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.
-------
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*.
-------
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
-------
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.
-------
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.
-------
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
-------
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
-------
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;
-------
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
-------
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
-------
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
-------
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..
-------
WILLIAM DICK LAGOONS
RECORD OF DECISION
TABLES 1 through 14
-------
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
9OOK>OO
»OOK«OO
I.HHIC-OI
1 HHKOI
I.HHK Ol
IO2K«O2
245KOI
1 HHKOI
1 HHK 01
1 HHKOI
1 HHKOI
I.26K05
2 OOK 05
4 96K-O2
I50K06
1 49K 01
|.60»:06
25IEOS
I.OOE-O6
2.4BKtOI
u.A»
^•CVft
MAXIMUM
992KOH
23IK05
2G4KO7
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
4 IHKO3
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
.74K02
39K07
.KIK07
7IKO7
2.H9KO(i
latake
MAXIMUM
1 XIK II
3. IOK O9
3.54K II
1 /SK 04
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
-------
ttfmtmn MMT CMcnlmlloM ••* Cakafele4 UUko Pot Oit-tMc Croud Water
Bo*Uof CfeMBkMt*! "••fpvrt
b^^an f^^^n r • •!•
It*-)
OmudConuct rtilaihm S6OEOI
I.S^kbtaortlwnc 1 2OE 01
IrtrhhMr infra I.GOEtOI
DMMt 1 HOE 01
tetnchkaraelhene 32OE-OI
•MftMB 837E02
kaytJuM ICOE-03
•MMgMcae 8.63E-OI
JJMI illfi«l|<|«l>ilill I.7OE-OI
phenol I40E«OI
• , «ii ' linJiomnl iW.«oiB*«M ' ft i8fl»V* ftl
*l*«Mnii|fipncm ifrocivov ».ou«.*wi
^4 dhlitoraphcnol 46OE412
1,^^^— drfarafcm S.6OE4H
l.a-4«chlDfWlhMie I.20E4I
MchhmcllKai IWEMII
beatne 1 80EOI
ltU«thlnrr*1t**~f 3.20E-OI
kaylhMi I.60E-03
MM^ncM 8.«3E-OI
MtO-dlVMwVtphlhablc I.7OE-OI
phenol I.40E«OI
l.l-4 2. IDE -01
chlarabment 32OE-O2
3.4-«)chtMoabe)Ml 4.6OE-O2
lntuteaondurlr« chhrniomi S60EOI
ShnKfk« 1.2 dkhtoroellune 1 2OE 01
irtcMaroclheae • l.60E«Ol
bcracne IHOKOI
IcUachktroclliciic :i.2i»: Ol
I.'J dn-liliMUtOriiellolall '* UW. Ill
cliluroUriurm: :l '•**• o:i
Avcntfo
••VVBV^W
4O7EO2
1 .4SE-02
I.2SE«00
I6SEO2
224E02
6.83E-03
26BEO2
6 77E O4
2.I3EOI
1 97E 02
928EOI
2.72E-O2
S6SE03
4OOEO2
700E03
4O7EO2
I4SE02
I2SE.OO
I6SE02
224E02
683E-03
268E02
677E04
2I3EOI
I97E02
9.28EOI
2.72E02
S.6SC-03
4.OOEO2
7.0UE03
4.07E02
I.4SE02
I.2SE>00
1 6SF.-02
2 24K 02
2.72E Itt
S ILSK II 1
— ktui ci — i~
l^kl/o^l
24IEOS
SI6E06
6H8E04
774E06
inatos
3 60E 06
6 8HE OH
:i7IK05
7.3IEO6
6.02E04
9.O3E-O6
l38EOfi
2.4IEOS
I9BEO6
I.20E02
2.S7E03
'3.42EOI
3 BSE 03
68SE03
S.7BE-O4
I79E03
342EOS
1 8SEO3
364E03
3 DUE 01
449K03
6.8SE04
I2OE-O2
9.B4E04
I20E02 •
2 57E tt»
.•I42K Ol
:iH5t:u:i
li MSI : (II
4 -I'.ii: (ii
i; Hiii: IM
M — | rr.fc.tiir 1
1^/kiAuV)
1 75K06
6/MK07
5 :IHK o&
7 IOK 07
9&IE 07
1 I5EO6
29IEO8
9.I6E-06
B47E07
399EOS
1 I7E-OB
243EO7
I.72E06
30IE07
8.7IE04
3.IOEO4
2.68EO2
3S3C04
478EO4
I.46E-O4
S.74E04
I.4SE06
4.S6EO3
422E04
I.99E02
S.83E04
I.2IE-04
8.S6E-04
I.SOEO4
8.7IEO4
3IOEO4
2.68EO2
II i3E 04
4 /HK m
s H:U: IM
1 'JIMM
=1
-------
r!»•••«• Mai C*ac«alnlUM Mid Calculated telahc* for On-Stic Ground Walci
VUUfUB Dtck l^g-rrr
CklMA-ia
MM CkfMlC
ItaUyUtoka
OtnMlConUd
S.60E-OI
i60E«oi
i.me-01
320EOI
2 TOE O2
bcfytfcn
I60E03
863E4I
I.40E«OI
a.ioe-oi
3.30E42
SGOEOI
460E-O2
4O7E02
I4SEO2
I2SE>00
I65E02
224E02
683E03
677E04
2 I3EOI
I97E02
928EOI
272EO2
S65E03
400E02
7 ODE 03
334EO5
7.ISE06
9S4E04
I07E05
I HIE OS
I 6IE06
4.99E06
9S4E08
SI4EOS
IOIE05
8U4E04
I2SEO5
I9IEOS
334EOS
274E06
2.43E OB
8 64K 07
7.46E 05
9 8MK 07
I :I:IK OK
4 07E 07
I 6OE-O6
4.O3EOH
I.27EOS
I I7E06
SS3EOS
I.62E06
337E07
2.38E OH
4.I7E07
56OE-OI
i.aoe-01
I80EOI
3.30G-OI
bayttua
(P^oc««
1.2 (ttcMoroclhanc
Utchlococlhenc '
bciutnc
Iclrathlurutllirlie
1.2 ilklihiruriU-iK (loul)
flilufutiriufiic
8.37E-03
I60E-03
S63E-OI
I.70EOI
I40E>OI
2IOEX)I
3.20E-03
S.60C-OI
4.6oe-oa
S.60EOI
I.2UKOI
I HOE 01
2 IOKOI
4.O7EO2
I4SE02
I25E
-------
>•»•••>« Mat CmwutntUM «*4 Calculate* l»t*k«« r«t On-SIU Cioiui4 Valet
WUHMlNckUgMM
cuwa-c
Hmttmmm Chnmlc
MM! Pratoblc
OcnMlCootad
S.6OE-OI
i ate oi
i60E«oi
I.DOE 4)1
3aOEOI
8.37EOa
I 60K03
863E-OI
I TOE 01
I40E.OI
2IOEOI
407E02
I.4SE09
I2SE.OO
I65C02
224EO2
6.83E03
368E02
677E04
2 I3KOI
I97E02
9.28EOI
372E02
&.6SE 03
400EOa
7 ODE 03
403EOS
8.U4E06
I.ISE03
I.30EUS
230tOS
I94EOK
I I5K07
6 21K OS
I.OIEOII
I SIE05
4UIEOS
3.3IE06
29:iK06
KHE06
9OIK OS
I I9E (Mi
!6IE(Ni
4 92E 07
I.93K06
4.H7EOH
I SJt OS
I 42E06
66HKOS
I.96EO6
4 U7E O7
S04E07
S.60E-OI
laOE-OI
i.6oe«oi
laoE-oi
saoE-oi
aTOE-oa
4Mttlqr«l
I.60C-O3
8.63E-OI
I.70E-OI
I.40E«OI
aioE-oi
3.aoE-oa
S60E-OI
4.60K-02
4O7E02
!4SEOa
lasEtoo
tesEoa
saeEoa
• B3E03
368EOa
677E04
ai3EOI
I97E09
038EOI
aTaEoa
56SE03
400EO2
7.0UEU3
ISOEtOO
I69EO2
3OIEO2
2.S4E03
7.87E03
I.SOEO4
8 HE 02
I.GOEO2
I32E.OO
I97E02
3 01 £03
S2£E02
4.33E03
3.83E03
I36EO3
I.I8EOI
I 5SE03
a IOE03
643E04
a sat 03
636EOS
aooEoa
I 85E 03
H72E02
S.3IE04
376C03
6SME04
Sterner**
cMorafona
l.aittchlotDcllunc
Uichfcrorthene
btiaciic
Icliachtoiocthcnc
1.3 dtcMuruclhriic (luluU
S.60E-OI
l.iiOKtOI
I HOK 01
a 201: oi
2 101:01
4.07EU3
|.4SEOa
I 6SK02
a.2*4E IU
2 V2K IM
ft li!>K III
5 26E 02
1.SOt. 110
I li'JK 02
Mil IK 02
I &E 03
I I8EOI
I SSK03
2 I OK O:i
2 SliK o:i
-------
A
of l«
«.8Tt-fl»
i.iac-12
l.tlf-01
MIC-IJ
i.ou-o*
1.J3C-O4
l.MC-Of
a.«ac-OT
4Mt-OT
s.we-os
i.a
2JIC-0*
1.039*01
I-IJ£-04
(4U-0*
..•(•07
J.MC-0*
IOC-0*
1MI-07
4.9U-OT
s.ais-a
4.04 C-Oi
4.4TC-OT
4.40C-0*
5.01C-W
utc-or
1JOC-C*
X41C-0*
4.tat-os
I.OK-W
UK-OB
urc-a*
l.JIC-OT
l.MC-OS
1.ISC-0*
IJK-OT
1.41C4B
7JIKJT
I4M-OT
3.07101
4«B«-0»
tutor
7.MC-07
3.MB-0*
i ut-
-------
,i A
1.I3C-U
1.40C-OS
1.03C-W
I.MB-04
1411-Oi
\MtrOt
).!>•• 13
I.17C-13
1.0
t.J3«-O»
!.Ǥȥ or
I-9M4*
I.OiC-O*
3.93B-07
4.MC.OT
6.MC-OS
4JU-OT
J. !«*•<»
&MC43
1J4B4*
1.01S-OI
1.10B-OT
i.ra-or
l.MC-O*
J.3i«-0»
a. lie-or
7JIE-OT
4.04C-0*
4.47C-OT
440C-0*
5.0II-0
l.MB-4*
14SIVOT
1.07*0*
I.MK-OS
• •(•or
l.MC-Oi
l.MC-O*
I.MC-Oi
1.44C/OS
S.41C-IO
1.43C-Oi
s.aec-o*
2.43C-0*
t.au-os
s.rrt-ie
7.3T»Oi
t.lltOT
• ait-o»
4*OC~0§
J.44C-OI
rret-oi
4.HC-0*
I.39C-OT
i.aic-or
I.IK-0*
l.MC-Oi
rait-o*
I.MC-O*
l.MC-0*
rm-ii
rritw
raoe-or
i.aic-or
1.14X-OT
l.OU-07
i.ist-or
-------
A
»? «f Ms
3 nt-n j.iit-u i.iw-ia I.IM-I*
1.40C-0* 1.40C.O* 9.I4C-0* I.14t-0>
I.OIC-O* . l.OOC-0* 3.MB-07
1 ill 04 1.31B-04 VOtt-Oa S.O
«.4»c-oi i.4ii-ot 3.iic-o» xnt-ot
ll»t-07 I.OiB-07 0.43S-OI S.43C-C*
3UC-0* 1.9M-0* I.MK-0* l.MC-OI
•.OiC-OB •.QBC'OS l.OM-06 1.0tt-4V
1.UI-O7 1.83B-O7 1.13X-OT UB-O7
4.9H-O7 4.9*»OT 1.74C-O7 1.741-Of
fl.ac-09 e^a»os rtse-os _ x»4i-os
I.4M-M 4.04CO» S.CK-0* 1.141-O1
2.XC-0* 4.47C-OT 1.3W-07 l.70e-O7
I.MC-0* 44CC-Oi 7MC-01 1.4U-0
1.11 tOI 9.O1C-O* «.7»e-0» lllt-0*
0.1)t-O7 I.3U-OT 113C-O7 4.I7I-0*
7111-O7 14AC-O7 X74C-O7 l^It-O
9.J7C-OS 2.O7C-0* l.STC-Ot 7IK-O*
4«t-OI \.M*:t» l.TM-0* 4.73t-O»
*ma-*a>i i.nc-a* i sit-o* usc-o
I.HI-M 711t-0» 7JSC-0* 1.74t-0»
I.44C-0* l.SCfrO* S.4M4* l.MC-4*
94IC10 19THO IQK-IO 7V5C.ll
1.4W-OI 7.7IC-0* I.MC-0* IMt-O*
3.06t-OS 1.3MM l.nt-M ISTt-O*
1.4U-OI 7.aOfr«f 9.21C-07 XMC-07
I.3K-0* 331107 4.MC-OT 1.MI-O7
i. 77t-io a-JM-or xaec-ie
797CO* a.OK-0* IMC«
•.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.
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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.
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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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