  (3HW21)

FROM:  Bill Foster .-^"T"
       Drinking Water Section  (3WM41)

RE:    William Dick Lagoons/CLTL Site-  Comments  on Drinking Water
       Supply Options...
     In reviewing EPA's pending decision in this case regarding the
development   of   alternative  water  supplies  and/or   treatment
solutions for the private wells impacted (or potentially impacted)
by ground water  contamination from the Site and  the Respondent's
criticisms,  I tried  to  balance out  the  relative benefits  and
disbenefits of PWS and Point of Entry solutions.   (By the way, make
sure to change those  references from "point of use"  to "point of
entry".   That terminology will  cause  confusion every  time  a new
person reads it.)  In general, I feel that the arguments presented
by CLTL against  connection of  the  residences in question to the
Coatesville  PWS   are  good  ones, however,  I  do not  feel  their
analysis of the  situation covers all the bases.

     The  regulations,  which  CLTL's  attorneys  are so  fond  of
quoting, [40 C.F.R. §§ 300.430(a)(1)(i) and 300.430(e)(9)(iii)(A)]
do specify that  EPA attempt to reduce the  impact to human health
to the greatest  extent  possible.  However,  each of  these sections
specifically  refers  to  long  tern,   as  well  as  short  term,
effectiveness of remedial solutions.   There is,  without a doubt,
a greater degree of long  ten reliability attributable to the PWS
option, a  number of  which  are mentioned  below.   With regard to
CLTL's  specific  assertion  that the  cancer  risk   posed by  the
presence  of  THM's in  Coatesville water  is greater  than  that
attributable; to  treated well  water, my response is  three-fold:

     1)  First,  the excess  cancer risk for GAC treated water will
NEVER be zero. The point may be mute, but it is not an appropriate
statement.

     2)    The  cancer  potency  factor  for  THM's,  specifically
chloroform, is still under review, and is by no means well accepted
in the scientific  community.   There is  a possibility  that the
potency factor could be reduced by as much as an order of magnitude
by the time the  smoke clears.   This uncertainty apparently stems
                                                           /ViltleJ ttl Hrf \flfJ Pi

-------
                                                          A of 3


from  the  particular  study,  which  was  done  on mice  who  had
chloroform  administered  orally  in a corn  oil-based  medium,  upon
which the existing unfinalized cancer risk assessments are based.
Apparently., there  is reason to believe that  the  corn oil medium
itself  can  be related to the incidence of cancer among  the  test
animals.

     3)   The  most important point:   The risk  incurred  by water
consumers- does  not end with exposure  to  THM's.   There  are  many
chemical  and  bacterial  water-borne  health threats.   PWS's  are
regulated to  address the entire  spectrum  of  such threats.   PWS
water  quality  is  presently  monitored regularly' for  bacterial
presence and for about 60 additional contaminants and water quality
parameters.  The extent to which water would be monitored under the
Respondent's point of entry proposal is no greater than twice per
year,  for  a restricted list of  VOC's.   The  level of preemptive
protective measures  involved is on an entirely different level.

     The ground water quality in Chester County has been impacted
by  intense  agricultural  activity, urbanization,  and residential
and industrial waste discharges for many years.  Frankly, I doubt
there is any place  in the county that is not vulnerable to nitrate,
pesticide or  organic  chemical  contamination.  Radon is  also a
health  potential  health threat  in  some  areas.    While it  is
obviously not within the  scope of this project  to consider removing
all  contaminants from regional  drinking  water supplies, it  is
required that EPA consider the overall protection of human health
in selecting a remedial option.   It is not appropriate to consider
only THM's in addition to the contaminants of concern at the Site
when examining water supply options.   Bearing this and the above
points  in  mind,  and the  fact  that  ground  water  quality  and
information on health effects are both constantly  changing, I feel
that a  PWS, which  will  be required  to respond  to  any  upcoming
regulatory changes and is best capable of detecting and reacting
to changes in water quality, is clearly  the most protective option
overall.

     Further, there are technical and economic aspects of the long-
term point of entry system option with which I am  not  comfortable.

     1)  Selection of such a program would  require oversight by
EPA's  remedial  program  far  into  the  future,  which  is  not
desireable.  It would require not only that proper maintenance and
monitoring of units be assured, but that the  Responsible  Party be
able to carry out  such operations for as long as necessary.  The
PWS  option  would  require no  such effort,  since all  PWS's are
regulated by  state  and federal  programs specifically designed to
assure the provision of  safe drinking water to  PWS customers.

     2)  Disposal  or recycling of spent  filters—  Note that 40
C.F.R.  § 300.430(a)(1)(i) also addresses minimization of untreated
waste.   PWS are generally pretty good at this.  At least they have
an economy of scale  on their side.

-------
                                                                 C
                                                           3 of 3


     3)  Newly  constructed houses  and existing wells that become
impacted by contamination will need new treatment systems.  I know
that some level of analysis has been done in this area.  However,
CLTL claims, that the characteristics of the ground water plume have
not been  identified  well enough yet to begin  remediation of the
ground water operable unit.  I fail to  see how a reliable estimate
of the future cost associated with  installation of POE systems can
be  made if  such is  the  case.    How  many homes  are  likely  to
impacted?-  What level of  development  is  likely to  occur in the
area?  There are some calculations available in the FS, but I can't
find any basis for them.

     4)  This lack of  certainty regarding the ground water plume
also raises questions as  to the predicted effectiveness of POE
units  in  the future.   If  we cannot be certain about  the ground
water  quality in each of  the  wells  in  question,  we  cannot  be
certain about the level of protection  provided by  the treatment
units.

     Finally, as far as the relative benefits of connecting to the
Coatesville PWS versus establishing a new  system...   I have an old
copy of the design and  operations manual for a PWS operating in PA.
It is  pretty detailed.  Also, I believe  it is required that new
systems have redundant treatment  now, which could  increase the
construction costs.  There are also many  new requirements in the
regulatory  pipeline  which will make  it very hard  for all small
water systems to survive, economically. Consequently,  I feel that
connection to the Coatesville system, regardless of the THH issue
is preferable to establishing a new system.

     Also, small systems are not required  to monitor  as frequently
as larger systems for certain biological and chemical contaminants
and therefore could potentially be considered less protective to
human  health,  although,  in  the  opinion  of  the drinking water
section, a small PWS would  still be more protective than individual
point of entry treatment systems.


SIERRA CLUB COMMENTS:

     I think the suggestion regarding retrofitting of reduced-flow
water fixtures in the homes being effected is a very valuable  idea.
It is something we never would have thought of, but  it is an idea
the EPA should  support 100%.   If this option would  be  considered
appropriate  under Superfund guidelines, we should  sound out  the
residents to see if they'd be agreeable to  it.  I'm  not convinced
that there  would a  huge dent put  in monthly water bills, but it
could  make  a  little  deference.   The  fixtures themselves  are
relatively  inexpensive,  as Mr.  cassel noted.  Unfortunately,  EPA
does not have any information on them, to the best of my knowledge.
I am checking with a couple of offices at headquarters and the with
American Water Works Association.   I'll let you know if I get  any
useful information.

-------
                                                  APPENDIX  D


                                                            I
     THE  COUNTY  OF  CHESTER

      Commtntooers:                     HEALTH DEPARTMENT
      D. T. Marrone. Chairman                326 North Walnut Street
      Joseph J. Kama                     West Chester, PA 19380
      Patricia M. Baldwin                  (215) 3444225
                             November 23. 1990


Mr. Abraham Ferdos
Acting Director
Superfund Office
U.S. Environmental Protection Agency
Region 3
841 Chestnut Building
Philadelphia, PA   19107

Dear Mr. Ferdos:

     As  a follow-up to Ms. Batory's  letter to you dated  October
29.  1990.  this letter is to inform you that the  Chester  County
Health  Department has  instituted the  recommended  water  well
testing procedures outlined in your letter of October 17, 1990.

     All  wells drilled within the  outlined study areas of the  9
NPL  sites in Chester County will be  tested for the  contaminants
of concern. If any of the contaminants are above drinking  water
standards,  treatment will be required prior to granting approval
to  use the supply.  Additionally,  yearly testing of  the  supply
for the known contaminants will be  required as a condition of the
approval.

     To keep your  staff informed we will contact the  appropriate
project  manager   if a well is contaminated.   Therefore,  it  is
important  that the County be kept  informed as to  any personnel
changes that are made at these sites.

     Please feel  free to contact me  at 344-6239 should you  have
any questions concerning our procedure.  Thank you for providing
the information necessary for us to institute this program.

                             Sincerely.
                              nria T. Goman
                             Environmental Health Supervisor
MTG/svf

cc:  David Jackson. R.S.
     Joan Batory
     George Danyliw. PA DER
     File

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    'I't   i;  COUn i IT  UF  lima IE,
     Commiuiooen:                       HEALTH DEPARTMENT
     D T. Mamme, Chairman                 326 North WUnut Street
     Joseph J. Kennt                       West Chester. PA 19380
     Patricia M. Baldwin                    (215)344-6225
                                         November  14.  1990
TO:       Water and Sewage Staff

FROM:     Maria T. Goman
          Environmental Health'Supervisor

RE:       Additional Water Testing Requirements for
           Wells Drilled Near Superfund  Sites

Distributed at today's staff meeting  are maps  of the 9  Superfund
sites  identified  in the County thus far.   Also mapped  are  the
"study  areas"  which  EPA has  identified   as   being  potentially
impacted by the sites.  Also, a  list  of  the contaminants found at
each  site  and  a list of  potentially  responsible  parties  is
included in the packet.

Any  wells drilled in these "study areas" must be tested for  the
contaminants  listed  for  the specific  site as  a  condition  of
permit  issuance.  If any tested substance  is  above the  drinking
water  standard treatment must be in  place  prior to  approval  to
use  being  granted.  Also, as a condition  of  approval  the  well
owner  will  be  required  to test  the  well   annually  for  the
contaminant that is above drinking water standards.

Should y:u have i~y questions, please feel  free to contact, me.

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