Agency
Eniergency and
Remedial Response
EPA/ROD/R03-92/144
December 1991
£EPA Superfund
Record of Decision:
Raymark, PA
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement, but adds no further applicable information to
the content of the document All supplemental material is, however, contained in the administrative record
for this site.
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50272-101
REPORT DOCUMENTATION*
PAGE
1. REPORT NO. N
EPA/ROD/R03-92/144
3. Recipient's Accession No.
4. TWe ana Subtitle
SUPERFUND RECORD OF DECISION
Rayraark, PA
First Remedial Action - Final
5. Report Date
12/30/91
7. Aianor(s)
8. Pertonnlng OrgantzsSon Rapt No.
9. Performing Oigaliilaaion Name and Address
10. ProJectfTasWWortcUnltNo.
11. Contract(C)orGrant(G)Na.
(G)
12. Sponsoring Organbadon Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report a Period Covered
800/000
14.
IS. Supplementary No*
PB93-963902
16. Ab«ract(Urr«:200word*)
The 7-acre Raymark site is an active metal manufacturing and electroplating plant in
tiie Borough of Hatboro, Montgomery County, Pennsylvania. The site, located in an
industrial area, is approximately 100 feet from the nearest residence. The nearest
surface water is Pennypack Creek, which flows 4,000 feet southwest of the site. As
part of the rivet manufacturing process at the plant, VOCs, including 30 to 40 gallons
of TCE, were used daily at the site to clean and degrease metal parts. Facility
documents indicate that piping may have directed waste from the degreasing unit to four
small lagoons, which contained effluent from an onsite wastewater treatment building.
The lagoons were subsequently cleaned and backfilled in the 1970s. In 1979, when EPA
discovered TCE in the Hatboro public water supply wells, the Hatboro Borough Water
Authority removed the wells from operation, and supplemented the water supply using an
interconnection with a neighboring water company. Further EPA site investigations from
i960 to 1987 identified TCE in soil and other wells onsite and adjacent to the property
and concluded that site contaminants were a contributing source of contamination in the
downgradient public water supply wells. In 1987, the site owners agreed to install
ground water treatment units with air stripping towers, and, as necessary, air emission
(See Attached Page)
PA
17. Doeunent Analysis a Descriptors
Record of Decision - Raymark,
First Remedial Action - Final
Contaminated Media: soil
Key Contaminants: VOCs (1,2-DCE, PCE,
la. Idanflflers/Open-Ended Terms
TCE)
e. COSAT1 FWdfGroup
18. AvaUabOty Statement
19. Security Class (IWs Report)
None
20. Security Class (TMs Page)
None
21. Mo. of Pages
134
22, Price
(SeeANSt£39.18)
See {RCttuctTons on ttBvonv
OPTIONAL FORM Z72 (4*77)
(Formerly NTISOS)
Depmnent of Commerce
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EPA/ROD/R03-92/144
Raymark, PA
First Remedial Action - Final
Abstract (continued)
control units, at two Hatboro public supply wells to return these to routine operation.
EPA site investigations also revealed high concentrations of TCE and lower levels of PAHs
and PCBs in soil. In 1990, a pilot scale treatability study was conducted to evaluate
the effectiveness of Soil Vapor Extraction (SVE) as a remedial technology for the site
soil and underlying bed rock. This ROD addresses the soil/source of contamination as the
final action at the site and is referred to as OU1. The drinking water and risks posed
by groundwater (OU2 and OU3, respectively) were addressed in a previous 1990 ROD. The
primary contaminants of concern affecting the soil/source are VOCs, including 1,2-DCE,
PCE, and TCE.
The selected remedial action for this site includes constructing, operating, and
maintaining a SVE system to remove contaminants from soil and unsaturated bedrock;
constructing and operating a vapor phase carbon adsorption system on the vapor extraction
system to remove contaminants from the extracted air; constructing and maintaining a low
permeability cap to minimize infiltration through soil; institutional controls, including
access restrictions; and additional sampling of surface soil. The estimated present
worth cost for this remedial action is $3,654,400, which includes an O&M cost of
$1,220,600 for operation of the SVE system for 2 years and maintenance of the cap for
20 years.
PERFORMANCE STANDARDS OR GOALS: Chemical and location-specific performance goals are
based on federal and state standards. VOCs will be removed from the soil/source such
that TCE in subsurface soil does not exceed 50 ug/1. VOCs will be removed from
subsurface soil so that leaching of TCE from subsurface soil will not exceed SDWA ground
water MCLs. Organic emissions will be minimized from the vapor extraction system such
that the maximum rate of organic emission does not exceed 3 pounds per hour or 15 pounds
per day. Infiltration of contaminants through the low permeability cap shall not exceed
9 cubic feet per day. Water potentially generated during implementation of SVE will be
treated to meet CWA levels, as stated in the ROD for OU2 and OU3. The excess cancer risk
resulting from site-related contamination will be reduced to a 10~6 level and the HI will
be reduced to one.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Raymark Site
Hatboro Borough, Montgomery County, Pennsylvania
Operable Unit I
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the selected remedial action
for Operable Unit 1 for the Raymark Site (Site), chosen in accordance
with the requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended, and to
the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based on the
Administrative Record file for the Site.
The Commonwealth of Pennsylvania has participated in the development
of remedial alternatives and has provided comments on this Record of
Decision in accordance with the NCP, 40 C.F.R. § 300.515. The
Commonwealth concurs with EPA's selected remedial alternative as set
forth in this Record of Decision. PADER maintains that surface soil
at the Site poses a potential threat to ground water and must be
addressed pursuant to Pennsylvania's environmental regulations and
statutes, e.g. Clean Streams Law. A copy of the letter of
concurrence can be found in Appendix G.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine, pursuant to
Section 106 of CERCLA, 42 U.S.C. § 9606, that actual or threatened
releases of hazardous substances from this Site, if not addressed by
implementing the response actions selected in this ROD, may present
an imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE REMEDY
Operable Unit 1 is the last of three operable units for the Site.
Operable Unit 1 addresses contamination in soil and bedrock which is
the principal threat posed by the Site. The selected remedy removes
the majority of the contamination from the soil and bedrock beneath
the site and minimizes potential future leaching of residual
contamination to the ground water aquifer. Operable Units 2 and 3
addressed the potential risks posed by ground water contaminated at
the Site.
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The major components of the selected remedy include:
1. Construction, operation, and maintenance of a vapor extraction
system to remove contamination from subsurface soil;
2. Construction, operation, and maintenance of a vapor extraction
system to remove contamination from unsaturated bedrock;
3. Construction, operation and maintenance of a vapor phase
carbon adsorption system on the vapor extraction systems to
remove contaminants from the extracted air;
4. Construction and maintenance of a low permeability cap to
minimize infiltration through soil containing residual
contamination and resultant leaching to ground water and to
increase the efficiency of the vapor extraction system by
decreasing the moisture content of the soil;
5. Institutional controls to ensure that the integrity of the cap
is maintained; and
6. Additional sampling of surface soil to determine if surface
soil contiguous to the former lagoon area is a characteristic
hazardous waste.
STATUTORY DETERMINATIONS
This action is protective of human health and the environment
and complies with Federal and State requirements applicable or
relevant and appropriate to this action. In addition, this action is
cost-effective. It employs permanent solutions and alternative
treatment technologies to the maximum extent practicable and
satisfies the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a principal element.
Because this remedy will result in residual levels of hazardous
substances remaining on-Site, a review will be conducted in
accordance with Section 121(c) of CERCLA, 42 U.S.C. § 9621(c), within
5 years after commencement of the remedial action to ensure that the
remedy continues to provide adequate protection of human health and
the environment. A five-year review will apply to this action until
leaching, if any, of residual hazardous substances does not result in
exceedance of the ground water cleanup goals specified in the Record
of Decision for Operable Units 2 and 3 issued by EPA in September
1990.
-XL—TXA
DEC a 01991
Edwin B. Erickson Date
Regional Administrator
Region III
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Table of Contents
for the
Decision Summary
SECTION
LIST OF FIGURES ii
LIST OF TABLES ii
INTRODUCTION iii
I. SITE NAME, LOCATION, AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITY ... 3
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION ... 9
IV. SCOPE AND ROLE OF OPERABLE UNIT 1 .... 10
V. SUMMARY OF SITE CHARACTERISTICS 12
VI. SUMMARY OF SITE RISKS 19
VII. ALTERNATIVES . 30
VIII. COMPARATIVE ANALYSIS OF ALTERNATIVES 39
IX. SELECTED REMEDY 45
X. STATUTORY DETERMINATIONS 50
XI. EXPLANATION OF SIGNIFICANT DIFFERENCES .. 51
APPENDIX A - RESPONSIVENESS SUMMARY
APPENDIX B - ADMINISTRATIVE RECORD INDEX
APPENDIX C - DEFINITIONS
APPENDIX D - SUMMARY OF ANALYTICAL DATA
APPENDIX E - SUMMERS MODEL CALCULATIONS
APPENDIX F - RISK CHARACTERIZATION TABLES
APPENDIX G - LETTER OF CONCURRENCE
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List of Figures
1. Site Location Map
2. Site Map
3. Public Supply Well Locations
4. Extent of Ground Water Contamination
5. Location of Places of Historical or Archeological
Significance
6. Tax Parcel Map
7. Off-Site Monitoring Well Locations (R-Series)
8. November 1986 USEPA Sample Locations
9. Soil Gas Survey Results
10. Surface Soil Sample Locations and Results
ila. Subsurface Soil Sample Locations and Results (Volatile
Organic Compounds)
lib. Subsurface Soil Sample Locations and Results (Semi-Volatile
Organic Compounds, Pesticides, and PCBs)
12. Geologic Cross Section
13. Surface Water Sampling Locations
14. Subsurface Area Requiring Remediation
15. Conceptual Layout of SVE System
List of Tables
1. Site Specific Remedial Response Objectives
2. Summary of Site Contamination
3a. Contaminants of Concern
3b. Other Contaminants in Soil
4. Reasonable Maximum Exposure Assessment Assumption
5. Summary of Excess Cancer Risks
6. Summary of Non-Cancer Risks
7. Remedial Technologies and Process Options
8. Remedial Alternatives
9. SVE Percent (%) Cleanup Estimates
10. Infiltration Calculations Through Multilayered Caps
11. Applicable or Relevant and Appropriate Requirements
ii
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INTRODUCTION
The Raymark Site consists of an area of ground water beneath
Hatboro, Pennsylvania and neighboring communities contaminated by
multiple sources including a metal fabrication facility
previously owned by Raymark Industries, Inc. ("Raymark
facility"). The Raymark facility is located on Jacksonville Road
in the borough of Hatboro, Montgomery County, Pennsylvania. The
Raymark facility is located in an industrial area approximately
100 feet from the nearest residence.
The Raymark facility has been the location of a metal fabrication
shop since 1948 and is currently operated by Penn Fasteners, Inc.
Solvent containing trichloroethene (TCE), which is a hazardous
substance as defined in CERCLA Section 101(14) 42 U.S.C. §
9601(14), was historically used in the manufacturing process to
clean and degrease metal parts at the facility. Volatile organic
compounds (VOCs), primarily TCE, have been detected by the United
States Environmental Protection Agency (USEPA) in soil, bedrock,
and ground water beneath the facility and in several public water
supply wells operated by the Hatboro Borough Authority. TCE was
first discovered in public supply wells in 1979. The Site was
placed on the National Priorities List (NPL) in October 1989
making the Site eligible to receive Superfund monies for cleanup.
The United States and Hatboro Borough Authority filed a complaint
in the United States District Court for the Eastern District of
Pennsylvania, against past and current owners and operators of
the Raymark facility in 1985. A trial was conducted in 1987
which resulted in a settlement between USEPA, Hatboro Borough
Authority, and several defendants. The requirements of the
settlement, which include treatment at contaminated public water
supply wells, are contained in a Consent Decree entered by and
between USEPA, Hatboro Borough Authority, and several settling
defendants. The Consent Decree was judicially entered by the
Court in February 1989.
To expedite remedial response at the Raymark Site and in an
effort to better manage the cleanup of the Raymark Site, USEPA
divided response actions into operable units. The operable units
are:
1. Operable Unit 1 (OU1) - Soil/Source Control
2. Operable Unit 2 (OU2) - Drinking Water Supply
3. Operable Unit 3 (OU3) - Ground Water
This Record of Decision (ROD) addresses the response action for
OU1. Since OU1 is the last operable unit to be addressed, this
will be the final ROD for the Raymark Site. This ROD selects a
remedial alternative to remove TCE and other VOCs from subsurface
soil and bedrock and to construct a low permeability cap over the
111
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contaminated soil and bedrock at the Raymark facility to minimize
infiltration of precipitation through the soil and bedrock which
could result in leaching of TCE into the underlying ground water.
Operable Unit 1 addresses the remedial response action for the
source of contamination to ground water beneath the Raymark
facility.
A Remedial Investigation and Feasibility Study (RI/FS) of the
contaminated soil and bedrock (source area) was begun in December
1989 and completed in June 1991 in an effort to: l) characterize
the nature and extent of contamination related to the Raymark
facility, 2) evaluate potential risks posed by the Site, and 3)
develop potential remedial alternatives. In addition, Pennypack
Creek was sampled to determine if contamination related to
operations at the Raymark facility are impacting this surface
water body.
A pilot-scale soil treatability test was completed in 1991 to
evaluate the effectiveness of soil vapor extraction (SVE) as a
potential soil and weathered bedrock treatment alternative.
Since the pilot-scale test was successful, SVE could be
implemented as a full-scale remedial alternative. •
To the maximum extent practicable, the remedy selected for OU1 is
consistent and compatible with the remedies selected for OU2 and
OU3. USEPA believes that the remedy for OU1 selected in this ROD
is flexible enough to accommodate any possible modifications
required for the remedies previously selected for OU2 and OU3.
In addition, USEPA believes that the remedy selected for OU1 will
benefit from implementation of the remedies implemented for OU2
and OU3, e.g. components of OU2 or OU3 would enhance remediation
of the source area by lowering the water table beneath the
facility thereby allowing the contaminants within the soil and
bedrock previously saturated by ground water to be removed by the
SVE system.
This decision document presents the selected remedial action for
Operable Unit 1 of the Raymark Site in Hatboro Borough,
Montgomery County, Pennsylvania, chosen in accordance with
CERCLA, 42 U.S.C. S 9601 et. seq., as amended, and, to the extent
practicable, the National Contingency Plan codified at 40 CFR
Part 300. The Administrative Record file for this Site and
comments received by USEPA during the public comment period for
the Proposed Plan provide the basis for USEPA's decision.
iv
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I. Site Name, Location, and Description
The Raymark Superfund Site ("Raymark Site") consists of an area
of ground water beneath Hatboro and neighboring communities
contaminated by multiple sources including a metal fabrication
facility previously owned by Raymark Industries, Inc. ("Raymark
facility") and the soil and bedrock contaminated by the Raymark
facility. The Raymark facility is located along Jacksonville
Road in Hatboro, Montgomery County, Pennsylvania (Figure l).
Since this ROD addresses remediation of the contamination within
soil and bedrock beneath the Raymark facility and in an effort to
simplify further discussion of contamination within the soil and
bedrock beneath the Raymark facility, the remainder of this
document utilizes the word "Site" to include: 1) the volume of
contaminated soil and bedrock beneath the Raymark facility, as
defined in the Remedial Investigation and within this ROD, 2) the
structures and features which contributed to the contamination of
soil and bedrock, and 3) the area necessary to properly implement
a remedial alternative for OU1. However, as stated previously,
the Raymark Site includes the area of ground water contamination
resulting from releases of hazardous substances from the Raymark
facility.
Hatboro Borough ("Hatboro") had a population of nearly 7600
people in 1980 (U.S. Census Bureau, 1980). Although the Site is
located at the perimeter of an industrial area, it is within one
block of the nearest residential home. The area surrounding the
Site is zoned primarily for industrial use. However, residential
areas are located within one quarter mile east, west, north and
south of the Site.
The Site consists of a manufacturing building, which also
contains office space, and a waste water treatment building,
which was historically used to treat electroplating wastes.
Available documents indicate that cadmium, copper, zinc, brass,
and nickel plating were done at the Site. A metal
cleaning/degreasing operation is located in the rear (east)
section of the manufacturing building and an above-ground solvent
storage tank was historically located immediately outside this
area along the southern wall of the manufacturing building. A
septic tank is located near the waste water treatment building.
Four small lagoons, which contained effluent from the wastewater
treatment building, were located in the rear of the property, but
were cleaned and backfilled in the early 1970's under supervision
of Pennsylvania Department of Environmental Resources (Figure 2).
Presently, the manufacturing facility at the Site is operated by
Penn Fasteners, Inc. The facility operates on approximately 3.5
acres of relatively flat land. The existing 3.5-acre property is
part of a 7-acre parcel of land owned by prior owners of the
manufacturing facility.
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PTNNSVIVANU
SCALE 1:24000
o
t mj.
CONTOUR INTCMVAI. 10 FCCT
NNDONM. MDOCT1C VOmCM. MTUM OF Mi
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SOURCE:
HATBORO QUADRANGLE
PENNSYLVANIA
7.5 MINUTE SERIES (TOPOGRAPHIC)
FIGURE 1 LOCATION OF RAYMARK FACILITY
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APPROXIMATE LOCATION OF
•ACXF&LCD LAC
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The Raymark facility has been a metal fabrication shop since
1948. Solvent containing trichloroethene (TCE) was used in the
fabrication process to clean and degrease metal parts inside the
manufacturing building. Over several decades of operations at
the facility, TCE was introduced into the environment at the
location of its use, i.e., solvent storage tank and metal
degreaser, and, apparently, at the location of the lagoons. The
most probable means by which TCE entered the environment was by
small leaks and spills from the piping and tanks near the
degreaser. In addition, facility documents suggest that piping
may have directed waste from the degreasing unit to the waste
water treatment building which in turn discharged to the lagoons.
The residents of Hatboro rely upon ground water within the
Stockton Formation bedrock beneath the Borough for their drinking
water supply. The Stockton Formation consists of interbedded
sandstones, siltstones, and shales which imperfectly separate the
Stockton Formation into several different aquifers. For example,
at least three separate water-producing and/or water-receiving
zones have been identified beneath the Raymark Site, but the
fractured nature of the bedrock may allow the zones to be
connected. The Stockton Formation is one of the most important
aquifers in southeastern Pennsylvania. The Formation contains
the water supply for nearly 1 million residents. Ground Water
within the Stockton Formation beneath Hatboro is pumped from 12
public supply wells currently operated by the Hatboro Borough
Authority. The locations of Hatboro's wells are depicted on
Figure 3 (Wells l, 2, 3, and 16 are currently not in use).
Contamination of ground water in the Stockton Formation beneath a
large portion of Hatboro, Montgomery County, PA, Warminster,
Bucks County, PA, and neighboring communities was discovered in
1979 after TCE was detected in several public water supply wells
including eight wells operated by the Hatboro Borough Authority.
The approximate extent of ground water contaminated by the site
and other sources is depicted on Figure 4. After several
environmental investigations were completed, USEPA concluded that
the Site was one of the sources of TCE contamination of the
aquifer beneath Hatboro and Hatboro's public water supply.
Analysis of samples collected from the Site indicated the
presence of TCE in soil, bedrock and ground water beneath the
site. The highest concentration of,TCE detected in soil and
weathered bedrock at the site was 3,100,000 parts per billion
(ppb) and 210,000 ppb, respectively, in November 1986. Section
v, "Summary of site Characteristics", of this ROD contains
further discussion of contamination identified in the soil and
bedrock beneath the Site. TCE concentrations as high as 11,000
ppb were detected in ground water beneath the Site as recently as
August 1990. Elevated concentrations of TCE and other VOCs have
also been detected in ground water monitoring wells and public
supply wells near the Site.
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HATBORO QUAUKANGLE
PENNSYLVANIA
7-5 MINUTE SERIES (TOPOGRAPHIC)
\
SCALE 1:24000
o
1000 • 0 1000
MOO 4000 MOO MOO TOO
OtMOMNGU IOCATIO"
FIGURE 3 HATBORO PUBLIC SUPPLY
WELL LOCATIONS
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HATBORO QUADRANGLE
, PENNSYLVANIA
7.5 MINUTE SERIES (TOPOGRAPHIC)
1000
1000 MOB 3000 4000 SOOO MOO 'OBO
PENNSYLVANIA
QUAOMNGU LfiCATlON
FIGURE If. APPARENT EXTENT OF TCE
CONTAMINATION IN GROUND
ftATER
M
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The surface water body nearest to the Site is the Pennypack Creek
which flows generally northwest to southeast through Hatboro.
The Pennypack Creek is approximately 4000 feet southwest of the
Site (see Figure l). A small tributary to the Pennypack Creek
flows generally from north to south through Hatboro. The Site is
not located within the floodplain of Pennypack Creek. The
Pennypack Creek is used for recreation; several park areas are
located along its banks.
EPA identified several wetland areas within the floodplain of
Pennypack Creek. For the most part the wetland areas were
confined to the Creek's bottom and bank. Sporadic occurrence of
wetland plant species were also identified along the route
draining the Site as well as the surrounding urban and
residential areas.
Several buildings and places of potential historical or
archeological significance were identified in Hatboro (Figure 5).
One historic property is located near the Site and is eligible
for listing on the National Register of Historic Places.
II. Site History and Enforcement Activity
USEPA sent Toxic Substances Control Act (TSCA) subpoenas to over
100 companies located within the area of contaminated ground
water discovered in 1979. Upon determining that TCE was used at
the Raymark facility, USEPA completed a search for past owners
and operators of the Raymark facility to identify the potentially
responsible parties. USEPA also determined that other companies
have used TCE and has identified other parties which are
potentially responsible for the ground water contamination
beneath Hatboro.
Metal fabrication operations, including rivet manufacturing and
electroplating, began at the Site in 1948. The Milford Rivet &
Machine Company, under two separate ownerships, operated the
facility from 1948 to 1969 (Milford I) and from 1969 to 1981
(Milford II). In 1982, the Milford Rivet & Machine Company
(Milford II) merged with RMFPC, which changed its name to Raymark
Formed Products, Inc. Previously, Milford I had merged with
Raybestos-Manhattan, Inc., which then merged into Raymark
Industries, Inc. in June 1982. Raymark entities ceased ownership
at the Site in 1981 when the facility was sold to the Telford
Industrial Development Authority.
Milford Rivet and Machine Company once owned 7 acres of land
consisting of 3 individual tax parcels, Lots #1, #2, and #3
(Figure 6). In 1972, Lot #3 was conveyed from Milford Rivet and
Machine Company to Suburban Moving and Storage Company (later
Reads Van Service, Inc.). In 1981, Lots #1 and #2 were conveyed
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ARCHAEOLOGICAL AND
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from Milford Rivet and Machine Company to Telford Industrial
Development Authority (TIDA). In 1983, Lot #2 changed ownership
several times and was eventually conveyed to the entities
operating Reads Van Service, Inc. Also in 1983, Lot fi was
conveyed from TIDA to Mr. and Mrs. Richard Walker who own and
operate the manufacturing facility under the name of Penn
Fasteners, Inc.
Manufacturing operations at the Site included the use of a
degreasing unit which utilized TCE to clean metal parts during
the rivet manufacturing process. In response to a TSCA subpoena
and on November 27, 1979, the then current operator of the
Raymark Site, Milford II, stated that it used 30 to 40 gallons of
TCE per day. TCE is no longer used at the Site.
A series of environmental samples collected in late 1979 and 1980
by USEPA, the Pennsylvania Department of Environmental Resources
(FADER), and Hatboro revealed the presence of TCE and several
other VOCs in 8 of 16 public supply wells pumped by Hatboro. TCE
was detected in Hatboro wells HI, H2, H3, H7, H12, H14, H16, and
H17 ("H" for Hatboro)(see Figure 3). Subsequent to the discovery
of TCE and other VOCs in the public supply wells, the Hatboro
Borough Authority removed the affected wells from routine
operation and began to supplement its water needs from an
interconnection with a neighboring water company.
USEPA installed a monitoring well (identified as PF-1) on the
Raymark Site in 1981 as part of an effort to investigate regional
ground water contamination (refer to Figure 2). Ground water
samples collected from this well contained high concentrations of
TCE. The highest concentration of TCE detected in well PF-1 at
this time was 19,900 ppb.
Soil samples were collected from the area of the former TCE
storage tanks and from the area of the former lagoons in 1982.
The highest concentration•of TCE, 640 ppb, was detected at a
depth of 3 feet next to the former TCE storage tank location.
A pump test was also conducted in 1982 on well PF-1. During the
pump test, ground water samples were collected from the pump
discharge. USEPA detected 37,000 ppb of TCE in well PF-1 before
the pumping began and over 4000 ppb from most samples collected
after pumping began.
In June 1983, USEPA conducted a Site Investigation for the
Raymark Site. The information collected was used to determine
the relative hazards posed by the Site, e.g., the type of
contaminants and routes of contaminant migration, in a subsequent
Hazard Ranking System (HRS) report. The HRS report, completed in
July 1983, calculated a score which portrayed the relative risks
posed by the Site according to available information. The
Raymark Site scored 26.08 in 1983. A score of 28.5 is necessary
for placement on the National Priorities List (NPL).
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In the Fall of 1984, USEPA installed an additional 5 monitoring
wells (R-series) along the Southeastern Pennsylvania
Transportation Authority (SEPTA) railroad tracks located west of
the site (Figure 7). These wells, well PF-1, and other nearby
monitoring wells or abandoned water supply wells, e.g., well MS-
10 which is an abandoned water supply well located north of the
Raymark Site, were sampled in October 1984. High levels of TCE
were detected in each well.
In October 1984, USEPA collected samples of soil from the area of
the former TCE storage tank and lagoons. The highest
concentration of TCE detected in the soil was 460 ppb from a
location within the area of the former lagoons. In addition, low
levels of other VOCs were also detected in soil samples.
Polycyclic aromatic hydrocarbons (PAHs), including benzo(a)pyrene
detected at 360 ppb, were identified in composite soil samples.
Finally, low concentrations (66 ppb) of polychlorinated biphenyls
(PCBs) were detected in the soil within the area of the former
lagoons.
The wells sampled in October 19*84 were sampled again in November
1985. Again, high levels of TCE were detected in the wells.
Each time the monitoring wells on or near the Site were sampled
between 1981 and 1985, high concentrations of TCE were detected
in the wells. Other VOCs, e.g., cis 1,2-dichloroethene (cis 1,2-
DCE), which are degradation products of TCE and hazardous
substances as defined in CERCLA, were detected in the R-series
wells and other wells, but were detected infrequently in well PF-
1. In addition, contaminants, which are most likely unrelated to
the Site, e.g., l,1,1-trichloroethane (TCA), have been identified
in monitoring wells located off-Site.
The information obtained by USEPA by 1985 was sufficient for the
United States to file a CERCLA and RCRA complaint against Raymark
Industries, Inc., et. al., in accordance with Sections 104, 106,
and 107 of CERCLA, 42 U.S.C. §§ 9604, 9606, and 9607, and Section
7003 of RCRA, 42 U.S.C. S 6973. The complaint was filed by the
United States Department of Justice (USDOJ) on behalf of USEPA
and requested reimbursement of USEPA's costs, injunctive relief,
and declaratory relief for future remedial action and an "extent
of contamination" survey.
In May 1986, a new HRS score was calculated for the Raymark Site.
The new HRS used information collected since the 1983 HRS score
was calculated, e.g., revised population estimates and new
contaminant types and concentrations detected in the soil and
ground water. The 1986 HRS score was 53.47.
-------
SCALE 1:24,000
Figure 7. Off-Site Monitoring Well Locations
-------
In 1986 and 1987, USEPA prepared for trial stemming from the
complaint filed in 1985. In November 1986, USEPA conducted an
extensive investigation of the soils and bedrock beneath the
Site. USEPA's samples indicated that high levels of TCE existed
in the soil and weathered bedrock beneath the Site. The highest
TCE concentration detected in a soil sample was 3,100,000 ug/kg
from location A3 (refer to Figure 8 for soil boring locations).
It is important to note, however, that the soil sample was
submerged in methanol, a solvent, before analysis. Since all of
the TCE that was in the soil would move into the methanol, the
analytical result depicts the total concentration of TCE in the
sample and not necessarily the amount of TCE that would leach to
the water table or the amount that could be remediated. The
highest concentration of TCE detected in soils using standard
analytical procedures was 9,200 ug/kg.
In January 1987, the PF-1 well, the R-series of wells, and other
nearby monitoring wells were again sampled by USEPA. The sample
results indicated that high levels of TCE existed in well PF-1.
The data also indicated that high levels of TCE, degradation
products of TCE, e.g., cis 1,2-DCE, and other VOCs existed in the
R-series of monitoring wells and other nearby wells.
The Raymark Site was proposed for the NPL in June 1988 and
promulgated on the NPL in October 1989.
The case resulting from USEPA's complaint filed in 1985 was tried
in the United States District Court for the Eastern District of
Pennsylvania in May 1987. Before a decision was rendered, and in
late 1988, a settlement was reached between the United States
(USEPA)(Plaintiff), Hatboro Borough Authority (Plaintiff-
Intervenor), and Raymark Industries, Inc., Raymark Formed
Products Company, Penn Fasteners, Inc. and two individual Site
owners (defendants). The terms of the settlement were eventually
embodied within a Consent Decree judicially entered in February
1989. The Consent Decree obligated the settling defendants to
pay for treatment units to be installed at Hatboro wells #16 and
#2 (H16 and H2) respectively located along Earl Lane and
Montgomery Avenue in Hatboro (refer to Figure 3).
The Consent Decree required Hatboro Borough Authority to
implement a work plan which was attached to the Consent Decree.
The work plan included tasks which would provide the necessary
information to properly design treatment units at public supply
wells.
Once the work plan is fully implemented, wells H16 and H2, which
are not currently operated by the Hatboro Borough Authority,
would be equipped with air stripping towers and could be returned
to routine operation. The air stripping towers would reduce
ground water contaminant levels below enforceable standards under
-------
LEGEND:• • ANGLE BORINGS
9 • STRAIGHT BORINGS
Figure 8. Noveober 1986 USEPA Sample Locations
-------
the Safe Drinking Water Act. The standards (Maximum Contaminant
Levels or MCLs) are set at levels which eliminate or reduce
dangerous health effects from exposure to the contaminants. For
example, the MCL for TCE is 5 ug/1 (ppb). In addition, under the
Consent Decree, air emissions controls may be installed on the
air stripping towers at wells H16 and H2 if the risks posed by
the air emissions present an unacceptable risk to the nearby
population as estimated by modelling.
Additional ground water investigations were completed by USEPA in
1990 and 1991. Several ground water monitoring wells were
installed at the Site in an effort to provide information which
USEPA could use to best design a ground water recovery and
treatment system to address the most contaminated ground water
beneath the Site. In a Record of Decision issued by USEPA in
September 1990 for OU2 and OU3, USEPA selected on-Site ground
water recovery and treatment as the alternative to remediate
contaminated ground water. Because of the terms of the Consent
Decree, USEPA was precluded from seeking additional funds from
the settling defendants for implementation of the remedy embodied
within the ROD for OU2 and OU3.- Thus, USEPA has waived the
procedures for special notice and negotiation and has proceeded
to implement the ground water remedy using Superfund money.
A Remedial Investigation and Focused Feasibility Study (RI/FS)
for contaminated soil and bedrock (source area) was initiated at
the Site in December 1989 and completed in June 1991. The
primary purpose of the RI/FS was to: l) characterize the nature
and extent of contamination in the soil, bedrock and sediments
related to the Raymark facility, 2) assess potential human health
and environmental risks posed by the Site, and 3) develop and
evaluate potential remedial alternatives.
During the RI/FS a soil gas survey was conducted. A soil gas
survey allows measurement of the amount of VOCs in the air
located within the pore space of the soil. The soil gas results,
once contoured, provide an indication of the areas of soil which
most likely contain elevated levels of VOCs.
After the soil gas survey was completed, samples of soil were
collected from the uppermost soil layers to provide information
on the levels of contaminants to which an individual may be
exposed through contact with the soil. The analytical results
are discussed in Section V, "Summary of Site Characteristics".
Samples of soil were then collected from areas of subsurface soil
with elevated levels of TCE, as determined by the soil gas survey
and previous investigations, and from areas intended to provide
better definition of the extent of contaminated soil. Thus, the
soil sampling program in the RI/FS was designed such that earlier
sampling efforts (e.g. November 1986) were not duplicated. The
-------
analytical results indicate that the soil beneath the Site
contains elevated levels of TCE thereby confirming earlier
sampling results. The soil sampling results also confirm that
the extent of soil contaminated by high levels of TCE is limited
to the areas near the former TCE tanks and lagoons. A more
complete discussion of the sampling results is contained within
Section V, "Summary of Site Characteristics", of this ROD.
A pilot-scale treatability study was conducted in 1990 to
evaluate the effectiveness of soil vapor extraction (SVE) as a
remedial technology for the Site. During the SVE treatability
study, a vacuum was applied to several boreholes at the Site to
remove contaminated air from .the soil. After several weeks of
testing at various holes, more than 200 pounds of TCE were
removed from the subsurface. A more complete discussion of the
SVE treatability study is contained in Section V, "Summary of
Site Characteristics", and Section VII, "Alternatives".
Because the Raymark Site has a long history of environmental and
chemical characterization studies pre-dating the RI/FS, USEPA
also utilized the results of the previous investigations,
primarily soil and bedrock sampling data from 1986, to scope the
RI/FS and to supplement the information USEPA relied upon to
develop potential remedial alternatives. The documents USEPA
used to develop remedial alternatives for OU1, including the
Remedial Investigation Report and the Focused Feasibility Study
Report, are contained within the Administrative Record file.
To simplify and expedite Remedial Action at the Site, which
includes construction of the remedies selected for the Site,
USEPA divided the Site into three manageable components or
operable units. The three operable units are:
1. Operable Unit 1 (OU1) - Soil/Source Control;
2. Operable Unit 2 (OU2) - Drinking Water; and,
3. Operable Unit 3 (OU3) - Ground Water.
Due to the large amount of available ground water data, USEPA
prepared a baseline risk assessment and Focused Feasibility Study
for contaminated ground water in July 1990 and selected remedies
for OU2 and OU3 in a ROD issued in September 1990.
USEPA completed a baseline risk assessment for contaminated soil
in July 1991. The risk assessment quantified the potential risks
posed by the Site through various exposures to Site-related
contamination. The results of the risk assessment are contained
within Section VI, "Summary of Site Risks", of this ROD.
8
-------
USEPA completed an ecological assessment in July 1991. The
results of the ecological assessment are discussed in Section V,
"Summary of Site Characteristics" and Section VI, "Summary of
Site Risks".
USEPA completed a Focused Feasibility Study (FFS) addressing the
contaminated soil and bedrock (source area) in July 1991. The
FFS evaluated alternatives to clean up or control the source of
ground water contamination beneath the Site. The FFS developed
and evaluated remedial alternatives in accordance with the
requirements of Section 121 of CERCLA, 42 U.S.C. § 9621, which
reguires that Superfund remedial actions comply with applicable
or relevant and appropriate requirements of federal and state
environmental laws, and the NCP (40 C.F.R. Section
300.430(e)(9)(iii)), which requires that each remedial
alternative be evaluated against nine criteria.
III. Highlights of Community Participation
USEPA has several public participation requirements that are
defined in Sections 113(k)(2)(B), 117(a), and 121(f)(1)(G) of
CERCLA, 42 U.S.C. §§ 9613(k)(2)(B), 9617(a), and 9621(f)(1)(G).
The documents which USEPA utilized to develop, evaluate, and
select a remedial alternative for the Raymark Site were sent to
the information repository, located at the Union Library of
Hatboro, on July 18, 1991. These documents make up the
Administrative Record file for the Site. The Administrative
Record is a compilation of documents, required by Section 113 of
CERCLA, 42 U.S.C. § 9613, which USEPA used to support the
selection of a remedy for the Raymark Site.
A Proposed Plan for OUl, which described USEPA's preferred
alternative, as well as other alternatives, for remediating
contaminated soil and bedrock, was released to the public on July
18, 1991. The Proposed Plan, which states the availability of
the Administrative Record, was also sent to the information
repository. Also on July 18, 1991, USEPA published a notice of
availability of the Proposed Plan and Administrative Record file
in two newspapers of general circulation; Today/s Spirit and the
Philadelphia Inquirer.
The public was encouraged to review the Proposed Plan and
Administrative Record file and to submit comments on any remedial
alternative and USEPA's preferred remedial alternative during a
30-day comment period from July 18, 1991 to August 18, 1991. The
public was given additional opportunity to comment on the
Proposed Plan and Administrative Record file at a public meeting
held at the Hatboro Borough Building on August 8, 1991. At this
-------
meeting, representatives from USEPA answered questions and
received comments about the Site, the remedial alternatives under
consideration and the proposed remedy.
At the conclusion of the 30-day public comment period and on
August 19, 1991, a representative of one of the potentially
responsible parties notified USEPA that the Administrative Record
file was not available for public review at the Union Library
Company of Hatboro throughout the 30-day public comment period.
Thus, to fulfill its responsibilities under Sections 113 and 117
of CERCLA, USEPA reopened the public comment period until
November 6, 1991. A notice of the extension was published in
Today*s Spirit and the Philadelphia Inofuirer.
A stenographic report of the public meeting was prepared by
USEPA. A response to the comments received during the 30-day
public comment period, and the extended public comment period, as
well as the August 8, 1991 public meeting is included as part of
this ROD in the Responsiveness Summary (Appendix A). Community
concerns with the selected remedy are contained within Section
VIII, "Comparative Analysis of Alternatives", of this ROD and
within the Responsiveness Summary*
The index for the Administrative Record, upon which this decision
document is based, is contained within Appendix B. This decision
document is also based upon comments contained within the
stenographic report of the public meeting on August 8, 1991 and
other comments received by USEPA during the entire public comment
period, which are included in the Site file maintained at USEPA's
offices in Philadelphia and which will be added to the
Administrative Record file.
Appendix c contains a glossary of terms used in this ROD which
may be unfamiliar.
IV. Scope and Role of Operable Unit 1
To simplify and expedite Remedial Action at the Site, USEPA has
divided the Site into three manageable components or operable
units. The three operable units are:
1. Operable Unit 1 (OU1) - Soil/Source Control
2. Operable Unit 2 (OU2) - Drinking Water Supply
3. Operable Unit 3 (OU3) - Ground Water
The response action in this ROD addresses a remedy for
contaminated soil and unsaturated bedrock (source area) at the
Site (OU1). The TCE-contaminated soil and bedrock constitute a
principal threat at the Site due to the high levels of TCE found
10
-------
in the soil and bedrock, the highly mobile nature of TCE in the
subsurface soil and bedrock, and the probable presence of TCE as
Non-Aqueous Phase Liquid (NAPL). NAPL can be simply defined as
TCE which has not yet dissolved into the ground water. Other
VOCs were also identified in the soil. Since these other VOCs
were not detected as frequently as TCE, were detected at levels
much lower than the detected levels of TCE, and migrate similar
to TCE, the areal extent of TCE contamination, discussed in
Section V, "Summary of Site Characteristics", is used to define
the area of soil and bedrock requiring remediation. The remedy
selected for cleanup of TCE-contaminated soil and bedrock would
also effectively remediate soil contaminated by other VOCs.
The NCP (40 CFR Part 300.430) states that the general goal of the
remedy selection process is to select remedies that are
protective of human health and the environment, that maintain
protection over time, and that minimize untreated waste. In
addition, Section 121 of CERCLA, 42 U.S.C. § 9621, includes
general goals for remedial actions at all Superfund sites. The
goals include; achieving a degree of cleanup which assures
protection of human health and the environment (Section 121(d))>
preference for selecting remedial actions in which treatment that
permanently and significantly reduces the volume, toxicity, or
mobility of contaminants is a principal element (Section 121(b)),
and requiring that the selected remedy comply with or attain the
level of any applicable or relevant and appropriate requirements
of federal or state environmental laws (Section 121(d)(2)(A)).
The primary objective of the remedy for OU1 is to control the
continued migration of contamination from the Site, i.e., source
control. Thus, the remedial objectives of OU1 include protection
of public health while preventing the further migration of
contaminants from the soil and unsaturated bedrock into the
ground water beneath the Site. Achieving the primary objective
would thereby eliminate or significantly reduce one of the
sources of contamination to the regional aquifer.
The Site-specific remedial response objectives, which take into
consideration the level of contamination and the risks posed by
the contamination, are identified in Table l.
11
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TABLE 1
SITE SPECIFIC REMEDIAL OBJECTIVES
FOR OPERABLE UNIT 1
1. Protect public health and the environment
2. Reduce amount of contamination in subsurface soil
and bedrock such that leaching of contamination to
ground water is minimized
3. Minimize leaching of residual contamination to the
ground water such that levels of TCE in ground water do
not exceed 5 ppb or background, whichever is lower, as
defined in the ROD for OU2 and OU3
4. Reduce the risk resulting from release of
contaminants into the air from treatment devices
The remedy selected in this ROD addresses each of these
objectives. To the maximum extent practicable, the remedy
selected for OU1 is consistent and compatible with the remedies
selected for OU2 and OU3. USEPA believes that the remedies for
OU2 and OU3 selected in a previous ROD and the remedy for OU1
selected in this ROD are flexible enough to accommodate any
possible modifications that may be required to optimally operate
each remedy and afford the best remediation of the Site. In
addition, USEPA believes that components of the remedies selected
for OU2 and OU3 would be necessary to efficiently address the
contaminated source area, e.g., components of OU2 or OU3 would
enhance remediation of the source area.
V. Summary of site Characteristics
All Hatboro residents connected into the public water supply
system, nearly 7500, could be potentially exposed to ground water
contaminated by the Raymark Site. However, existing treatment
systems at contaminated public wells remove VOCs before delivery
to the public.
The complexity of the aquifer, i.e., the existence of several
water zones, extensive pumping at public wells, differential
weathering of bedrock, and fractured bedrock, makes it extremely
difficult to separate contamination and determine its source.
Thus, it may not be possible to track a "plume" of contamination
12
-------
from the Site for significant distances beyond the source areas.
However, since water level studies indicate that pumping at
public wells causes ground water levels at the Site to decline,
it is logical to conclude that the Hatboro public wells most
likely pump ground water that originated beneath the Site. USEPA
has therefore determined that contamination beneath the Site is a
source of contamination to Hatboro's public wells.
Three areas of the Site have been identified as sources of TCE
contamination to the ground water. These areas are: l) the
lagoon area, 2) the solvent storage tank area, and 3) the
degreaser area (refer to Figure 2). The solvent tanks, which
were historically located outside the manufacturing building, are
adjacent to the area inside the manufacturing building where
degreasing operations occurred. Thus, the solvent storage tank
area and the degreasing area can be considered to be the same.
The results of the soil gas survey, the RI/FS, and the November
1986 sampling of soil and bedrock beneath the Site, discussed in
this section of the ROD, confirmed these source areas.
Figure 9 depicts the results of.the soil gas survey conducted
during the RI/FS. The soil gas measurements were collected from
an approximate depth of 3 feet below the ground surface. The
contoured data indicate that elevated levels of TCE exist in the
area of the lagoons and the area near the former TCE storage tank
and degreaser. The maximum concentration of TCE detected in soil
gas was 252 ppm near the area of the former TCE storage tank.
The soil gas survey results also suggest that the TCE-
contaminated soil gas has migrated from the source areas in a
northeast-southwest direction. The contaminated soil gas
readings distant from the source area have most likely resulted
from migration of contaminated vapors within soil pore space,
bedrock bedding planes or fractures, or from contaminated vapors
moving up from the contaminated ground water below. In either
case, the areas of elevated soil gas readings distant from the
confirmed source areas do hot necessarily represent areas of soil
contamination which require remediation. Subsequent soil
sampling indicates, for example, that the area of elevated soil
gas readings within the parking area southwest of the
manufacturing building does not correlate with an area of highly
contaminated soil.
Figure 10 depicts the locations of surface soil samples collected
during the RI/FS. These samples were collected from the upper
six inches of soil. Figure 10 also depicts the results of
organic analysis of surface soil samples. The analytical data
indicate that semivolatile organic compounds, primarily PAHs, are
the primary contaminant within the surface soil. PAHs, which
result from the incomplete combustion of organic matter, were
found at the Site at levels which exceed typical background
levels. Low levels of pesticides, e.g. 4,4-DDT, were also
13
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1. SOIL CAS SUKVl
CONCENTRATIONS CONTOURS TCC
(LOG IN PPB) 1
DECEMBER 1M9
-------
LE RO
JACKSO
1
e
5
9
Ualhylnaphthalana
Acanaolhylana
DtMniofuran
AnUracana
Pyrana
Bwuo (!) anthracana
Chrytana
B*fito (b) lluoro«nth*n*
Bwizo (k) rkioroanllMn*
Bwuo (a) pyran*
Indano (1Z3 cd) pyrana
Banzo (g h I) patylana
I'OJ
210 J
«OJ
3000 J
4*0 J
MOOJ
8100 J
1 1 00 J
MOOJ
0000 J
8BOO J
3400 J
2100 J
-^
Ug«nd:
A Suriac* wril Mmplt tocMhm
MH Itonhoto
Sample Date: December 1989
AH concentration* In ug/kg-
Sou umpl* locjUoni m approilmal*.
J- Analyt* PTMXII. Rtporttd valu* may not b* iccural* or pr«cli«.
60
120 180 FEET
M~^:~ ~:::"')
Figure 10.
BASE NEUTRALS ACID EXTRACTABLES,
PESTICIDES AND PCBS IN SURFACE SOILS
RAYMARK
-------
detected in one area of the Site, but are not attributed to site
operations. Soil samples were also analyzed for metallic
elements. The results of sampling for metals indicate that
cadmium is elevated in some areas of the Site and nickel is
elevated at one location. Cadmium and nickel can be attributed
to past Site electroplating operations.
samples of subsurface soil were analyzed in accordance with three
different analytical methods: 1) Routine Analytical Services
(RAS), which is USEPA's standard analytical procedure, 2) medium
detection level, and 3) methanol preservation. The standard
procedure simply involves placement of the sample in a jar,
possibly along with water. In the medium detection level method,
the analyzing laboratory is notified that the sample may contain
high levels of contaminant so that the analytical instruments can
be properly adjusted. In the methanol preservation method, the
soil sample is submerged in methanol before analysis. Since all
of the TCE in soil analyzed by the methanol preservation method
would move into the methanol, which is then analyzed, the
analytical result depicts the total (absolute) concentration of
TCE in the soil sample and not necessarily the amount of TCE that
would leach to ground water or the amount that could be
remediated. The amounts of TCE detected in the standard
analytical method and the medium detection level method are
closer to the actual value which may leach to ground water or
become available for remediation.
The highest level of TCE identified in the subsurface soil was
detected in a sample collected from a soil boring, completed in
November 1986, which angled beneath the manufacturing building in
the degreasing area/solvent storage tank area (location
identified as A-3 on Figure 8). The amount of TCE detected in
this sample (identified as A3-5'-7') was 3,100,000 ug/kg (ppb).
The concentration of TCE detected in the soil beneath the
degreasing area/solvent storage tank area utilizing standard
analytical methods was 9200 ppb.
During the RI/FS, subsurface soil samples were collected further
away from the degreasing area/solvent storage tank area in an
effort to determine the possible extent of the contaminated area.
The highest concentration of TCE detected in soil further from
the degreasing area/solvent storage tank area using the methanol
analytical method was 270 ppb and TCE was not detected using
standard analytical methods. This sampling therefore
demonstrates that the extent of TCE contamination in the vicinity
of the degreasing area/solvent storage tank area is limited to
the soil immediately beneath and/or adjacent to the manufacturing
building. Figure 11 depicts the locations of the subsurface soil
samples collected during the RI/FS and the results of the
analysis of the sample with the highest probable VOC
concentration as determined by field screening.
14
-------
I
e
* JACKSONVILLE ROAD
U~
Notes: AUconce
SoUbortai
J Ansrytep
L Anetylep
B Notdetec
NO Notdetec
— Sample n
RAS Routine i
METH Methsnol
MED Medium k
Total 1.2
\
V
\
\RAS METH MED
TCE — NO 1JOJ
: JL fc
TCE - 40 J NO
CMorolonn — NO MJ
A 8-9 -. ' ' V awa
VL
Vi ^ f 1
f __ r-» HAS METH MEO H -J
\ . Ct-L/VJ TCE - M J NO |L . •*! I
Ch|or9|onp - NO 770J IpXTNi f
••-r RAS METH MEO 1 ' ' ^^ B-/! H
CMorolonn NO NO 270 J 1 / B-6 y — B-4 A
0 B-1 A
1 S*'
1 B-^ A^
-3 A I
1— X— ' —1
A*.
/ r-r HAS METH MEO \
/ TCE 7B 130 J MJ \
I Cto-U-DCE NO* MJ NO \
\ ,,__ .,_. I Chtarolonn NO ND enj \
^ y v r i >
I J 0
^^s. ^x / ^^«»T •••/ewe!
\ ^ ^ AB-10--^
T-r HAS METH MED ****!
TCE 11 — — c
•a a — —
ig tocatlotn •«• •poraximeie. UH S!!.^!!."8 loca>
mewd. Reported analyte may not be accurate or precise.
reeenl. Reported value may be biased km. Actual value Is expected to be higher.
ted aubatenlleOy ebooe the level reported in laboratory Held blanks.
ted.
at snlyied el IMe depth by this method.
malytlcal service.
method.
tvel method. ° ^ 12(-
8 i 1
B V-I RAS METH MEO
S ^TCE • WJ 10J
i /^PCE 11 10 J NO
. ^ qif-1.2-OCE NO 10 J NO
/
T_ e"G
~~l —
T-4- RAS METH MEO
TCE 52 L 2400 290 J*
Cts-I.J-OCE »f MJ NO
*=. »<-. X
s~"~ \
r \ aiwn.
4 'r RAS MTTH
TCE 7,000 L ,0taoo
5/DG 4« 40J
*-**""* Xylenes n NO
1 A4 • Trlmethylberuene NO 2H J
Os-U-OCE no- ,MJ
NapmaiMw MQ 2/0 J
N-MyfteVUMM no I60J
Chlorotonn up ^p
N - Propytjeruene NO NO
P - lsopropy«okiene NO NO
Sec • Butytj«niene NO NO
1011 •"-•• HAS METH
TCE 440 L _
MEO
S4.000
1MJ
NO
1.700
1MJ
1.100
1,400
710 J
MJ
110J
230 J
270 J
MEO
1
1
Figure II a
.nncccT VOLATILE ORGANICS IN
I80 FEET SUBSURFACE SOILS
RAYMARK
-------
\
\
VOCa NO
BNAEa 1M
OBOu NO
PCS. NO
» —
i
i
^
VOCa
BNAEa
PCBe
X^ MM
NO
$70
NO
NO
AB-S
•M
1
1
, . r
V
V
VOCa
OMAC.
PCte
]
NO
NO
f
s
\
1
!*!
•-»
1
BNAE. NO
PCB» • 2.100
|—V-
oua 1 \
i i N
&
•—I a
^ h-
T~
1
8-1 A
~T 1
1 1
"ll 1
-21 A |
J 1
1 ,
I
B-3A-
I
-— I Tl
1 J laNAEs 1.200
iPMictdn NO
PC8» NO
EL2G
A Sol boring location
biugyhg.
M» nwta tor the MOiple wtth in* nuxlmum
ta «ctt boring KiMfMCtN* el itaplli.
VoMlto iwuta M* taM« MI HAS mHyito.
Sod bortng looUon* an ^fnataut».
R««uMi »IM U, UU UJ. and • qiMlMlw* w*ra not Included In totals
Estimated total TICS »• not Induocd in in* total*.
180 FEET
Figure II D
TOTAL CONCENTRATIONS OF VOLATILE
ORGANICS, BASE NEUTRALS ACIO EXTHACTABLES
PESTICIDES. AND
PCBS IN SUBSURFACE SOILS
RAYMARK
-------
In November 1986, elevated levels of TCE were also identified in
samples collected from the center of and near the four lagoons.
The highest level of TCE detected was 130 ppb using standard
analytical methods. During the RI/FS, a soil sample collected
from the southwest corner of the lagoon area from a depth of 4 to
6 feet contained 54,000 ppb of TCE using the methanol method and
7000 ppb using standard analytical methods. Based upon November
1986 sampling and RI/FS sampling, the extent of TCE-contaminated
soil in the vicinity of the four former lagoons is more
widespread, but at lower concentrations, than contamination near
the degreasing area/solvent storage tank area.
Samples of bedrock were collected only during the November 1986
sampling event. The highest concentration of TCE detected in the
bedrock was 210,000 ppb from weathered rock beneath the
degreasing area/solvent storage tank area, using methanol
analytical method, and 16,000 ppb from bedrock located beneath
the location of the former lagoons, using standard analytical
methods. The area of TCE-contaminated bedrock is difficult to
precisely establish since the TCE most likely moves within
discrete pathways, e.g. fractures, within the bedrock. To
conservatively estimate the extent of contamination, USEPA
assumed that the surface area of contaminated bedrock is
equivalent to the surface area of contaminated soil and the depth
of contaminated bedrock extends to the water table.
In addition to TCE, other VOCs, including tetrachloroethene
(perchloroethene or PCE) and dichloroethene (DCE) were detected
in the subsurface soil beneath the Site. These other VOCs were
detected at concentrations which were much lower than TCE. It is
important to consider that remediation of TCE would also
accomplish cleanup of other VOCs at the Site.
Low levels of PCBs, identified as Arochlor 1260, were also
detected in the shallow subsurface soil (0'-27) within the
backfilled lagoons. PCB contamination is not attributed to Site
operations.
Table 2 depicts a summary of contamination in soil and bedrock
samples collected from the Site. Appendix D contains a summary
of all analytical data obtained during the RI/FS and the November
1986 soil and bedrock sampling.
15
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MEDIA
[Analytical
Method]1
TABLE 2
SUMMARY OF CONTAMINATION
# # CONCENTRATION
Contam. SAMPLES DETECTED RANGE AVERAGE
(PPb)
Surface
Soil
TCE
PAH
Pest . 3
Cd
11
11
11
11
3
6
2
11
ND2-18
ND-58,870
ND-426
1600-78,600
9
1363
283
26,000
Subsurface
Soil
[624]
[Meth]
TCE
TCE
TCE
TCE
(RIFS)
(1986)4
(RIFS)
(1986)
14
16
11
9
5
9
8
9
ND-700O
ND-9200
ND-10,000
2400-3,100,000
1502
1370
1656
429,844
[Ned]
Unsat.
Bedrock
[624]
[Meth]
TCE (RIFS) 11
TCE (1986) 44
TCE (1986) 4
ND-54,000
9085
8
4
ND-16,000 2094
5300-310,000 134,075
1 Method 624 is standard analytical method. "Meth" is
methanol preservation method. "Med" is medium detection level
method.
2 Not detected.
3 The pesticide was identified as 4,4-DDT.
4 Samples collected by EPA in November 1986.
16
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Detection of TCE in the bedrock indicates that TCE has migrated
from the soil beneath the Site down into the underlying bedrock.
since the ground water table, which can be anywhere from 15 to 60
feet below the ground surface depending on the season and pumping
status of public water supply wells, is within the bedrock
beneath the Site, and no protective layer, e.g., clay, exists
between the soil and ground water table, TCE has migrated into
the ground water system beneath the Site. In fact, high levels
of TCE have been detected in the monitoring wells installed at
the Site.
TCE in the unsaturated zone beneath the Site migrates downward
with infiltrating precipitation. Although some of the
contaminant may adsorb onto organic matter in the soil, some of
the contaminant migrates to the water table either dissolved in
infiltrating precipitation or as a non-aqueous phase liquid
(NAPL), which is TCE which has not dissolved into the ground
water. Once in ground water, TCE moves with local or regional
ground water flow and may flow off-Site. TCE which is not
dissolved into water and is denser than water (Dense Non-Aqueous
Phase Liquid or DNAPL) may migrate vertically downward until an
impermeable layer is reached. TCE residual may then remain in
fractures while slowly dissolving into the ground water.
Utilizing a relatively conservative model (Summers model), USEPA
has calculated the concentration of TCE which in the absence of
any remediation or control could remain in the soil without
causing the levels of TCE in the ground water beneath the Site,
via leaching from the soil, to exceed the ground water
remediation goal established in the ROD for Operable Units #2 and
#3 (Appendix E). In the absence of any remedial measure and
according to the Summers model, the subsurface soil and bedrock
would need to be cleaned to an approximate TCE level of 4 ppb in
order to protect ground water to the MCL of 5 ppb. In order to
protect ground water to a background level (assumed to be the
level of detection of TCE in ground water, or 0.19 ppb), the
subsurface soil and bedrock would need to be cleaned to a TCE
level of 0.15 ppb. These levels of cleanup are not detectable
using available soil analytical methods. In addition, available
evidence strongly indicates a background level which is higher
than 5 ppb.
Infiltration of precipitation through the contaminated soil is
the primary reason that TCE in the soil and bedrock presents a
risk to the ground water. As infiltrating water passes the
contamination, some of the contaminant may dissolve into the
water and then move down to the water table. Although some
contaminant may adsorb back onto a particle of soil, some
contaminant most likely enters the ground water system. Ground
water sampling conducted at the Site suggests that the soil and
bedrock continue to leach TCE into the ground water system. In
17
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some wells, the higher levels of TCE are found in the deeper
ground water levels. This may indicate that the TCE moved
vertically downward as DNAPL.
The contaminant detected most frequently and at the highest
concentrations in on-Site soil, bedrock, and ground water is TCE.
TCE is a volatile organic compound which USEPA considers to be a
class B2 probable human carcinogen. The classification means
that animal, and not human, data were used to determine that TCE
is carcinogenic. TCE tends to breakdown or degrade over time
into other VOCs including cis 1,2-dichloroethene (cis 1,2-DCE),
trans 1,2-dichloroethene (trans 1,2-DCE), 1,1-dichloroethene
(1,1-DCE) which is a Class C, possible human carcinogen, and
vinyl chloride (VC) which is a Class A, known human carcinogen.
Cis 1,2-DCE was identified in soil and ground water at the Site.
Tetrachloroethene (perchloroethene or PCE) was also frequently
detected in soil and ground water.
The only metal which appeared to be elevated in more than one on-
Site surface soil sample was cadmium. However, cadmium was not
elevated in subsurface soil or ground water. Nickel and lead
were each elevated in one on-Site surface soil sample, but were
not elevated in subsurface soil or ground water. In addition,
lead contamination is not attributed to past Site operations.
Although some ground water samples collected from well PF-1
contained elevated levels of lead, i.e. above the MCL, the
elevated values occur in unfiltered samples and duplicate samples
contain low levels of lead or non-detectable levels of lead. It
is important to note that a nearby abandoned water supply well
contains significant levels of inorganic contaminants, including
lead.
The bedrock beneath the Raymark Site consists of fractured
sandstones, siltstones, and shales of the Stockton Formation.
Figure 12 is a geologic cross section depicting the types of rock
found beneath the Site. A fracture can be considered to be any
planar break in the rock. Ground water and contaminants move
predominantly through the fracture system and through areas of
bedrock in which the matrix (cement) which holds the individual
minerals together, has weathered or dissolved leaving a large
amount of intergranular pore spaces through which ground water
and contaminants may flow.
As TCE moves from the soil into the underlying bedrock it would
preferentially migrate in the fractures within the bedrock. If a
sufficient amount of TCE migrates into the bedrock it may move as
a non-aqueous phase liquid (NAPL) following the bedrock fractures
and moving deeper into the aquifer instead of laterally with the
flow of ground water due to its density. Since the density of
TCE is greater than that of water, the downward movement of TCE
is exacerbated. Ground water sampling from deep downgradient
18
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_ Waata Traatmtnt
*f**^m*dtng
Lagoons
State and siltstOM
rHM
A1 toffng toemon
PF1
Source:
Stockton PoRMtton
Mlehul Taytor Towl, 1M7
Flgura 12.
UTHOSTRAT1GRAPHY OF THE
MIDDLE ARKOSE MEMBER OF THE
STOCKTON FORMATION NEAR
MONITORING WELL PF-1
RAYMARK FOCUSED FS
-------
monitoring wells at the Site, which contain higher levels of TCE
than shallow downgradient monitoring wells, suggests that, in
some areas, TCE may have migrated from the source area as a
DNAPL. Although the evidence is indirect, the existence of DNAPL
may present a problem since it is extremely difficult to
remediate.
The bed and banks of the Pennypack Creek contain wetland areas.
Obligate wetland species, e.g. species which exist only in
wetland areas, and facultative wetland species, e.g. species
which can adapt to different environmental conditions, were
identified by USEPA in the Pennypack Creek bed and immediate
floodplain. The majority of the wetland areas were located
downstream (south) of Hatboro since the streams run primarily
through residential yards, commercial properties, and/or
developed park areas within the Borough. Wetland species were
also identified near the Site in the drainageways which drain the
Site and surrounding industrial and residential areas.
Figure 13 depicts the locations where samples of water and
sediment were collected from Pennypack Creek and the storm drains
which pass water originating on the Site. The Creek sample was
collected from a location which is upstream from the area which
could be impacted by the Site. The analytical data (see Appondis
D) indicate that the contaminants found within the storm drain
area are similar to those found within the Creek. USEPA has
concluded that the Site has not impacted the Pennypack Creek.
The results of water and sediment sampling collected from
Pennypack Creek and an evaluation of the possible pathways for
migration of contaminants from the Site to the Creek, led USEPA
to determine that Cr$ek contamination is not attributable to the
Site and Site activities should not affect the wetland areas.
Pigura 5 depicts the locations of places and structures of
potential historical or archeological significance. Although the
Site has not impacted these features and places, USEPA would
ensure that the remedy selected for OU1 would not impact
historical or archeological features.
Based upon consultation with federal and state authorities and a
survey conducted at the Site, no potentially threatened or
endangered species were identified near the Raymark Site.
19
AR30I972
-------
Legend:
Approximate surface water/
sediment sampling locaions
FLOODPLAIN CONSERVATION DISTRICT
100 YEAR FLOOD BOUNDARY
Soutct lor Ftoo
-------
VI. Summary of Site Risks
The first part of this section of the ROD discusses risk
assessment terminology and methods in order to better understand
the presentation of the risk posed by the Site in the latter part
of this section. The uncertainty inherent within the
quantitative assessment of risk is discussed at the end of this
section.
The potential risks posed by a Superfund site if no remedial
action were taken are calculated in a baseline risk assessment.
A baseline risk assessment for the contaminated ground water at
the Raymark Site was completed by EPA in 1990. A baseline risk
assessment for the contaminated surface and subsurface soil was
completed by EPA in July 1991 as part of the recently completed
RI/FS for the source area.
Surface soil is defined as the uppermost 6 inches of soil and
represents that portion of the soil column to which an individual
would most likely be exposed through contact or ingestion.
subsurface soil means all soil from ground surface to bedrock.
The baseline risk assessment for surface and subsurface soil
evaluates the potential risks posed if an individual is exposed
to soil at the Site. Since it is unlikely that anyone will be
exposed to bedrock beneath the Site, since it is buried by
several feet of soil, it was not evaluated. Since the
contamination in the sediments within Pennypack Creek are not
attributable to the Site, the risks potentially posed by exposure
to contaminated Creek sediments also were not evaluated.
Contaminants which: 1) present a potential risk to human health
and the environment at the detected concentrations; 2) originated
from the Site or could have originated from the Site, e.g.,
degradation products of TCE; and 3) were above background levels,
are considered to be contaminants of concern for the Site. The
contaminants of concern in the soil are identified in Table 3a.
Contaminants in Table 3a are related to Site operations and were
detected at least once in ground water and subsurface soil
suggesting that they are relatively mobile in the environment.
Table 3b lists soil contaminants which may be related to Site
operations and contribute to the overall risk posed by the Site
and contaminants which are not related to the Site, but
contribute to the overall risk posed by the Site. It is
important to consider that the risk posed by the soil
contaminants within Table 3b is within USEPA's acceptable risk
range defined within the NCP (40 C.F.R. S 300.430(e)(2)). PAHs,
cadmium, and nickel may be related to past Site operations.
PCBs, pesticides, arsenic, beryllium, and vanadium are not
related to past Site operations. Each of the contaminants in
20
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Table 3b is relatively immobile in the environment as
demonstrated by the absence of elevated levels of these
contaminants in deep soil or ground water.
The contaminants of concern listed in Table 3a differ from those
listed within the Risk Assessment Report. The contaminants of
concern listed within the Risk Assessment Report include all
organic chemical compounds detected at the Site and inorganic
compounds which may be related to background, regardless of the
risk posed.
TABLE 3a
CONTAMINANTS OF CONCERN
IN SOIL
Contaminant Maximum Concentration
TCE (refer to Table 2)
PCE 180 ppb
1,2-DCE 150 ppb
TABLE 3b
OTHER CONTAMINANTS IN SOIL
ContaminantMaximum Concentration
PAHs
Benzo(a)Pyrene 6900 ppb
Benzo(a)anthracene 5100 ppb
Benzo(b)fluoranthene 6300 ppb
Benzo(k)fluoranthene 6600 ppb
Ideno(l,2,3cd)pyrene 3400 ppb
Benzo(g,h,i)perylene 2500 ppb
Phenanthrene 3700 ppb
Fluoranthene 9600 ppb
Pyrene 9100 ppb
Chrysene 5400 ppb
PCBs
Arochlor 1254 2100 ppb
Pesticides
4,4 - ODE 76 ppb
4,4 - DDT 350 ppb
Cadmium 78,600 ppb
Nickel 755,000 ppb
Arsenic 7,900 ppb
Beryllium 1,700 ppb
Vanadium 40,400 ppb
21
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A contaminant presents a potential risk to human health if its
concentration exceeds the IxlO"6 (1 extra chance in 1,000,000)
excess cancer risk level for cancer-causing compounds or the
maximum safe dose for non-cancer effects, i.e. a Hazard Index
(HI) greater than 1.
An excess lifetime cancer risk of lxlO~6 indicates that, as a
plausible upper bound, an individual has an additional one in one
million chance of developing cancer as a result of Site-related
exposure to a carcinogen over their entire lifetime. This risk
exists in addition to the risk posed by all other sources, e.g.,
30,000 extra chances out of 1,000,000 of contracting cancer from
smoking.
Cancer potency factors (CPFs), also called slope factors, have
been developed by EPA's Carcinogenic Assessment Group for
estimating excess lifetime cancer risks associated with exposure
to potentially carcinogenic (cancer-causing) chemicals. CPFs,
which are expressed in units of (mg/kg-day)"1, are multiplied by
the estimated chemical intake of a potential carcinogen, in
mg/kg-day, to provide an upper bound estimate of the excess
lifetime cancer risk associated' with the exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. It is a statistical term
related to the degree of certainty of the data used to calculate
the CPF. Use of this approach makes underestimation of the
actual cancer risk highly unlikely. CPFs are derived from the
results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty
factors have been applied. CPFs for the contaminants of concern
at the Site, as well as the models from which the CPFs were
obtained are referenced within the risk characterization tables
in Appendix F.
USEPA has represented the toxicity of individual PAHs with no
known CPF in terms of a toxicity equivalence factor (TEF) to the
CPF of benzo(a)pyrene. This is a conservative asumption since
benzo(a)pyrene is a potent carcinogen. The TEFs are multiplied
by the CPF of benzo(a)pyrene to yield a lower, individual CPF.
The TEFs used in the Raymark risk assessment are contained within
Appendix B.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as a hazard quotient
(or the ratio of the estimated chemical intake derived from the
contaminant concentration in a given medium to the contaminants'
reference dose (RFD)). By adding the hazard quotient for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across all media.
22
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Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g. the
amount of chemical ingested from contaminated drinking water) can
be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (to account for the use of animal data
to predict effects on humans). These uncertainty factors help to
ensure that the RfDs will not underestimate the potential for
adverse noncarcinogenic effects to occur. RfDs for the
contaminants of concern as well as the models from which the RfDs
were obtained are referenced within the tables in
Appendix F.
The assessment of risk involves many conservative assumptions
about the amount and likelihood of exposure to contaminants and
the toxicity of the contaminants. USEPA strives to select
protective remedies and thus utilizes risk estimating assumptions
which are somewhat conservative. For example, USEPA assumes that
an individual lives at the same residence for 30 years which
represents the 90th percentile value from a national database for
residential permanence. USEPA utilizes exposure assumptions
which combine to form a reasonable maximum exposure (RME)
scenario. Table 4 depicts those exposure assumptions which were
used to develop the RME scenario for which the highest risk posed
by direct contact with soil at the Site was calculated.
TABLE 4
REASONABLE MAXIMUM EXPOSURE ASSESSMENT ASSUMPTIONS
(Soil Ingestion by Future Resident Toddler)
Ingestion Rate (grams/day) 0.2
Exposure Frequency (days/yr) 168
Exposure Duration (years) 6
Body Weight (kilograms) 16
Averaging Time (years)
Carcinogens 70
Non-Carcinogens 6
Note: Toxicity Equivalent Factors
(TEFs) used to estimate risk
posed by PAHs
23
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Chemical intakes are calculated by combining the amount of
chemical with the duration of the exposure to the environmental
media contaminated by the contaminants of concern. The chemical
intake is an estimate of the amount of the contaminant to which
an individual would be exposed under various exposure scenarios.
Chemical intakes for the RME scenarios are found within the
tables in Appendix P.
Contaminants from the Site which may leach into the ground water,
identified in Table 3a, migrate towards public water supply wells
through the ground water system. Thus, all users of Hatboro's
public water supply system, approximately 7500 people, could be
potentially exposed to Site-related contaminants if ground water
were hot addressed. All contaminants may pose a potential risk
to any individual exposed via direct contact.
Previously, EPA determined that human exposure to contaminated
ground water via ingestion posed a potential carcinogenic risk in
the 10~4 to 10~3 excess cancer risk range. This level of risk
means that 1 person has 100 to 1000 extra chances in 1,000,000 of
contracting cancer as a result of exposure to contaminated ground
water beneath the Site depending upon actual location of the
well.
Based upon an evaluation of ground water analytical data
collected at the Site and modelling, EPA has determined that
contaminants, primarily TCE, in the subsurface soil and
unsaturated bedrock contribute to the ground water contamination
and associated risk through continued leaching into the ground
water system. TCE and other VOCs are generally much more mobile
in the environment than semivolatile organic compounds and
inorganic constituents. For example, elevated levels of
inorganic or semivolatile organic contaminants were not found in
the subsurface soil or ground water indicating that they are not
leaching from the surface soil.
An estimate of the threat to ground water posed by the leaching
of contamination in the soil and bedrock beneath the Site was
calculated using a simple transport model called the Summers
model. The Summers model actually provides an estimate of the
amount of leachate which may reach and mix with ground water
beneath the Site. Once the concentration of the "leachate" and
ground water is determined, the risk posed by ingestion of the
ground water/"leachate" mixture can be calculated. Using the
Summers model, EPA evaluated the potential for TCE to migrate
from the unsaturated soil and bedrock into the ground water. The
model results indicate that the level of TCE presently in the
subsurface soil and bedrock at the Site would leach to ground
water and result in TCE levels in the ground water which are
greater than 5 ppb, which is the MCL for TCE. Other VOCs in the
24
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subsurface soil are as mobile as TCE, but are present at much
lower concentrations. Other contaminants, e.g. PAHs, at the Site
are not mobile in the environment and are not considered to be a
threat to the ground water.
EPA calculated the potential risk posed by direct exposure, i.e.,
dermal contact and ingestion, to contaminated surface soil for
two plausible exposure scenarios. Risk was calculated for the
current situation, e.g. exposure to on-Site workers and child
trespassers, and for a potential future scenario of exposure to
residents living at the Site if the contaminated property were
rezoned and developed for residential use without first being
cleaned. In addition, exposure to subsurface soil was considered
to be possible under a future residential use scenario if
foundation excavation activities resulted in a redistribution of
soil at the Site. The current land use is industrial. EPA
expects that the future land use would be industrial based upon
existing zoning maps. However, since residential property exists
close to the Site, a potential future residential land use was
considered.
Table 5 contains the excess cancer risks greater than IxlCT6
associated with various exposures to contaminated soil assumed
likely to occur at the Site. Table 6 contains the non-cancer
risks with an HI greater than 0.01 associated with exposure to
contaminated soil at the Site. Appendix F contains tables which
include the concentrations of the contaminants posing the risk
and the exposure assumptions for estimating the risks under each
scenario in Table 5.
According to Table 5 and Table 6, the greatest potential risk
posed by exposure to contaminated soil at the Site results from
ingestion of surface soil by a toddler whose family resides on
the Site at some point in the future. The excess lifetime cancer
risk to the exposed toddler would be approximately 6.3xlO~5 (63
in 1,000,000) and the hazard index (HI), which is a measure of
the non-carcinogenic risk, would be 1.2. The risk is due mainly
to PAH contamination (specifically the first 6 PAHs listed in
Table 3b), which accounts for approximately 90% of the
carcinogenic risk, arsenic and beryllium, which account for the
majority of the remaining carcinogenic risk, and cadmium, which
accounts for 75% of the non-carcinogenic risk. EPA assumes that
the toddler ingests 200 mg/day of contaminated soil, 168
days/year, for 6 years. If the same toddler resided at the Site
for an additional 24 years and continued to be exposed (total
duration of exposure of 30 years), the estimated excess cancer
risk would be IxlO'4 (1 in 10,000).
The majority of the Site's potential carcinogenic risk is posed
by exposure to PAH, arsenic and beryllium contamination in the
surface soil and PCS in the subsurface soil. However, the
25
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potential carcinogenic risk is within USEPA's acceptable risk
range as defined in the NCP (and discussed further at the end of
this section of the ROD) especially when the uncertaintites
associated with the Raymark risk assessment, as outlined below,
are considered.
TABLE 5
SUMMARY OF EXCESS CANCER RISKS
RISK RECEPTOR SCENARIO PATHWAY PRIMARY
CONTAMINANT
6.3X10'5
3.8X10'5
3.6X10'5
2.9X10'5
2.3X10"5
2.2X10'5
1.6X10"5
1.6X10~5
1.3X10"5
1.1X10"5
9.4X10'6
4.2X10"6
Toddler
Adult
Adult
Adult
Toddler
Adult
Toddler
Child
Child
Child
Adult
Child
Future
Resident
Current
Worker
Future
Resident
Future
Resident
Future
Resident
Current
Worker
Future
Resident
Future
Resident
Current
Trespass
Future
Resident
Future
Resident
Future
Resident
Ingestion
Surface
Ingestion
Surface
Ingestion
Surface
Dermal
Subsurface
Dermal
Subsurface
Ingestion
Indoors
Ingestion
Subsurface
Ingestion
Surface
Ingestion
Surface
Dermal
Subsurface
Ingestion
Subsurface
Ingestion
Subsurface
PAH
PAH
PAH
PCB
PCB
PAH
PCB
PAH
PAH
PCB
PCB
PCB
26
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TABLE 6
SUMMARY OF NON-CANCER RISK
RISK (HI) RECEPTOR SCENARIO PATHWAY PRIMARY
CONTAMINANT
1.2
0.3
0.2
0.2
0.2
0.1
0.1
0.04
0.03
Toddler
Toddler
Adult
Child
Child
Adult
Adult
Child
Adult
Future
Resident
Future
Resident
Current
Worker
Current
Trespass
Future
Resident
Future
Resident
Current
Worker
Future
Resident
Future
Resident
Ingestion
Surface
Ingestion
Subsurface
Ingestion
Surface
Ingestion
Surface
Ingestion
Surface
Ingestion
Surface
Ingestion
Indoors
Ingestion
Subsurface
Ingestion
Subsurface
Cadmium
Cadmium
Cadmium
Cadmium
Cadmium
Cadmium
Cadmium
Cadmium
Cadmium
In order to make the most informed decision about the need for
remediation based upon the assessment of risk, the uncertainty
associated with the quantitative assessment must be considered.
Typically this consideration is qualitative. Several factors
cause the Raymark quantitative assessment of risk to be overly
conservative. These factors include: 1) consideration of
unlikely future land use, 2) consideration of background
contamination, 3) use of PAH CPFs which may be overly
conservative, 4) no consideration of spatial distribution of
contaminants, and 5) use of maximum concentration rather than
Upper 95% confidence limit value (UCLo5) • Each of these
uncertainties is discussed in the following paragraphs.
27
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The degree of PAH contamination in certain soil samples collected
on the Site is higher than the background level of PAHs. Although
the PAH detection limit for many on-Site samples was high, the
excess cancer risk associated with the high detection limits
under various scenarios is within the 10~° excess cancer risk
range. The degree of arsenic and beryllium contamination on the
Site is not higher than background levels. The level of cadmium
in the surface soil is not statistically different than
background levels, but is elevated in certain areas of the Site,
e.g. near surface soil samples SS-3 and SS-4.
After the risk assessment was completed, USEPA reassessed the
issue of PAH carcinogenicity. Evidence suggests that the oral
CPF will be reduced from 11.5 (mg/kg/day)"r to 5.8 (mg/kg/day)"1.
The Raymark risk assessment utilized the existing and approved
CPF of 11.5 (mg/kg/day)"1. If the assessment were done again it
is probable that the new CPF would be used effectively reducing
the PAH risk values by 50%.
The majority of the non-carcinogenic risk posed by the Site is
due to cadmium in the surface soil. The elevated HI indicated in
the toddler exposure scenario above is due in part to one sample
which contained high levels of nickel in addition to cadmium.
However, the Raymark risk assessment assumed that during the
entire period of exposure, the toddler would ingest soil only
from sample SS-4 (the sample location with the highest
concentration of cadmium) and sample SS-2 (the sample with the
highest concentration of nickel), which is an unlikely situation.
USEPA recommends using the upper 95% confidence limit value
(UCL9^) for the concentration term rather than the maximum as
used in the Raymark risk assessment. The UCL95 is a statistical
estimate of the arithmetic average of a series of data points and
is intended to reflect the maximum concentration which an
individual would reasonably be expected to contact at the Site.
Using the UCLoS instead of the maximum concentration would
probably result in a hazard index less than 1.0 for the toddler.
A UCL95 was not calculated for each contaminant due to the
limited amount of data for some contaminants, e.g. PAHs. To be
consistent, USEPA did not calaculate a UCL^ for any contaminant.
The following factors contributed additional elements of
uncertainty in the risk assessment: 1) some carcinogenic
contaminants at the Raymark Site have been found to cause cancer
in animals only, since human experimental data are not available,
2) CPFs were derived from responses to high doses given to
animals and extrapolated to low doses predicted from
environmental exposures, 3) carcinogenic potency was extrapolated
from animal data to human responses on the basis of dose per
surface area, 4) non-cancer effects were extrapolated from animal
28
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data to humans by a set of protective 10-fold uncertainty
factors, and 5) data on synergism or antagonism among the
contaminants were not available.
In accordance with the NCP (40 C.F.R. Section 430(e)(2)), EPA
strives to reduce the carcinogenic risk posed by a Superfund Site
to within an excess cancer risk range of IxlO"4 to ixlO"6 (l
excess cancer in 10,000 to 1 in 1,000,000) and to reduce the non-
carcinogenic risk to a HI less thah 1. The excess cancer risks
posed by surface soil and subsurface soil depicted in Table 5 are
within EPA's acceptable risk range, especially when the
uncertainties discussed above are considered. The excess cancer
risk posed to an individual who resides at the Site as a toddler
and then as a child and an adult is at the upper end of USEPA's
acceptable risk range (e.g. IxlO"4) , but is an unlikely scenario
considering the probable future land use and the conservative
assumptions. As depicted in Table 6, the HI is less than 1 for
all exposure scenarios except ingestion by a future resident
toddler, which is greater than 1 under one overly conservative
scenario. Thus, USEPA has concluded that remediation of the
surface soil contaminated by PAHs, PCBs, and cadmium is not
necessary.
EPA's ground water risk calculations indicate that the potential
carcinogenic risk posed by contaminated ground water at the
Raymark Site is higher than IxlO"4 and is due primarily to TCE
which leaches from contaminated soil beneath the Raymark facility
and most likely from other sources in the area. According to
sampling data and using the Summers model, USEPA has determined
that the TCE contaminated soil and bedrock beneath the Site
represents a principal threat and contributes to the ground water
contamination. Using a conservative modelling approach, USEPA
has calculated that remediation of soil may result in an
approximate reduction of 50 years in the time for ground water to
be cleaned to levels below the MCL of 5 ppb. Remedial action to
address the TCE contaminated soil and bedrock at the Site, in
accordance with the NCP, is justified.
Based upon consultation with State and Federal agencies
knowledgeable about threatened and/or endangered species in the
Commonwealth of Pennsylvania, EPA has determined that no
threatened and/or endangered species are located within or near
the Raymark Site. In addition, an evaluation of potential
migration pathways from the Site to Pennypack Creek indicates
that Site contaminants have not impacted Pennypack 'creek. An
environmental assessment was performed at the Site to
characterize the resources on and near the Site. Wetland areas
and species were identified in Pennypack Creek and in the urban
drainage passing near the Site. In addition, historical and
archeological resources were identified. No impacts to these
resources were identified.
29
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Actual or threatened releases of hazardous substances from the
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 environment.
VII. Alternatives
This section of the ROD describes the process of screening and
developing remedial alternatives and discusses in detail each of
the alternatives evaluated in the Proposed Plan. Remedial
alternatives are developed which meet the remedial objectives of
this response action.
Screening of Alternatives
Table 7 identifies each of the remedial technologies and process
options considered for contaminated soil. In accordance with the
NCP (40 C.F.R. Section 430(e)(9)(iii)) a total of 6 possible
alternatives were developed from the remedial technologies and
process options identified in Table 7. Table 8 describes each of
the 6 alternatives developed in the FFS to address contaminated
soil.
The significance of the screening exercise is to determine which
technologies and options can best satisfy the remedial
objectives. Each of the technologies and options are evaluated
on the basis of their effectiveness and their ability to be
implemented considering Site-specific conditions. Only those
measures which could conceivably meet the remedial action
objectives, or the majority of them, were further developed into
remedial alternatives. Remedial action alternatives are further
limited to proven and/or innovative technologies and process
options which have been used successfully at other sites.
Description of Alternatives
Based upon the screening and evaluation of potentially applicable
remedial technologies and management or process options and the
requirement within the NCP (Section 300.430(e)(6)) to evaluate a
"No Action" Alternative, the following remedial action
alternatives have been selected for further development and
detailed evaluation:
30
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Table 7,
Results of Initial and Secondary Screening of Technologies for Soils
i
General Response
Action
No Action
Institutional Controls
Containment
; - Capping
Removal
Excavation
Removal
Ground Water Collection
Treatment
- Soil Treatment
Treatment
Solidification/Fixation
Treatment
- Physical
Treatment
- Chemical
Treatment
- In situ
Treatment
- Thermal
Treatment
- Air Emission Controls
Disposal
- Wastewater Discharge
Disposal
• Landfill
Monitoring
Potentially Applicable Process Option
Retain Through
Initial Screening
No Action
Deed Restrictions
Fences
Native Soil
Asphaltic Concrete
Concrete
Clay
Synthetic Membrane
Multilayered Cap
Soil Excavation (Surface and Subsurface)
Extraction Wells
Water Washing (Soils and Bedrock)
Solvent Washing
Pozzolonic Agents
Encapsulation
Flow and Strength Equalization
Adsorption
Air Stripping
Steam Stripping
Critical Fluid Extraction
Thermal Evaporation
Steam/Hot Air Stripping
Soil Vapor Extraction
Soil/Bedrock Bushing
Incineration
Adsorption
Catalytic Conversion
POTW
Surface Water
Retnjection
RCRA Landfill
Non-RCRA Landfill
Soils Monitoring
Ground Water Monitoring
Retain Through
•Secondary Screening
No Action
Deed Restrictions
Native Soil
Asphaltic Concrete
Clay
Synthetic Membrane
Multilayered Cap
Soil Excavation (Surface)
Extraction Wells
Water Washing (Bedrock)
Pozzolonic Agents
Encapsulation
Flow and Strength Equalization
Air Stripping
Soil Vapor Extraction
Soil/Bedrock Flushing
Incineration
Adsorption
Surface Water
Reinjection
RCRA Landfill
Non-RCRA Landfill
Soils Monitoring
Ground Water Monitoring
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Table 8.
Description of Remedial Alternatives
Alternative
Number
Description
1
The no-action alternative calls for no remediation of surface and subsurface soils and unsaturaied
bedrock. Monitoring of Site conditions (soils and ground water) would be implemented. Site
inspections annually and Site reviews every 5 years would be performed. This alternative is
included to provide a baseline condition for comparison with the developed remedial alternatives.
The second alternative addresses contamination in surface soils by excavating soils contaminated
with PAHs, PCBs, and cadmium: stabilizing/encapsulating cadmium-contaminated soils, if needed.
for disposal; disposing of all excavated soils in an off-site RCRA landfill; backfilling the excavation
with clean fill; and restoring the Site. Postexcavation soil samples would be collected to confirm
that all contaminated soils were removed from the Site. VOC contamination in subsurface soils
and unsaturated bedrock would be remediated using SVE. Soil vapors would be extracted using a
system of vacuum wells. The soil vapor would be treated by activated carbon. Any ground water
encountered in the vacuum wells would be pumped out, treated by air stripping followed by vapor
phase carbon, and discharged to off-site surface water. Spent carbon would be sent off-site for
regeneration. Periodic sampling of subsurface soils during the SVE would be used to confirm the
attainment of soil cleanup levels and long-term ground water monitoring would be implemented
to evaluate the effectiveness of remediation. Site reviews would be performed every 5 years.
The third alternative addresses contamination in surface soils by excavating contaminated areas;
incinerating the excavated soils; stabilizing the ash residues, if needed; disposing the residues in a
RCRA landfill; backfilling the excavation with clean fill; and restoring the Site. Postexcavation
soil samples would be collected to confirm that all contaminated soils were removed from the
Site. VOC contamination in subsurface soils and unsaturated bedrock would be addressed as in
Alternative 2. Sampling and Site reviews would be performed as in Alternative 2.
The founh alternative addresses contamination in surface soils by grading and capping the
contaminated areas. The cap may be asphaltic concrete, clay, or a synthetic membrane. Site
reviews would be performed every 5 years because contaminated surface soils would be left on-
site. Subsurface soils and unsaturated bedrock contamination would be addressed as in
Alternative 2. Sampling would be performed as in Alternative 2.
The fifth alternative addresses contamination in surface and subsurface soils at Raymark using the
same components as Alternative 2. Unsaturated bedrock would be treated using bedrock flushing.
This would consist of infiltration trenches excavated to bedrock. Water would be pumped into the
trenches where it would infiltrate into the fractured unsaturated bedrock. The water would flush
out volatile organics that are present in the unsaturated bedrock fractures affected by the system.
The flushed contaminants would be collected by shallow extraction wells in the saturated bedrock.
Contaminated water from the extraction wells would be treated in an air stripper and recycled
back to the infiltration trenches. Emissions from the air stripper would be treated by activated
carbon and the carbon would be sent off-site for regeneration. No sampling of unsaturated
bedrock is included. Long-term monitoring of selected on-site wells is included to evaluate the
effectiveness of remediation. Frequent sampling of on-site wells during implementation is
included to monitor migration of flushed contaminants.
The sixth alternative addresses contamination in surface soil by grading and capping contaminated
surface soil areas to prevent direct contact and maintaining the cap. The cap may be asphaltic
concrete, clay, or a synthetic membrane. In addition, source areas of VOC leaching would be
covered with a cap to limit rainwater infiltration. This cap may consist of native soil, asphaltic
concrete, clay, a synthetic membrane, or a multilayered cap. Cadmium-contaminated soils may
require solidification under the cap. Subsurface soils and unsaturated bedrock would be addressed
as in Alternative 2. Site reviews would be performed every 5 years since contaminated surface
soils would be left on-site. Sampling for the subsurface component would be performed as in
Alternative 2.
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ALTERNATIVE 1 - NO ACTION
ALTERNATIVE 2 - Surface Soil: Excavation/ Stabilization/ RCRA
Landfill; Subsurface Soil: Soil Vapor Extraction; Unsaturated
Bedrock: Soil Vapor Extraction
ALTERNATIVE 3 - Surface Soil: Excavation/ Incineration/
stabilization/ RCRA Landfill; Subsurface Soil: soil Vapor
Extraction; Unsaturated Bedrock: Soil Vapor Extraction
ALTERNATIVE 4 - Surface Soil: Cap; Subsurface Soil: Soil Vapor
Extraction; Unsaturated Bedrock: Soil Vapor Extraction
ALTERNATIVE 5 - Surface Soil: Excavation, Stabilization, RCRA
Landfill; Subsurface Soil: Soil Vapor Extraction; Unsaturated
Bedrock: Flushing
ALTERNATIVE 6 - Surface Soil: Low Permeability Cap; Subsurface
Soil: Soil Vapor Extraction; Unsaturated Bedrock: Soil Vapor
Extraction
Each alternative, except Alternative 1, includes implementation
of soil vapor extraction (SVE) to reduce the level of VOCs in the
subsurface soil and/or bedrock at the Site. Between October and
December 1990, EPA conducted a SVE treatability study at the Site
and concluded that this technology was effective and could be
utilized to remove VOCs from the subsurface soil and bedrock at
the Site. Since a great deal of the contamination exists in soil
and bedrock beneath the buildings at the Site, an in-situ
treatment technology, e.g. a technology which can treat the
contamination without removing the soil (and the buildings), is
preferred over a technology which requires excavation. In
addition, the contamination has entered the bedrock which is not
practical to excavate. The discussion of SVE in Alternative 2 is
also applicable to Alternatives 3, 4, 5, and 6.
Based upon the results of the soil vapor extraction treatability
study, the FFS includes an estimate of the amount of time needed
to provide TCE cleanup ranging between 99% and 99.99998% removal
of TCE from the subsurface soil and bedrock using SVE. The
results are depicted in Table 9.
31
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TABLE 9
SVE % CLEANUP ESTIMATES
% REMOVAL
TCE
99 %
99.5 %
99.9 %
99.95 %
99.99 %
99.99998 %
TIME TO ACHIEVE
CLEANUP
263 Days
302 Days
394 Days
434 Days
525 Days
617 Days
SOIL CLEANUP
LEVEL
2,550 ppb
1,280 ppb
260 ppb
130 ppb
30 ppb
3 ppb
The calculations in Table 9 represent ideal conditions. The
actual amount of TCE that nay be removed during a period of soil
vapor extraction may be more or less than the amount stated in
Table 9. According to the results of the SVE treatability study
and USEPA's experience with implementation of SVE, a soil cleanup
level of approximately 50 ppb should be achievable at the Site
within 2 years of operation of the SVE system.
In order to minimize the leaching of TCE to ground water, the
amount of contamination in the soil and/or the amount of
infiltration through the contaminated soil has to be reduced.
USEPA has calculated that an infiltration rate of 9 ft3/day is
necessary in order for a soil cleanup level of 50 ppb to provide
protection of ground water at the MCL or background levels,
whichever is lower. This represents an infiltration rate which
is 24 times less than the current rate of approximately 216
ft3/day.
If a low permeability cap were placed on top of the Site,
infiltration of precipitation through contaminated soil would be
minimized. If a cap were emplaced, the soil cleanup level could
theoretically be higher (e.g. 50 ppb) than the level necessary to
protect ground water if the Site remained uncapped (e.g. 4 ppb).
Using a model called Hydrologic Evaluation of Landfill
Performance (HELP), USEPA evaluated, in the FFS, the amount of
reduction in infiltration provided by various types of caps.
Table 10 depicts the various multilayered caps evaluated in the
FFS and the corresponding reduction in infiltration provided by
each cap. Table 10 indicates that any one of the multilayered
caps evaluated would provide sufficient reduction in
infiltration, i.e. greater than 24 times less than the current
rate of infiltration. USEPA's analysis indicates that a
multilayered cap placed on the Site in combination with operation
of a vapor extraction system could minimize infiltration and
32
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Table 10
HELP Model Results for a Multilayered Cap
Model
Native9
Native 10
Native 11
Native 12
Cap
Configuration
6 inches of topsoil
6 inches of native soil
geonet
18 inches of clay
(total thickness 30 inches)
6 inches of topsoil
6 inches of native soil
geonet
18 inches of native soil
(total thickness 30 inches)
6 inches of topsoil
6 inches of native soil
6 inches of sand
18 inches of native soil
(total thickness 36 inches)
6 inches of topsoil
6 inches of native soil
6 inches of sand
18 inches of clay
(total thickness 36 inches)
Infiltration
(Ft3/Day)
0.002
0.04
0.4
0.01
Reduction in
Infiltration
48,000
2500
260
9400
Table IO
Screening Runs of HELP Model for Site Cap
Model
NativeS
Asphalt3
Cap
Configuration
6 inches of topsoil
geonet
18 inches of clay
4 inches of asphalt
6 inches of sand
6 inches of native soil
Infiltration
(Ft3/Day)
0.3
2.9
Reduction in
Infiltration
320
33
RAYMARK
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remove enough TCE from the soil such that leaching of residual
TCE should not occur to impact ground water. In addition, the
cap would minimize exposure to other contaminants in the surface
soil which currently do not pose a risk warranting remedial
action.
Each remedial alternative is detailed below. The estimated costs
and implementation timeframes are included in the discussion of
the alternatives.
ALTERNATIVE 1
MO ACTION
Estimated Capital Cost : $ 0
Estimated Annual O&M Cost : $ 30,600
Estimated Present Worth Cost : $ 381,400
Estimated Implementation Time: N/A
The NCP (40 C.F.R. Section 300.430(e)(6)) requires that EPA
consider a "No Action" Alternative for each site. This
alternative provides only for 20 years of sampling and periodic
reviews to monitor the levels of contamination at the Site. In
the No Action Alternative the contaminants in the soil and
unsaturated bedrock at the Site would continue to leach to the
ground water system. Thus, ground water monitoring is included.
Alternative 1 relies entirely upon the controls implemented
pursuant to the remedy for OU2 and OU3 to address the release of
hazardous substances from the Site. The time for aquifer
remediation would be exceedingly long since the source of ground
water contamination at the Site would continue to leach TCE.
ALTERNATIVE 2
Surface Soil: Excavation, Stabilization, RCRA Landfill
Subsurface Soil: Soil Vapor Extraction
Unsaturated Bedrock: Soil Vapor Extraction
Estimated Capital Cost : $ 1,187,400 - $ 2,153,100
Estimated Annual O&M Cost : $ 1,200,600 - $ 1,779,700
Estimated Present Worth Cost : $ 3,419,200 - $ 5,461,500
Estimated Implementation Time: 3 years
Alternative 2 includes treatment of surface soil to reduce
overall Site risks to the 10"6 excess cancer risk range.
According to the USEPA risk assessment for contaminated soil, the
potential carcinogenic risks posed by the surface soil are within
the acceptable risk range of IxlO"4 to IxlO"6. However, low
levels of PAHs in limited areas of the Site result in risk which
exceeds the IxlO"6 risk level.
33
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Alternative 2 includes sampling to determine with more
specificity the volume of soil to be excavated in order to reduce
the carcinogenic risk posed by the Site to the 10"6 excess cancer
risk range. The estimated volume of contaminated surface soil to
be excavated is, at most, 83 cubic yards. This soil volume
includes excavation of soils near surface samples SS-2 and SS-3
(refer to Figure 9) contaminated with a mean total PAH
concentration above 800 ppb. The cleanup level of 800 ppb is the
approximate background concentration determined in the RI for the
6 PAHs, listed first in Table 3b, representing nearly 90% of the
carcinogenic risk. The cleanup level of 800 ppb would reduce the
level of PAHs below detection limits for most on-Site soil sample
locations and well within the 10"6 excess cancer risk range. As
a secondary benefit, the area of excavation would also include
the area of sample SS-2 which had a high level of nickel and most
of the area of elevated cadmium.
The excavated soil would be sampled and tested to determine if it
would need to be handled as hazardous waste, as defined under the
Resource Conservation and Recovery Act, as amended, (RCRA)
(relevant"regulations at 40 C.F.R. Sections 261.20 through
261.24). Existing sample documentation indicates that the soil
does not contain a RCRA hazardous waste. Nonetheless, to be
conservative, Alternative 2 assumes that treating the soil with
stabilizing agents to prevent migration of contaminants
(stabilization) would be required before disposal (placement) in
a RCRA Subtitle C disposal facility in order to comply with RCRA
Land Disposal Restrictions (LDRs)(40 C.F.R. Part 268). If the
excavated soil does contain hazardous waste, the RCRA clean
closure requirements would be applicable (40 C.F.R. Part 264).
If soil does not contain a RCRA hazardous waste, then the
excavated soil would be considered a solid waste and closure
would occur under Pennsylvania solid waste regulations
(Pennsylvania's proposed residual waste regulations should be
considered since the waste could be a residual waste under these
proposed regulations).
Alternative 2 includes SVE to remove VOCs from subsurface soil
and unsaturated bedrock. The amount of subsurface soil requiring
remediation is approximately 4,200 cubic yards (refer to Figure
14). The amount of unsaturated bedrock requiring remediation is
approximately 25,200 cubic yards assuming that the area of
contaminated bedrock coincides with the area of contaminated soil
and the entire depth of unsaturated bedrock, i.e. above the
ground water table (approximately 30 feet), is contaminated. SVE
wells would be installed in the soil and unsaturated bedrock only
in or close to the areas where contaminants have been detected in
soil or bedrock samples. Soil vapor would be extracted from the
wells and passed through vapor phase carbon adsorption units to
remove VOCs from the air before the air is vented to the
34
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Hgur. It
AREAS OF SUBSURFACE SOILS AND
BEDROCK REQUIRING REMEDIATION
BASED ON TCE CONTAMINATION
RAYMARK FOCUSED F5
~ — • Fl *f* > <.
-------
atmosphere. The air emissions would be below federal and state
standards, e.g. National Ambient Air Quality Standards (NAAQS)
regulated under the Clean Air Act (40 C.F.R. Part 500) which are
translated into source specific emission limitations by the
Commonwealth of Pennsylvania.
A more stringent emission rate to be considered is USEPA's policy
of installing air controls on treatment units which emit more
than 3 Ibs./hour or 15 Ibs./day of total VOCs in ozone non-
attainment areas (USEPA OSWER Directive 9355.0-28). An ozone
non-attainment area is an area in which the NAAQS for ozone are
not met. USEPA's policy was developed since most VOCs treated at
Superfund sites are precursors to the formation of ground level
ozone.
Operation of the SVE system may generate water which requires
treatment before disposal. USEPA would treat the water to levels
which do not exceed the NPDES permit levels developed for the
Site by PADER for the ground water remedy selected in the ROD for
OU2 and OU3. Treatment would occur in the treatment units
installed pursuant to the remedy for OU2 and OU3.
The costs for Alternative 2 assume the SVE system would be
operated for 2 years until TCE levels in soil outside the
building area are less than approximately 50 ppb. The volume of
soil and bedrock containing residual levels of contamination
would then most likely be the same as the volume of soil and
bedrock requiring remediation.
The SVE system would be run for an additional time period if
unanticipated delays, weather-related delays, confirmatory soil
sampling, ground water sampling, and/or subsequent modelling
indicate that such additional operation is warranted. Residual
TCE levels beneath the buildings may exceed the cleanup level
since the buildings essentially eliminate infiltration. The
spent carbon would be sent off-Site for regeneration in
accordance with hazardous waste transportation requirements of
RCRA (40 C.F.R. Part 263). RCRA LDRs are applicable to
regeneration of spent carbon. Periodic subsurface sampling would
be performed to evaluate the progress of the remedy.
The cost of Alternative 2 ranges from $3,419,200 to $5,461,500.
The low cost estimate assumes that the SVE system will not be
expanded and additional bedrock dewatered by the ground water
remedy will not yield significant additional volumes of TCE
requiring removal via SVE. The high cost estimate assumes that
the SVE system will be expanded to include areas where TCE has
been detected in soil gas (additional 20,274 cubic yards). In
addition, USEPA anticipates the upper end of the cost range would
cover operation and maintenance which is necessary beyond the 2
year remediation time period. The cost range in all remaining
35
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alternatives is due to identical reasons. The cost estimate for
Alternative 2 also assumes that surface soil contains RCRA
hazardous waste and will require stabilization before disposal.
The estimated implementation time includes approximately l year
to design the remedy and 2 years of operation of the SVE system
to meet the cleanup levels. These assumptions are the same for
all remaining alternatives. The costs for long-term inspection
and maintenance of the cap are not included in the O&M costs.
ALTERNATIVE 3
Surface soil: Excavation, Incineration, Stabilisation, RCRA
Landfill
Subsurface Soil: Soil Vapor Extraction
Unsaturated Bedrock: Soil Vapor Extraction
Estimated Capital Cost : $ 1,932,700 - $ 3,092,300
Estimated Annual O&M Cost : $ 1,540,500 - $ 2,249,200
Estimated Present Worth Cost : $ 3,873,500 - $ 5,992,300
Estimated Implementation Time: ? years
Alternative 3 is identical to Alternative 2 except that the
surface soil would be incinerated off-Site prior to disposal into
a RCRA Subtitle C disposal facility. The incineration process
would comply with applicable requirements of RCRA (40 C.F.R. Part
264, Subpart O). In addition, Alternative 3 would comply with
other major requirements identified in the description of
Alternative 2, e.g. Clean Air Act. The amount of surface soil to
be treated is the same as stated in Alternative 2. Incineration
would reduce the amount of soil requiring disposal and would
destroy the organic material in the soil, primarily PAH, but
would increase the concentration of inorganic material in the
soil. As with Alternative 2, the requirements of RCRA are
applicable only if additional soil sampling indicates that the
surface soil contains a RCRA hazardous waste.
ALTERNATIVE 4
Surface Soil: Cap
subsurface Soil: soil Vapor Extraction
Unsaturated Bedrock: soil Vapor Extraction
Estimated Capital Cost : $ 982,900 - $ 1,628,000
Estimated Annual O&M Cost : $ 1,213,000 - $ 1,798,900
Estimated Present Worth Cost : $ 3,369,200 - $ 5,175,600
Estimated Implementation Time: 3 years
36
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In Alternative 4 the surface soil would remain in place. The
soil would be covered with an asphalt cap to reduce the total
risk posed by the Site, via exposure to contaminated surface
soil, to the 10"6 level. The asphalt cap would also improve the
effectiveness of SVE and would also provide some protection of
the ground water by reducing the amount of infiltration which
could result in leaching of contamination from the soil and
bedrock into the ground water. Institutiopal controls, e.g. deed
restrictions to minimize damage to the cap, would be instituted
as part of the remedy in Alternative 4. RCRA LDRs or
Pennsylvania solid waste regulations are not applicable since
placement is not occurring in Alternative 4.
USEPA believes that soil at the Site would not be a waste if it
were left in place. Alternative 4 does not include any activity
which would require disposal of soil. There is no evidence that
disposal of PAHs, cadmium, and other surface soil contaminants
occurred on the soil at the Site. In addition, the levels of
PAHs, cadmium, and other surface soil contaminants do not pose an
unacceptable risk. The soil does contain levels of cadmium and
PAHs which exceed typical background levels. Nonetheless, the
cap placed on the Site would minimize risk due to exposure to the
surface soil and any threat that surface soil contaminants may
pose to the ground water. Available analytical data do not
indicate that the surface soil contaminants (e.g. PAHs and
cadmium) are mobile since elevated concentrations are not present
in subsurface soil or ground water. USEPA believes that
Pennsylvania's waste regulations are not applicable and although
relevant, are not appropriate for the remedial action.
Since the asphalt cap would reduce the amount of precipitation
which infiltrates through the contaminated soil, additional TCE
could theoretically remain in the soil without increasing the
threat of leaching into the ground water.
ALTERNATIVE 5
Surface Soil: Excavation, Stabilization, RCRA Landfill
Subsurface Soil: Soil Vapor Extraction
unsaturated Bedrock: Flushing
Estimated Capital Cost : $ 1,036,200 - $ 1,713,900
Estimated Annual O&M Cost : $ 740,400 - $ 1,038,400
Estimated Present Worth Cost : $ 2,412,500 - $ 3,644,100
Estimated Implementation Time: 3 years
Alternative 5 is identical to Alternative 2 except that a bedrock
flushing system would be implemented to remove contaminants from
the unsaturated bedrock rather than SVE. Bedrock flushing
involves construction of infiltration trenches at the Site to
promote infiltration of clean water into the contaminated
37
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bedrock. Ground water would be extracted from the subsurface,
passed through an air stripping system to remove VOCs, and
discharged into infiltration trenches. Emissions from the air
stripping system would be treated by vapor phase carbon units
which remove the contaminants from the air before it is vented.
The spent carbon would be regenerated off-Site similar to spent
carbon from the SVE system. Alternative 5 would comply with the
major requirements identified in Alternative 2, e.g. Clean Air
Act and RCRA LORs. In addition, Alternative 5 would need to
comply with the Underground Injection Control (UIC) Program (40
c.F.R. Part 144 and Part 146).
The cost assumptions for Alternative 5 are similar to those for
Alternative 2. However, since there is more uncertainty
associated with the bedrock flushing system, a longer remediation
period would be required which would potentially increase the
costs of O&M.
ALTERNATIVE 6
Surface soil: Cap
Subsurface Soil: soil Vapor Extraction
unsaturated Bedrock: Soil Vapor Extraction
Estimated Capital Cost : $ 1,272,400 - $ 1,671,700
Estimated Annual O&M Cost : $ 1,220,600 - $ 1,801,100
Estimated Present Worth Cost : $ 3,654,400 - $ 5,173,000
Estimated Implementation Time: 3 years
Alternative 6 is identical to Alternative 4 except that the cap
placed on the Site would be constructed specifically to reduce
infiltration of precipitation through the subsurface soil and
bedrock to minimize leaching of VOCs to ground water. The cap
would be constructed as a multi-layer cap consisting of a low
permeability layer (to minimize infiltration of precipitation) on
top of a drainage layer (to allow infiltrating water to flow off
the capped area) on top of a low permeability layer to prevent
infiltrating water from reaching the contaminated soils. A
summary of suitable caps is depicted in Table 10. The most
likely cap to be emplaced consists of 18 inches of compacted soil
beneath a 6" drainage layer beneath 6 inches of soil and then a
vegetation layer. The actual design of the cap may not be
determined until the final design of the remedy is completed and
the conditions at the Site are fully considered, however, any
cap, or combination of caps, described in Table 10 is/are
suitable provided the infiltration rate of the final design is no
more than 9 ft3/day. In addition, the thickness of the caps
described in Table 10 may be reduced provided that the final cap
performs to reduce infiltration to 9 ft3/day.
38
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Decreased infiltration reduces the possibility that contaminants
remaining in the soil after treatment, i.e. residual
contamination, would leach to the ground water system. EPA
estimates that a soil cleanup level of approximately 50 ppb
beneath a multi-layer cap would not result in TCE levels in
ground water higher than 0.19 ppb. The cleanup level applies to
areas outside the buildings, since the roof and floor of the
building prevent infiltration beneath the building. RCRA LDRs
are not applicable since no placement is occurring.
USEPA believes that soil at the Site would not be a waste if it
were left in place. Alternative 6 does not include any activity
which would require disposal of soil. There is no evidence that
disposal of PAHs, cadmium, and other surface soil contaminants
occurred on the soil at the Site. In addition, the levels of
PAHs, cadmium, and other surface soil contaminants do not pose an
unacceptable risk. The soil does contain levels of cadmium and
PAHs which exceed typical background levels. Nonetheless, the
cap placed on the Site would minimize risk due to exposure to the
surface soil and any threat that the contaminants may pose to the
ground water. Available analytical data do not indicate that the
surface soil contaminants (e.g.' PAHs and cadmium) are mobile
since elevated concentrations are not present in subsurface soil
or ground water. USEPA believes that Pennsylvania's waste
regulations are not applicable and although relevant, are not
appropriate for the remedial action.
The cost range for Alternative 6 does not include the cost of
capping to prevent exposure to surface soils as included within
the discussin of Alternative 6 within the FS. The extra cost for
this capping would not exceed approximately. $74,000. The O&M
costs assume a period of cap maintenance of 20 years.
VIII. Summary of the Comparative Analysis of Alternatives
Each of the remedial alternatives for OU1 was compared and
evaluated against nine criteria to determine which remedial
alternative would best meet the remedial objectives of this
response action. The evaluation of remedial alternatives against
the nine criteria is required by the NCP (40 CFR, Section
300.430(e)(9)(iii)). The nine criteria are:
i
Threshold Criteria;
Overall Protection of Human Health and the Environment; whether
each alternative provides adequate protection of human health and
the environment and describes how risks posed through each
exposure pathway are eliminated, reduced or controlled through
treatment, engineering controls, or institutional controls.
39
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Compliance with ARARs; whether each alternative will meet all of
the Applicable or Relevant and Appropriate Requirements (ARARs)
of Federal and State environmental laws and/or justifies invoking
a waiver; whether a remedy complies with advisories, criteria and
guidance that EPA and PADER have agreed to follow.
Primary Balancing Criteria:
Long-term Effectiveness and Permanence; refers to expected
residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time, once
clean-up goals have been met.
Reduction of Toxicity. Mobility, or Vplywe through Treatment;
addresses the statutory preference for selecting remedial actions
that employ treatment technologies that permanently and
significantly reduce the toxicity, mobility or volume of
hazardous substances.
Short-term Effectiveness; the period of time needed to achieve
protection and any adverse impacts on human health and the
environment that may be posed during the construction and
implementation period, until clean-up goals are achieved.
Implementability; the technical and administrative feasibility of
a remedy, including the availability of materials and services
needed to implement a particular remedy.
Cost; estimated capital, operation & maintenance (O&M) , and net
present worth costs.
Modifying Criteria;
State /Support Agency Acceptance; whether the state concurs with,
opposes, or has no comment regarding the RI/FS and the preferred
alternative.
Community Acceptance; the public's general response to the
alternatives which will be assessed in the Record of Decision
following a review of the public comments received on the
administrative record and the proposed plan.
The remainder of this section of the ROD compares each of the
remedial alternatives developed in this ROD against each of the
nine evaluation criteria.
40
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Overall Protection of Human Health and the Environment
Alternative 1 is not protective of human health since long-term
leaching of contamination to the ground water, resulting in
levels of TCE exceeding the MCL for TCE, would continue and is
therefore no longer carried through the 9 criteria analysis.
USEPA has calculated- that remediation of soil to a level of 50
ppb may result in a 50-year reduction in the time period during
which leaching of TCE causes ground water to exceed the MCL.
Alternatives 2, 3, and 5 each eliminate, via off-Site treatment
and/or disposal, the potential risk posed at the Site by a small
area of surface soil and limited amounts of shallow subsurface
(0' to 2') soil. Alternatives 4 and 6 significantly reduce the
potential risk posed by direct contact with surface soil at the
Site, but the cap requires maintenance to provide continued
protection.
The risk posed by surface soil is within USEPA's acceptable risk
range as defined in the NCP (40 C.F.R. Part 430(e)(2)). However,
Alternatives 2, 3, and 5 each contain treatment components which
reduce the risk posed by direct contact with surface soil to the
10~6 excess cancer risk range. Alternatives 4 and 6 do not
specifically address potential risks posed by surface soil, but a
similar level of protection is achieved by capping soil areas
which would not otherwise require a cap based on the need to
reduce infiltration.
Each alternative, except Alternative 1, provides protection to
ground water by removing VOCs from the subsurface soil and
bedrock. SVE will reduce the levels of contamination in the
subsurface soil and bedrock and a cap (Alternative 6) will limit
infiltration to.minimize leaching of residual contamination into
the ground water. The cap in Alternative 4 will also limit
infiltration. However, the cap in Alternative 4 is not
specifically designed to reduce infiltration of precipitation.
Alternatives 2, 3, and 5 also remove TCE from subsurface soil and
bedrock, but leaching of residual contamination may occur. Thus,
Alternatives 2, 3,4 and 5 rely on the ground water remedy
selected in the ROD for OU2 and OU3 to provide protection of
human health and the environment.
Each Alternative, except Alternative 1, significantly reduces the
chance for impact to the environment via runoff of contaminated
soil to nearby surface water. Since Alternatives 2, 3, and 5
involve movement of contaminated soil, the chance for migration
of contamination to surface water is increased.
41
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Compliance with ARARs
USEPA expects that the technologies and controls employed in each
alternative will comply with all ARARs for each alternative which
are identified in Table 11, subject to Section 121(e) of CERCLA,
42 U.s.c. § 9621(e). Although several buildings of potential
historic significance are located within Hatboro, no potential
impacts were identified.
USEPA believes that surface soil at the Site would not be a
waste if it were left in place. There is no evidence that
disposal of PAHs, cadmium, and other surface soil contaminants
occurred into the soil at the- Site. Thus, Pennsylvania's waste
regulations are not applicable and although relevant, are not
appropriate for remedial alternatives 4 and 6 since
Pennsylvania's regulations do not intend to address as a waste,
soil containing any constituent occurring above background
levels. In addition, the levels of PAHs, cadmium, and other
surface soil contaminants do not pose an unacceptable risk to
human health or the environment. Available analytical data do
not indicate that the surface soil contaminants (e.g. PAHs and
cadmium) are mobile since elevated concentrations are not present
in subsurface soil or ground water. Inaddition, the cap placed
on the site would practically eliminate risks due to exposure to
the surface soil and any threat that the contaminants may pose to
the ground water. PADER asserts that surface soil contaminants
pose a potential threat to the ground water"and must be addressed
pursuant to Pennsylvania's environmental regulations and
statutes, e.g. Clean Streams Law.
•-:?
Long-term Effectiveness and Permanence
Implementation of Alternatives 2, 3, and 5 would result in the
greatest reduction in the volume of contamination at the Site
through removal of the surface soil. However, if stabilization
is required, the volume of contaminated soil would be increased.
Alternatives 2, 3, 4, 5 and 6 each remove contaminants in the
subsurface soil. Alternative 6 utilizes engineering controls
which minimize infiltration through soil with residual
contamination thereby minimizing future impact to ground water.
The cap in Alternative 4 is not specifically designed to reduce
infiltration through contaminated soil.
USEPA evaluated several types of caps to be installed in
Alternative 6. In evaluating caps, USEPA considered the
potential success of the SVE technology and the ground water
cleanup goals specified in the ROD for OU2 and OU3. USEPA then
determined the design of a cap which would limit infiltration to
the point that potential residual material left in place after a
2 year operation of the SVE system would not leach to ground
water.
42
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TABLE 11
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
and TO-BE-CONSIDERED (TBC) REQUIREMENTS
CHEMICAL SPECIFIC
Safe Drinking Water Act (42 U.S.C. S 300ffn
Maximum Contaminant Levels (MCLs)
(40 CFR SS 141.11-141.16)
TCE
1,1-DCE
cis 1,2-DCE
trans 1,2-DCE
vc
TCA
carbon tet.
005 mg/1
007 mg/1
070 mg/1
070 mg/1
002 mg/1
,200 mg/1
,005 mg/1
*
*
*
*
*
For water that is to be used
for drinking, the MCLs are
relevant and appropriate
standards. The aquifer should
be cleaned to these levels, if
practicable, in order to return
to beneficial use. ARARs are
stated in ROD for OU2 and OU3.
Soil remedy should reduce the
infiltration of precipitation
and subsequent leaching to
meet these levels.
Proposed Maximum Contaminant Levels (PMCLs)
PCE - .005 mg/1 *
For water that is to be used
for drinking and an MCL is not
yet established, a PMCL may be
relevant and appropriate.
* Contaminants of concern which are or may be related to the Site.
MCLs for other contaminants are provided since these contaminants
are found within the area of the plume. However, these contaminants
are most likely unrelated to the Site.
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TABLE 11 (continued)
Clean Water Act f33 U.S.C. S 1251)
Federal Water Quality Criteria (FWQC)
rQuality Criteria for Water. 1986, 51 CFR 43665)
protection of human health
Fish Consumption
Water and Fish
Ingestion
DCE - .000033 mg/1
PCE - .0008 mg/1
TCA - 18.4 mg/1
TCE - .0027 mg/1
VC - .002 mg/1
CT - .0004 mg/1
.0019 mg/1
.0089 mg/1
1000 mg/1
.0081 mg/1
.525 mg/1
.0069 mg/1
Federal standards which must be
met in the stream adjacent to
the Raymark Site. These
standards are relevant and
appropriate since the stream
may be used for recreational
purposes. Water potentially
generated during implementation
of SVE would be treated to meet
these levels downstream of the
of the discharge point. These
ARARs are stated in the ROD
for OU2 and OU3.
Pennsylvania Chemical-Specific ARARs
*** Clean Streams Law
(25 PA Code Section 93.1 et. sea.)
Water Quality standards
State standards for the quality
of Pennsylvania's surface water
These are the same as the
federal standards.
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TABLE 11 (continued)
ACTION SPECIFIC
Clean Air Act fPart Dl f42 USC SS 7401-7642)
National Ambient Air Quality Standards (NAAQS)
(40 CFR Part 50)
Ozone - 0.12 ppm (1 hour)
Resource Conservation and Recovery Act (42 U.S.C. S 6901)
The NAAQS for ozone should not
be exceeded more than 1 time per
year. VOCs are precursors to
the development of ground-level
ozone. Pertains to use of air
strippers and SVE system.
Land Disposal Restrictions
(40 CFR 268.1-268.50)
General handling, transportation
of hazardous waste
(40 CFR Parts 262, 263)
Standards for Process Vents
(40 CFR S 265.1032)
Requires use of specific technology to
treat specific hazardous wastes. Spent
carbon from carbon adsorption units is
most Jikely a characteristic RCRA waste.
The treatment technology for the TCE in
the spent carbon filter is incineration.
Transportation and handling of charac-
teristic hazardous wastes to comply with
all requirements of RCRA. The spent
carbon from the carbon adsorption units
would most likely be a characteristic
RCRA hazardous waste.
Establishes air emission standards for
systems such as the vapor extraction
system. Total organic emissions shall be
reduced to 3 lb/hr., 3.1 ton/yr., or by
95 weight percent. Relevant and
appropriate since the vapor phase carbon
units most likely contain a hazardous
waste.
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TABLE 11 (continued)
Standards for Equipment Leaks
(40 CFR § 265.105 through § 265.1060)
Pennsylvania Action-Specific ARARs
25 PA Code Sections 127.1 et. seq.
25 PA Code Sections 92.1 et. seq.
Average Monthly
Limit
carbon tetra. 7.3 ug/1
PCE no limit
trans 1,2-DCE no limit
TCE 73 ug/1
25 PA Code Section 264.90 through 264.100
25 PA Code Section 260.1 through 270.42
Establishes standards for various pieces
of equipment, e.g. compressors, used in
treat hazardous wastes. Similar to
standards for process vents.
Requires that air emissions from new
sources, such as air stripping towers or
SVE system, be controlled with bes.t available
technology. In addition approval is required
for any air stripping/soil venting plan.
Sets forth provisions for the NPDES
program administration within Penna.
PADER would set discharge* limitations
based upon .the designated uses of the
receiving stream and Site-specific
parameters related to the design of the
proposed treatment system. These are
ARARs for OU2 and OU3 and for disposal
of water generated during SVE. Note
that these numbers have changed since ROD
for OU2 and OU3 was issued.
Requires that all ground water must
be remediated to background quality. The
remedy for OU1 treats soil such that leaching
to ground water no longer occurs.
Contains regulations for generation,
transportation, storage, and treatment
of hazardous waste. The spent carbon
is most likely a hazardous waste.
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TABLE 11 (continued)
25 PA Code Sections 271, 273, 277, and 285 Contains regulations for generation,
transportation, storage, and treatment
of solid waste generated during the
Remedial Action.
25 PA Code 123.1 et seq. Regulates fugitive emissions during
Remedial Action.
25 PA Code Section 264 Requires a 50-foot buffer zone between
property line and treatment, storage,
disposal activities, e.g. SVE system.
REQUIREMENTS TO-BE-CONSIDERED (TBC1
EPA OSWER Directive.9355.0-28
Suggests that total VOC releases from
air strippers and/or SVE system should
not exceed 3 Ibs./hr or 15 Ibs. day in an
ozone non-attainment area.
25 PA Code Sections 75.21 through 75.38
Regulates generation, transportation,
storage, and treatment of residual waste
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Alternatives 2, 3, 4, and 5 rely upon the engineering controls
and treatment technologies previously selected for contaminated
ground water to reduce exposure to Site-related contamination.
Alternative 5 relies on previously selected treatment and
controls more so than any other alternative involving treatment
since the bedrock flushing system simply moves contaminants to
extraction wells installed as part of the remedy for contaminated
ground water. The infiltration trenches employed in Alternative
5 may increase contaminant mobility and result in migration of
additional contaminants into the drinking water aquifer.
Alternatives 4 and 6 require long-term maintenance of a cap to
provide continued protection from continued leaching of residual
contamination to ground water. Alternative 6 provides the
greatest protection of ground water since, based on modelling,
the cap would eliminate leaching of residual TCE to ground water.
Should erosion controls fail during the long-term operations and
maintenance of Alternatives 4 and 6, an environmental impact,
i.e., migration of contaminants to Pennypack Creek in storm
runoff, may occur.
Reduction of Toxicitv. Mobility and Volume through Treatment
Alternatives 2, 3, and 5 include treatment technologies to reduce
the volume of on-Site contaminants in the surface soil and
limited subsurface soil. Alternatives 2, 3, and 5 also include
stabilization, as needed, to reduce the mobility of contaminants
in the surface soil before disposal. Alternative 3 also includes
incineration, which reduces the soil volume, but may increase
toxicity of inorganic constituents. Alternatives 2 through 6
each include treatment of subsurface soil which reduces the
volume and mobility of the contamination and eventually reduces
the toxicity during regeneration of the carbon. Alternatives 2,
3, 4, and 6 also include treatment of contaminants in the bedrock
similar to subsurface soil. Alternative 5 relies on treatment
employed pursuant to the remedy for contaminated ground water.
Alternative 5 may increase contaminant mobility if the remedy for
contaminated ground water is not designed or operated properly.
while in-situ technologies other than SVE may also work to reduce
the levels of VOCs in soil, SVE was determined to be effective
and potentially less costly than other types of in-situ
treatment.
Short-term Effectiveness
Alternatives 4 and 6 reduce the risk posed by direct human
contact more quickly than other alternatives since the
engineering controls (e.g. cap) are rather easily designed and
43
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constructed. Alternatives including excavation, i.e., 2, 3, and
5 require more definitive sampling and analysis, stabilization
and transportation before the contamination is removed from the
Site and the exposure pathway eliminated. In addition, a small
increase in risk occurs during the transportation process in
Alternatives 2, 3, and 5. Alternative 3 also causes a potential
increase in risk while the soils await the availability of an
off-Site incinerator (this risk could be addressed by a temporary
soil cover). Each alternative employing SVE (Alternatives 2, 3,
4, 5, and 6) results in a small increase in potential exposure to
site-related contamination during the process of transporting
spent carbon for regeneration.
Placement of a low permeability cap at the Site (Alternative 6)
would also increase the efficiency of the SVE system by
decreasing the moisture content of the soils. The decrease in
moisture content increases the effective porosity of the soil,
thereby increasing the efficiency of SVE.
Implementability
Since the Site is an active industrial facility and located on a
small lot near other industrial facilities, coordination of on-
Site activity will be difficult for all alternatives.
Alternatives employing excavation (Alternatives 2, 3, and 5)
require additional coordination with plant owners and operators
and local utilities and authorities to precisely locate
underground conduits and facilities. Except for the availability
of an incinerator, each alternative employs technologies,
transportation, and controls which should be readily available or
constructed.
The presence of significant amounts of TCE in the bedrock and the
presence of high levels of TCE in the deep aquifer beneath the
Site suggests that TCE is present as a non-aqueous phase liquid.
Feasible treatment technologies are probably not capable of
removing all the contamination from the subsurface. Thus, TCE
may dissolve into ground water from NAPL pockets after a remedy
for the Site is implemented. Even the best treatment remedy may
still rely upon engineering controls and institutional controls
to limit further leaching to ground water.
The presence of TCE at depth beneath the manufacturing building
and within the bedrock indicates that remedial alternatives which
include excavation to remove the contamination would not be
practical for the Raymark Site. Although excavation of shallow
soil would remove TCE from the Site, the presence of high levels
of TCE deeper in the subsurface, which are not practical to
excavate, would mean that an alternative technology would also
need to be employed, e.g. SVE. SVE would be effective at
44
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removing TCE from both shallow and deeper levels. The SVE
technology has proven effective in similar situations
State/Support Aoencv Acceptance
PADER has indicated.a preference for excavation of a small amount
of surface soil to remove the risk posed by surface soil
contaminants, e.g. cadmium. PADER asserts that the surface soil
at the Site poses a potential threat to the ground water and
therefore must be addressed pursuant to Pennsylvania's
environmental regulations and statutes, e.g. Clean Streams Law.
Community Acceptance
In general, the public agrees with remedial alternatives which
remove the threat posed by TCE leaching to the ground water
table, i.e. alternatives which include SVE. Some comments were
received suggesting that excavation would be a better method of
addressing the TCE contamination. However, excavation was not
considered to be practical or feasible for the Raymark Site. The
potentially responsible parties do not believe that USEPA should
implement a remedy for OU1. USEPA's response to public comments
received during the public comment period is contained within the
Responsiveness Summary appended to this ROD (Appendix A).
IX. Selected Remedy
Six potential remedial alternatives were evaluated by USEPA. The
selected remedial alternative for OU1 at the Site is Alternative
6. Specifically, this ROD selects:
l. Construction, operation, and maintenance of a vapor
extraction system to remove contamination from
subsurface soil;
2. Construction, operation, and maintenance of a vapor
extraction system to remove contamination from
unsaturated bedrock;
3. Construction, operation and maintenance of vapor phase
carbon adsorption units on the vapor extraction systems
to remove contaminants from the extracted air;
45
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4. Construction and maintenance of a low permeability cap
to minimize infiltration through soil containing
residual contamination and resultant leaching to ground
water;
5. Institutional controls to ensure that the integrity of
the cap is maintained; and
6. Additional sampling of surface soil to determine if
surface soil contiguous to the former lagoon area is a
characteristic hazardous waste and must be handled in
accordance with RCRA.
The expected estimated cost of the selected remedy, including
capital costs, 2 years of SVE O&M costs, and 20 years of cap
maintenance costs, is $3,654,400.
The selected remedy includes construction of vapor extraction
wells to remove contamination from the subsurface soil. As TCE
moves from the soil into the air within the soil pores, it will
be removed from the ground by the vacuum created by the SVE
system. As clean air then moves into the soil pore spaces, more
TCE releases from the soil, moves into the air and is then draw
to the surface for treatment.
USEPA expects to construct vapor extraction wells such that the
vacuum radius from the wells influences only those areas of the
Site in which TCE was detected at concentrations exceeding 50 ppb
and lie outside the building perimeters. USEPA will rely more on
analytical data from samples analyzed using analytical methods
other than the methanol method since not all the TCE detected
using the methanol method can be remediated. Areas in which TCE
was detected above 50 ppb in sampling completed in 1986 are also
included and are generally the same as those areas detected in
the RI with TCE above 50 ppb. USEPA has preliminarily delineated
the area of subsurface soil remediation as depicted in Figure 14.
A more definitive delineation of the soil contamination,
including 1986 and prior soil sampling data, will be done during
design of the selected remedy. The area of subsurface soil
requiring remediation depicted on Figure 14 is an approximation
for cost estimating purposes, the actual locations of vapor
extraction wells will be determined during design of the SVE
system. A conceptual layout of the SVE wells, based upon Figure
14 is depicted in Figure 15. USEPA may arrange the wells in a
different manner to provide the best capture of subsurface
contamination and to include only those areas of soil
contamination above 50 ppb TCE.
50 ppb TCE was determined to be an appropriate soil cleanup level
based upon the SVE treatability study and the performance of the
multilayered cap as determined using the HELP model as well as
the leachability of TCE as calculated using the Summers model.
46
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rof CMftcnpoon Oil MM) Hyout, JMMM9 MA FlQUrt 1-3-
o
B-2A Apfwo«l««l» location ol «oJI bortnfl ««c««dlng «•• TCE
praftrtMiyctoMiiptowl tart tout OM
•I fVE MM to 25 tort.
»dta9
OlMM
180 FEET
J
Flgur* |5
CONCEPTUAL LAYOUT OF SVE
BASED ON TCE CONTAMINATION
BAYMARK FOCUSED FS
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Simply stated, 50 ppb remaining in the soil beneath a
multilayered cap would not leach to ground water at levels above
the ground water remediation goals specified in the ROD for OU2
and OU3, e.g. MCL of 5 ppb TCE.
The cap emplaced at .the Site would reduce the rate of
infiltration at the Site to 9 ft /day. Any variation of caps
depicted in Table 10 is suitable. The final design of the cap
will take into consideration the activities on-going at the Site,
the Site characteristics, and the ability to overlap various
types of caps. For example, during design-related activities,
USEPA may determine that the thickness of the cap must be
minimized. Areas of the Site in which the TCE in the soil could
impact ground water above the remediation goals specified in the
ROD for OU2 and OU3 shall be capped.
FADER expressed concern about levels of metals, e.g. cadmium,
in the surface soil adjacent to the former lagoon area.
Specifically, PADER believes that surface soil contaminants pose
a potential threat to the ground water beneath the Site. To
ensure that PADER1s concerns relating to leaching of Site-related
metals from the surface soil are addressed and that the cap
extends over additional areas of contaminated surface soil, as
necessary, the lateral extent of the low permeability cap will be
established after additional surface soil samples are collected
from areas contiguous to the lagoons, i.e. near surface soil
samples SS-2, SS-3, and SS-4, (and from background areas) during
the early phases of remedial design. The samples will be
subjected to the Toxic Characteristic Leaching Procedure (TCLP)
test to determine if Site-related contaminants could leach from
the soil. If Site-related contaminants cause soil samples
collected near the lagoons to fail the TCLP test, and similar
metals do not leach from background samples, USEPA intends that
surface soil contaminated with Site-related metals shall be
excavated and handled in accordance with RCRA. If the soil
passes the TCLP test, the surface soil shall remain in place.
The low permeability cap shall extend over those areas in which
the level of TCE in the subsurface soil exceeds 50 ppb and those
contiguous areas necessary to minimize infiltration through soil
containing more than 50 ppb TCE. The area to be capped will be
determined by USEPA during the remedial design, but USEPA
anticipates that soil beneath and surrounding soil boring
locations B-3 and B-5, which includes surface soil sample
locations SS-3 and SS-4, will be covered with the low
permeability cap. In addition, the low permeability cap shall
extend over those areas deemed by USEPA during design of the SVE
system as necessary to maximize the efficiency of the SVE system.
47
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Areas of the Site which have TCE levels greater than 50 ppb and
are currently located beneath asphalt pavement shall be repaved
to limit leaching of residual TCE. Existing data indicate that
no such areas exist. Some of the parking area may be repaved to
provide a better connection to capped areas and to further limit
potential migration of residual TCE located beneath the asphalt
areas to the ground water at levels which exceed the ground water
remediation goals specified in the ROD for OU2 and OU3. The
specifics of capping overlap and areas to be repaved shall be
finalized during the design of the selected remedy.
Additional areas of the Site may also be capped if existing Site
data and modelling performed -during remedial design indicate that
areas with TCE levels less than 50 ppb and which won't be capped
pose a potential threat to ground water.
Water generated during operation of the SVE system would be
treated in the treatment units constructed pursuant to the remedy
for OU2 and OU3. As specified in the ROD for OU2 and OU3, USEPA
expects to meet the NPDES discharge requirements at the point of
discharge into the storm sewer system near the Site. The remedy
would not rely upon further dilution within the storm sewer
system. USEPA expects to meet Ambient Water Quality Criteria and
water quality standards downstream of the point of discharge into
the Pennypack Creek. Thus, potential impacts to the Pennypack
Creek would be minimized.
The FFS suggests that use of catalytic incineration instead of
vapor phase carbon for the first year of remediation may result
in a potential cost savings of $150,000. Prior to final design
of the SVE system, USEPA will determine if catalytic
incineration, which basically destroys the VOCs on-Site rather
than containing them within the vapor phase carbon and destroying
them off-Site, can be utilized at the Site and achieve the same
degree of protection achieved by use of carbon. An Explanation
of significant Differences (ESD) would be issued prior to
selecting catalytic incineration rather than vapor phase carbon.
The VOCs contained within the carbon units will be destroyed or
treated in accordance with RCRA at a permitted facility.
Additionally, on-Site regeneration of the carbon would be
evaluated prior to final design. Similar to catalytic
incineration, an ESD would be issued prior to implementation of
on-Site regeneration of the carbon.
48
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After the remediation is completed, the lifetime excess cancer
risk levels posed by the Site would be within the 10"4 to 10"6
excess cancer risk range, and the soil would no longer pose a
threat to the ground water, consistent with the NCP. The
residual soil contamination beneath the low permeability cap
would not leach to ground water. The cap would need to be
maintained until the residual contamination no longer poses a
threat to ground water. Institutional controls, e.g. deed
restrictions, would be used to prevent disturbance of the cap.
USEPA expects that soil would not leach contaminants to ground
water after 2 years of vacuum extraction.
Summary of Performance Standards
The performance standards for the selected remedy, Alternative 6,
are as defined in this section.
1) USEPA has determined that two performance standards for the
vapor extraction system relate to subsurface soil. The SVE
system shall: a) remove VOCs from subsurface soil such that the
concentration of TCE in the subsurface soil outside the perimeter
boundary of any on-Site building shall not exceed 50 ppb, and b)
remove VOCs from subsurface soil such that leaching of residual
TCE from subsurface soil beneath the Site shall not result in
exceedance of the ground water MCLs for contaminants of concern,
identified in Table 3a and listed in Table 11, in the ground
water beneath the Site.
2) USEPA has determined that two additional performance
standards for the vapor extraction system relate to unsaturated
bedrock. The SVE system shall: a) remove VOCs from unsaturated
bedrock for a period of time equal to extraction of vapor from
subsurface soil, and b) remove VOCs from unsaturated bedrock such
that leaching of residual TCE from unsaturated bedrock beneath
the Site shall not result in exceedance of the ground water MCLs
for contaminants of concern, identified in Table 3a and listed in
Table 11, in the ground water beneath the Site.
3) USEPA has determined that a performance standard for the
vapor extraction system shall be a requirement for vapor phase
carbon adsorption ("air controls") to treat the organic emissions
from the vapor extraction system, atf required, unless the
Pennsylvania Department of Environmental Resources determines,
pursuant to 25 PA Code SS 127.1 et. sea, and 25 PA Code SS 123.1
et. seq.. that air controls are not necessary. USEPA expects to
minimize organic emissions from the vapor extraction system such
that the maximum rate of organic emission does not exceed 3
Ibs./hr. or 15 Ibs./day. However, USEPA expects further that
organic compounds will not exit the treatment system, but instead
be adsorbed onto vapor phase carbon and handled as hazardous
waste.
49
-------
4) USEPA has determined that a performance standard for the low
permeability cap shall be that infiltration through the low
permeability cap shall not exceed 9 ft3/day.
X. statutory Determinations
The selected remedy which was outlined in Section IX satisfies
the remedy selection requirements of Section 121 of CERCLA (42
U.S.C. S 9621) and the NCP (40 C.F.R. Section 300.430(e)). The
remedy provides protection of human health and the environment,
achieves compliance with ARARs, utilizes permanent solutions to
the maximum extent practicable, contains treatment as a principal
element, and is cost effective.
A. Protection of Human Health and the Environment
No unacceptable short-term risks or cross media impacts would
result from implementation of the selected remedial alternative.
B. Compliance with ARARs
USEPA expects that the selected remedy will comply with all ARARs
which are identified in Table 11, subject to Section 121(e) of
CERCLA, 42 U.S.C. S 9621(e). The air emissions from the SVE
system would not exceed levels established in USEPA's policy
(OSWER Directive 9355.0-28). EPA expects that no volatile
organic compounds shall escape the vapor extraction system.
C. Cost Effectiveness
The selected remedy is cost effective. It provides a high level
of protection for reasonable cost. The selected remedy provides
overall effectiveness proportionate to its costs, such that it
represents a reasonable value for the money to be spent.
0. utilization of Permanent Solutions to the Maximum Extent
Practicable
The selected remedy provides the best balance of tradeoffs among
the alternatives with respect to the evaluation criteria,
especially the 5 balancing criteria. The selected remedy meets
the statutory requirement to utilize permanent solutions and
treatment technologies to the maximum extent practicable.
50
-------
E. Preference for Treatment as a Principal Element
The selected remedy utilizes a treatment technology (SVE) which
was tested at the Site and proved to be effective at removing
VOCs from the subsurface soil and bedrock. The SVE system can be
constructed from readily available components, e.g. vacuum
blowers and PVC piping. Since treatment is used to address the
principal threats at the Site, this remedy employs treatment as
its principal element.
XI. EXPLANATION OF SIGNIFICANT DIFFERENCES
USEPA's public comment period was extended to November 6, 1991
after a representative of one of the potentially responsible
parties informed USEPA that the administrative record file was
not available for public review during the 30-day public comment
period. An addendum to the Proposed Plan was issued on October
2, 1991 which discussed the extended public comment period and an
alternative treatment technology, catalytic conversion, which
USEPA will may evaluate during the design of the selected remedy.
If catalytic conversion is a suitable and less costly alternative
to address air emissions, USEPA may consider implementation of
this alternative.
The Proposed Plan stated that the cap considered in USEPA's
preferred Alternative #6 would include a relatively impermeable
base of 18" of compacted soil covered by a 6" sand drainage layer
covered in turn by a vegetated soil layer. However, the
Feasibility Study and Table 10 within this ROD describe several
alternative cap designs which achieve the required level of
performance, i.e. reduce infiltration such that TCE no longer
poses a threat to the ground water. Thus, this ROD does not
select a specific cap, but provides for several design options as
described herein.
The discussion of the risk posed by the Site is more detailed
within this ROD to justify USEPA's decision that surface soil at
the Site will not be addressed by the selected remedial action.
51
-------
APPENDIX D
SUMMARY OF ANALYTICAL DATA
-------
TABLE 4-1
SURFACE SOIL ANALYTICAL RESULTS
ORGANIC COMPOUNDS
RAYMARK
SAMPLE LOCATION
SAMPLE DEPTH (ft)
SAMPLE DATE
VOC*
MelhyleneChloilde
Acetone
Tilchkwoelhene
NUMBER OF TIC*
ESTIMATED TOTAL TIC*
BN/AE*
2-Methylnaphlhalene
Acenaplhylene
Ottwnzofciian
Phenanthiene
Anthiacene
Fluofoanlhene
Pyiene
Butylbeniylphlnalale
Benio|a)anthiacane
Chiysene
bit(2-Elhylhexyl)phlhalale
Benio(b)HuoianUiene
Benzo(k)Uuoianthene
8enzo(a)pyiene
ludeno( 1 .2.3-cd)pyiene
Benzo(g .h.l)pei yteite
NUMBER OF TIC*
ESTIMATED TOTAL TIC*
PESTICIDE8/PCB*
4.4-ODE
4.4-OOT
001
0-0.}
I2/I9VI9
7 B
12 U
!•
NO
•30 UJ
•30 UJ
•30 UJ
•30 UJ
•30 UJ
•30 UJ
•30 UJ
•30 UJ
•30 UJ
•30 UJ
•30 J
280 J
•30 UJ
•30 UJ
•30 UJ
•30 UJ
16
14.334 J
18 U
18 U
002
0-0.}
12/19/19
(uoAg)
U B
14 U
7 U
NO
1.000 UJ
1.800 UJ
1.000 UJ
3.700 J
380 J
0.100 J
4.400 J
1.000 UJ
2.400 J
3.000 J
700, J
2.300 J
2.000 J
1.800 J
1.300 J
•80 J
14
18.360 J
23 U
S3 U
003
0-0.}
I2/I9/W
6 U
10 U
6 U
NO
170 J
230
l«0
3.008
410
8.600
8.100 J
660 UJ
6.100 J
6.400 J
MO UJ
6.300 J
6.600 J
6.800 J
3.400 J
2.600 J
II
22.130 J
20 U
20 U
004
0-0.}
12/19/19
• u
13 U
• u
NO
800 UJ
800 UJ
000 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
6
3.770 J
21 U
140
DUPE 004
0-0.}
!2/l9/t9
("9*0)
6 U
13 U
4 J
NO
800 UJ
800 UJ
000 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
800 UJ
3
2.420 J
76
360
DOS 006
O-Oi 0-0}
12/IWW 12/19/19
16 B 20 B
7 B 16 U
7 U 8 U
1
NO 0006 J
820 UJ .100 UJ
820 UJ .100 UJ
02O UJ .100 UJ
820 UJ .180 UJ
820 UJ .100 UJ
340 J .100 UJ
300 J .100 UJ
820 UJ .100 UJ
820 UJ .100 UJ
820 UJ .100 UJ
820 UJ .100 UJ
820 UJ .100 UJ
820 UJ .100 UJ
820 UJ .100 UJ
•20 UJ .100 UJ
820 UJ .100 UJ
• 22
13.630 J 68.620 J
21 U 26 U
21 U 26 U
007
0-0.}
12/19/19
23 B
14 U
7 U
1
0.003 J
850 UJ
860 UJ
•60 UJ
860 UJ
860 UJ
850 UJ
850 UJ
• 850 UJ
850 UJ
860 UJ
850 UJ
850 UJ
850 UJ
850 UJ
060 UJ
850 UJ
12
17.020 J
22 U
22 U
001 009
0-0.} 0-0.}
12/19/19 I2/I9/W
• U 7 U
16 U 16 U
• U 7 U
NO NO
.100 UJ
.100 UJ
.too UJ *
.100 UJ
.100 UJ
400 J
320 J
.too UJ
.100 UJ
.100 UJ
320 J
.100 UJ
.100 UJ
.100 UJ
.100 UJ
.100 UJ
.000 UJ
.000 UJ
.000 UJ
.000 UJ
.000 UJ
.000 UJ
.000 UJ
.000 UJ
.000 UJ
.000 UJ
.000 UJ
.000 UJ
.000 UJ
.000 UJ
.000 UJ
.000 UJ
20 12
26.740 J 11.160 J
26 U 24 U
26 U 24 U
010 TRIP
0-0.} BLANK
12/19/19 12/19/19
(ug/kg) (ug/l)
I U 6 U
17 U 10 UJ
• U 6 U
NO NO
.
1.200 UJ
t.200 UJ
I.2OO UJ
300 J
t.200 UJ
670 J
660 J
680 J
1.200 UJ
400 J
1.200 UJ
350 J
320 J
350 J
1.200 UJ
1.200 UJ
II
40.400 J
27 U
27 U
EQUIP
BLANK
12/19/19
(ug/l)
6 U
6 J
6 U
NO
to u
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
to u
to u
to u
1 U
62 U
010 U
010 U
NOTES;
I) Only the** paiamelei* that weie delected haw bam ptaeanlad In the above table
BNAE* - Ba*« nmili al/acitf exliaclabte compound*
TIC* - Tentatively Identified compound*
VOC* - Volatile otganto compound*
B - Not delected *ub*tanllally above lit* (aval In UtxxaUxy of Uald blank*
J - Analyle pietenl Reputed valua may not ba accuiala o* pieclte.
NO - Not delected
U - Not delected Paiamelei wa* analyzed lot bul wa* not delected.
Attocialed value indicate* the minimum detection limit.
U J - Not detected, quantitalion limit may be inaccuiate M tmpiecite.
AicocUled value Indicate* the minimum detection limit.
-------
SURFACE SOIL ANALYTICAL RESULTS
METALS AND CYANIDE
RAVMARK
SAMPLE LOCATIO 001
SAMPLE DEPTH (ft) 0-0.6
SAMPLE DATE 12/19/10
(mo/kg)
Aluminum
Antimony
Arsenic
Barium
Beiyllium
Cadmium
Calcium
Chfomium
Cobalt
Coppai
lion
Lead
Magnesium
Manganese
Meicuiy
Nickel
Potassium
Selenium
Sodium
Thallium
Vanadium
Zinc
Cyanide
13.200
•.7
40
sea
11
no
1.000
17.6
• 4
343
14.600
as 7
1.830
421
0.12
25.6
661
097
1.520
0.45
31.4
326
132
BIL
L
B
L
J
J
B1J
J
K
J
L
B
BIJ
UL
B
J
J
002
0-0.6
12/19/10
(rag/kg)
14.000
10.4
4.1
66.3
0.76
26:6
2.070
41.0
12.7
431
16.100
46.6
3.090
373
O.I
755
976
1
1.660
026
270
476
22.9
BIL
L
B
L
J
J
BIJ
J
K
J
L
B
BIJ
UL
B
UJ
J
003
0-0.6
12/19/19
(mg/hg)
16.000
66
6.4
119
1.2
46.3
2.340
24.6
11.6
112
10.400
11.4
2.610
462
007
125
1.610
6
1.700
027
206
346
20.6
BIL
L
B
L
J
J
BIJ
J
K
J
L
B
J
UL
B
BIJ
J
004 DUPE. 004
0-0.6 0-0.6
12/19/69 12/19/19
(mg/hg) (mO*9)
13.700
106
6.3
110
1.2
76.6
2.020
22.9
0.1
132
14.200
10.4
1.730
397
0.00
976
601
1.1
1.600
027
26.0
341
16.6
BIL
L
B
L
J
J
BIJ
J
K
J
L
B
BIJ
UL
B
UJ
J
11.700
119
51
101
13
67.2
1.770
207
72
125
12.000
62.4
1.660
359
007
903
443
1
i.ieo
025
21.4
300
233
BIL
L
B
L
J
J
BIJ
J
K
J
L
B
UJ
UL
B
UJ
J
DOS
0-0.6
12/19/69
-------
TABLE 4-3
SUBSURFACE SOIL ANALYTICAL RESULTS
ORQANIC COMPOUNDS
RAVMARK
o
I
SAMPLB LOCATION
SAMrLBRANOBdU
SAMPLB DATS
VOC*
Total 1.2-CHchloroelrtene
Titehlotoelherw
Tetiachtoroethene
Total Xyterte*
NUMBER OF TIC*
ESTIMATED TOTAL TIC*
BN/AE*
Napthatena
2-Malhylnaplhaiene
bla(2-Elhylhexyl)phthalala
NUMBER OF TIC*
ESTIMATED TOTAL TIC*
PESTICIDES/PCa*
4.4 -DOT
Arochlot-1264
SAMPLE RANQE(N)
TOC (roe/kg)
•VI B-l
0-1 1-4
OWTMIO OWZ1/W
<>l/kB> («Af>
0 U 0 U
0 U • U
e u • u
• U 6 U
— NO
•30 U
030 U
— IM J
— ND
40 U
— 400 U
— -*-"•
B-2
0-2
ot/nno
(<«AC>
a u
9
II
e u
NO
770 U
770 U
770 U
ND
31 U
2.100
™—
•-1 B-J
4-6 *-•
OVCT/W 04/Z7/W
(•HAD <«A«)
30 U 730
7.000 L 440
40 730
16 730
7 J
6.460 J ND
400
740
770
13
4.101.000
31
3M
4-8
3.050
B-4
J-7
OW1VW
(uf/k|)
L
L
U
U
J
J
U
J
U
u
6
7
0
•
1
•
770
770
1.200
ND
37
370
3-6
0.000
U
B
U
L
J
J
U
U
U
u
B-S
2-4
O6/THW
(ut/U)
0 J
62 L
7 U
7 U
NO
700 U
700 U
710
•
3
207.000
M
370 U
4-a
1.000
B-6 oura B-«
1-10 1-10
06/iiroo 06/it/w
dv/it) (m/i*)
0 U
0 U
e u
0 L
2
10
760 U
760 U
720 J
ND
36 U
300 U
2-4
3.050
6 U
6 U
6 U
0 L
ND
760 U
760 U
1.100
ND
37 U
370 U
2-4
1.070
B-7
3-J
owitroo
<•«/**>
6
6
6
6
NO
•00
•00
170
NO
30
300
—— —
U
U
u
UL
U
U
J
U
U
NOTES:
1) Only IhOM compound* Uuri w»i« dclaclad h»v« b«*n pi«Mnl0d In the «bov« Ubto.
2) Sarnpto NJO4-B3-6 wa* dHutad KM tolchloioalhylana only; all olhai analyla* wma validalad udng ottglncl *ampto.
3) Saropto* lor BNAE and p«*Uclda/PCB analy*** w«t* collected al depth ol 6-7 to«l.
BNAE* - BaM naulial/acM •xliaclabla compound*
TIC* - Tanlallvrty M*nllH«d compound*
TOC - Total otganie caibon. (••uHt by dry welghl.
VOC* - VolalUa Of ganlo compound*
B - Not dalcctad *ub«anUally abov* MM (aval i*potl»d In Uboiotwy 01 llald blank*.
J - Analyt* pi*Mnl. Rapoilad value may not be accurate or pteclw.
L - Analyt* piea*nl. Repotted value may be blaeed low. Actual value I* expected to be higher
NO - Not delected.
UJ - Not delected, quanlilatkm limit may be Inaccurate or Impreclte.
UL - Not delected, quanlllallon limit U probably higher.
U - Not delecled. Sample analyzed lor but not delected. Attoclaled value I* the minimum detection limit.
Parameter not analyzed tor.
-------
SUBSURFACE SOIL ANALYTICAL RESULTS
ORGANIC COMPOUNDS
RAVMARK
o
i
SAMPLE LOCATION B-t B-* B-B B-IO TRIP BLANK TRIP BLANK TRIP BLANK EQUIP BLANK EQUIP BLANK EQUIP BLANK
SAMPLE RANGE (ft) 0-8 10-12 t-IO 7-9 TB-I TB-2 TB-3 EB-I EB-2 EB-3
SAMPLE DATE 00/2MO OQ/2I/BO 00/20*00 00/20/90 00129190 OO/27/BO 00/287BO OO/20/00 08/27/00 00/28/00
(ug/hg) (ug/kg) (ug/kg) (ug/kg) (ug/1) (ug/l) (ug/1) (ug/l) (ug/l) (u8/l)
VOCe
Total 1.2-Dlchioroelhene 0 UJ 0 U
Trtehlotoelhene 0 UJ 6 U
Tetiechloroelhene 6 UJ 6 U
Total Xylene* 0 UL a U
NUMBER OF TIC* 1
ESTIMATED TOTAL TIC* NO 0 J
BN/AE*
Naplhalene 780 U
2-Melhylnaplhalene 700 U
blep-ElhylhexyQphlhalal 330 J —
NUMBER OF TIC*
ESTIMATED TOTAL TIC* —
PESTtCIDES/PCB*
4.4'-OOT 37 U —
Afochlof-1254 370 U —
SAMPLE RANGE (II)
TOC(mg/kg) —
0 U
a u
a u
a u
ND
700 U
700 U
670 J
ND
37 U
370 U
~™~
6 U 6 U 5 U S
II 6 U S U S
5 6 U S U S
6 U 6 U 5 U 5
NO ND NO ND
720 U
720 U
720 U
NO ND ND ND
B
39 U
360 U
™~~ """*" ™ M —
6 U
S U
S U
S U
ND
10 U
10 U
10 U
ND
0.10 U
10 U
...
S U
6 U
5 U
6 U
ND
10 U
10 U
10 U
ND
010 U
1.0 U
...
6
6
S
S
ND
,
to
10
10
ND
0 10
to
...
U
u
u
u
u
u.
u
u
u
NOTES:
It Only UIOM compound* that were delected have been patented In the above table.
2) Sample NJO4-B3-0 was diluted for IrtoMoroethvlene only: all other analyst weie validated utlng original wimple
BNAE* - Bate mubaj/acld exliaciabl* compound*
TIC* - Tentatively tdenliHed compound*
VOC* - Volatile otganlc compound*
TOC - Total organic cat boo. leeutlt by diy weight.
B - Not detected eubrtanllaHy above the level lepoited In laboiotory w field blank*.
J - Analyt* pietenl. Repotted value may not be accuiat* or pieclte
L - Analyle pietent. Reported value may be Maead low. Actual value U expected lobe hlghec
ND - Not delected.
U - Not delected. Sample analyzed lot but not delected. Aitoclaled value I* the minimum detection limit.
UJ - Not delected, quenlllatlon limit may be InaccuiaU
-------
TABLE 4-4
SUBSURFACE SOIL ANALYTICAL RESULTS
VOLATILE ORGANIC COMPOUNDS
METHONAL PRESERVATIVE AND MEDIUM LEVEL VOC METHODS
RAYUARK
SAMPLE LOCATION
SAMPLE DEPTH (ft)
SAMPLE DATH
METHANOL PRESERVATIVE VC
1.1.1-TiichlofoelhafM
1 .2.4-Tiimethylbeniene
2-BuUnone
Biomomelhane
Chloiomelhane
cis- 1 .2-Dichloi oelhene
DichkxodilluofOfnelhan*
HexachkNObuladiafM
Melhylene Chloride
Naplhalene
n-Bulylbenzene
Teli achkx oelhene
TiichkM oelhene
TiichkMolluoiomelhane
Vinyl ChlMide
NUMBER OF TIC*
EH1MATED TOTAL TlCsfug/k
MBDJUM LEVEL VOC METHOD
1 2X-Tiimelhylbenzene
Cpmf oleum
c!l*T 2-Dichloioelhane
HeTachloi obuladiene
Nlplhalene •
iCs£lytben*ene
iCW>pylbeniene
p-leopiopylloluene
sec-Bulyl benzene
Teliachlorelhene
Tuchtucoelhena
NUMBER OF TICt
ESTIMATED TOTAL TIC«(UQA
fr-l
4-6
06/27/90
("tt*(D
1C METHOD
6 U
6 U
10 U
U
U
U
U
U
U
U
U
U
U
6 U
6 U
NO
U
U
U
U
U
U
U
U
U
U
160 J
0
11.000
B-2
0-2
06/27/90
-------
SUBSURFACE SOIL ANALYTICAL RESULTS
VOLATILE ORGANIC ANALYTICAL METHOD COMPARISON
RAYMARK
SAMPLE LOCATION
SAMPLE DEPTH (A)
SAMPLE DATE
1 ,2.'4-Trlmelhylbenzene
CMbtokxm
cl»- 1 .2-Olchloi oelhene
Dichlorodifluoramelhane
Irtexachlorobutadlene
Naplhaiene
n~Qutylbanzen«
n-Propytbenzene
p-laopropylloluene
•ec-Butylbenzene
Tetrachloroelliene
Trlchlofoethene
Tola! Xylenet
NUMBER OF TICi
ESTIMATED TOTAL TICt (tig/kg)
MBTHANOL MEDIUM HAS
BVI B-l B-l
4-* 4-6 2-4
06/27/90 06/27/90 06/27/90
OW*8)
6 U 6 U U
6 U 6 U U
' 10 J 5 U U
U 6 U U
U 6 U U
U 6 U U
U 5 U U
U 6 U U
U 6 U U
U 6 U U
10 J 6 U 1
80 J 10 J
5 U 6 U U
NO NO NO
MBTHANOL MEDIUM HAS
B-3 B-3 B-J
4-6 4-6 4-6
06/27/90 06/27/90 06/27/90
(<*/k«) (iia/kg)
250 J 1.700 30 U
5 U 30 J 30 U
130 J 150 J 30 U
6 U 6 U 30 U
250 J 1.100 30 U
270 J I.40O 30 U
180 J 760 J 30 U
6 U 110 J 30 U
5 U 230 J 30 U
6 U 270 J 30 U
40 J ISO J 46
10.000 54.000 7.000 L
5 U 5 U 16
50 68 7 J
42.010 141.600 6.450 J
MBTHANOL MEDIUM HAS
B4 B-4 B-4
i-7 i-7 i-7
06/21/90 06/21/90 06/21/90
(URAg) <<«/k«) ("gig)
5 U 5 U 6 U
5 U 90 J 6 U
30 J 6 U 6 U
5 U 6 U 6 U
6 U 6 U 6 U
5 U 6 U 6 U
6 U 5 U 6 U
6 U 5 U 6 U
6 U 5 U 6 U
5 U 6 U 6 U
6 U 6 U 6 U
130 J 30 J 7 B
5 U S U 6 U
1 J
NO NO 8 J
NOTES:
I) Only thoee compound* that were detected are presented In the above table.
2) Sample NJO4-B3-* wa* diluted tor Klchkxoelhytene only: all other analyte* were validated using original sample.
TIC* - Tentatively Identified Compounds: non-Uigel VOCs
VOCs - Volatile Organic Compounds
B - DATA SUSPECT: Not detected substantially above the level In lab/field blanks
J - Estimated value: presence ol compounds Is Indicated, but the response Is less
JMhan the quanlilatlon limit.
(SQuialyte present. Reported value may be biased low. Actual value Is expected to be higher.
rfjpd Not detected.
ITtiiiritn detected: Parameter was anlalyzed lor but was not detected. Associated
Talue Is the nominal quanUlatlon limit.
uTP^Not detected, quantltallon limit may be Inaccurate or imprecise.
Not detected, quantitatlon limit Is probably higher.
- Parameter* not analyzed lor.
-------
TABLE 4-5 (conl'd)
SUBSURFACE SOIL ANALYTICAL RESULTS
VOLATILE ORGANIC ANALYTICAL METHOD COMPARISON
RAYMARK
SAMPLE IjOCATION
SAMPLE DBfTH <•)
9AMPLBOATB
1 .2.4-Trimethylbenzene
Chloroloim
cla- 1 ,2-Dtchloioelhane
DtehlofOdiauofOmefhan*
Hexachkxobutadlene
Naplhalene
n-Bulylbenzene
n-Piopylbenzane
p-liopropyNohiene
•ec-Bulytbenzene
Teliachloroelhene
Tilchlotoelhene
Total Xylene*
NUMBER OF TICt
ESTIMATED TOTAL TIC*(ug*g>
MBTIIANC
BS
2-4
otmm
(««AO
w
2.4W
«
NC
>L MBOIU
B-J
2-4
06/27/i
(>«At
u
u
J
u
u
u
u
u
u
u
u
1 2«
i U (
» NC
M RAS
B-J
2-4
10 06/27/90
) <<«AD
U 7 U
U 7 U
u g j
U 7 U
U 7 U
U 7 U
U 7 U
U 7 U
U 7 U
U 7 U
U 7 U
> J 62 L
i U 7 U
> ND
MBTIIAN
B-t
4-1
(M/2I/M
(•SAD
63C
(
NC
OL MEDIUM HAS
B-I B-I
6-1 6-1
1 06/2S/90 06/2I/
I)
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UL
>
MBTIIAN
B-9
I- 10
06/tt/W
(«,/U)
.
1
NC
OL MEDIUM RAS
B-9 B-9
1 10 I-IC
1 OU1V90 OUMI
(m/U) NO Nt
i
W
1)
U
u
u
u
u
u
u
u
u
u
u
u
9 U
)
o
t
-4
9Q
CO
CO
NOTES:
I) Only MIOM compound* UMI «*•(• d«l*cl*d w* pi•Mnl*d In III* above tabto.
2) SMnpto NJO4-83-* «>•* diluted to utentoKMlhytoM only, all othm •nalylti w«i« valldal*d utlng original sample.
TIC* - Tanlallvaly ktonlltod Compound*: non-Uig*l VOCa
VOC* - Volallto Oiganlc Compound*
B - Data wiapaol; Not dataclad wbdanllally abov* In* l*v«l In lab/Bald blank*
J - Ecttmatod value pi«»WK* ol compound* I* Indicated, bul In* i*»ponM I* let*
than lira quanlMalion limit
L - Analyl* piecwtt. R*poil*d value may be bla**d low. Actual value I* expected lo be higher
NO - Not delected.
U - Not delected; Paiamelei wa* anlalyied lor but wa* not delected AMOclaled
value I* lite nominal quanMatkm limit.
UJ - Not delected, quanlilallon limit may be inaccuiale 01 Imprecise.
UL - Not delected. quanlllaUon UmU I* probably higher.
Paiameleii not analyzed lor.
-------
o
fp
00
TABLE 4-6
SUBSURFACE SOIL ANALYTICAL RESULTS
METALS AND CYANIDE
RAYMARK
SAMPLE LOCATION
SAMPLE RANGE (It)
SAMPLE DATE
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Thallium
Vanadium
Zinc
Cyanide
B-2
2-4
06/27/90
(mg/kg)
14.300
5.3
69.9
1.3 U
15.6
1.080 B
22.1
5.8 B
52.3 B
20.200
30.3
2.140
146
81.4
921 B
167 B
0.26 U
26.6
58.3
12.3
B-4
3-5
06/28/90
(mg/kg)
19.300
5.7
125
1.2
0.48 U
1.070 B
24.9
8.6 B
15.3 B
20.800
26.0
2,090
567
14.3
651 B
129 B
0.24 U
34.0
39.6
0.60 U
B 5
4-6
06/27/90
(mg/kg)
9.350
1.4
20.4
1.2
1.8
531
9.3
1.8
7.6
5.380
3.3
569
61.2
4.1
197
79.6
0.25
11.1
13.1
0.68
B
B
U
B
B
B
B
B
U
B
U
B
B-6
2-4
06/28/90
(mg/kg)
16.100
6.7
45.2 B
1.2 U
2.7
1.320
24.9
7.2 B
39.1 B
24.500
12.5
2.630
136
148
685 B
526 B
0.57 B
38.8
36.2
0.62 U
DUPE B-6
2-4
06/28/90
(mg/kg)
18.100
7.9
64.7
1.2
1.5
1.680
27.6
79
34.3
28.800
14.6
2500
203
14.8
422
317
0.67
40.3
44.5
0.68
EQUIP BLANK
06/27/90
(ug/i)
72.6
1.0
1.0'
U 5.0
2.0
510
0.50
B 4.0
B 61.4
102
10
90.0
5.7
10.0
B 800
B 1.170
B 1.0
4.0
4.1
U 10.0
B
U
U
U
U
B
U
U
U
U
B
U
U
B
U
U
B
U
EQUIP BLANK
06/28/90
(ug/i)
20.0
1.0
1.0
5.0
2.0
31.3
1.2
4.0
18.3
16.3
1.0
90.0
1.0
10.0
800
272
1.0
40
2.0
10.0
U
U
U
U
U
B1
B1
U
B
B
U
U
U
U
U
Bt
U
U
U
U
NOTES:
1) Only (hose parameters that were delected have been presented In (he above table.
2) Due to possible contamination ol the associated equipment blank (NJO4-EB-2). the
reported results lor copper In the other samples may be biased high.
B - Not detected substantially above the level In laboratory or Held blanks
B1 - Analyle present. As values approach the IDL the quantitalion may not be accurate.
U - Not delected; Parameter was anlalyzed lor but was not detected. Associated
value Indicates the minimum detection limit.
-------
TABLE 4-7
SUBSURFACE SOIL ANALYTICAL RESULTS
GEOTECHNICAL PARAMETERS
RAYMARK
SAMPLE LOCATION
SAMPLE DATE
SAMPLE RANGE "(ft)
CEC(meq/100g)
Sodium (ug/l) (2)
SAMPLE RANGE (ft)
Moisture Content (%) (3)
Bulk Density (pcf) (3)
Permeability (cm/sec) (3)
ASTM SHAKE TEST FOLLOWED
Aluminum
Arsenic
Barium
Cadmium
Chromium
Copper
Iron
Lead
Mangnesium
Manganese
Silver
Mercury
Nickel
Selenium
Sodium
Vanadium
Zinc
B-3
06/27/90
4-6
10.9
125.000
22.8
. 103.3
8.9E-08
B-4
06/28/90
3-5
100.0
176,000
24.4
100.4
2.0E-06
B-5
06/27/90
4-6
5.3
66.900
3-4
18.4
106.6
1.3E-06
B-6
06/28/90
2-4
16.6
191.000
21.9
103.7
2.5E-OS
B2/3(l)
06/27/90
2-4
—
BY EXTRACTION (mg/l) (2)
—
—
—
—
—
—
—
—
—
___
—
—
* • *
—
—
__
—
—
—
—
—
— -
• *
—
—
—
—
___
—
—
—
—
_—
—
1
__
__
_
—
—
__
___
—_
___
—
*
5.0
0.045
0.041
0.025
0.851
0.008
0.143
6.2
0.023
0.474
0.04
0.0006
0.079
53.7
0.045
0.094
J
L
K
J
J
K
R
J
NOTES:
1) Sample for ASTM shake test collected from both B2 and B3 at depth of 2-4 ft.
2) Laboratory reported value measured in the extract Conversion to dry or wet soil basis was
not performed.
3) Value is the average of two data points reported by the laboratory.
CEC - Cation exchange capacity
J - Analyte present. Reported value may not be accurate or precise.
K - Analyte present. Reported value may be biased high. Actual value is expected to be lower.
L - Analyte present Reported value may be biased low. Actual value is expected to be higher.
R - Unreliable result. Analyte may or may not be present in the sample. Supporting data
necessary to confirm result.
AR30!I 39
-------
TABLE 4-9
SURFACE WATER ANALYTICAL RESULTS
ORGANIC COMPOUNDS
RAYMARK
SAMPLE LOCATION Penaypack Penaypack
Creek Creek
SAMPLE NUMBER SW-l DUPE SW-1
SAMPLE DATE 08/28/90 08/28/90
(ug/I) (ug/1)
VOCs
Trichloroethene
NUMBER OPTICS
ESTIMATED TOTAL TICs
BN/AEs
PESTICIDES/PCBs
CONVENTIONAL PARAMETERS
COD (mg/l)
Hardness (mg/l)
TDS (mg/l)
TSS (mg/l)
Alkalinity (mg/l)
1 J
35 J
ND
ND
21.0
116
178
18
79.6
1 U
ND
ND
ND
25.6
122
176
24
79.0
Storm
Drain
SW-2
08/28/90
(ug/0
1 U
ND
ND
ND
24.4
141
206
8
49.6
NOTES:
1) Only those parameters that were detected have been presented
in the above table.
BNAEs - Base neutral/acid extractable compounds
COD - Chemical Oxygen Demand
TDS - Total dissolved solids
TICs - Tentatively identified compounds
TSS - Total suspended solids
VOCs - Volatile organic compounds
J - Analyte present Reported value may not be accurate or precise.
ND - Not detected
U - Not detected. Parameter was analyzed for but was not detected.
Associated value indicates the minimum detection limit.
-------
TABLE 4-10
SURFACE WATER ANALYTICAL RESULTS
METALS AND CYANIDE
RAYMARK
SAMPLE LOCATION Pomypeck Pennypack
Creek Creek
SAMPLE NUMBER SW-1 DUPE SW-1
SAMPLE DATE 08/28/90 08/28/90
(ug/l) (ug/I)
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Potassium
Sodium
Zinc
Cyanide
1.400
5
106
3.2
26,900
13.8
21
1.660
23.4
8,120
71.4
3,100
10,500
44.2
10
B
U
B1
B1B
B
U
B
B
J
J
B
U
463
5
115
2.7
27.400
9
21
758
13.2
8,190
69.0
3.000
10,800
51.5
10
B
U
B1
B1B
U
U
B
B
J
B1J
B
U
Storm
Dram
SW-2
08/28/90
(UQ/1)
212.0
8.8
55.9
3.4
28.200
9
25.8
848
10.8
7.750
15.8
5.600
10,300
51.5
10
B
B1
B1
B1B
U
B
B
B
B
J
B
U
NOTES:
i) Only those parameters that were detected have been presented
in the above table.
B - Not detected substantially above the level in laboratory or field blanks.
81 - Analyte present. As values approach the IOL the guantitation may not be accurate.
J - Analyte present. Reported value may not be accurate or precise.
U - Not detected. Parameter was analyzed for but was not detected.
Associated value indicates the minimum detection limit.
AR30I U8
-------
TABLE 4-11
SEDIMENT ANALYTICAL RESULTS
ORGANIC COMPOUNDS
RAYMARK
SAMPLE LOCATION Pennyptck Peanyptck
Creek Creek
SAMPLE NUMBER SED-1 DUPE SED-l
SAMPLE DATE 08/28/90 08/28/90
(ug/kg) (ug/kg)
VOCs
Acetone
Trichloroethene
NUMBER OPTICS
ESTIMATED TOTAL TICS
BN/AEs
Acenapthene
Dibenzofuran
Fluorene
Phenanttirene
Anthracene
Fluoranthene
Pyrene
Butylbenzytphthalate
Benzo(a)Antnracene
Chrysene
bis(2-Ethy1nexyl)phthalat
Benzo(b)Huoranthene
Benzo(k)Ruoranthene
Benzo(a)Pyrene
ldeno(l ,2.3-cd)pyrene
Dibenz(a.h)amhracene
Benzo(g,h,i)perylene
NUMBER OP TICS
ESTIMATED TOTAL TtCs
PESTICIDES/PC Bs
Dieldrin
Alpha-Chlordane
Gamma-Chlordane
11 B
3 J
•NO
850 U
850 U
850 U
800 J
120 J
1,300 J
1,100 J
850 U
500 J
570 J
850 U
480 J
850 U
550 J
850 U
850 U
850 U
3
840 J
41 U
3.5 J
210 U
52 B
6 U
ND
140 J
110 J
240 J
2.800. J
490 J
5,400 J
4,600 J
820 UJ
1,700 J
1,800 J
120 J
1.600 J
1,200 J
1,400 J
1,000 J
86 J
840 J
7
5.620 J
39 U
4.2 J
200 U
Storm Thp Equip
Drain Blank Blank
SED-2 TB-1 EB-1
08/28/90 08/28/90 08/28/90
(ug/kg) (ug/l) (ug/l)
29 B 10 U
6 U 5 U
ND NO
780 U
780 U
90 U
1,300 J — -
230 J
2.700 J
2,200 J
86 J
1,000 J
960 J
420 J
840 J
710 J
800 J
790 J
780 U
720 J
7
5.550 J
22 J
11 J
11 J
10 U
5 U
ND
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
ND
0.10 U
0.50 U
0.50 U
NOTES:
1) Only those parameters mat were detected have been presented in the above table.
BNAEs - Base neutral/acid attractable compounds
TICs - Tentatively identified compounds
VOCs - Volatile organic compounds
B - Not detected substantially above the level reported in laboratory or field blanks.
J - Analyte present. Reported value may not be accurate or precise.
NO - Not detected
U - Not detected. The associated number indicates approximate sample concentration necessary to be detected.
UJ - Not detected, quantitation limit may be inaccurate or imprecise.
Parameter not analyzed for.
IR30IU9
O-ii.
-------
TABLE 4-12
SEDIMENT ANALYTICAL RESULTS
METALS AND CYANIDE
RAYMARK
SAMPLE LOCATION Pomyptck F
Creek
SAMPLE NUMBER SED-1 Dl
SAMPLE DATE 08/28/90
(mg/kg)
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Vanadium
Zinc
Cyanide
TOC
2.630
• 1.9
36.4
1.6
3,500
16.1
3.3
19.8
3,410
26.8
2,090
189
13.4
474
6.5
93.7
1.2
1661
B
B1
B1
B
B
B
U
L '
B
B
B1J
B1J
L
U
«MU^|JVwK
Creek
JPE SED-1
08/23/90
(mg/kg)
1,870
1.6
32.2
1.2
2.860
15.7
3.4
12.1
10,200
20.1
1,510
188
6.6
388
7.7
120
1.2
885
B
81
B1
B
B
B
U
L
B
U
B1J
B1J
L
U
J
Storm
Drain
SED-2
08/28/90
(mg/kg)
5.610
3.7
105.0
1.9
9.450
18.0
10.6
28.3
14,200.0
82.1
5.360.0
597.0
11.2
1,390
19.4
211
1.2
168
B
B
B
B
B1
L
J
L
U
B
Equip
Blank
EB-1
08/23/90
(ug/l)
2,730
5
29
2.7
870
53.2
14
21
2.010
6.5
770
12
27
920
24
11
10
166
U
U
B1B
U
U
U
J
U
U
U
UJ
U
U
U
NOTES:
1) Only those parameters that were detected have been presented
in the above table.
B - Not detected substantially above the level in laboratory or field blanks.
81 - Analyte present As values approach the IOL the quantitation may not be accurate.
J - Analyte present. Reported value may not be accurate or precise.
L - Analyte present Reported value may be biased low. Actual value is
expected to be higher.
U - Not detected. Parameter was analyzed for but was not detected.
Associated value indicates the minimum detection limit.
UL - Not detected, quantitation limit is probably higher.
D-ii
-------
APPENDIX E
SUMMERS MODEL CALCULATIONS
-------
Appendix
DEVELOPMENT OF CLEANUP LEVELS
IN SUBSURFACE SOILS
This appendix calculates preliminary cleanup levels for subsurface soils. These
cleanup levels are used to develop areas and volumes for subsurface soil remediation.
The areas for bedrock remediation are then inferred from the defined areas for
subsurface soil remediation. This approach was used because cleanup levels are not
directly applicable to bedrock due to the fractures and the technical limitations of
achieving uniform cleanup and obtaining representative bedrock samples.
Subsurface soil cleanup levels were initially developed using a leaching model. The
cleanup levels based on this model were found to be in the low ug/kg range and are
unlikely to be achieved by any one of a number of technologies short of excavation
and backfill with clean fill. This is impractical at Raymark, where contamination has
migrated into the unsaturated bedrock and the Site is an active facility. Therefore, a
technology-based cleanup level was developed that could be achieved within a
reasonable time frame during remediation. Following technology screening, SVE
emerged as the most likely remedial option for subsurface soils and bedrock at
Raymark. Therefore, the technology-based cleanup level was based on the SVE
treatability study results. Achieving this cleanup level would reduce the source of
VOC contamination and the corresponding leaching to the Hatboro aquifer. Because
this cleanup level may result in ground water concentrations that exceed the cleanup
levels in the ground water ROD, any soil alternative achieving this level must be
supplemented by ground water pumping at the Site.
As previously noted, the remedial alternative selected in the ground water ROD
involves both on-site and off-site ground water pumping and treatment It is also
possible to reduce infiltration through the contaminated unsaturated zones by using a
Site cover. This cover would be expected to limit the leaching of the VOCs left in
the unsaturated zone following remediation. Therefore, the last part of this appendix
evaluates the reduction in infiltration that should be achieved such that the VOCs
remaining in the soils and bedrock following remediation would not result in VOC
concentrations in ground water that exceed the cleanup levels in the ground water
ROD. Ground water pumping and treatment, as specified in the ground water ROD,
would then provide additional protection to public health.
LEACHING MODEL
A leaching model was employed to estimate preliminary soil cleanup levels at
Raymark. The model was used to calculate two soil contaminant concentrations: (1)
a concentration that would result in ground water concentrations below the cleanup
levels specified in the ground water ROD, and (2) a concentration that would result
AR30I686
-------
in ground water concentrations below the minimum detection limits of the most
sensitive water analytical method.
COMPOUNDS OF CONCERN
The model was used to calculate cleanup levels for VOCs detected in both subsurface
soils (RAS data) and ground water at the Site. These included TCE, PCE, and cis-
1,2-DCE. Cleanup levels were not developed for xylenes, chloroform, and several
other VOCs. Xylenes were detected in soils (RAS data) but not in ground water and
chloroform was detected in ground water but not in soils using RAS. Although
chloroform was detected in soils using the methanol method, a cleanup level was not
developed for this compound because of the low ground water concentration at which
it was found (below 1 ug/1).
Several other VOCs were detected in either subsurface soils or ground water but not
in both media. This FFS does not develop cleanup levels for these VOCs because
they were not present in both media at the Site, had limited occurrence in the media
in which they were detected, and some could not be clearly attributed to facility
operations. VOCs detected only in ground water included 1,2-DCE; 1,1-DCA;
benzene; toluene; 1,1,1-TCA; and a few others. The presence of these in ground
water may be due to past subsurface sofl contamination with compounds which have a
higher tendency to leach than TCE and could have already migrated to ground water.
It is also possible for their presence to be associated with off-site contamination
migrating onto the Raymark Site. In soils, other VOCs detected included 1,2,4-
trimethylbenzene, hexachlorobutadiene, N-butylbenzene, N-propylbenzene, and a few
others. These were detected by the medium, or methanol, analytical method in only
one boring in the area of the former lagoons. The presence of these organics in the
soils and not in the ground water may indicate that they have a lesser tendency to
leach than TCE due to their physical and chemical properties. Because of this and
the fact that they were detected at only one location, this FFS did not develop
cleanup levels for these compounds.
BNAEs and the PCB Arochlor 1254 were detected in subsurface soils. These
compounds, however, adsorb to sofl and generally do not present a leaching concern.
This is supported by the ground water sampling results, since BNAEs and PCBs were
not detected in on-site ground water. Pesticides were not detected in both ground
water and subsurface soils at the Site and, therefore, would not be considered a
concern. Metals were detected in subsurface soils. However, they appeared to be
associated with background conditions. Metals also tend to adsorb to the sofl matrix
and are considered to have limited mobility. This is supported bj the fact that none
of the metals detected in ground water at the Site exceeded the primary Maximum
Contaminant Levels (MCLs) for drinking water under the Safe Drinking Water Act.
Therefore, preliminary subsurface sofl cleanup levels were not developed for metals.
A more extensive discussion of the fate and transport of organic and inorganic
contaminants at the Site can be found in Appendix M.
RAYMARK4/00851
-------
METHOD
The leaching model accounts for two processes that affect the fate and transport of
contaminants in ground water-adsorption and mixing. The adsorption component is
based on the partitioning between the solution phase and soil phase of the VOCs in
ground water. The resulting solution concentration is assumed to completely mix with
the ground water and'is solved for by a mass balance approach. The model is an
analytical solution and is represented by the following relationship:
Cgw - QpCp/(Qp + Qgw) (1)
where:
Cgw* contaminant concentration in the ground water (mg/1)
Qp » volumetric flow rate of infiltration (soil pore water) into the ground
water (fr/day)
Qgw* volumetric flow rate of ground water (rWday)
Cp * contaminant concentration in the infiltration (mg/1)
The above relationship is true only if the reactions that cause the partitioning
between the solution phase and the solid phase are fast, compared to the flow
velocity; if the reactions are reversible; and if the isotherm is linear. Mixing is
assumed to be complete and not a function of factors such as advection and
dispersion.
ASSUMPTIONS AND RESULTS
The volumetric flow rate of ground water is estimated as the Darcy ground water
velocity times the cross-sectional area of the aquifer perpendicular to the ground
water flow across the contaminated area. This relationship is represented by the
following:
.(V)(L)(D)(2)
where:
Qgw * volumetric flow rate of ground water (ft*/day)
V » Darcy velocity (ft/day)
L - length of Site perpendicular to flow (ft)
D • depth of aquifer (ft)
RAYMARK4AXJ8JL. £.3
A830I688
-------
The Darcy velocity of .0088 ft/day was derived by assuming aquifer transmissivity to
be 6^63 gpd/ft This is the average transmissivity derived for the regional aquifer, as
identified in a Ground Water Technical Memorandum (CH2M HILL, 1991). The
aquifer thickness was assumed to be 100 feet. This is an uncertain estimate but it is
not important here because it is eventually factored out The hydraulic gradient was
calculated to be .001 ft/ft from depth to water measurements collected in wells MW-
1D and MW-3D on September 27, 1990. The length of Site perpendicular to flow,
270 feet, was approximated by measuring the distance perpendicular to flow between
opposite property boundaries. The resulting volumetric flow rate of ground water is
238 fWday.
The infiltration volumetric flowrate was calculated by multiplying the contaminated
area by the rainfall infiltration rate. The rainfall in Southeast Pennsylvania averages
about 42 inches per year. It was assumed that half of this is lost to evapotranspiration.
The contaminated area was assumed to be approximately 22,500 square feet which
encompasses the area of the TCE tanks and the former lagoons, as shown in Figure
D-l. The resulting infiltration flow-rate is 216 frVday.
The concentration in the infiltrating ground water, Cp, is estimated by using the
following relationship:
Cp-Cs/Kd (3)
where:
Cp = solution concentration (mg/1)
Cs = sofl concentration (mg/kg)
Kd * soil/water equilibrium partition coefficient (I/kg)
The partition coefficient was derived using the following relationship:
Kd - f oc x Koc
where:
foe * organic carbon content fraction
Koc = organic carbon content adsorption constant
The fraction of TOC foe was determined to be 0.003 from averaging the TOC values
of soil samples obtained in the above area during the Site remedial investigation. The
Koc values for TCE, PCE, and cis-l,2-DCE used in the analysis were 126 I/kg,
364 I/kg, and 49 I/kg, respectively.
RAYMARK4/008J1 E-4
< • - "830J689
-------
\
For description on *M» layout pl»HI M* Figure 1-3.
In M*A !• • f h^ifl mAj-t&l t+iKt
in in0 Mvcfnng mooM ui»i
•MnMTOI
B 2 A ApproihMto location o» sol boring i
lovol* In at (MSI on* ol ttw Ihrao MM
PF1 ® Monllorlno w»H.
60
120
180 FEET
i
•d
FlgimO-1
AREAS OF SUBSURFACE SOIL
CONSIDERED M THE LEACHING MODEL
RAYMARK FOCUSED FS
DS
-------
The ground water concentrations of TCE and PCE used in this model were 5 ug/1
based on the ground water ROD and 0.19 ug/1 and 0.14 ug/1, respectively, based on
the most sensitive analytical method (EPA Method 524.2). The corresponding values
for cis-l,2-DCE were 7 ug/L and 0.2 ug/L. The acceptable residual concentrations in
soil are calculated by combining equations (1) and (3):
Cs = Cgw x Kd x (Qp + Qgw)/ Qp
The resulting concentrations in soils were calculated as follows:
Based on the ground water cleanup level in the ROD
Cgw TCE = 5 ug/1 Cs TCE - 4 ug/kg
Cg PCE » 5 ug/1 Cs PCE - 11-5 ug/kg
Cgw cis-l,2-DCE » 7 ug/1 Cs cis-l,2-DCE » 2.2 ug/kg
Based on the detection level of the most sensitive analytical method
Cgw TCE - 0.19 ug/1 a TCE - 0.15 ug/kg
Cgw PCE » 0.14 ug/1 Cs PCE • 0.32 ug/kg
Cgw cis-l,2-DCE » 0.12 ug/1 Cs cis-l,2-DCE » 0.04 ug/kg
DISCUSSION
There are several factors not accounted for in the previously described model,
resulting in very conservative soil cleanup concentrations. If these factors were
included in the model, the soil cleanup concentrations would be higher. Specifically,
the model does not account for the attenuation of contaminants in the unsaturated
zone, which would greatly impact the concentrations in infiltrating rainfall. The depth
to water at the Site is approximately-25 to 42 feet below grade. This means that
rainwater infiltrating through contaminated soils is subjected to dilution, dispersion,
and, possibly, biodegradation in the unsaturated zone before reaching the water table.
Also, the effects of biodegradation once contamination reaches the saturated are not
accounted for.
The mode! is based on conditions of isotropy and homogeneity in a granular porous
media. Tie ground water system underneath the Raymark Site consists of layered and
fractured bedrock of differing porosities and conductivities and certain anisotropy.
Fractures will have the effect of increasing average ground water velocity, thus
enhancing mixing. In addition, reduced matrix porosity means less solid medium
surface area for adsorption, thus inhibiting chemical equilibria between the solid
phase and solution phase contaminant concentrations. These influences impact the
processes represented in the analytical solution and, thus, the resulting TCE
concentration in soils.
Irrespective of these conservative assumptions, achieving the developed cleanup levels
would be technically infeasible. In fact, they are unlikely to be achieved by any one
-------
number of technologies short of excavation of all materials exceeding these levels and
backfilling with clean fill. The soil cleanup levels corresponding to ground water
concentrations below the detection limits of the most sensitive analytical method are
particularly conservative. These levels are below the 5 ug/kg quantitation limit for the
compounds using the most sensitive soil analytical method. The detection limit may,
in actuality, be higher. In order to develop achievable soil cleanup levels, a
technology-based approach was used. A description of the approach follows.
TECHNOLOGY-BASED METHOD
The technology-based level is based on the SVE treatability study results at the Site.
Following technology screening, SVE emerged as the most likely remedial technology
for subsurface soils and bedrock. Because the SVE study focused on TCE as the
main contaminant of concern at the Site, cleanup levels using this approach can be
calculated only for this compound.
METHOD
The cleanup that can be achieved within the zone of influence of a SVE vacuum well
can be estimated based on the cumulative pounds-extracted-versus-time data for the
well collected during the treatability study. These data for the various vacuum wells
installed during the study were presented in Table 1 of appendixes B, C, D, and E in
the SVE treatability study results report (Terra Vac, 1991). Plots of the natural log
of the cumulative pounds extracted in successive equal time units versus time were
made from the data. These data were then fit into linear equations in the form:
In (d#/dtu) « S tu + I
A 95% confidence interval around the slope (S) and interval (I) can then be
calculated. Conservative estimates of the initial pounds of VOCs (M0) within the
zone of influence of the vacuum well and the days for a desired percentage cleanup
(Tf) can be made from the extreme part of the confidence interval, according to the
following equations:
M0 = e'/|s|
Tr = 2.08 In (fraction remaining)
where
M0 s Initial pounds of VOCs within zone of influence
I s Interval (change)
RAYMARK4/UQ8JI £.7
••- -.•••• U361692
-------
I s I s Absolute value of slope of cumulative pounds-versus-time
plot or change in concentration with time for the
particular well
Tr = Days for desired percentage cleanup
RESULTS AND DISCUSSION
The cleanup levels were calculated'for the area affected by vacuum well VE1D in the
vicinity of the former TCE tanks. This well reflects the most contaminated area of
the Site, based on the treatability study results. Therefore, it is likely to drive the
total time needed to complete cleanup at the entire Site. Well VE1D had a zone of
influence of 27 feet and was screened to 14 feet below the ground surface. The
weight of soil within the cone of influence of this well was calculated as 3.2 million
pounds based on a soil density of 100 pounds per cubic feet. Based on the vapor
data, the above model shows that the zone of influence of this well contained 816
pounds of TCE at the beginning of well extraction.
The absolute value of the slope of the cumulative pounds-extracted-versus-time plot
was calculated to be 0.03647 for a 95 percent confidence interval. This slope reflects
the slowest change in concentration with time and, therefore, will result in the longest
time needed to achieve a certain cleanup.
Using the previously described model, Table D-l presents the percentage removals
and time needed to achieve various cleanup levels in soils around well VE1D. Based
on these data, to achieve a cleanup that is better than 99.5 percent, 20 percent more
time is needed to get an additional 0.4 percent cleanup or a total 99.9 percent
cleanup. In order to go from 99.9 percent to 99.99 percent cleanup (an additional
cleanup of less than 0.1 percent), 25 percent more time is needed. For the purposes
of this FFS, a 2-year cleanup period of all the areas requiring remediation at
Raymark was assumed. This remediation period should be able to achieve cleanup in
the 50-ppb range and at the same time account for delays as a result of Site, weather,
or other conditions. The SVE may achieve lower cleanup levels.
REDUCTION IN INFILTRATION
The preliminary cleanup levels using the leaching model were based on the
assumption that there would be rainwater infiltration. This, in turn, would cause
leaching of TCE from the unsaturated to the saturated zone in amounts that are
likely to result in TCE concentrations in ground water that exceed the cleanup level
in the ground water ROD. This leaching could be reduced by placing a cover of
limited permeability over the areas of concern at the Site and, thus, limiting the
infiltration in these areas. The concentrations of VOCs, say TCE, left in the
-------
Table D-l
Technology-Based Cleanup Levels and
Time Required to Achieve Cleanup
Percentage Removal
(%)
99
99.5
99.9
99.95
99.99
99.99998
Time to Achieve Cleanup
(days)
263
302
394
434
525
617
Resultant Soil Concentration or
Cleanup Level
(ppm)
155
1.28
0.26
0.13
0.03
0.003
RAYMARK4AW9.51/1
£-9
4ft30lfi
-------
subsurface soils following remediation could then be higher than the concentration
calculated using the leaching model. In fact, this concentration may be as high as the
cleanup level achievable by the SVE and a cover can be designed to limit infiltration
to the needed rate. Therefore, this FFS estimates the infiltration rate that would
allow up to 50 ug/kg of TCE to be left in the soil and, at the same time, would not
result in a ground water concentration exceeding the TCE cleanup level in the ground
water ROD. Using the leaching model (equation 1), this infiltration rate was
calculated to be approximately 9 frVday. This represents a reduction of
approximately 24 times from the 216 fr/day infiltration without a cover. A cover that
could achieve this reduction in infiltration would provide a protection of human
health and the environment by limiting the leaching such that the ground water
cleanup levels would not be exceeded. A conceptual design for this cover is provided
in Appendix L
RAYMARK4/008.51 £-10
BR301695
-------
APPENDIX F
RISK CHARACTERIZATION TABLES
-------
Table 3-4
TOXICTTY EQUIVALENCE FACTORS
Benzo[a]anthracene
Benzo[b]fluoranthene
Benzo[g,h,i]perylene
Benzofkjfluoranthene
Chrysene
Indeno[ 1,2,3-cdjpyrene
Pyrene
TEF
0.145
0.140
0.022
0.066
0.0044
0.232
0.081
x 11.53- kg-day/mg
1.67
1.61
0.25
0.76
0.051
2.67
0.93
TEF - Tenacity Equivalence Factor
'11.53 is the cancer slope factor of benzo[a]pyrene
WDCR554/045.31
48301371,
-------
rile C2A Revised 6-26-91
fable C 2
CURRENT IAMO USE: TRESPASSING CHILD SCENARIO
NOHCARCIMOGEN1C HEALTH RISK EVAIUAMOH Of SURFACE SOIL INCCSIION: MAXIMUM CONCENIRAIION OEIECIED
AVERAGE EXPOSURE ASSUMPTIONS
Reference
Dose (RfO)
Chealcal Mg/kg-day
2 Me thy (naphthalene
Acenaphthene
Anthracene
Reniolal anthracene
lento la) pyr ana
Benaofbl 1 luaranlhena
Ieiual9.li. ilperylene
Reniofk) f iuoranthene
bis(2-Ethylhe«yl )phthalale
dirysem
ME
001
Oibeniofuran
f (uorenthene
lndeno|1.2.1-cd)pyrene
Phenenthrene
Pyrene
Irictiloroethene
Arsenic
Reryllius
CadMius)
Cyanide
Mercury
-------
e C5A Revised 6 26 91
fable C-5
CURREN1 LAND UStt AOUII OCCUPAIIOMAt SCENARIO
NONCARCINOGENIC MEA11M RISK EVAUIAIION Of SURFACE SOU INGESIION: MAX I MM CONCENIRAIIOM OEIECIEO
AVERAGE EXPOSURE ASSUNPIIONS
REASOMARIE MAMINUH EXPOSURE ASSUNPIIONS
Jcal
Reference Maximum
Doee (RfB) Concentration
mg/kg-day Sourc* • ug/kg
Average
Deily Intake
(01)
mg/kg-day
Retard
Quotient
DI/RfO
Does Intake
Exceed RfO?
Percent of
Ml
Maximum
Dally Intake
(01)
mg/kg-day
Maiard
Quotient
OI/RfD
Does Intake Percent
Exceed RfOI
of
Ml
Mlhvlnaphlhaleno
•afAthana
-recerte
so lal anthracene
•olalpyrena
tolbl I luoranthene
lolg.h.ilperylone
lolklfluorantkane
[2-Cthylbaxyl )pfc that ate
•sene
raofuran
^rajitnana
rw(1.2.3-cd)pyrene
«nlhrone
— n
Moroethene
rile
I HUB
>UB
.ide
z-ry (alkyl ant Inorganic)
si
-«lUB
•^
NA
0.06
0.3
MA
MA
NA
NA
NA
0.02
NA
NA
0.0005
NA
0.04
NA
NA
0.01
NA
0.001
o.oos
0.0005
0.2
0.0003
0.02
0.0*7
NA
IRIS
IIIS
MA
MA
NA
NA
NA
IIIS
MA
NA
HEASf
NA
IIIS
NA
NA
IIIS
NA
MEASI
IIIS
IIIS
IIIS b
IIIS
IIIS C
MEASI
170 .66E-OB .41E-07
210 .2SE-08 3.75E-07 NO 0.0 .9IE-07 3.19E-06 NO 0.0
410 .01E-00 t.ME-07 NO 0.0 .41E-07 1.14E-06 NO ' 0.0
S100 .99E-07 .24E-06
MOO .7SE-07 .74E-06
AIM .16E-07 .24E-06
2500 .45E-07 .08E-06
•600 .468-07 .49E-06
nM .ME -OB 3.42E-06 NO 0.0 .I2E-07 2.91E-OS NO 0.0
5400 .20E-07 .49E-06
76 .44E-09 .12E-OB
ISO .42C-00 6.0SE-05 NO 0.3 .91E-07 5.02E-04 NO 0.1
160 .57E-00 .31E-07
9600 .19E-07 2.1SC-OS NO 0.1 .90E-06 2.00E-04 NO 0.1
3400 .33E-07 .ME-OA
1700 .62E-07 .OIE-D6
9100 .90E-07 2.97E-OS NO 0.1 .57E-04 2.S2E-04 NO 0.1
10 .74E-09 • .50E-00
MOO .24E-07 A.26E-04 NO 1.1 .12E-06 S.12E-01 NO 3.1
1400 .37E-07 2.74E-OS NO 0.1 .IftE-M 2.31E-04 NO 0.1
78600 .69E-06 1.ME-02 NO 75.1 .54E-05 1.31E-01 NO 75.1
23300 .20E-06 1.14E-OS NO 0.1 .94E -OS 9.69E-OS NO 0.1
120 .171-08 3.91E-OS NO 0.2 .98E-08 3.33E-04 NO 0.2
755000 7.39E-OS 3.69E-03 NO 18.0 .28E-04 3.14C-02 .NO 18 0
40100 1.94E-06 5.61E-04 NO 2.8 .3SE-05 4.79E-03 NO 2.8
•rd Index (Sua of DI/RfD) 0.020
0.174
DfUU ASSUNPIIONS AVERAfiE
NAKINUN
•llntake (graM/d*y) d
- Height (kllograM)
ttlon ingeated froa conta«lnated aoll Cunltli
bsure froojuMicy (days/year)
Mura Duration (yeara)
Vagina HM (yaara)
•er*ion factor 1 (graa to kilogram)
•ereIon factor 2 (•Icrogra* to •illlgrM)
•ereIon factor 3 (year to day)
0.05
70
1
50
5
5
0.001
0.001
365
0.085
70
1
250
25
25
0.001
0.001
165
-ourcee of RfDa:
• IS - Integrated Rlak Information Syateai. U.S. EPA 1990.
:ASI • Mealth Effecta Aaseaaawnt Suamary lablaa. fourth Quarter, U.S. EPA 1990
yanlde value baaed on free cyanide.
Ickel value baaed on nickel-soluble aalta.
ME soil Intake based on 4 hours Indoors at 0.050 ga/8 hrs * 4 hra outdoor*
t 0.480 g/8 hrs » 25X fraction ingested fro* contaminated soil.
rauiicatlon from Debra Forman to Juliana Mess. June 1991. Soil intake includes contaminated dust.
- Hot Available
F-2
-------
lie C6A Revised 6-26-91
Iable C-6
CURRENI LAND USE: AOULt OCCUPAIIOUAL SCENARIO -- IHOOOftS
NONCARCIMOGEN1C HEAL IN RISK EVAIUAIION Of SURfACE SOIL INCESIIOM: MAXIHUH CONCENTRAIION OEIECIEO
AVERAGE EXPOSURE ASSUWMIONS
REASONABLE MAXI HUN EXPOSURE ASSUMPIIONS
ihcaical
:-Metbylnafnihalene
tcenapnthena
utthracene
lensola) anthracene
leniqlalpyrene
leniolbl f luor anthem
lemolg.h. ilperylene
icniofkl f luoranthena
>ia<2-Elhylhexyl )phlhatate
:hrysene
•05
"07. '
libtntofuran
luoranthena
ndeno(l.2.3-cd)pyrene
•henanthrane
•yrene
richloroethena
isenic
•erylllus
ad»iua
y an Ida
ercury (alkyl and Inorganic)
ickel
anadiua
Reference
Dose (RfD)
•g/kg-day
NA
0.06
0.3
NA
NA
NA
NA
NA
0.02
NA
NA
0.0005
NA
0.04
NA
HA
0.03
NA
0.001
0.005
0.0005
0.2
0.0003
0.02
0.007
Source •
NA
HIS
HIS
NA
NA
NA
NA
NA
HIS
NA
NA
N6AS1
NA
HIS
NA
NA
HIS
NA
N6ASI
HIS.
HIS
HIS b
HIS
HIS c
H6ASI
Average
Haxious Daily Intake
Concentration (Dl)
ug/kg Mg/kg-dey
170
230
410
5100
6900
6300
2500
6600
700
5400
76
350
160
9600
3400
3700
9100
10
6400
1400
78600
23300
120
755000
40300
.32E-08
.136-07
.OIE-07
.506-06
.386-06
.086-06
.226-06
.236-06
.426-07
.646-06
.726-08
.716-07
.836-08
.706-06
.666-06
.016-06
.456-06
.816-09
.136-06
.856-07
.856-05
.146-05
.876-08
.696-04
.976-05
Haiard
Quotient
DI/RfD
1.886-06
6.696-07
1.716-05
3.426-04
1.176-04
1.486-04
3.136-03
1.376-04
7.696-02
S.706-OS
1.966-04
1.856-02
2.826-03
Does Intake
Exceed RfD?
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
Maxiaua
Daily Intake
Percent of (Dl)
Nl av/kg-day
0.0
0.0
0.0
0.3
0.1
0.1
3.1
O.t
75.1
O.t
0.2
18.0
2.8
.I2E-08
.111 07
.OIE-07
.50E-06
.386-06
.086-06
.22E-06
.23E-06
.426-07
.64E-06
.72E-08
.716-07
.836-08
.706-06
.66E-06
.B1E 06
.4SE-06
.81E-09
.HE -06
.6SE-07
.BSE -05
.146-05
.876-08
.696-04
.976-05
Haiard
Quotient
DI/RlD
1.8aE-06
6.69E-07
-.
1.716-05
3.426-04
1.176-04
1. 486-04
3.136-03
1.376-04
7.696-02
5.706-05
1.966-04
1.856-02
2.826-03
Does Intake
Exceed RfDl
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
Percent of
Nl
0.0
0.0
0.0
0.3
0.1
O.t
3.1
O.t
75. 1
O.t
0.2
18.0
2.8
aurd Index (Sua of DI/RfD)
0.102
0.102
IXPOSURE ASSUMPIIONS
orrnntake (araaN/dav)
njPOmight (kllograM)
iratMon ingested froa conta»lnated soil (unit less)
nafurm frequency C days/year)
inpVaare Duration (years)
vaveving liaa (years)
onMacsion factor 1 (graai to kllogrea))
onftrslon factor 2 (aicrogra* to •illigraa)
lorivvlsion factor 3 (year to day)
. Sources of RfOs:
AVERAGE
0.05
70
1
250
5
5
0.001
0.001
365
REASONABLE MAXIMUM
0.05
70
1
250
25
25
0.001
0.001
365
IRIS - Integrated Risk Information Syste*. U.S. EPA 1990.
HEASI - Health Effects Assessment SuMary tables, fourth Quarter. U.S. EPA 1990
. Cyanide value based on free cyanide.
. Nickel value base on nickel-soluble salts.
A - Hot Available
F-3
-------
Hi* CUM Revised 6-26-91
Table C-10
OJMENT LAND USE: TRESPASSING CHILD SCENARIO
CARCINOGENIC HEALTH RISK EVALUATION Of SURFACE SOIL INGESTIOH: MAXIHUM CONCENTRATION DETECTED
TOMICITT EQUIVALENCE FACTORS INCLUDED
AVERAGE EXPOSURE ASSUMPTIONS
U.S.EPA
Carclnamen
Chemical Classification I
Slope
•actor
Concentration
Source a us/kg
Lifetime Average
Chemical Intake
mg/kg-dey
Excess
Lifetime
Cancer Rlak
Percent of
Riak
REASONARLE MAXIMUM EXPOSURE ASSUMPTIONS
Lifetime Maxfsus
Chemical Intake
mg/kg-day
Excess
Lifetime
Cancer Rlak
Percent of
Risk
i2-Hetaylnapiithalene
lAconephthone
Anthracene
mieniota) anthracene
•eniplajpyrone
•araolbl f luoranthene
•eoxolg.h. llperylena
•onto Ik) f luoranthena
blst2-Etaylhexyl )phthaiate
•"ysene
««
•ST
ibaniofuran
luoranthene
ndsno(1.2.3-cd)pyr«ne
iienanthrone
rrene
•rlchloroatbene
rsanlc
-rylllua
-adalua
yanlde
.;rcury (alkyl and Inorganic)
Ickel
•anadlw
MA
HA
HA
•2
•2
•2
12
•2
R2
12
R2
12
D
D
R2
0
HA
•2
A
•2
•1
0
e
HA
0
HA HA 170 .UE-09 1.68E-06
HA HA 230 .19E-09 2.28E-08
HA NA 410 .24E-09 .066-08
1.67 c 5100 -15E-07 1.92E-07 6.6 .OSE-07 B.A3E-07 6.
11. SJ b 6900 .S6E-07 1.79E-06 61.8 .8JE-07 7.87E-06 61.
1.61 c 6500 .42E-07 2.29E-07 7.9 .23E-07 1.00E-06 7.
t.2S c 2500 .ME-08 1.41E-OB O.S .47E-07 6.18E-08 0.
0.76 c 6600 .49E-07 1.13E-07 3.9 .53E-07 4.96E-07 3.
0.014 IRIS 700 .S8E-06 2.21E-10 0.0 .93E-OB 9.70E-10 0.0
O.OS1 C 5400 .22C-07 .5*6-07
0.34 IRIS 76 .71E-09 5.83E-10 0.0 .S2E-09 2.56E-09 0.0
0.34 IRIS 350 .B9E-09 2.6BE-09 0.1 .46E-OB 1.18E-00 0.1
160 .61E-09 .50E-OB
9600 .16E-07 .506-07
2.67 c 3400 .66E-00 2.05E-07 7.1 .36E-07 0.90E-07 7.1
3700 .34E-00 .66E-07
0.93 c 9100 .05E-07 • .OOE-07
0.011 NEAST 10 .06E-10 4.46E-12 0.0 .7RE-09 1.96E-11 0.0
1.5 EPA 6400 .44E-07 2.16E-07 7.5 .33E-07 9.50E-07 7.5
4.3 IRIS 1400 .16E-00 1.36E-07 4.7 .39E-07 5.96E-07 4.7
HA HA 70600 .77E-06 .70E-06
23300 .25E-07 .31E-06
120 .71E-09 .19E-00
HA HA 755000 .TOE-OS .47E-05
40300 .09E-07 .99E-06
otal EaceM llfetlav Cancer Riaka
2.90E-06
1.27E-OS
EXPOSURE ASSUNPTIOBS
AVERAQE
REASONARLE MAXIMUM
Mil Intake (graM/day)
tdJtaMalfkt (kllograM)
eStlon Ingeated fro* conteailnated aoll (unitlesa)
iaWure freo^iency (daya/year)
iiiilure Duration (yeera)
i^mina TiM
-------
ile C16A Revised 6-26-91
table C-16
CURRENI LAND USE: AOULI OCCUPAIIONAL SCENARIO
CARCINOGENIC NEAIIN BISK EVALUA1IOM Of SURFACE SOU INCESIIOH: MAXIMUM CONCENIRAIION DEIECIEO
IOXICI1V EQUIVALENCE fACIORS INCLUDED
AVERAGE EXPOSURE ASSUMPIIONS
REASONABLE MAXIMUM EXPOSURE ASSUMP1IOMS
U.S.EPA
heaicai
Card
Class!((cat
nooen
at Ion
Slopa
factor
kg-ofcyAag
Sourca a
Concentration
ug/kg
LifetisM Average
Chemical Intake
mg/kg-day
Excess
lifetime
Cancer Bisk
Percent of
Bisk
Lifetime Maximum
Chemical Intake
mg/kg-day
Excess
Li let IBM Percent of
Cancer Blak Bisk
Methylnaphthalene
cenapblbana
ntbracena
i eitsofalanthracane
tnpojalpyrene
i eniolbl f luorantbana
cniofg.b, llperylene
i eraplklf luorantbana
is(£.-ElhyllMMyl )phtbalate
hrysene
OE Zi'j
01 --
ibeniofuran •
luorantbana
ndenoCI,2,3-cd]pyrene
henantbrana
yrena
richloroatbena
rsenic
cry Ilium
Mtaiue
yanlda
ercury (alkyl and Inorganic)
ickal
•nediua
NA
NA
NA
82
82
82
82
82
82
82
82
82
0
0
82
0
HA
82
A
82
81
D
0
HA
0
NA
NA
NA
1.67
11.51
1.61
0.25
0.76
0.014
0.51
0.14
0.14
..
2.67
-.
0.93
0.011
1.5
4.3
HA
-.
--
HA
--
HA
HA
NA
c
b
c
c
c
IBIS
c
IBIS
IBIS
.-
C
..
c
NEASI
EPA
IBIS
HA
..
--
HA
"
170
230
410
5100
6900
6300
2500
6600
700
5400
76
150
160
9600
3400
3700
9100
18
6400
1400
78600
23300
120
755000
40300
.I9E-09
.61E-09
.B7E-09
.56E-08
.82E-08
.40E-08
.75E-OB
.61E-08
.89E-09
.77E-08
.31E-10
.4SE-09
.12E-09
.71E-08
.38E-08
.59E-08
.36E-08
.26E-10
.47E-08
.78E-09
.49E-07
.tie -or
.39E-10
.28E-06
.82E-07
5.95E-08
S.56E-07
7.09E-08
4.37E-09
3.S1E-08
6.BSE-11
1.8IE-10
8.32E-IO
6.34E-08
.
1.38E-12
6.7IE-OB
4.21E-08
6.
61.
7.
0.
3.
0.0
0.0
0.1
7.1
0.0
7.5
4.7
S.05E-08
6.B3E-08
1.22E-07
l.SU 06
2.05E 06
1.87E-06
7.43E-Q7
1.96E-06
2.08E-07
1.60E-06
2.26E-08
1.04E-07
4.7SE-OB
2. BSE -06
1.01E-06
1.10E-06
2.70E-06
S.3SE-09
1.90E-06
4.16E-07
2.33E-OS
6.92E-06
3.56E-08
2.24E-04
1.20E-05
2.53E-06
2.36E-05
3.01E-06
1.86E-07
1.49E-06
2.91E-09
7.60E-09
1.53E-08
2.70C-06
S.B8E-11
2.85E-06
1.79E 06
6.6
61.6
7.9
0.5
3.9
0.0
0.0
0.1
7.1
0.0
7.5
4.7
olal Excess Lifetime Cancer Risks
UPOSUBE ASSUNP1IONS
fit Intake (grams/day) d
itW Might (kilograms)
lajgplon ingested from contaminated soil (unit I ess)
iiBMjura frequency (daya/year)
tpwura Duration (year a)
vMging lima (yeara)
o«|llrston factor t (gram to kilogram)
aoMKsion factor 2 (mlcrogram to milligram)
oMfslon factor 3 (year to day)
AVERAGE
0.05
70
1
SO
5
70
0.001
0.001
365
9.00E-07 3.02E-OS
REASONABLE MAXIMUM
0.085
70
1
250
25
70
0.001
0.001
365
. Sources of BIDs:
IBIS • Integrated Blak Information Systea. U.S. EPA 1990.
EPA - Special Report on Ingested Inorganic Arsenic. July 1988.
HEASI - Health Effects Asaessaent Suosary I•bias, fourtb Ouarter. U.S. EPA 1990
. federal Register 45(231).
. Based on toxlclty equivalence factor to beniolalpyrene. Monorendua fro* Debra foraan to Mike fowle. June 1991.
. RME soil intake based on 4 hours indoors at 0.050 gat/8 bra * 4 hours outdoors
at 0.460 9/8 l>rs N 2SX fraction ingested from contaminated soil.
Coanunication Iroet Debra foraan to Juliana Nets, June 1991. Soil intake includes contaminated dust.
A: Not Available
; Not Applicable
-------
file ClflA Revised 6-26-91
fable C-1B
CURRENT LAMO USE: A04M.1 OCCUPAIIONAL SCENARIO -- INDOORS
CARCINOCENIC HE At IN RISK EVALUATION Of SURFACE SOU INCEST ION: MAXIMUM CONCENIRAIION OEIECIEO
IOXICIIV EQUIVALENCE fACIORS INCLUDED
AVERAGE EXPOSURE ASSUNPIIOHS
REASONARLE MAXIMUM EXPOSURE ASSUMPTIONS
Cheaical
U.S.EPA
Carcinogen
ClassIfleet|on
Slope
factor
Source •
MMleun
Concentration
ug/kg
LI fat law Average
Chealcal Intake
•V/kg-day
Excess
Lifetla*
Cancer Risk
Percent of
Risk
11 fells* Naxlaua
Chealcal Intake
•a/kg-day
Excess
Life!law
Cancer Risk
Percent of
Risk
2-Nelhylnephthalene
Acenaphthene
Anthracene
•eniof al anthracene
•eniolalpyrem
•eniolbl 1 luoranthene
•entafg.il. llperylene
•entolkl f iuoranthene
bisfcElhylbexyDphthalala
Chrycene
ODE '
001™
DiQgjRtofuran
flMManlhene
lnP||1.2.3-cd)pyrem
PMMftthrane
Irfjporoethane
Arstnlc
RtnMiua
CaaDLa)
CyMWe
Mercury (alky I and inorganic)
Nickel
Vanadlua
HA
MA
NA
12
•2
•2
•2
•2
•2
U
•2
12
P
•
•2
D
NA
•2
A
•2
•1
0
0
NA
0
NA NA 110 .94E-09 2.97E-OB
NA NA 2U .ME-09 4.02E-08
NA NA 410 .43E-08 .16E-00
1.67 c 5100 .78E-07 2.98E-07 6. .91E-07 1.49E-06 6.
11.5$ b 6900 .41E-07 2.78E-06 61. .21E-06 1.39E-05 61.
1.61 c 6500 .20C-07 J.54E-07 7. .10E-06 1.77E-06 7.
0.25 c 2500 .74E-08 2.18E-08 0. .17E-07 1.09E-07 0.
•.76 c 6600 .S1E-07 1.75E-07 1. .1SE-06 6.76E-07 1.
0.014 IRIS 700 .45E-08 J.42E-10 0.0 .22E-07 1.71E-09 0.0
0.51 c 5400 .69E-07 .44E-07
0.54 IRIS 76 .66E-09 9.03E-10 0.0 .3SE-OB 4.S1E-09 0.0
0.14 lilt 350 .22E-06 4.16E-09 0.1 .12E-OB 2.06E 06 0.1
160 .59E-09 .aOE-OS
9600 .15E-07 .6BE-06
2.67 c 3400 .19C-07 3.17E-07 7.1 .WE -07 1.59E-06 7.1
3700 .29E-07 .46E-07
0.93 c 9100 .15E-07. .59E-06
0.011 NEASI 18 .29E-10 6.92E-I2 0.0 .1SE-09 3.46E-11 0.0
1.5 EPA 6400 .24E-07 3.35E-07 7.5 .12E-06 1.66E-06 7 5
4.3 IRIS 1400 .B9E-08 2.10E-07 4.7 .4SE-07 LOSE 06 4 7
NA NA 71600 .75E-06 .37E-05
23300 .14E-07 .07E-06
120 .19E-09 .10E-OB
NA NA 755000 .64E-05 .32E-04
40300 .41E-06 .ME -06
total Excess Llfetiaw Cancer Risks
4.SOE-06
Sources of RfOs:
IRIS - Integrated Risk Information Syataai. U.S. EPA 1990.
EPA - Special Report on Ingested Inorganic Arsenic, July 1988.
NEASI - Health Effects Assessatent Suawy fables, fourth Quarter. U.S. EPA 1990
b. federal Register 45(231).
Rased on tpnicity equivalence factor to benio(a)pyrene. Meanranduaj fro* Debra forswn to Nike Towle. June 1991.
HA:
Hot Available
Not Applicable
2.2SE-OS
EXPOSURE ASSUNPIIONS
Soil intake (greaw/day)
Body Height (kilogram)
fraction ingested fro* contaaiinated soil (unitless)
E>po«ure frequency (days/year)
Expoaure Duration (years)
Averaging flaw (years)
Conversion factor 1 (great to kllograat)
Conversion factor 2 (•Icroflra* to ail! (great)
Conversion factor 3 (year to day)
AVERAGE
0.05
70
1
250
5
70
0.001
0.001
365
REASONARLE MAXIMUM
0.05
70
1
250
25
70
0.001
0.001
365
-------
le C2BA levised 6 26 91
Iable C-28
fUlURE LAND USE: TODDLER RESIDENTIAL SCENARIO
MOHCAICIMOGEN1C HEALTH RISK EVALUATION Of SURFACE SOIL INCESIIQH: NAXINUN CONCEHIRATION OE1ECIED
AVERAGE EXPOSURE ASSUMPTIONS
esUcal
Nethylnephtbalene
thracena
tniolalenthr scene
nzolalpyrane
wuolbl I iuoranthana
nzofg.h. llperylene
molkl f luarantbana
•(2-Ethylheiyl )pfcthalate
rysane
••;
1
bantofuran
uorantaene
d-nolt ,2.3-cdlpyrene
:±nanlhrana
Ichloroethene
senic
rytllua
dslua
anide
rcury (alkyl and Inorganic)
cket
nadlua
Reference
Dose (IfD)
av/kg-day
NA
0.06
0.1
NA
NA
NA
NA
NA
0.02
NA
NA
0.0005
NA
0.04
NA
NA
0.01
NA
0.001
0.005
0.0005
0.2
0.0001
0.02
0.007
Source a
NA
IRIS
IIIS
NA
NA
NA
NA
NA
IIIS
NA
NA
•EAST
NA
IIIS
NA
NA
IIIS
NA
HEAST
IRIS
IRIS
IIIS b
IIIS
IRIS C
HEAST
Averege
NaxlauB Daily Intake
Concentration (01)
ug/kg ag/kg-day
170 4.19E-07
230 .67E-07
410
5100
6900
6300
2500
700
S400
76
ISO
160
9600
1400
1700
9100
10
6400
1400
70600
21100
120
755000
40100
.011 06
.26E-OS
.TOE-OS
.S5E-OS
-16E-06
.63E-OS
.73E-06
.33E-OS
.07E-07
.63E-07
.95E-07
.37E-OS
.10E-06
.12E-06
.24E-OS
.44E-00
.SOE-OS
.4SE-06
.94E-04
.7SE-OS
.96E-07
.06E-01
.94E-OS
Hazard
Quotient
Dl/lfO
9.4SE-06
1.17E-06
0.63E-05
1.73E-01
5.92E-04
7.40E-04;
1.50E-02
6.90E-04
3.80E-01
2.07E-04
9.06E-04
9.31E-02
1.42E-02
REASONABLE NAXINUN EXPOSURE
Naniaua
Dally Intake
Does Intake Percent of (Dl)
Exceed RfO? HI av/kg-day
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
0.0
0.0
0.0
0.3
0.1
0.1
3.1
0.1
75.1
0.1
0.2
10.0
2.0
.70E-07
.S2E-06
.36E-06
.9JE-05
.97E-OS
.62E-OS
.44E-OS
.OOE-OS
.01E-06
.HE-OS
.17E-07
.01E-06
.21E-07
.S2E-OS
.96E-05
.11E-OS
.24E-OS
.04E-07
.60E-OS
.OSE-06
.S2E-04
.34E-04
.90E-07
.34E-03
.32E-04
Hazard
Quotient
OI/RIO
2.21E-05
7.06E-06
(
2.01E-04
4.03E-03
1.30E-03
1.7SE-03
3.60E-02
1.61E-03
9.04E-01
6.70E-04
2.30E-03
2.17E-01
3.3IE-02
ASSUMPTIONS
Does Intake
EMceed RfOf
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
Percent of
HI
0.0
0.0
0.0
0.3
0.1
O.I
3.1
O.I
75.1
0.1
0.2
10.0
2.0
Into* (Sua of DI/RfO)
0.516
1.204
ASSUMPTIONS
AVERAGE
REASONAILE NAXINUN
•mintake (graM/day)
^.Height (kilogram)
ion Ingeated from contaolnated aoll (unities*)
freojuancy (days/year)
Duration (years)
lia* (years)
tion factor 1 (great to kilograai)
iweralon factor 2 (•Icrograa to •illigraai)
-•version factor 1 (year to day)
0.2
16
1
72
6
6
0.001
0.001
165
0.2 d
16
1
160
6
6
0.001
0.001
36S
Sources of RfOa:
IRIS - Integrated Risk Inforawtion Systesi. U.S. EPA 1990.
HEASI • Health Effects Assassavnt Suanary Tables, fourth Quarter. U.S. EPA 1990
Cyanide value based on free cyanide.
Nickel value bate on nickel-soluble salt*.
RNE of 0.2 g/day soil intake as per aoaorandua fro* Nike Towle to Joe Cleary. June 1991.
- Hot Available
F-7
-------
fit* C50A levUod 6-20-91
Table C-JO
fUIUM LAND USE: CNIID lESIDENTIAL SCENAIIO
NDNCMCINOGENIC NEAUN UK EVALUATION OF SURFACE Mil INCEST ION: NAKIMJM COHCCHTIUI ION OEIECIEO
AVEIAGE EXPOSUU ASSUMPTIONS
•EASONMIE MAXIMUM EKPOSUU ASSUMPTIONS
Chemical
•aference
Do** (IfO)
•o/ko-*y
Average
Naxlaua Dally Inlaka
Concentration (01)
• ug/kg av/kg-day
Naiard
Ouatlont Po«t Intake Percent of
•l/lft Ewaad IfOt HI
Na«Uu*
Daily Intaka
(Dl)
e»/kg-day
Naiard
Quotient Ooea Intake Percent of
01/110 Eweed tfO? Ml
2-Nethylnaf*thaiana
AcenepMbcra
Antnracane
leniofal anthracene
Oeniolalpyrane
Oaniolbl f luoranthane
OejuoCg.h. llperylen*
Oaniolkl f luoranlhena
bl*<2-Ethylbaayt)f*tbalate
ChfyMna
ODE
00.1
OlaejHefuran
fiaganthena
lrJBol»,2,5 cdjpyrene
Pfcjggnthrem
If%9lorootbano
AQJMHiC
geKfllui
CaHMua
CiflBda
Mercury (alkyl and Inorganic)
Nickel
Vanadlua
MA
0.06
0.5
MA
MA
MA
MA
MA
0.02
MA
MA
0.0005
MA
0.04
MA
MA
0.05
MA
0.001
0.005
0.0005
0.2
0.0005
0.02
0.007
MA
HIS
HIS
MA
MA
MA
MA
MA
HIS
MA
MA
NEAST
MA
HIS
MA
MA
HIS
MA
NEAST
IIIS
.HIS
IIIS b
IIIS
IIIS c
MEASf
170
250
410
5100
6900
6500
2500
6600
700
5400
76
5SO
160
9600
5400
5700
9100
10
6400
1400
70600
25500
120
755000
40500
.62E-00
.05E-07
.04E-07
.29E-06
.09E-06
.02E-06
.12C-06
.96E-06
.14E-07
.42E-06
.41E-00
.57E-07
.1/E-OO
.50E-06
.S2E-06
.66E-06
.OOE-06
.07E-09
.07E-06
.20E-07
.52C-05
.046-05
.501-00
.50E-04
.01E-OS
1.721-06
6.15f-07
1.57E-05
5.14E-04
1.0K-04
1.561-04
2.07E-05
1.26E-04
7.05C-02
5.22C-OS
1.79E-04
1.69E-02
2.50E-05
NO
HO
NO
NO
NO
NO
NO
NO
MO
HO
NO
NO
NO
0.0
0.0
0.0
0.5
0.1
0.1
5.1
0.1
75.1
0.1
0.2
10.0
2.0
.10E-07
.04E-07
.121-07
.11E-06
.S9E-06
.10E-06
.02E-06
.ME 04
.67E-07
.57E-04
.1SE-00
.05E-07
.50E-07
.771-04
.7SE-06
.OOE-06
.J7E-04
.46C-OB
.1IE-04
.15E-06
.56E-05
.09E-OS
.71E-00
.11E-04
.26C-OS
5.10E-06
1.11E-06
A
2ioiE-OS
5.67E-04
1.94E-04
2.46E-04
S.10E-05
2.27E-04
1.27E-01
9.45E-OS
5.24E-04
5.04E-02
4.66E-05
MO
NO .
NO
NO
MO
NO
NO
NO
NO
NO
NO
NO
NO
0.0
0.0
0.0
0.5
0.1
O.t
I.I
O.t
75.1
0.1
0.2
10.0
2.0
Naiard IndiM (Cua of Ol/lfO)
O.OM
0.169
EMPOSUtf ASSUMPflflMS
Soil Intake (sraM/day)
Oody walffjit (klloa/Ma)
fraction Ineeated fro* contoalnated aoll (unltleaa)
EMOoeure frequency (days/year)
EMfMtaure Our at Ion (year*)
Averaolno I low (yewa)
Converaion factor 1 (ore* to kilogram)
Conweralon factor 2 (•IcrooroB to •Illloraai)
Convert Ion factor 5 (year to day)
AVCtAtf
O.t
44
1
72
9
9
0.001
0.001
565
•FASQMAMC HAIIMM
0.1
44
1
150
11
11
0.001
0.001
565
a. Source* of IfOat
IIIS - Integrated llak Information Syatea. U.S. EPA 1990.
NEASI • Health Effect* Aaaeaaawnt Suevary Table*, fourth Quarter. U.S. EPA 1990
b. Cyanide value baaed on free cyanide.
c. Nickel value baaed on nickel-aoluttle aalta.
HA - Not Available
F-8
-------
file C32A levleed 6-27-91
fable C-32
FUTURE LAND USEi ADULT KSIOfNIIAL SCENAIIO
NQNCARCINufiEHIC HEALTH RISK EVALUATION Of SURFACE SOIL INGESTIOH: MAXIMUM CONCENTRATION DETECTED
AVERAGE EXPOSURE ASSUMPTIONS
REASONABLE MAXIMUM EXPOSURE ASSUMPTIONS
CheBlca!
2-Netkylnaphthalano
Aceneplitbene
Antkrecene
•eniofa) anthracene
•eniolelpyrene
lepiolb) f luoranthem
•aniofg.h. llperylone
Oeniaf kl fluoran thane
bis(2-Ethylhexyl )phthelate
Chryseno
DOE
DDT
Dibffuofuren
FldDtntheno
lndjn»(l.2.3-cd)pyrane
Phapenthreno
py|M
TrCfc»orMthene
Arsenic
BefyNlua
CeflUuB
CMMUda
NlrKry (alkyl and Inorganic)
Nickel
Vensdlue
Reference
DOM (IfO)
ao/kg-dsy
NA
0.06
0.1
NA
NA
NA
NA
NA
0.02
NA
NA
0.0005
NA
0.04
NA
NA
0.03
NA
0.001
0.005
0.0005
0.2
0.0003
0.02
0.007
Source a
NA
IIIS
IIIS
NA
NA
NA
NA
NA
IIIS
NA
NA
NEAST
NA
IIIS
NA
NA
IIIS
NA
NEAST
IIIS
IIIS
IRISb
IIIS
IIIS C
NEASI
Average
MaxlouB Dally Intake
Concentration (01)
ug/kg •g/ki-day
170 4.79E-00
230
410
5100
MOO
6300
2500
MOO
700
MOO
76
350
160
9600
MOO
1700
9100
10
6400
1400
70600
23300
120
.40E-00
.16E-07
.44C-Q6
.94E-06
.70E-06
.051-07
.061-06
.97E-07
.S2E-06
.HE-OB
.R6E-08
.S1C-00
.716-06
.50E-07
.04E-06
.56E-06
.07E-09
.OOE-06
.95E-07
.21E-OS
.S7E-06
.36C-00
755000 2.13E-04
40300 1. HE-OS
Retard
Quotient
OI/RfO
1.00E-06
3.05E-07
9.06E-06
1.97E-04
6.76E-05
O.S5E-05
1.00E-03
7.09E-05
4.43E-02
3.20E-05
1.13E-04
1.06E-02
1.62E-03
DOM Intake
Exceed Rf07
HO
HO
NO
NO
NO
HO
NO
NO
NO
NO
NO
NO
NO
Maxlaue
Dally Intake
Percent of (01)
HI ag/kg-dsy
0.0
0.0
0.0
0.3
0.1
0.1
3.1
0.1
75.1
0.1
.12E-07
.S1E-07
.70E-07
.551-06
.S4E-06
.HE 06
.64E-06
.ME-06
.60E-07
.55E-06
.OOE-00
.30E-07
.05E-07
.I1E-06
.24E-06
.43E-06
.9BE-06
.18E-00
.21E-06
.211-07
.ire-os
-5JE-05
0.2 7.B9E-00
10.0 4.96E-04
2.0 2.6SE-05
Neierd
Quotient
DI/lfD
2.S2E-06
0.99E-07
..
2.30E-OS
4.60E-04
1.50E-04
1.99E-04
4.21E-03
1.04E-04
1.03E-01
7.66E-05
2.63E-04
2.4BE-02
3.79E-03
DOM Intake
Exceed RfOf
HO
HO
HO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
Percent of
HI
•
0.0
0.0
0.0
0.3
0.1
O.t
3.1
0.1
75.1
O.I
0.2
ta.o
2.0
Mierd Index (Sua of Ol/lfO)
0.059
0.130
EIPOSUBE ASSUMPTIONS
Soil Intake (gram/day)
lody Melfkt (kitoeraaa)
fraction Invested froa centaalnated Mil (unities*)
Expoaure frequency (daya/year)
Expoaure Duration (years)
Awereglna Tl*e (year*)
Conversion factor 1 (ara» to klloarexi)
Conversion factor 2 (•icrotraei to •! Ultra*)
Conversion factor 3 (year to (toy)
AVERAGE
0.1
70
1
72
9
9
0.001
0.001
36S
SEASONABLE MAXIMUM
0.1
70
1
160
30
30
0.001
0.001
365
e. Sources of IfOat
IRIS - Integrated llsk Information Systesi. U.S. EPA 1990.
MEAST - Neeltb Effects AsietssMnt SUMary Tables, fourth Quarter. U.S. EPA 1990
b. Cyanide value based on free cyanide.
c. Mickcl value based on nickel-eoluble selts.
NA - Hot Available
-------
• CJoA Revised 6-26-VI
I able C-J6
fUIURE LAND USE: TODDLER RESIDENIIAL SCENMIO
CARCINOGENIC HEAtIN RISK EVAIUAIION Of SURFACE SOIL INCESIION: NAXINUN CONCENTRATION OEIECIEO
IOXICIIV EQUIVALENCE fACIORS INCLUOEO
AVERAGE EXPOSURE ASSUMPTIONS
REASONARLE NAXINUN EXPOSURE ASSUNPIIOMS
-leal
nethylnaphthatana
-^eonthene
eJCfccene
niqfal anthracene
-Jofalpvrana
niolblfluoranthene
[uolg.h, llperylone
iMMfluorantlMne
iQ* thylhaxyl )phthalata
ioHnRTlMl
o
^-jofuran
^wthane
•aVRl.2,1 cdlpyrene
eMhrane
enic
ylllua
lue
tide
cury (alkyl and Inorganic)
kel
-dlua
U.S. EPA
Carcinogen
Classification
MA
MA
MA
M2
•2
02
•2
02
•2
02
02
•2
g
g
•2
0
MA
02
A
02
01
0
0
MA
*
Rlopa
factor
kg-dey/aa
MA
MA
MA
1.67
11.51
1.61
0.2S
0.76
0.014
O.S1
O.M
0.14
..
..
2.67
--
0.91
0.011
t.S
4.1
HA
--
--
MA
••
Source a
HA
MA
MA
c
I)
c
c
c
IRIS
c
IRIS
lilt
• •
..
c
• »
c
HEASI
EPA
IRIS
HA
» •
--
MA
••
NaxlaMi Llfatlae Average
Concentration Caeaical Intake
ug/kg ao/kg-day
170
2 JO
410
5100
6900
6100
2500
6600
700
5400
76
ISO
160
9600
1400
1700
9100
10
6400
1400
70600
21100
120
755000
40100
.S9E-00
.86E 08
.67E-00
.OOE-06
.46E-06
.11E-06
.28E-07
.J9E-06
.48E-07
.14E-06
.61E-00
.40E-08
.IOC-OB
.01E-06
.19E-07
.02E-07
.92E-06
.BOE-09
.35E-06
.96E-07
.66E-OS
.92E-06
.S4E-08
.60E-04
.S2E-06
Excess
LtfettM
Cancer Risk
t.aOE-06
1.6BE-05
2.14E-06
1.12E-07
1.06E-06
2.07E-09
S.46E-09
2.S2E-OB
1.92E-06
'
4.18E-11
2.03E-06
1.27E-06
Lifetime Naxiaua
Percent of Cheat cat Intake
Risk ag/kg-day
6.6
61.0
7.9
O.S
1.9
0.0
0.0
0.1
7.1
0.0
7.5
4.7
.UE-oa
.HE -07
.02E-07
.S2E-06
.40E-0&
.HE -06
.21E-06^
.25E-06
-45E-07
.66E-06
.75E-08
.736-07
.09E-00
.73E-06
.60E-06
.82E-06
.49E-06
.OOE-09
.T6E-06
.90E-07
.OK-OS
.ISC-OS
.92E-08
.72E-04
.99C-05
Exceaa
Llfatiae
Cancer Rlak
,
4.20E-06
3.92E-OS
5. OOE-06
3.00E-0?
2.47E-06
4.8SE-09
1.27E-00
S.M7E-M
4.48E-06
9.76E-I1
4.73E-06
2.97E-06
Percent of
Risk
6.6
61.0
7.9
O.S
3.9
0.0
0.0
0.1
7.1
0.0
7.5
4.7
•1 fxcMB
M Cancor R»»k«
2.72E-OS
6.HE-OS
lOSURf ASSUNPIIOMS
AVERAGE
REASONABLE NAXINUN
I Intake (praM/day)
, Might CklloaraM)
tctlon Inaaataal fro* contaalnatad aoil (unltlaat)
Maura fraojuancy (daya/yaar)
waura puratlon (yaara)
raaina flaw (yaara)
Waion factor 1 (ITOB to kltograa)
varalon factor 2 (•Icrooraai to •illloraa)
varalon factor 1 (yaar to day)
0.2
16
1
72
6
70
0.001
0.001
165
0.2 d
16
1
166
6
70
0.001
0.001
I6S
Sources of RfDai
IRIS - Integrated Risk Infonaitlon Systaa. U.S. EPA 1990.
EPA - Special Report on Ingested Inorganic Arsenic, July 1980.
HEASI - Health Effects Assaaaamt SuMary lablaa. fourth Quarter. U.S. EPA 1990
federal Register 45(211).
Based on tonlcity equivalence factor to beniolalpyrene. Neaurandus fro* Oebra forwt to Nike Ionic, June 1991.
•HE of 0.2 g/day soil Intake as per amaorandua fro* Nike Towla to Joe Cleary. June 1991.
Not Available
Not Applicable
-------
• C40A Revised 4-26-91
table C-40
FUIURE LAND USE: CM110 IfSIOENIIAL SCENARIO
CARCINOGENIC MEAIIH RISK tVALUAIIOM Of SURFACE SOU IHCESflOM: MAXIMUM COHCENIRAIIOH DEIECIED
10XICI1V EQUIVALENCE FACTORS IHCIUDEO
AVEtAGE EXPOSURE ASSUMPTIONS
REASONABLE MAXIMUM EXPOSURE ASSUMPIIONS
U.S.EPA
Card
ClassIf(cat
nogan
:at|on
Slop*
factor
Source •
Conetntrat I on
ug/kg
11 fat Us Avaraga
CkMlcal Intaka
•g/kg-day
Excess
llfatlM
Cancar llafc
Parcant of
• lak
llfatlM NaxlM
Chaalcal Intaka
ag/kg-day
Exctaa
lltatlM
Cancar Ilak
Parcant of
• lak
lathylnapMftalana
ntpMhane
kracana
Mofalanthracana
iolalpyrane
iiolblfiuorantliana
tofg fc.llperylana
iiolklfiuorantlMna
l(2-Etftylke«yl)pntlMlata
yaana
craofuran
cjRnthana
:ao|1.2.1-cd)pyrana
-*nthrana
-y»
-plorostkane
;sle
,-IUua
JIM
•Ida
ury (alkyl and Inorganic)
at
^lui .
NA
MA
M
•2
•2
•2
•2
•2
•2
•2
•2
•2
•
•
•2
•
M
•2
A
•2
•1
•
0
MA
•
MA MA 170 .6DE-09 2.16E-OB
MA NA .210 .IK-OB 2.9SE-08
MA MA 410 .ME -08 .2ft -08
1.67 c SIM .94E-07 4.91E-07 6. .49E-07 I.06E-06 6.
1I.5J b 4900 .98E-07 4.S9E-06 61. .78E-07 1.01E-05 61.
1.61 c 6300 .65E-07 S.65E-07 7. .01E-07 . 1.29C-06 7.
0.2S c 2500 .44E-07 1.60E-06 . .I8E-07 7.95E-08 0.
•.76 c 6600 .80E-07 2.89E-07 . .40E-07 6.UE-07 S.
0.014 HIS 700 .OSE-OB S.6SE-10 . .90E-00 1.2SE-09 0.
•.Oil C MOO .11E-07 .47E-07
O.M lilt 76 -58E-09 1.49E-09 .0 .67C-OV I.29E-09 0.0
O.M HIS 350 .02E-00 6.86E-09 .1 .45E-OB 1.S1E-08 0.1
-- 160 .22E-09 .04E-08
9600 .53E-07 . .22E-06
2.67 c 1400 .96E-07 S.2X-07 7.1 .J2E-07 1.1SE-06 7.1
1700 .111-07 .716-07
0.91 C 9100 .25E-07 .16E-06
0.011 NEASI 10 .04E-09 1.14E-11 0.0 .29E-09 2.52E-1I 0.0
1.5 EPA 6400 .69E-07 5.SSE-07 7.5 .HE -07 I.22E-06 7.5
' 4.1 HIS 1400 .07E-06 1.47C-07 4.7 .78E-07 7.66E-07 4.7
MA MA 78600 .5X-06 .OOE-05
21300 .141-06 .96E-06
120 .92E-09 .53E-00
MA MA 755000 .15E-05 .60E-05
4*100 .121-06 .11E-06
•i Ewaaa llfatlaa Cancar Mlaka
MUM MtunriioMt
n Intaka Cpraaa/day)
- Malgkt (MIograM)
g" n Ingaatad from contaalnatad aoll Cwlttaaa)
a fraojuancy (daya/yaar>
a turatlon (yaara)
ng flaw (yaara)
Calon factor 1
-------
le C«A Revised 6-27-91
Iable C 4*
FUTURE LAND USE: ADULT RESIDENTIAL SCENARIO
CARCINOGENIC HEALTH RISK EVALUATION OF SURF ACE. SOU INGESIIOH: NAXINUN COMCEN1RAIION OEIECIED
lOXICIM EQUIVALENCE FACTORS INCLUDED
AVERAGE EXPOSURE ASSUMPTIONS
sslcal
U.S.EPA
Carcinogen
Classification
Slope
Factor
Nan ISMS
Concentration
Source a ug/kg
Llfetla* Average
Cheajlcal Intake
av/kg-day
Excess
It fat la*
Cancer Rlak
Percent of
RUk
REASONABLE MAXIMUM EXPOSURE ASSUMPTIONS
Llfetla* Men (sue
Cheailcal Intake
an/kg-dey
Excess
llfetla*
Center Rlak
Percent of
RUk
iNethylnaphthalene
enephtheno
•Kractne
Huola) anthracene
-ritolalpvrene
Muolbl f luoranthene
rniolg.h.llperylane
biiofklf luoranthene
is(2-Ethylheiyl)phthelate
ryaeno
5
)•
btniofuran
uoranlhano
-?i!no(1,2.3-cd)pyrene
enentferene
/rent
Ichloroethcne
aenlc
ryllliai
islua
anlda
rcury (atkyl and Inorganic)
ckel
t^sdlua
M
NA
M
•2
•2
U
U
U
U
•2
•2
•2
•
0
12
•
M
•2
A
•2
•1
•
•
M
0
M NA 170 .I6E-09 4.79E-08
NA NA MO .S1E-09 .48E-(W
NA NA 410 .49E-08 .166-07
1.67 c 5100 .05E-07 3.09E-07 6.6 .44E-06 2.40E-06 6.6
11.53 b 6900 .50E-07 2.68E-06 61.8 .WE -06 2.24E-05 61.8
1.61 c 6SOO .28E-07 J.67E-07 7.9 -78E-|6 2.86E-06 7.9
0.25 c 2500 .06E-OB 2.26E-08 0.5 .05E-07 1.76E-07 0.5
0.7* C 6600 .S9E-07 1.B2E-07 3.9 .86E-06 1.41E-06 3.9
0.014 HIS 700 .54E-08 3.5SE-10 0.0 .97E-07 2.76E-09 0.0
0.051 NA c 5400 .966-07 .52E-06
0.34 HIS 76 .75E-09 9.36E-10 0.0 .14E-08 7.26E-09 0.0
0.34 lilt 350 .27E-08 4.31E-09 0.1 .86E-OB 3.35E-08 0.1
160 .80E-09 .S1E-08
9600 .48E-07 .71E-06
2.67 C 3400 .23E-07 3.29E-07 7.1 .S8E-07 2.56E-06 7.1
3700 .34E-07 • .04E-06
0.93 C 9100 .30E-07 .56E-06
0.011 NEAST 18 .52E-10 7.17E-12 0.0 .07E-09 5.5BE-1I 0.0
1.5 EPA 6400 .32E-07 3.48E-07 7.5 .80E-06 2.71E-06 7.5
4.3 HIS 1400 .07E-08 2.18E-07 4.7 .95E-07 1.70E-06 4.7
NA NA 78600 .WE- 06 .21E-05
23300 .44E-07 .57E-06
-• 120 .3SE-09 .JBE-08
NA NA 755000 2.74E-OS .13E-04
40300 1.46E-06 .14E-05
tal EMeaa II fat la* Cancer Rlaka
4.66E-06
3.63E-05
tPOSUK AStUNPIIONf
AVERAGE
REA80NAILE NAXINUN
ill
Intake (araaa/day)
Melfht (kllagraM)
Ion Ingeated froai contaailnatod aolt (wiltlaaa)
~ frequency (daya/yaar)
•tN-atlon Cyaara)
nf Ila» Cyaara)
Ian rector 1 (great to kllograai)
Ian factor 2 <«lcrograe> to •Illlgraai)
Ion factor 3 (year to day)
0.1
70
1
72
9
70
0.001
0.001
365
0.1
70
1
168
30
70
0.001
0.001
365
tiQrcea of RfOa:
IMS - Integrated Rlak Inforaatlon Syatea). U.S. EPA 1990.
M* - Special Report on Ingeated Inorganic Arsenic. July 1988.
IEASI - Neelth Effects Aeeeaea*nt Suaaery Table*. Fourth Quarter, U.S. EPA 1990
federal Register 45(231).
•osed on toiilclty equivalence factor to beniolalpyrene. Neanrandua) fro* Debra Foraan to Nike Towle, June 1991.
: Not Available
: Not Applicable
-------
File C58A Revised 6-27-91
lable C 58
FUTURE LAND USE: IOOOLER RESIDENTIAL SCENARIO
IMNCARCINOGENIC HEALTH RISK EVALUATION Of SUBSURFACE SOIL INGEST ION: MAX I MM CONCENTRATION DETECTED
AVERAGE EXPOSURE ASSUMPTIONS
REASONABLE MAXIMUM EXPOSURE ASSUMPTIONS
ChMlcal
Arochlor 1294
2-MethylnapMftslene
bis(2-EthyltMayl iphthalata
DOT
Naphthalene
cls-1.2-0lchloroethena
trans- 1,2-OlcfclorotlMne
letrachioroethena
IrlcMoroethene
lotal lylanea
Arsenic
Oerylllus
Cadalua
Cyanide
Nickel
Vanadlua
Reference
Dost (RfO)
esj/kg-day
NA
M
0.02
0.0005
t.004
0.01
0.02
0.01
M
2
0.001
0.005
0.0005
0.2
0.02
0.007
Average Max (BUI
Naxlnua Dally Intake Nsterd Dally Intake Haiard
Concentration (Dl) Quotient Does Intake Percent of (01) Quotient Does Intake Percent of
Source a us/kg •o/kg-day DI/RfO Exceed RIOT Nl ao/kg-day OI/RIO Exceed RIOT HI
HA 2100 -1BE-06 -21E-OS
M 740 .82E-06 .26E-06
IRIS 1200 -96E-06 1.48E-04 NO 0.1 .90E-M J.45E-04 NO 0.1
NEASI 50 .41E-07 2.86E-04 NO 0.2 .ME-07 6.67E-04 NO 0.2
NEAST 460 ,1JE-06 2.04E-04 NO 0.2 .6SE-06 6.62E-04 NO 0.2
•EAST 6 .4BE-00 1.4K-06 NO 0.0 .45E-08 3.45E-06 NO 0.0
HIS « .48E-08 7.40E-07 NO 0.0 .4SE-08 1.73E-06 NO .0.0
IBIS 46 .15E-07 1.15E-05 NO 0.0 .65E-07 2.6SE-05 NO 0.0
NA 7000 .73E-05 .05E-05
IRIS 16 -95E-08 1.97E-00 NO 0.0 .21E-OB 4.6OE-OB NO 0.0
NEAST 7900 .95E-05 1.95E-02 NO 16.0 .5SE-05 4.SSE-02 NO 16.0
UIS 1200 .94E-06 5.92E-04 NO O.S .901-06 1.30E-OI NO 0.5
IRIS 15600 .OSE-05 7.69E-02 NO 61.0 .98E-OS 1.60E-01 NO 65. 0
IRIS b 12100 .05E-05 1.S2E-04 NO ' 0.1 .OOE-05 1.S4E-04 NO 0.1
IRIS c 01400 .01E-04 1.00E-02 HO 0.2 .68E-0* 2.S4E-02 NO 0.2
NEAST 40300 .94E-05 1.42E-02 NO 11.6 .S2E-04 J.J1E-02 NO 11.6
Haiard Index (Sua of DI/RfD)
0.122
0.285
1 EXPOSURE ASSUMPTIONS
AVERAGE
REASONABLE NAKINUN
Soil Intake (grama/day)
Body Height (kilograms)
i Fraction Ingested fro* contasilnated soil (unit less)
Exposure fraqutnty (days/yaw)
Exposure Duration (years)
Averaging KM (yesrs)
Conversion factor 1 (graai to kilogram.)
Conversion factor 2 (•lerograra to milligram)
Conversion factor 3 (year to day)
0.2
16
1
72
6
6
0.001
0.001
365
0.2 d
16.
1
160
6
6
0.001
0.001
5*5
EK Sources of RfOs:
~^IRIS - Integrated Risk Information Systea). U.S. EPA 1990.
EPA - Special Report on Ingested Inorganic Arsenic. July 1988.
NEASI - Health Effects Assessment Suaaary Tables, fourth Quarter. U.S.
EPA 1990
Cyanide value based on free cyanide.
T Nicke
ckel value based on nickel-soluble salts.
-tfr RNE of 0.2 a/day soil Intake as per memorandum fro* Nike Towle to Joe CI eery. June 1991.
-m • Hot Available
±0
F-13
-------
C64A Revised 6-27-91
table C 64
FUTURE LAW USE: ICOOLEI RESIDENTIAL SCENARIO
CARCINOGENIC HEALTH RISK EVALUATION OF SUBSURFACE SOIL INGESIION: MAX I NUN CONCENTRATION DETECTED
AVERAGE EXPOSURE ASSUMPTIONS
REASONABLE MAXIMUM EXPOSURE ASSUMPTIONS
lcm\
U.S.EPA
Carcinogen
Clarification
Slop*
Factor
kg-day/a*
Source a
Maxim
Concentration
LIletla* Average
Oiaa)lcat Intake
•g/kg-day
Enceaa
llfetla*
Cancer Risk
Percent of
RUk
Iffctta* MantMi
Chealcal Intake
ev/kg-dey
EHceaa
LlfetlM
Cancer tick
Percent o(
Rl»k
lor 1254
hylnantithaleno
[-Etfcylk
-------
le C66A Revised 6-27-91
Table C 66
fUlURE LAND USE: CHILD KSIDENIIAl SCENARIO
CARCINOGENIC HEAIIH RISK EVAUMIION Of SUBSURFACE SOU INCESIION: MAXIMUM CONCEHIRAtlON OEIECIEO
AVERAGE EXPOSURE ASSUMPIIONS
REASONABLE MAXIMUM EXPOSURE ASSUMPIIONS
tarical
U.S.EPA Slope Manlaus
Carcinogen factor Concentration
Classification kf-slsy/agj Source • ug/kg
LlfetlM Average
Chaailcal Intake
a»/kg-day
EMceaa
LlfetlM
Cancer Risk
Percent of
RUk
Lifetlsw Mafttaua
Cheailcal Intake
•g/kg-dsy
Eiiceaa
IIfat law
Cancer Htsk
Percent of
Risk
octilor 1254
•jetRylnepkthalena
s(2-E thrthexyl HAtkalate
I
phthalene
•-1.2-Hlchloraetkene
ens 1.2-aicfcloroe thorn
trachlaroetfcon*
Ichloreethent
tal Xytenes
sanlc
rylllua
dMtua
enlde
ckel
nadlua
U
M
U
•2
D
•
•
U
U
•
A
U
•1
0
HA
0
7.7
M
o.ou
».S4
..
..
0.051
l.tll
••
1.9
4.S
HA
M
• V
IRIS 2100 1.2IE-07 9.32E-07 48.6 2.67E-07 2.06E-06 48.6
HA 740 4.27E-08 .4IE-08
IRIS 1200 .92E-OB 9.68E-IO O.t .SIE-07 2.14E-09* O.I
IRI» 58 .B4E-09 1.14E-09 O.I .38E-09 2.51E-09 O.I
460 .65C-08 .85E-08
6 .46E-10 -6JE-10
6 .46E-10 .61E-10.
HEAST 46 -65E-09 1.35E-10 0.0 .WE -09 2.9BE-10 0.0
•Mf 7000 .OJE-07 4.441-0? 0.2 .90E-07 9.79E-09 0.2
16 .22E-10 .ME -09
EPA 7900 .SSE-07 6.85E-07 35.6 .OOE-06 1.5 IE -06 3S.6
IRIS 1200 .92E-08 2.97E-07 15.5 .55E-07 6.56E-07 15.5
KA 15600 -99E-07 .9K-06
12300 .09E-07 .S6E-06
M 81400 .69E-06 .0*6-05
40300 .32E-06 . .13E-06
Ul Encesa U fat law Cancer Rlaka
1.92E-06
4.24E-06
I POSURE ASSUNPMOn
AVERAGE
MAXIMUM
(•raw/day)
(kltofraa*)
II Intake
dy Mtlflkt ___________
i action Inteated fro* contaminated soil
i posure rreo^wncy (dkyB/
i poaure Duration (years)
i eraflnp live (yeara)
I iwerslan factor 1 (ajraai to ktlotraat)
i ifMrslon Factar 2
-------
file C68A Revised 6 27-91
C:
Table C-68
FUTURE LAND USE: ADUU RES IDEM HAL SCENARIO
CARCINOGENIC HEALTH RISK EVALUATION OF SUBSURFACE SOIL INCESIION: MAXIHUH CONCENTRATION DETECTED
AVERAGE EXPOSURE ASSUMPTIONS
REASONABLE MAXIMUM EXPOSURE ASSUNPIIONS
U.S.EPA
Che»tcat
Card
CUsstflcat
inofvn
:atton
Slop*
factor
kg-dsy/*)
Source •
HaxllMi
Concentration
ug/kg
Lifetime Average
Chealcal Intake
•g/kg-day
Execs*
LlfetlM
Cancer Risk
Percent of
Risk
llfetla* HaNlmm
Cheailcal Intake
•g/kg-day
Excess
LlfetlM
Cancer Risk
Percent of
Risk
Arochlor 125*
2-Methylnephthalene
bls(2-EthyU*xyl)phthalate
~>T
Naphthalene
els 1,2-Dlchloroethene
trans- 1.2-Dlchtoroethene
letrachloroethen*
Irlchloroethene
total MyltnM
Arsenic
•eryl 1 lua
Cadatua
Cyanide
Hlckel
vanadlua
02
•A
02
•2
0
0
0
•2
•2
0
*
•2
•1
0
M
0
7.7 IRIS 2100 .61E-00 S.86E-07 48.6 S.92E-07 4.56E-06 48.6
NA M 740 .68E-08 2.09E-07
0.014 IRIS 1200 .351-08 6.09E-10 0.1 .I8E-07 4. HE 09 0.1
0.34 IRIS J8 .10E-09 7.14E-10 0.1 .63E-08 5.S6E-09 0.1
460 .676-08 .30E-07
6 .171-10 .69E-09
6 .176-10 .69Et09
O.OS1 HEASr 46 .67E-09 8.50E-11 0.0 .JOE -08 6.61E-10 0.0
0.011 BEAST 7000 -54E-07 2.79E-09 0.2 .971-06 2.17E-00 0.2
16 .80E-10 .5 IE -09
t.S EPA 7900 .86E-07 4.29E-07 3S.6 .2JE-06 I.34E-06 IS. 6
4.1 UIS 1200 .1SE-00 1.67E-07 15.5 .38E-07 1.4SE-06 15.5
NA NA 15600 .65E-OT .40E-06
12300 .46E-07 .47E-06
NA NA 01400 .95E-06 .29E-05
40300 .46E-06 . .14E-05
Total Excess life!law Cancer Rlaka
1.21E-06
_. Source* of RfOs:
IRIS - Integrated Rlak Inf onset Ion Syatc*. U.t. EPA 1990.
EPA - iMclil Report en Infested Inoreanlc Araenlc, July 1988.
^-NEASI • Health Effect a AaaeeesMnt SuMary Teblee. rourth Ouerter, U.S. EPA 1990
•JU Not Available
-: Not Applicable
9.30E-06
EXPOSURE ASSUNPIIONS
-sll Intake (arcM/day)
-ady Melftit (kllograw)
fraction Ingested fro* cont*»lnated soil (unities*)
iiposur* frequmcy (day*/ytw)
inposure Ourctlon Cyeara)
•veratlnf Hew (year*)
Conversion factor 1 (troai to ktlogra*)
Conversion Factor 2 (alcrograo) to •! Ultra*))
lonvertlon Factor S (yrar to day)
AVERAGE
0.1
70
1
72
9
70
0.001
0.001
365
REASONABLE MAXIMUM
0.1
70
1
168
30
70
0.001
0.001
365
-------
(• C76A Revised 6-27-91
table C-76
FUTURE LAND USC: TODDLER RESIDEMIIAl SCENMIO
CMCINOGCHIC HEALTH RISK EVALUATIOH Of OEMML CONIACT UIIH SURSURFACE Mill NAKINM CONCENTRATION OE1ECIEO
AVERAGE EXPOSURE ASSUMPTIONS
REASONMLE NAM I NUN EXPOSURE ASSUMPTIONS
• 1
r-leal
junior 1254
nethylnapMhelcne
i(2-ithyTlie*yl H*thalate
^tkalene
•» 1 , 2-0 Icfcloroethene
•ne-1(2-»lcMoroetlieno
Iradilereettiene
Icfcloroathene
al Rytonaa
•nle
ylllu.
.Ide
iel
Dtdlua
U.S.EPA
Carclnooan
classification
U
M
•2
•2
•
•2
12
•
A
12
•1
B
•A
•
Slope
Factar
krday/o,
f.f
NA
•.•14
..
..
•.051
•.til
1.5
4.3
M
..
M
**
Source a
HIS
M
IRIS
IIIS
..
•EAST
•AST
EPA
IIIS
M
..
M
Absorption
Factor
(Percent) b
a
in
in
3X
in
ion
ion
ion
ion
ion
IX
IX
IX
1X
IX
IX
N*«laua llfetle* Averege
Concentre! Ion Ckeoilcal Intake
ua/lf o*ykf-day
2100
740
1200
SI
460
^
46
7000
16
7900
1200
15600
12300
•1400
40300
.18E-07
.72E-07
.41E-07
.40E-09
.69E-07
.21E-08
.21E-OB
.69E-07
.571-05
.ME-08
.91E-07
.41E-OS
.74E-07
.521-07
.99E-06
.4K-06
EMCtts LI let IBM NeHleui
Llfetloe CKcailcal Intake
Cancer Risk og/kg-day
4.76E-06 2.82E-06
1.24E-06
6.18E-09 2.02E-06
2.10E-09 2.9K-08
7.73E-07
I.63E-09
2.UE-07
,
.011-07
.01E-07-
.73E-07
.1BE-04
.69E-07
.33E-06
.02E-07
.62E-06
.07E-06
.37E-05
.77E-06
Eiicese
Llfetlsw
Cancer lick
2.17E-05
2.82E-M'
9.94C-09
3.94E-OB
1.29E-06
Percent of
Risk
94.1
0.1
0.0
0.2
5.6
•I Ewete IHetlw Cancer Rlak*
5.06E-06
2.31E-OS
POSURE ASSUNPHOm
AVERAff
RCASOMM.E NAXIMM
•n aurfaca area avaltable far contact (af/day)
of MlaM fkllotraM)
• I ta akin aaTmame factor (as/ca»
•Mure Fraojuancy (daya/yaar)
poaur* Buratlon (yaara)
braflnf Tlaa lyaara)
hveralan factor I (a2 ta art)
nwaralan factor I (Mtcroajraai ta klloara*)
iwaralan factor 3 Cyaar ta day)
0.
0.24
U
1.4S
72
6
70
10000
1
365
0.47
16
1.43
168
6
70
10000
0*00000000)
365
iSeurcea of Ifttai
till • Integrated Rlek Inf
it Ion Syatas). U.S. EPA 1990.
ted Inoreanlc Arsenic. July 1988.
ElEASI •'•ealta Effect a AaaesoMnt tua»ai| Tables. Fourth Quarter. U.S. EPA 1990
Hbaarptlan factora for PAaa. akthalata ceopeunds and Mtala baaed on a
p$l*t AvallaMa
H lot Applicable
aJPA • Spaclet Report on I
" " • .Effects
froa Oebra Fonam to Nike Toule, June 1991.
-------
rile C78A Revised 6-27-91
lable C-78
ruiURE LAW USE: CHI 10 RESIDENTIAL SCENARIO
CARCINOGENIC HEALTH RISK EVALUATION Of DERMAL CON IACI WlfH SUBSURFACE SOIL: MAXIMM CONCENIRAIION OETECIEO
AVERAGE EXPOSURE ASSUMPTIONS
REASONABLE MAXIMUM EXPOSURE ASSUMPTIONS
, U.S.EPA Slope
Carcinogen factor
Cheailcal Classification kg- day/a*
Arochlor 1254
2rMethylnaphthalene
bi«(2-E thylheiiyl )phthalato
DOT
Naphthalene
cls-1.2-0lchloroethene
trans- 1,2-DlchloroetlMne
letracmoroethans
Irlchloroethane
lout Xylenes
Arsenic
Beryl llua
Cadalue
Cyanlds
tticket
VamdlUS
12
M
12
•2
0
D
D
•2
•2
•
A
•2
It
0
M
0
7.7
NA
o.ou
0.34
..
..
0.051
•.•It
• •
1.5
4.1
M
..
HA
••
Absorption Manlaua lllettaw Average EHCCSS lifetime Ma* I ML* Excess
r actor Concentration Cheeilcal Intake Ufetla* Chcsrical Intake llfetisw Percent o(
Source • (Percent) b ug/kg ng/kg-day Cancer Risk eig/kg-day Cancer Rlak Risk
IRIS
NA
IRIS
IRIS
..
..
NEASI
RUST
••
EPA
IRIS
M
• -
NA
-•
8X
10X
10X
3X
10X
100X
100X
10W
10W
10W
IX
IX
IX
IX
IX
IX
2100
740
1200
58
460
6
6
46
7000
16
7900
1200
15600
12)00
•1400
40100
3.7VE 07 2.92E-06
1.67E-07
2.7IE-07 3.79E-09
I.93E-09 1.14E-09
1.04E-07
1.SSE-08
1.J5E-08
1.04E-07 5.29E-09
1.5BE-05 1.74E-07
3.61E-OS
1.78E-07
2.71E-08
3.S2E-07
2.78E-07
I.ME -06
9.09E-07
1.36E-06 1.05E-05
6.01E-07
9.74E-07 1.36E-08'
1.41E-M 4.MK-09
3. HE 07
4.87E-OS
4.87E-08
3.7SE-07 1.90E-08
5.68E-05 6.2SE-07
1.30E-07
6.41E-07
9.74E-08
1.27E-06
9.98E-07
6.61E-06
3.27E-06
94.1
O.t
0.0
0.2
5.6
lotal EXCCM llfetUe Cancer RUka
3.10E-06
1.12E-05
EXPOSURE ASSUMPIIONS
Skin surface area available for contact (ri/day)
•ooV Height (kllograav)
Soil to akin adherence factor
-------
lie C80A Revised 6-27-91
Table CM
FUTURE LAND USE: AOUU RESIDENTIAL SCENARIO
CARCINOGENIC MEALIN RISK EVALUAIION Of OERNAL CONTACT UIIH SUBSURFACE SOU: MAX I MM CONCENIRAtlON DEIECIED
AVERAGE EXPOSURE ASSUMPTIONS
REASONABLE MAXIMUM EXPOSURE ASSUMPIIONS
U.S.EPA
heaical
Caret
ClassIf(cat
nogan
:atton
Slept
Factor
k|-d*y/"0 Sourct
Absorption
factor
(Pirctnt) b
NaKleuB
Concentration
UR/kg
lifeline Average
Chealcat Intake
•g/kg-dey
Eneas*
llfatlM
Cancar Risk
Lifetime
Chcailcal Intake
a«/kg-day
EMcess
II fat law
Cancar Risk
Percent of
Risk
rochlor 1254
-Methylnepnthalene
Is(2-Ethylbe«yl>ptithalate
Dl
aphthalene
la-t.2-0lchloroethefie
rans-t.2-alchtoroathene
elradiloroethene
rlcMoroethen*
atal Kylanta
raanlc
erylllua
edBlua
yantde
Ickel
anadlua
•2
M
•2
02
D
D
D
12
•2
•
A
M
•1
0
M
P
7.7
M
0.014
0.34
• •
..
o.ost
0.01 1
• *
1.5
4.1
HA
• •
HA
••
IRIS BX 2100 .74E-07 2.11E-06 .50E-06 2.70E-05 94.1
•A . 101 740 .21E-07 .54E-06
IRIS 10X 1200 .95E-07 2.74E-09 . JOE -06 l.SOE-00 • 0.1
IRIS SX 50 .OIE-09 9.63E-10 .63E-08 1.2X-00 0.0
10X 460 .49E-08 .S9E-07
100X 6 .77E-09 .25E-07
100X 6 .771-09 .2SE-07
•MSI 1001 44 .49E-08 3.82E-09 .59E-0/ 4.09E-08 0.2
•JASI 1001 7000 .14E-05 1.25E-07 .46E-04 1.60E-06 S.6
100X 16 .61E-08 .3SE-07
(PA W 7900 .296-07 .65E-06
IRIS 11 1200 .9SE-00 .SOE-07
RA 11 15600 .54E-07 .2SE-06
11 12300 .OOE-07 .56E-06
HA 11 01400 .35E-06 ' .TOE-OS
U 40300 .56E-07 .40E-06
Mai Eiicess Llfatlaw Cancar Rlaka
2.24E-06
2.07E-OS
IIPOSURE ASSUNPIIOHS
AVERAGE
MILE NAKINUN
kin surface araa available for contact (af/day)
looV Height (kllograaa)
oil to skin aontrenca factor
inpoaure Frequency (daya/year)
inposure Duration (years)
Iveraglng !!••
(II
EPA 1990
awaorandua froai Debra fonsen to Nike Tonte, June 1991.
-------
APPENDIX G
PADER LETTER OF CONCURRENCE
-------
WW I I tk.1 (W I UUU i Wll*
i nn iiu. £.1
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OP ENVIRONMENTAL RESOURCES
FIELD OPERATIONS - DIRECTOR'S OFFICE
Suite 6010, Lee Park
555 North Lane
Conshohocken, PA 19428
215 832-6027
December 27, 1991
Mr. Edwin B. EMckson
Regional Administrator
U.S. EPA Region III
841 Chestnut Building
Philadelphia, PA 19107
Re: Raymark NPL Site
Hatboro Borough, Montgomery County
Letter of Concurrence
Record of Decision (ROD)
Operable Unit 1, Soil/Source Control
Dear Mr. EMckson:
The Record of Decision for the soil/source control operable unit at the Raymark
site has been reviewed by the Department.
The major components of the selected remedy include:
* Construction, operation, and maintenance of vapor extraction system to
remove contamination from subsurface soil.
* Construction, operation, and maintenance of a vapor extraction system
to remove contamination from unsaturated bedrock.
* Construction, operation, and maintenance of a vapor phase carbon
adsorption system en the vapor extraction system to remove contaminants
from the extracted air.
* Construction and maintenance of a low permeability cap to minimize
Infiltration through soil containing residual contamination and
resultant leaching to ground water and to Increase the efficiency of
the vapor extraction system by decreasing the moisture content of the
soil.
* Institutional controls to ensure that the integrity of the cap 1s
maintained.
* PADER shall take surface soil samples near the lagoon area and subject
them to the Toxic Characteristic Leaching Procedure (TCLP) for heavy
metals. If these samples fall TCLP the contaminated soil w111 be
disposed of as a hazardous waste at an approved RCRA facility.
-------
nun IO-OH
JcR/ouumtnoi KHUIUN fHA NO, ^latt^Wbd P. 03
Mr. Edwin B. CMekson
December 27, 1991
- 2 -
I hereby concur with the EPA's proposed remedy at this funded sue, with the
following conditions:
* The Department will be given the opportunity to concur with decisions
rented to subsequent operable units end the future remedial
Investigation and feasibility study, which will address the ground
water, and to evaluate appropriate remedial alternatives to ensure
compliance with Pennsylvania ARARs.
* EPA will assure that the Department 1s provided an opportunity to fully
participate 1n any negotiations with responsible parties.
* The Department will be given the opportunity to concur with decisions
related to the design of the remedial action, to ensure compliance with
design-specific ARARs.
* The Department's position 1s that Us design standards are ARARs
pursuant to CERCLA Section 121 as amended by SARA, and win reserve our
right to enforce those design standards.
* The Department will reserve the right and responsibility to take
independent enforcement actions pursuant to state law.
* This concurrence with the selected remedial action Is not Intended to
^provide any assurances pursuant to CERCLA Section 104(c)(3) as amended
by SARA.
-------
Mr. Edwin B. Erlckson
December 27, 1991
- 3 -
Thank you for the opportunity to concur with this EPA Record of Decision, If ycu
have any questions regarding this matter, please do not hesitate to contact me.
Very truly yours,
LEON T. GONSHOR
Regional Director
LTQ:TRH;ce
cc: Office of Held Operations
Mr. Snyder
Ms. Deere Bassett
Mr. Lynn
Mr. Danyliw
Mr. Becker
Mr. Sheehan
Mr. Mat lock
Mr. Brents
Mr. Hartnett
Re (0)336.1
------- |