United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-92/148
June 1992
SEPA Superfund
Record of Decision:
Westinghouse Elevator Plant,
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.
EPA/ROD/R03-92/148
a. Recipients Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Westinghouse Elevator Plant, PA
First Remedial Action - Subsequent to follow
5. Report Date
06/30/92
7. Authors)
8. Performing Organization Repl No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grmnt(G) No.
(C)
12 Sponsoring Organization Nama and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report ft Period Covered
800/000
14.
15. Supplementary Notes
PB93-963911
16. Abstract (Umrl: 200 words)
The approximately 90-acre Westinghouse Elevator Plant is a manufacturing plant for
elevator and escalator components in Cumberland Township, Adams County, Pennsylvania.
The surrounding land is mixed residential and small commercial properties with the
Gettysburg Battlefield National Park to the south. The site is located within the
watershed of Rock Creek, a smallstream that receives discharge from the northern
tributary that traverses the site. Ground water is the only source of potable water
and area residents near the site rely on municipal or private wells for drinking
supply. Prior to its current use, most of the property consisted of farm land. From
1968 to the present, the facility has used degreasing solvents, paints, and cutting and
lubricating oils in the manufacturing process for elevator and escalator components.
Waste solvents, paint sludge, oils, and greases were stored in various areas at the
site for offsite disposal. In 1983, after complaints from local residents, the state
initiated an investigation that revealed soil, sediment, and widespread ground water
contamination with VOCs. In November 1983, Westinghouse removed a total of 43 drums of
contaminated soil from two areas of the site. In 1984, Westinghouse installed an air
stripping tower to treat contaminated ground water and constructed water mains to
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Westinghouse Elevator Plant, PA
First Remedial Action - Subsequent to follow
Contaminated Medium: gw
Key Contaminants: VOCs (TCE, TCA, 1,1 DCE)
b. Identifiers/Open-Ended Terms
c. COSATI field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
74
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4*77)
(Formerly NTIS-3S)
Department of Commerce
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EPA/ROD/R03-92/148
Westinghouse Elevator Plant, PA
First Remedial Action - Subsequent to follow
Abstract (Continued)
provide affected residents with access to the public water supply. Since 1984,
Westinghouse has installed several public water main extensions for affected residences
and also installed monitoring wells in the area. In 1987, EPA ordered Westinghouse to
perform an RI/FS at the site. Schindler Elevator Corporation has leased and operated
the plant building since 1989. In 1991, there was a TCA spill at the site, which was
then and is currently owned by Westinghouse Elevator. This ROD addresses remediation of
dense non-aqueous phase liquids (DNAPLs) in the fractured bedrock and the highly
contaminated ground water resulting from contact with, DNAPLs. Additional investigation
'of contaminated soil is needed because of the recent TCA spill and a subsequent ROD will
be issued for soils. The primary contaminants of concern affecting the ground water are
VOCs, including TCA, TCE, and 1,1 DCE.
The selected remedial action for this site includes ground water pumping and treatment
by air stripping followed by carbon adsorption from two areas: onsite, in the center of
the contamination plume in contact with DNAPLs, and offsite, downgradient from the
center of the plume, to control migration of dissolved contaminants; offsite surface
discharge of treated ground water to the northern tributary of Rock Creek under an NPDES
permit. Ground water monitoring and residential well sampling; and deed restrictions on
the use of ground water on plant property. The estimated present worth cost is
$4,400,000, which includes an annual O&M cost of $142,000 for a 30-year operational
period.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific clean-up goals for ground water are
based on SDWA MCLs and non-zero MCLGs for VOCs, including TCE 5 ug/1, TCA 200 mg/1, and
1, 1 DCE 7 ug/1; and state Water Quality Criteria for discharge to surface water. The
state standard for ground water cleanup to background levels is waived due to technical
impracticability. Emission reduction from the air stripper/adsorber will be reduced to
the minimum obtainable levels through the use of best available technologies.
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RECORD OF DECISION
WESTINGHOUSE ELEVATOR CO. PLANT
Operable Unit 1
DECLARATION
SITE NAME AND LOCATION
Westinghouse Elevator Company Plant
Cumberland Township
Adams County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the selected remedial
action for the Westinghouse Elevator Company Plant Site in
Cumberland County, Pennsylvania. The selected remedial action
was chosen in accordance with the Comprehensive Environmental
Response, Compensation; and Liability Act of 1980, as amended by
the Superfund Amendments and Reauthorization Act of 1986
(CERCLA), 42 U.S.C. §§ 9601 et. sea.: and, to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Part 300. This decision is based
on the Administrative Record for this Site.
The Pennsylvania Department of Environmental Resources (PADER),
acting on behalf of the Commonwealth of Pennsylvania, does not
concur with the selected remedy.
ASSESSMENT OF TEE 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, as
discussed in Summary of Site Risks, if not addressed by
implementing the response action selected in this Record of
Decision (ROD), may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
The Westinghouse Plant at the Site was constructed in 1968 for
the manufacture of elevator and escalator components. Schindler
Elevator Corporation has leased and operated the plant building
since January 1989. This ROD addresses ground water, surface
water and sediment contamination. The ground water at the plant
property and in residential wells to the east of the Plant is
contaminated above health based levels. The Selected Remedy will
address the Principal Threats at the Site which are Dense Non-
Aqueous Phase Liquids (DNAPLs) in fractured bedrock and the
highly contaminated ground water in contact with the DNAPLs. No
action is necessary for surface water and sediment contamination.
Additional investigation of contaminated soils is needed because
of a recent trichloroethane (TCA) spill and a subsequent ROD will
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be issued for soils (Operable Unit 2) after a supplementary
remedial investigation/feasibility study for soils is completed.
The selected remedy for this Site addresses the long term threats
present at the Westinghouse Elevator Plant Site. The selected
remedy includes the following components:
Extraction wells on the Plant property to contain the
highly contaminated ground water plume.
Extraction wells to the east-northeast of the Plant
property to both contain and clean up the contaminated
ground water that has migrated from the Plant property.
Treatment of contaminated ground water by air stripping
followed by removal of contaminants from the air stream
using carbon adsorption.
Discharge of the treated water to the northern tributary
of Rock Creek under an NPDES permit.
Deed restrictions on the use of ground water on the plant
property.
Ground water monitoring and residential well sampling.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective.
This remedy utilizes 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 the selected remedy will result in hazardous substances
remaining onsite above health-based levels, a review under
Section 121(c) of CERCLA, 42 U.S.C. §9621 (c) will be conducted
within five years after initiation of the remedy to ensure that
the selected remedy is providing protection of human health and
the environment.
/ Edwin B. EricksonDate
Regional Administrator
Region III
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TABLE OF CONTENTS
FOR
DECISION SUMMARY
SECTION PAGE
I. SITE NAME, LOCATION AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION ... 6
IV. SCOPE AND ROLE OF RESPONSE ACTION 6
V. SUMMARY OF SITE CHARACTERISTICS 7
VI. SUMMARY OF SITE RISKS 17
VII. SUMMARY OF ALTERNATIVES 22
VIII. COMPARATIVE ANALYSIS OF ALTERNATIVES 35
IX. THE SELECTED ALTERNATIVE 41
X. STATUTORY DETERMINATIONS 46
XI. EXPLANATION OF SIGNIFICANT CHANGES 48
APPENDIX A APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
APPENDIX B FIGURES
APPENDIX C RI DATA TABLES
APPENDIX D RESPONSIVENESS SUMMARY
APPENDIX E ADMINISTRATIVE RECORD INDEX
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RECORD OF DECISION
WE8TZN6BOD8E ELEVATOR CO. Plant Sit*
OPERABLE UNIT 1
DECISION SUMMARY
I. SITE NAME, LOCATION AND DESCRIPTION
Site Description
The Westinghouse Elevator Plant is located on approximately
90 acres of land along the vest side of Biglerville Road (Route
34), approximately 1.5 miles north of downtown Gettysburg in
Cumberland Township, Adams County, Pennsylvania (figure 1 -
Appendix B). The Site coordinates are latitude 39° 51' 08" north
and longitude 77° 14' 21" west. The Plant is bounded to the
south by property that is part of the Gettysburg Battlefield
National Park; and to the west, north and east by residential and
small commercial properties (Figure 2-Appendix B). The closest
private residences are approximately 200 feet east of the Plant
building.
Prior to its current use, most of the property consisted of
farmland. A farm pond, approximately two acres in area, existed
on the property near what is now the main entrance to the
Westinghouse Plant. The Westinghouse Plant ("Plant") was
constructed in 1968 for the manufacture of elevator and escalator
components. The Westinghouse Electric Co. ("Westinghouse11) began
operating the Plant following completion of construction and used
the solvents TCE and TCA in the manufacturing process. Since
January 1989 the Plant has been leased and operated by the
Schindler Elevator Corporation ("Schindler").
The regional topography in the area of the Site is low to
medium relief, undulating terrain. Specifically, the Site slopes
moderately to the east, dropping in elevation from 600 feet above
mean sea level (MSL) in the west to 525 feet above MSL in the
east.
Ground water is the only source of potable water in the area
and residents near the Site are dependent on municipal or private
wells. EPA considers this source of drinking water to be a class
IIA aquifer.
The Site is located within the watershed of Rock Creek, a
small southward-flowing stream located approximately three-
quarters of a mile to the east of the Plant. Two small
intermittent streams (Northern and Eastern Tributaries - figure
2-Appendix B) are present near the Site. Most surface water at
the plant is collected by a storm drain system which eventually
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discharges to the two tributaries. No flood plains or wetlands
are present on the Plant property.
As used herein, the term on-Plant refers to the property on
which the Plant is located and the term off-Plant refers to the
property beyond the Plant property boundaries. Both on-Plant and
off-Plant areas, however, are considered to be part of the Site.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Site History
The Plant has been in operation since 1968 as a
manufacturing Plant of elevator and escalator components and
continues operations currently. The manufacturing process
utilized by Westinghouse and continued to be used by Schindler
consists of several steps including parts delivery and unloading;
metal parts degreasing; rust prevention; primer and finisher
paint booth operations oven drying; acoustical coating; machining
and sawing; adhesive application; final assembly; and shipping.
Chemical feed materials used in many of the operations
include solvents, paints, cutting and lubricating oils, and
insulation board. The major solvent used up to 1975 was
trichloroethene (TCE), after which time 1,1,1-trichloroethane
(TCA) was substituted for TCE. Waste materials generated include
spent solvents, paint sludges, spent oils and greases, and excess
insulation board. The processes which generate the majority of
hazardous or otherwise regulated wastes related to contaminants
found in ground water are described below.
Metal parts degreasing operations remove thin coatings of
oil applied by the parts suppliers to bare metal surfaces
for corrosion prevention. Spent solvent saturated with oil
is containerized and stored in the drum storage area for
off-Site disposal.
Prior to 1975, a Triclene-phosphatizing process preceded
paint booth operations. Triclene-phosphatizing is a process
of producing a crystalline iron phosphate layer on steel
surfaces to prevent corrosion. Major ingredients include
TCE and phosphoric acid. Waste materials were either
drummed for storage in the drum storage area or pumped into
large holding tanks, located near the southwest corner of
the Plant, for off-Site disposal. The Triclene procedure
was eliminated in 1975 and replaced by a lead chromate
primer application process.
Machining and sawing operations utilize lubricating and
cutting oils. Some solvents are used to remove oils from
metal parts after cutting operations or to clean equipment
motors. Waste oils and degreasing solvents are drummed and
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stored in the drum storage area for off-Site disposal.
Prior to 1981, drummed waste chemicals were stored in an
area located in the southern portion of the Plant. This area is
currently referred to as the old waste drum storage area.
Drummed wastes are currently stored on a covered, diked concrete
pad referred to as the hazardous waste drum storage area which is
located near the shipping docks.
As a result of Plant operations, a number of potential
source areas for the detected contamination were identified at
the Site. These areas include the former solvent remote fill
line, the degreasing solvent storage tank location, pumphouse
area, railroad dock, and the old waste drum storage area. The
location of each area is shown on Figure 3-Appendix B. Each area
is briefly described below.
The former solvent remote fill line is located in the
southwestern portion of the facility. Beginning in 1980,
tank trucks containing fresh degreasing solvent filled a
storage tank in the interior of the building through this
buried line. Prior to 1980, degreasing solvent was
purchased and stored in 55-galIon drums. In 1985,
Hestinghouse discontinued the use of the buried remote line.
This area is considered to be a potential source due to the
possibility of spills during filling operations or line
integrity failures.
Degreasing solvent is currently stored in an above-ground
tank located on a diked concrete pad in the courtyard of the
building. This tank is filled through the current remote
fill line. The fill connection is located at the south end
of the building and feeds directly to the tank. This area
is considered a potential source due to the possibility of
leaks, spills, or ruptures. In May 1991, a spill of about
twenty gallons of solvent occurred and was reported to the
PADER by Schindler. Schindler removed contaminated soil
along the concrete pad. During the sampling necessary to
verify this cleanup, a new area of TCE contamination was
discovered that could be due to past spills or the former
solvent remote fill line.
In the past, metal grates from the Plant's paint booths were
cleaned on a concrete pad in the pumphouse area, located at
the southwest corner of the Plant. Caustic solutions with
solvents were used to loosen excess paint build-up on the
grates. The loosened paint was then scoured off using a
steam cleaner. This is considered a potential source area
due to the nature of operations whereby solvent-contaminated
washwater may have been discharged directly into the
environment.
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At the railroad dock area, located at the north end of the
Plant, solvent-coated metal chips and shavings that
accumulated at the bottom of degreasing tanks were stored in
metal bins prior to removal by truck for recycling.
Information in EPA's files indicates that these bins had
holes in the bottom to drain the solvent. This area is
considered to be a potential source due to solvent drippings
leaking out of the containers and migrating into the
subsurface environment.
The old waste drum storage area is located on the southern
side of the building. Prior to 1981, drummed waste was
stored in this area until shipped for disposal. This is
considered to be a potential source due to the possibility
of spills. The transcript of the lawsuit Merry vs
Westinahouse Electric Corporation. Civil Action No. 86-
1673(M.D.PA) contains testimony regarding several major
spills in this general area.
In addition to the above-listed potential sources, the
former pond area, located on the eastern side of the Plant is
considered a potential source based on the soil analyses. This
area may have become contaminated by migration of contaminants
from the pumphouse and railroad loading docks along a subsurface
channel in the bedrock surface identified in the RI report.
Westinghouse has alleged that some drums may have been disposed
in the pond before their ownership, but no information has been
supplied to EPA to support this assertion.
INVESTIGATIONS
Investigations of alleged environmental problems related to
the Site were initiated in 1983, based on complaints from local
residents to the Pennsylvania Department of Environmental
Resources (FADER). FADER representatives visited the Plant in
1983 and collected samples from the Plant irrigation well and
from neighboring residential wells. Chemical analyses of these
samples confirmed the presence of Volatile Organic Compounds
(VOCs) including TCE and TCA in the on-Plant and off-Plant ground
water. Analysis of residential well samples continued until
alternative water supplies were provided by Westinghouse. The
residential well sampling indicated widespread contamination
throughout the area bounded by Biglerville, Table Rock and Boyd's
School Roads.
In October 1983, PADER sampled two suspected source areas on
the Plant property including soils from the railroad dock and
surface water samples from the old waste drum storage area.
Chemical analysis by both PADER and Westinghouse indicated the
presence of volatile organics in surface water, ground water, and
soil samples from the Site. In November 1983, Westinghouse
initiated the removal of 10 drums of contaminated soil from the
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railroad dock area and 33 drums of contaminated soil from the
pumphouse area. The drums were manifested as a hazardous waste
and were sent to a secure landfill in New York State. Figure 3-
Appendix B shows these areas.
In January 1984, Westinghouse contracted R.E. Wright to
serve as a consultant. During 1984, Wright collected additional
water and soil samples from various locations at the Site,
installed fifteen monitoring wells and conducted a pump test.
In 1984, Westinghouse installed water mains along
Biglerville Road and a portion of Boyd's School Road to provide
residents with access to the public water supply. Since 1984,
Westinghouse has installed additional mains along stretches of
Boyd's School Road, Cedar Avenue, Maple Avenue, and Apple Avenue.
Westinghouse also installed monitoring wells and sampled ground
water from these wells during this time. The extent of the
waterlines is shown in figure 2 - Appendix B.
In June 1984, Westinghouse installed and began to extract
ground water at the Site and to operate an air stripping tower to
remove TCE and other VOCs from ground water. At a later time,
PADER ordered Westinghouse to continue the operation of the
stripping tower, but Westinghouse contested the Order. The
stripper has been shut down several times for various reasons and
then restarted. The stripper has generally been in operation
since February 1989 and currently treats about nine gallons per
minute of contaminated ground water. The stripper discharges to
the Northern Tributary, a stream along Boyd's School Road, and is
regulated by a National Pollutant Discharge Elimination System
(NPDES) permit.
On March 10, 1987, Westinghouse entered into a Consent
Agreement with EPA to perform a Remedial Investigation and
Feasibility Study (RI/FS) of the Site. The Remedial
Investigation was completed in two phases: a) Phase I determined
the site contaminants and hydrogeology and b) Phase II
investigated the extent of contamination. The Phase II Remedial
Investigation Report was completed on July 2, 1991 and a draft
Feasibility Study was submitted to EPA in October 1991, which
needed substantial modifications. Additionally, finalization of
the report was further delayed by the need to investigate soil
contamination from a TCA spill which occurred on May 3, 1991, at
which time, Schindler Elevator Corporation was operating the
Plant. Schindler Elevator removed contaminated soils and sampled
the area to verify the cleanup at PADER's request. This area
needs additional sampling and study before a remedial action
decision can be made on the soil. Therefore, to avoid further
delay in the ground water cleanup, EPA has allowed Westinghouse
to submit a revised Feasibility Study that only addresses
sediments, surface water, and ground water at the Site. A
supplementary (FS) for soils will be issued in the future and a
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6
separate Record of Decision (ROD) will be issued for soils at the
Site.
CERCIA ENFORCEMENT
An initial PRP search identified only Westinghouse as a
Responsible Party and only Westinghouse was issued a General
Notice letter for the RI/FS. However, the TCA spill at the Plant
that occurred in May 1991, prompted EPA to issue a General Notice
letter to Schindler Elevator Corporation.
Currently, there is ongoing litigation between the PADER and
Westinghouse Electric Corporation regarding contamination at the
Site. During this litigation, Westinghouse has questioned the
basis for their liability, however, EPA considers the
Westinghouse Plant operations to be the primary source of ground
water contamination at the Site.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS and Proposed Remedial Action Plan (Proposed Plan)
were released for public comment as part of the administrative
record file on April 17, 1991, in accordance with Sections
113(k)(2)(B), 117(a), and 121(f)(l)(G) of CERCLA, 42 D.S.C.
§§ 9613 (k) (2) (B), 9617 (a), 9621 (f) (1) (G). These and other
related documents were made available to the public in both the
administrative record file located in Region III Offices and at
the Adams County Public Library; a notice of availability was
published in the Gettysburg Times and The Hanover Evening Sun on
April 17, 1991. A public meeting to discuss the Proposed Plan
was held on May 6, 1991 in Cumberland Township, Pennsylvania.
The comment period was extended at the request of a nearby
resident until June 17, 1992. EPA's response to all comments on
the Proposed Plan and related documents received during the
comment period is included in the Responsiveness summary in this
ROD. In addition, a copy of the transcript of the public meeting
has been placed in the administrative record file and information
repository.
IV. SCOPE AND ROLE OF RESPONSE ACTION
The Principal Threat at the Site is from Dense Non-Aqueous
Phase Liquids (DNAPLs) that have migrated into fractured bedrock
beneath the water table at the Site and the highly contaminated
ground water associated with the DNAPLs.
The only significant threat to human health and the
environment, identified by the RI, is from domestic use of
contaminated ground water. The overall remedial goals for all
Site media relate to this threat. The scope and role of the
selected alternative addressing on-Plant ground water is to
prevent migration of all contaminated on-Plant ground water to
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the extent technically practicable, especially ground water in
contact with DNAPLs, to off-Plant residential wells. The scope
and role of the selected alternative addressing off-Plant ground
water is the prevention of migration of all of the less
contaminated ground water past the area served by public water
and the restoration of the off-Plant ground water to health based
levels (MCLs/MCLGs). The capture zone of both the on-Plant and
off-Plant wells will attempt to contain all ground water
contaminated above non-zero MCLGs and MCLs, except in the area of
the stagnation zone as explained in the description of the
selected alternative section.
Soils at the Site were studied during the Phase II
investigation and the Risk Assessment did not identify any direct
exposure risk to employees or residents, because the
contamination is several feet below the surface. However,
contaminants may be leaching from subsurface soils, therefore
contributing to ground water contamination. Additionally, the
recently discovered area of soil contamination near the
degreasing fluid storage tank (figure 3-Appendix B) needs
additional study and assessment. Contaminated soils will be
addressed in a subsequent Proposed Plan and Record of Decision
(ROD). When EPA addresses problems at a site in more than one
ROD, EPA calls each ROD an Operable Unit. Sediments, surface and
ground water will be considered Operable Unit One and the
following ROD for soils will be considered Operable Unit Two.
EPA considers this a final action ROD for Operable Unit One
(ground water), but not a final action for the Site.
V. SUMMARY OF SITE CHARACTERISTICS
GENERAL
The Westinghouse Plant is located on approximately 90 acres
of land along the west side of Biglerville Road (Route 34),
approximately 1.5 miles north of downtown Gettysburg in
Cumberland Township, Adams County, Pennsylvania (figure 1 -
Appendix B). The Gettysburg area has no large rivers nearby and
is very dependent on ground water. Yields from wells in the
Gettysburg Formation are relatively low and the area is
experiencing substantial development placing continuing pressure
on the current municipal water supply. The area has three
Superfund sites including the Hunterstown Road Site, the
Shriver's Corner Site and the Westinghouse Elevator Co. Plant
Site. Additionally, a RCRA Site in downtown Gettysburg
contaminated several of the municipal wells which were shut down.
Before the contamination was discovered at the Westinghouse Plant
Site, the adjacent residential areas used private wells for full
domestic use. These areas are now served by water lines, but
some residents have refused to use public water and some
residents use their wells for watering gardens.
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8
Prior to its current use, most of the Plant property
consisted of farmland. A farm pond, approximately two acres in
area, existed on the property near what is now the main entrance
to the Westinghouse Plant. The Westinghouse Plant was
constructed in 1968 for the manufacture of elevator and escalator
components by Westinghouse. Since January 1989 the Plant has
been leased and operated by the Schindler Elevator Corporation.
The manufacturing processes at the Site consist of several
steps: parts delivery and unloading; metal parts dagreasing;
Triclene phosphatizing; primer and finisher paint booth
operations; oven drying; acoustical coating; machining and
sawing; adhesive application; final assembly; and shipping.
Chemical feed materials used in some of these operations include
solvents, paints, cutting and lubricating oils, and insulation
board. Trichloroethene (TCE) was the primary solvent used at the
Site until 1975 at which time 1,1,1-trichloroethane (TCA) was
substituted.
LAND USE
The Plant is bounded to the south by property that is part
of the Gettysburg Battlefield National Park (Figure 2 - Appendix
B). The National Park Service (NFS) is concerned about the
limitations that the Westinghouse Plant contamination may place
on their ability to site a large well on park property. The NPS
is also concerned about the potential to contaminate a
residential well, just south of the Plant, and currently used by
NPS employees. This well was tested and only a trace of solvents
was detected and the level was far below drinking water standards
(less than 1 ppb TCE).
Adjacent to the Plant property and north and east of the
Plant are residential and small commercial properties. The
closest private residences are approximately 200 feet east of the
Plant along Biglerville Road. A residential area is to the west
of the Plant about 1000 feet from the Plant building. Ground
water is the only source of potable water in the area and
residents near the Site are dependent on municipal or private
wells. EPA's Ground Water Protection Strategy classifies
aquifers based on the following criteria:
1) Special Ground Water - Class One - Highly vulnerable
ground water that is irreplacable with no alternative source
of drinking water available to substanial populations.
2) Current and Potential Sources of Drinking Water - Class
Two - Class IIA is water currently used and Class IIB is
water that could potentially be used.
3) Ground water not a potential source of drinking water
because of quality.
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EPA considers this source of drinking water to be a class IIA
aquifer. It is estimated that the total population within a
three mile radius that uses ground water from the same
hydrogeologic formation is 11,600.
TOPOGRAPHY
The regional topography in the area of the Site is low to
medium relief, undulating terrain. Specifically, the Site slopes
moderately to the east, toward Rock Creek, dropping in elevation
from 600 feet above mean sea level (MSL) in the west to 525 feet
above MSL in the east.
Regional Geology
Prior to the Plant construction the natural soils were
classified by the U.S. Soil Conservation Service as part of the
Penn-Readington-Croton association. These soils are gently to
moderately sloping, shallow to moderately deep shaley soils
derived from the underlying Triassic red beds. These natural
soils were disturbed due to Plant construction activities. Based
on geotechnical information and summaries made by Paul C. Rizzo
Associates (PCR), a majority of the soil underlying the Plant is
fill material with a mixture of grain sizes from clay to
boulders. Some natural soil was encountered, with bed
thicknesses between two and four feet.
The Site is located within the Gettysburg Basin, one of a
number of discrete elongate sedimentary basins parallel to the
Appalachian orogen in eastern North America. These basins are of
early Mesozoic age (Late Jurassic-Early Triassic) and are
comprised largely of continental clastic rocks and accompanying
basic intrusive and extrusive igneous rocks (Froelich and Olsen,
1985). Geology local to the Site appears to be unmetamorphosed
sedimentary rock. The sedimentary rocks underlying the Plant are
mapped as the Heidlersburg member of the Gettysburg Formation.
The Heidlersburg member is described as a lacustrine (lake
deposited) series of red and gray arkosic sandstones, red
mudstones, and dark gray sandstones and shales (Root, 1988).
Site investigations have mapped the underlying stratigraphy as
being comprised of red and gray siltstones and shales overlain by
approximately two to ten feet of red to brown clay. Bedrock is
generally fractured and weathered in the upper fifty feet and is
encountered two to ten feet below ground surface (Rizzo, 1991).
Regional Hvdroaeology
Ground water in the vicinity of the Site is stored in and
transmitted through a complex system of interconnected fractures
consisting of bedding planes and steeply dipping joints.
Investigations have shown that there exists two flow regimes
(shallow and deep).
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10
The shallow regime consists of the localized saturated soils
and weathered bedrock. Groundwater flow direction in this regime
is generally to the east-southeast towards Rock Creek and is
primarily influenced by local topography, but bedding planes
still produce some anisotropic influence. The approximate ground
water gradient in the shallow regime is about 0.03 ft/ft. Net
permeabilities from packer tests for this zone ranged from 6 x
10~6 to 5 x 10'3 cm/sec.
The deep regime is below weathered bedrock and flow
direction is much more complicated and is strongly influenced by
the structure of the geology. A multilayered "sandwich" of
alternating shale and siltstones dips to the northwest downward
about 23 degrees (Figure 4-Appendix B). Water flows primarily
within the fractures in the siltstone layers which are the water
bearing units between the relatively impermeable shale layers.
The shale layers tend to confine the water but some vertical
fractures allow water to "leak" from one siltstone layer to a
deeper layer. Based on results of the Remedial Investigation and
review of other literature, it is estimated that contaminated
ground water moves through a complex network of fractures to the
northeast. The flow is highly anisotropic with the highest
permeability to the north-northeast and the ground water gradient
to the east. The general ground water flow direction is the
vector result of the direction between the permeability and the
direction of the ground water gradient producing a flow to the
east-northeast. This direction is consistent with the shape and
axis of the contaminant plume. However, the exact pathway taken
by the deep ground water, as it moves to the east-northeast, has
not been defined. The wells that will be installed to implement
the off-Plant remedial action should resolve the remaining
hydrogeological questions. The permeabilities in this formation
are strongly directionally dependent, with highest permeabilities
along strike. Net permeabilities from packer tests ranged from
6 x I0~6 to 3.3 x I0~3 cm/second. The approximate ground water
gradient in the deep zone was about 0.02 ft/ft.
Another complication to the hydrogeology is the large number
of residential wells to the east of the Plant. Although the
shale layers tend to confine the ground water into water bearing
"units", the open boreholes of residential wells may link many of
these units once ground water moves off-Plant.
EPA believes that Rock Creek is the ultimate discharge point
for contaminated ground water since Rock Creek is the only large
stream that drains the Gettysburg basin.
Known or Suspected Sources of Contamination
After a review of Plant processes and extensive remedial
investigations at the Site, at least six potential sources of
contamination have been identified. During Phase I and Phase II
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11
investigations, soil samples were obtained and analyzed from
these areas. The laboratory results indicated- that the following
contaminants were detected at each area:
* Former solvent remote fill line (fill connection)-
None Detected in Phase I, but contaminants in this
area have recently been detected by Schindler
Elevator Corporation. Possible source - needs
additional study.
* Degreasing solvent storage tank - Possible source
that needs additional study.
* Pumphouse area- l,1-dichloroethane (89 ppb) and
1,1,1-trichloroethane (432 ppb) during Phase I.
Contamination not detected in Phase II boring.
* Railroad dock- Contaminated with VOCs before
removal - Xylenes (total) (5,100 ppb) detected
during Phase II.
* Old drum storage area- None Detected
* Former pond area- trichloroethene (300 ppb);
1,1,1-trichloroethane (69 ppb); 1,1-dichloroethane
(73 ppb); 1,2-dichloroethane (19 ppb); 1,1-
dichloroethene (73 ppb); and 1,2-dichloroethene
(total) (97 ppb) during Phase II.
The solvents TCE and TCA are heavier than water and will
dissolve only very slowly in ground water. When large amounts of
these solvents are spilled they sink through the ground water as
a separate phase until they are trapped by solid rock or the
bottom of a fracture. They then will dissolve into ground water
over many years. These solvents are called Dense Non-Aqueous
Phase liquids (DNAPLs). EPA believes that DNAPLs have migrated
through the soil into bedrock at the Westinghouse Plant beneath
the water table and that this is the primary source of ground
water contamination. It is impossible to calculate or estimate
the amount of DNAPLs present in the bedrock.
Identified Compounds of Interest
Based on the Remedial Investigations, Compounds of Interest
(COI) for groundwater contamination at the Site have been
identified. The COI are trichloroethene, 1,1,1-trichloroethane,
1,1-dichloroethene, l,l-dichloroethane, 1,2-dichloroethene, and
1,2-dichloroethane. Trichloroethene is moderately toxic to humans
by ingestion and inhalation and is considered a probable
carcinogen. 1,1,1-trichloroethane is moderately toxic to humans
by ingestion, inhalation, skin contact, subcutaneous (beneath the
skin) and intraperitoneal (space between membrane that lines
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12
interior wall of abdomen and covers abdominal organs) routes and
is currently not considered a carcinogen. 1,1-dichloroethene is
a poison by inhalation, ingestion, and intravenous routes;
moderately toxic by subcutaneous route; and is currently
considered to be a possible carcinogen. 1,1-dichloroethane is
moderately toxic by ingestion and is a suspected carcinogen.
1,2-dichloroethene is a poison by inhalation, ingestion, and
intravenous routes; moderately toxic by subcutaneous route; and
is currently not considered to be a carcinogen. 1,2-
dichloroethane is a poison by ingestion; moderately toxic by
inhalation and subcutaneous routes; and is considered a probable
carcinogen (Sax and Lewis, 1989).
Contaminant Fate and Transport
The primary transport pathway of COI at the Site to off-
Plant areas is through ground water migration. Ground water
migration of COI appears to be their desorption from solids in
potential source areas and their subsequent infiltration into
ground water and more importantly, diffusion into ground water
from DNAPLs. Once in ground water, they are advected and
dispersed.
Ground water in the shallow zone (0-50 feet) flows with the
topography to the east-southeast and will carry Site contaminants
toward residents to the east-southeast of the Site. The
contaminated ground water may move into the deeper zone or be
dispersed, explaining the limited extent of the shallow plume.
Ground water in the deeper zone flows to the east-northeast
and could be drawn to the north-northeast along strike by wells
in a bedrock unit. In general, the ground water will move
towards the northeast to residential wells in this area (Figure
2-Appendix B). The extent of the plume in the east-northeast
direction will be further defined during the remedial design.
Trichloroethene slowly degrades in ground water sequentially
losing a chlorine atom to form dichloroethane and finally vinyl
chloride. TCA degrades similarly to dichloroethane and finally
chloroethane. Vinyl chloride and 1,1 - dichloroethene, two
degradation products of TCE, are regarded as more potent
carcinogens than TCE due to their high slope factor values. TCE
that is not captured may eventually form these compounds.
Currently, the area surrounding the Plant is served by water
lines, but in the past, the large number of residential wells in
the area south of the Plant in the area near the intersection of
Table Rock and Biglerville Roads (Figure 2 - Appendix B) may have
drawn some of the Site contaminants to the south along strike to
this area. Although EPA suspects that this may have happened,
EPA cannot take action without data that links the low levels of
contamination in this area with the currently identified plume.
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13
Any VOC-contaminated ground water discharging to streams
would be substantially diluted and the VOC contaminants would
quickly leave the surface water to air where they would be
further diluted and dispersed.
All soil contamination detected recently was in the
subsurface where human receptors cannot come into direct contact
with the contaminants. The contaminants can, however, leach into
ground water.
Extent of Contamination
An extensive ground water investigation has been completed
at the Plant Site which consisted of drilling, constructing and
sampling seventeen monitoring wells in Phase I of the RI. The
wells were logged during drilling and various geological tests
were performed during drilling to help define the Site geology.
An additional eleven wells were drilled and constructed during
Phase II and all twenty-eight wells were sampled. Well locations
are shown in figure 5-Appendix B.
On-Plant ground water is currently highly contaminated with
up to 20,000 parts per billion VOCs, consisting of the
contaminants listed above. Table 1-Appendix C summarizes
laboratory results for ground water samples with contaminants
above detection limits. The estimated extent of the ground water
plume at deep and shallow depths is shown in Figures 2 and 6
(Appendix B). The shallow wells are about 40 to 100 feet deep
and the deep wells about 100 to 300 feet deep.
Off-Plant ground water directly east of the Plant and
between Table Rock Road and Biglerville Road had TCE levels above
federal drinking water standards Maximum Contaminant Levels
(MCLs), 40 C.F.R. §141.61 and Maximum Contaminant Level Goals
(MCLGs) 40 C.F.R. $141.50. In the June 1989 Phase I RI, Table 1-
4 shows pre-RI TCE levels in well MW-1 at a level greater that
81,000 ppb of TCE and a pre-RI off-Plant residential well at a
level of 1,000 ppb of TCE. The highest contaminant level found
during the EPA Remedial Investigation in on-, iant and off-Plant
ground water is compared to the federal drinking water standards
below.
Contaminant
TCE
TCA
1,1 DCE
On-Plant
Ground Water,
ppb
54,000
6,000
3,200
Off-Plant
Ground Water,
ppb
230
7
6
MCL
or
MCLG
5 MCL
200 MCL
7 MCLG
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14
Based on these high levels of ground water contamination,
and the Site history, EPA believes that Dense Non-Aqueous Phase
Liquids are present in the bedrock on the Plant property. DNAPLs
are liquids which are heavier than water and form a separate
phase, such as oil and water. These liquids sink through ground
water and continue downward through cracks in bedrock until the
liquid is trapped. The trapped DNAPLs slowly dissolve into the
ground water over a very long period of time. At the
Westinghouse Site, DNAPLs would be composed primarily of TCE and
TCA. Separate phase DNAPLs have not been observed in any wells
or borings, but are almost certainly present considering the high
VOC concentrations and persistence of the contaminant levels in
on-Plant ground water for over eight years.
Numerous homes are present east of the Plant in the area
bounded by Biglerville, Boyd's School and Table Rock Roads. Site
contaminants in ground water above MCLs have been detected within
this bounded area. This entire area is serviced by a public
waterline and all residents in this area have been offered the
opportunity for connection to the waterline at Westinghouse's
expense (Figure 2-Appendix B).
Many homes are located north of the Plant across Boyd's
School Road and are dependent on residential wells. Several
residential wells in the area bounded by South Avenue, Meadow
Lane, North Avenue, and Biglerville Road have been tested
recently and Site contaminants have not been detected.
Homes on Table Rock Road north of Boyd's School Road are
dependent on residential wells. Several residential wells in
this area were recently sampled. The laboratory results for
these samples did not indicate the presence of Site contaminants
in the ground water.
Homes to the west of the Site should not be affected because
Site groundwater flow direction is to the east in the shallow
zone and to the northeast in the deeper zones away from these
homes. Wells in this area were sampled in 1983 by PADER and Site
contaminants were not detected. Additionally, monitoring wells
to the west of the Site did not detect contamination during the
Phase II of the RI.
Surface water and sediment samples were collected at the
locations shown in Figure 7-Appendix B and the detailed
analytical results in tables 2 and 3 Appendix C. Although some
1983 samples did detect VOCs in these streams, the more recent RI
laboratory results indicated that the Northern and Eastern
tributaries are not currently significantly affected by volatile
organic compounds. The Eastern Tributary may be receiving very
low levels of TCE, but the dilution in the stream and
volatilization probably reduces any contamination below detection
limits. The only RI surface water sample that contained Site
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15
related VOCs was sample SW-i, from 1990, at a level barely above
drinking water standards and a duplicate sample contained none.
The Phase II samples did not detect Site related VOCs. Metals
levels were within acceptable levels and appear to be background
levels. A compound N-nitososodi-n-propylamine was detected in
one sample at 40 ppb, but was not found in the ground water or in
any Site soil samples. A possible source of the very low and
questionable level of past VOC contamination is considered to be
either seepage from the Former Pond area that is intercepted by a
storm drain discharging to the Eastern Tributary or by seasonal
shallow ground water discharge.
Many residential well samples were collected in the area
near the Plant and analyzed by the PAOER between 1983 and 1986.
These samples showed widespread contamination in the area bounded
by Biglerville, Table Rock and Boyds School Roads. During the
development of the Sampling and Analysis Plan, EPA tried to
convince Westinghouse that the residential wells should be
resampled as part of the Phase II investigation. The monitoring
well network proposed by Westinghouse did not address the
contamination found in the triangle southeast of the Plant and
bounded by Biglerville, Table Rock Roads and Apple Avenue.
Westinghouse declined this sampling effort and argued that they
were willing to extend the well network as needed to define the
contaminant plume from the Plant but they were unwilling to
perform widespread sampling for fear that they might find
contamination unrelated to the Plant. Westinghouse argued that
some residents may have contaminated their own wells with
commonly available solvents such as brush cleaners that they may
have disposed into their septic systems (The Commonwealth of
Pennsylvania has informed EPA that it believes that this area
near the intersection of Biglerville Road and Table Rock Road has
had sewer service from the mid 1960s.). Westinghouse further
argued that professionaly installed monitoring well data was far
more useful that open borehole residential well data.
EPA finally agreed to a proposal to place several monitoring
wells to the southeast of the Plant in the general direction of
the Apple Avenue area. EPA expected that contamination would be
found in these wells and that additional wells would be needed
further to the southeast in the Apple Avenue area. The RI
results did not support this expectation, however, EPA suspects
that before the waterlines were installed, the numerous wells in
the Apple Avenue area may have drawn contamination to this area.
If this were true, EPA expects that contaminant levels in the
Apple Avenue area would have declined due to natural attenuation.
EPA's contactor, Dynamac, sampled two wells in this area that had
previouly been sampled by the PADER in 1986. The results seem to
support this hypothesis, but no firm conclusion can be made
regarding the past source of contamination.
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16
Residence 1986 1991
Resident 1 100 ppb TCA non detected
0.7 1,1 DCA
Resident 2 4 ppb TCE 2.0 TCE
0.7 TCA
0.9 PCE
EPA's RI data does not support taking action for this area,
however, if the wells installed during the Remedial Action
indicate a continuous plume that extends to the Apple Avenue
area, the remedial action will encompass this area.
Analysis of the sediment samples in both Phase I and Phase
II did not detect Site related VOCs, but did detect various
semivolatiles which were attributed to runoff from nearby paved
areas. One sample taken near the culvert that carries the
eastern tributary just east of Route 34, contained elevated
levels of Poly Aromatic Hydrocarbons (PAHs). PAHs are found in
the asphalt used to coat roads, coal tar and automobile/truck
exhaust. A focused study was conducted to identify the source of
the PAHs. The high levels were only found in the area near the
culvert and the road, and quickly decreased downstream.
Westinghouse also found high levels in the drainage system from
their parking lot which had recently been resurfaced. EPA
concluded that these levels were from the parking lot resurfacing
and were not related to waste disposal. Also, some of the PAHs
are certainly due to road runoff. Zinc and lead were also
somewhat elevated in SD-1, but these levels pose little risk to
human health, are probably attributable to road run-off and
attenuate quickly downstream.
Runoff was collected from the Plant roof and storm drains,
but contamination was not detected. The Westinghouse Plant
emitted substantial VOCs from a roof vent and the roof samples
were taken to determine if TCE mist could be a source of
contamination during rain. The total VOC emissions from the
Plant were less than 100 tons per year and therefore the Plant
was exempt from the Clean Air Act which at that time only
regulated major sources of organic emissions (greater than 100
tons per year). Schindler Elevator Corporation has since
installed equipment to capture these vapors.
Based on these results, EPA does not plan to remediate
surface waters or sediments at the Site.
Soil contamination will be further defined and discussed in
a future Record of Decision.
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17
VI. SUMMARY OF SITE RISKS
Overview
As part of the Remedial Investigation performed for the
Westinghouse Plant Site, a risk assessment was conducted to
evaluate the potential impacts of the Site on human health and
the environment. Compounds of interest were identified separately
for four environmental media: ground water, surface water,
sediments and soil. The risks potentially associated with
exposure to these chemicals for each media were assessed. In
summary, the risks which will affect remedial planning are
associated with ingestion of carcinogenic chlorinated aliphatics
in ground water. Under the assumed conditions, exposure to
soils, surface water and sediments were not associated with risks
in excess of EPA target levels.
Potential risks to human health were identified by
calculating the risk level or hazard index for each compound of
interest. Carcinogenic risks were calculated as the lifetime
incremental upper-bound risk (probability) of developing cancer
as a result of being exposed to the chemicals of concern under
the assumed conditions. Risk for noncarcinogens were evaluated
relative to a chronic reference dose (RfD), which is an EPA
estimate of a daily exposure level for the human population that
is likely to be without an appreciable risk of deleterious health
effects during a lifetime. The ratio of the estimated dose to
the RfD for each compound of interest is called the hazard index.
If the hazard index exceeds one (1.0), there may be concern for
potential systemic effects. As a rule, the greater the value of
the hazard index above 1.0, the greater the level of concern.
The Risk Assessment uses a statistical analysis concept called
Reasonable Maximum Exposure (RME) to predict the highest
reasonable expected concentrations that a receptor might be
exposed to for use in the Risk Assessment. In calculating the
risks at the Site, the exposures evaluated assume more extensive
contact with the Site contaminants than is probably occurring, or
is likely to occur in the future. This concept produces a
conservative estimate of risk which is protective of receptors
including sensitive sub-populations.
Standard EPA methodologies were -used in the Risk Assessment
for exposure times, Chronic daily intake factors and key risk
exposure factors. Toxicity information was obtained from the
IRIS and HEAST toxicological data bases. The Risk Assessment was
reviewed and certified by the EPA Site toxicologist.
Exposure Media
Soils and ground water are the media of concern at the Site.
Although there are two streams near the Site (tributaries of Rock
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18
Creek) they are intermittent streams that are dry much of the
year, and the sediments and surface water therein were not
considered media of concern for the human health risk assessment.
Compounds of Interest
Waste materials generated at the Plant included spent
solvents, paint sludges, and spent oils. The following compounds
of interest were identified:
o target compound list (TCL) volatiles;
o bis(2-ethylhexyl)phthalate; and
o polychlorinated biphenyls (in pumphouse soils only and at
very low levels)
Exposure Assessment
Current and future land use scenarios were considered.
Under both scenarios, workers were considered the population of
concern on-Plant, while nearby residents and distant residents
were the populations of concern off-Plant.
On-Plant workers were assumed to be exposed to Site
contaminants via direct contact with (including incidental
ingestion of) surface soils. Because the contaminated soils are
within the Plant boundary and below the surface, there was
assumed to be no soil direct contact exposure pathway for the
public. Please note that a supplementary FS for soils will be
issued in the future and separate Record of Decision will be
issued for soils at the Site.
The off-Plant ground water was evaluated for several risk
scenarios. The first risk scenarios assume the use of near-Plant
ground water for drinking, showering and watering gardens
combined, and also, just from watering gardens. The second set
of risk scenarios assume the use of distant off-Plant ground
water for drinking, showering and watering gardens and also, just
from watering gardens. The third set of risk scenarios assume
the use of distant off-Plant water in the future for drinking,
showering and watering gardens and also, just from watering
gardens. Each set of risk scenarios was evaluated for the risk
to adults, children and young children. Additionally, the third
set of risk scenarios assume that the ground water contamination
increases to the much higher levels of near-Plant ground water.
Site Risk Characterization
Under the assumed exposure conditions, the highest estimated
risks from exposure to Site contamination are the potential
cancer risks associated with use of contaminated ground water by
near-Plant residents. Most of the risk (99%) is associated with
ingestion and shower-room inhalation of 1,l-dichloroethene and
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19
trichloroethene in groundwater. Assumptions regarding potable
water and irrigation uses of groundwater produced estimated
lifetime excess cancer risks between 3 x 10~4 and 6 x 10~5 for
off-Plant residents.
A subsequent Proposed Plan will detail the risks due to Site
soils, it should be noted, however, that the only VOC
contaminated soils ever detected were adjacent to the
Westinghouse Plant Building, which is on private property, and
that exposure of residents or children to these soils would be of
very limited duration, even if trespassing occurred. Soils have
been removed from the pumphouse area and the railroad loading
dock. These areas were sampled in Phase II and no contamination
was detected. The contaminated soil in the pond area is deep and
poses no risk from contact with surface soil in this area. The
courtyard area is still under investigation, but is in an area
not accessible to the public. None of these areas evaluated in
the Risk Assessment posed a direct contact risk to the public
even if exposure occurred. The estimated risks associated with
direct contact with on-Plant surface soils were very low
(approximately 2 x 10~7).
On-Plant around water
vocs in ground water at the Site are above the Maximum
Contaminant Level (MCL) allowed in potable water by the Safe
Drinking Water Act. For example, the most contaminated well on-
Plant contained 20,000 parts per billion (ppb) TCE and the most
contaminated off-Plant well contained 230 ppb TCE. The MCL for
TCE is 5 ppb. The on-Plant ground water would be associated with
cancer risk levels several orders of magnitude in excess of EPA's
target risk levels if it were used for drinking water. This
water is not used currently for drinking water and a deed
restriction will prevent its use for drinking water in the
future.
Of f «»piant groundwater
The results of the risk assessment for off-Plant ground
water can be summarized as follows:
a) Watering gardens under any scenario did not pose a risk
in excess of EPA target levels to the public and risks
were quite low. The excess cancer risk varied from a
high of 3 x 10"7 to a low of 8 x 10~8. In other words,
the highest increased cancer risk from watering gardens
was less than one in three million.
b) An assumption of full domestic use of groundwater posed
an increased cancer risk that was outside of EPA's
target risk range. The increased cancer risk varied
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20
from a high of 3 x 10~4 for near-Plant resident adults
to a low of 1 x 10~4 for distant off-Plant resident
children. Acceptable exposure levels are generally
concentration levels that represent an excess upper
bound lifetime cancer risk to an individual of between
1.0 x 10~4 and 1.0 x 10~6 or one in ten thousand to a
one in one million chance of developing cancer.
SUMMARY OF POTENTIAL CANCER RISKS AND HAZARD INDICES
FOR RECEPTORS AT THE Plant
Current Land Use Scenario
Receptors Cancer Hazard
Risk Index
Future Land Use Scenario
Cancer Hazard
Risk Index
On-Plant Maintenance Worker
Near-Plant RESIDENTS
Irrigation Use Only:
- Adults
- Children
- Young Children
Potable Water and
Irrigation Uses:
- Adults
- Children
- Young Children
1.54E-07
0.00
1.49E-07
2.62E-07
l.OSE-07
2.71E-07
2.30E-04
1.19E-04
0.00
0.00
0.00
0.06
0.08
0.16
1.54E-07 0.00
1.49E-07 0.00
2.62E-07 0.00
1.05E-07 0.00
2.71E-04 0.06
2.30E-04 0.08
1.19E-04 0.16
DISTANT Off-Plant RESIDENTS
Irrigation Uses Only:
- Adults
- Children
- Young Children
Potable Water and
Irrigation Uses:
- Adults
- Children
- Young Children
7.60E-08
1.34E-07
5.3SE-08
1.38E-04
1.17E-04
6.07E-05
0.00
0.00
0.00
0.03
0.04
0.08
1.49E-07 0.00
2.62E-07 0.00
1.05E-07 0.00
2.71E-04 0.06
2.30E-04 0.06
1.19E-04 0.16
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21
Relevant Risk Management Issues
The excess cancer risk levels for domestic use of
groundwater are outside of EPA's acceptable risk range for both
on-Plant and off-Plant ground water. Contamination in both on-
Plant and off-Plant ground water is above the MCL's promulgated
under the Safe Drinking Water Act. Either of these conditions is
sufficient to require a Remedial Action for on-Plant and off-
Plant groundwater. It is important to note that a public water
line serves residents adjacent to the Plant and that there are no
known receptors using contaminated ground water as a source of
drinking water. There are however, some residents located in the
area of concern that have been offered the opportunity to be
connected to the water line and have declined the offer. Many
residential wells are still in operation and are used for
watering lawns and gardens. Future purchasers of the properties
in this area may be unaware of the problem. Additionally, there
exists a threat for possible human health risks if at sometime in
the future, development occurs down-gradient of the Site with
installation of new wells or if a change in the use of the
adjacent National Park property occurs that could lead to the
potential use of ground water as a major drinking water source.
Actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or, the environment.
ECOLOGICAL ASSESSMENT
Methods
Surface water and sediments of the tributaries to Rock Creek
were considered the media-of-interest for ecological receptors.
Soils at the Plant were not ecological exposure media because
contaminated surface soils are within or near process areas at
the Plant that are not likely exposure points for ecological
receptors. Ground water was considered as a source of
contamination based on the potential for ground water to
discharge into the tributaries, but not as a direct contact
medium.
Although several other chlorinated aliphatics were detected
at low levels in ground water during Phase I, trichloroethene
(TCE) accounted for 90 to 95% of total aliphatics in ground water
and was the only compound detected in sediment or surface water
samples at concentrations significantly above the detection
limit. During Phase II, only non-Site related contaminants were
detected in surface water. Acetone, carbon tetrachoride and
chloroform are solvents used in analytical labs that are often
found even in blanks (analysis of pure water). Therefore, TCE was
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chosen as an indicator chemical to evaluate potential
toxicological effects to ecological receptors resulting from
exposure to total chlorinated aliphatics.
A quantitative assessment of the toxicity of TCE in
tributary surface water to aquatic organisms was conducted.
Potential ecological effects to benthos under current conditions
were assessed assuming interstitial pore water concentrations
were the same as surface water concentrations. Possible future
contamination of sediment interstitial pore water via ground
water discharge and the potential toxic effects on benthic
invertebrates were also evaluated. The potential effects of
exposure to TCE in the tributaries by terrestrial vertebrates
were evaluated qualitatively. Mo ecological effects were
expected based on this evaluation. Aquatic toxicity tests,
bioassays, and terrestrial surveys were deemed*unecessary based
on the chemical sampling/analysis of surface water and sediments.
No critical habitats, wetlands or endangered species were
identified at this Site, which is an industrial property in a
developed surrounding.
Summary of Ecological Risk Characterization
Under current conditions, compounds of interest in surface
water and sediments are below the threshold level for chronic or
acute effects to aquatic and benthic organisms. Additionally, no
risks are anticipated for terrestrial vertebrates that may come
into contact with the streams.
Under future conditions, there is a potential for chronic
effects for benthic organisms in the Eastern Tributary and Rock
Creek if future interstitial pore water concentrations of
chlorinated aliphatics reach the levels currently present in
ground water near these surface water bodies. However, it is
very unlikely that these concentrations will be reached in the
interstitial pore water due to dilution and dispersion of the
contaminants during migration. EPA's remedial action for ground
water will address this very small risk.
VII. SUMMARY OF ALTERNATIVES
The Superfund process requires that the alternative chosen
to clean up a hazardous waste site meet two threshold criteria:
1) protect human health and the environment, and 2) comply with
federal and state Applicable or Relevant and Appropriate
Requirements (ARARS). EPA's primary balancing criteria for a
selecting a remedial alternative are: long term effectiveness and
permanence; short term effectiveness; reduction of volume,
toxicity, or mobility of contaminants; cost effectiveness; and
implementability. EPA's modifying criteria are state and
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community acceptance.
The Feasibility Study evaluated remedial alternatives for
contaminated ground water on the Plant property separately from
ground water which has migrated off-Plant. This was done since
ground water beneath the Site is considerably more contaminated
than off-Plant ground water and is in contact with DNAPLs. Since
technology presently does not exist to effectively recover DNAPLs
from fractured bedrock, cleanup efforts will be difficult.
Additionally, ground water beneath the Plant is not used for
human consumption, posing a risk only from future potential use
which can be prevented by way of institutional controls (i.e.
deed restrictions). Since off-Plant contaminated ground water
has been shown to contain contaminants in lower concentrations
and is probably not in direct contact with DNAPLs, cleanup
efforts should be less difficult. Institutional controls such as
deed restrictions on surrounding residential properties would be
extremely difficult, if not impossible, to implement. For this
section, ground water beneath the Site will be referred to as on-
Plant ground water, and groundwater which has migrated past the
Plant property boundaries will be referred to as off-Plant ground
water. The Superfund Site encompasses all areas of contaminated
soil and ground water.
The Feasibility Study reviewed a variety of technologies to
see if they were applicable to the contamination at the Site.
The technologies determined to be most applicable to these
materials were developed into remedial alternatives. These
alternatives are presented and discussed below. Many other
technologies were reviewed and screened out. This screening
process is fully detailed in the Feasibility Study in the
administrative record. The treatment alternatives evaluated are
well established technologies and treatibility studies were not
necessary.
Five on-Plant and five off-Plant alternatives were developed
during this scoping study. These on-Plant and off-Plant
alternatives can be combined to select a remedy for the Site. In
addition, instead of alternatives that combine off-Plant and on-
Plant responses, two overall Site-wide alternatives were
developed that have a common treatment system. For the two Site-
wide alternatives all off-Site extracted groundwater is piped on-
Plant and treated along with the on-Plant extracted ground water.
These two Site-wide alternatives provide options that avoid the
construction and operation of a treatment facility off-Plant.
All.costs and implementation time-frames specified below are
scoping estimates based on best available, information. The
Present Worth Cost is the total cost, in current dollars, of the
remedy including capital costs and 30 years of operation and
maintenance of the remedial action. Appendix B of the
Feasibility Study presents detailed preliminary cost estimates
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for each of the remedial alternatives. The time frames to reach
ground water cleanup goals are virtually impossible to predict at
this Site. A 30 year operation cost estimate was used for both
on-Plant and off-Plant. The "capture zone" (the area to which
contaminated ground water will be drawn to) for on-Plant
groundwater must be maintained until non-zero MCLGs and MCLs are
maintained for twelve consecutive quarters. The capture zone is
the entire area within which ground water is recovered through
the extraction well network. The off-Plant extraction wells must
operate until non-zero MCLGs or MCI levels are also reached and
maintained for twelve consecutive quarters.
The "area of attainment" for both on-Plant and off-Plant
ground water is the entire ground water contamination plume that
has COI levels above non-zero MCLGs and MCLs, is related to the
Plant property and can be be captured with a technically
practicable design as determined by EPA.
An EPA review of the Site every five years will be conducted
to ensure continued protection of human health and the
environment.
The following alternatives have been presented in the
Proposed Plan as possible remedies at the Site:
On-Plant Alternatives
1) No Action
2) Limited Action/Institutional Controls
3A) Extraction and Peroxidation/UV Catalysis Treatment
of Ground Water
3B) Extraction and Air Stripping of Ground Water -
Carbon Treatment of Effluent Air Stream
4) Aquifer Restoration
Off-Plant Alternatives
1) No Action
2) Limited Action/Institutional Controls
3A) Ground water Extraction with Aqueous Phase Carbon
Adsorption Treatment
3B) Extraction and Air Stripping of Ground Water -
Carbon Treatment of Effluent Air stream
4) Aquifer Restoration
Site-Wide Alternatives
1A) Site-Wide Extraction System with On-Plant
Peroxidation/UV Catalysis Treatment
IB) Site-Wide Extraction and On-Plant Air Stripping of
Ground Water - Carbon Treatment of Effluent Air
Stream
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Below are descriptions of each of the presented remedial
alternatives.
Common elements of all remedies except the no action and limited
action alternatives: installation of additional monitoring veils,
ground water monitoring quarterly for two years and annually
afterwards, annual residential well sampling and analysis, and
deed restrictions on the Westinghouse property.
On-Plant Alternative 1 - No Action
Capital Cost $ 0
Annual Operation & $ 22,500
Maintenance Cost
Present Worth $ 401,000
Months to Implement 0
On-Plant Alternative l is a no action alternative. As part
of this alternative, the ground water would be monitored
quarterly for the next 30 years. The existing interim pumping
and treatment system would not operate. The no action
alternative evaluation, which is required by the National
Contingency Plan (NCP), the EPA regulations that interpret the
Superfund Act, is retained for comparison purposes. Under the no
action alternative, there would not be deed restrictions nor any
other institutional controls. This alternative relies on natural
environmental attenuation mechanisms such as dispersion and
degradation to eventually decrease maximum VOC concentrations to
below MCLs.
On-Plant Alternative 2 - Limited Action/Institutional Controls
Capital Cost $ 171,930
Annual O&H Cost $ 113,180
Present Worth $ 2,035,840
Months to Implement 6
The on-Plant limited action/institutional controls
alternative for on-Plant ground water assumes that the existing
interim pump and treatment scheme would continue. Two wells
currently extract about 9 gallons per minute of ground water in
front of the Plant.
The ground water treatment consists of air stripping in a
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packed column on the Plant Site. In air stripping, the volatile
organic hydrocarbon contaminants in extracted ground water
trickling down through the packed column are vaporized into air
flowing up through the column. Carbon treatment of the effluent
air stream from the column would be added to the existing
stripper. This involves passing the air stream through activated
charcoal which adsorbs the hydrocarbons. Eventually, the carbon
becomes saturated with contaminants and must be disposed and the
effluent air stream must be periodically monitored to make sure
the carbon is functioning. The frequency on monitoring would be
determined by EPA during the Remedial Design. About two tons per
year of spent carbon would be regenerated at a RCRA permitted
facility or disposed of as a hazardous waste in accordance with
RCRA regulations.
The treated ground water would be discharged to the Northern
Tributary (figure 2-Appendix B) via the current outfall under the
current NPDES permit if possible. If a modified permit is
required, during the design of the ground water treatment system,
specific discharge criteria will be established by the PADER.
The system would continue to operate until non-zero MCLGs and
MCLs in ground water are reached throughout the plume.
On-Plant Alternative 3A - Source Control/Management of Migration
fSC/MM> Ground Water Extraction and Peroxidation/UV Catalysis
Treatment of Ground Water
Capital Cost $ 910,151
Annual O&M Cost $ 251,480
Present Worth $ 4,858,600
Months to Implement 18
This alternative would employ extraction of contaminated on-
Plant ground water using pumping wells. Source control is
defined as pumping near the Plant building and Management of
Migration is defined as pumping near the property boundary. The
pumping system would be designed to capture all contaminated
ground water at the Plant property technically practicable, as
approved by EPA during Remedial Design.
Extracted ground water would be treated on-Plant by the
peroxidation/UV catalysis process. This process involves the use
of the strong oxidizing chemical hydrogen peroxide to convert
undesirable chemical species by addition of oxygen. The process
reduces the carbon in the aliphatic hydrocarbon chains, breaking
down carbon-hydrogen and carbon-halogen bonds. Ultra-violet (UV)
is used as a catalyst in the peroxidation process. As a result,
complex and resistant chemical species can either be fully
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degraded to basic components such as carbon dioxide and water, or
broken down to simpler, more easily degradable molecules. The
discharged water would be periodically monitored for contaminants
at a frequency determined by EPA during Remedial Design.
The treated ground water would be discharged to the Northern
Tributary (figure 2-Appendix B) via the current outfall under the
current NPDES permit if possible. If a modified permit is
required, during the design of the ground water treatment system,
specific discharge criteria will be established by the PAOER.
The system would continue to operate until non-zero MCLGs and
MCLs in ground water are reached throughout the plume. This
alternative captures most of the on-Plant VOCs for on-Plant
treatment and disposal.
On-Plant Alternative 3B - SC/MM Ground Water Extraction
and Air-Stripping Treatment and Carbon Adsorption
Capital Cost $ 404,179
Annual O&M Cost $ 113,180
Present Worth $ 2,238,780
Months to Implement 12
This alternative would employ extraction of contaminated on-
Plant ground water using pumping wells. Source control is
defined as pumping near the Plant building and Management of
Migration is defined as pumping near the property boundary. The
pumping system would be designed to capture all contaminated
ground water at the Plant property technically practicable, as
approved by EPA during Remedial Design.
Ground water would be treated on-Plant using air stripping
and carbon adsorption of contaminants from the air stream. The
first stage of ground water treatment consists of air stripping
in a packed column on the Plant Site. In air stripping, the
volatile organic hydrocarbon contaminants in extracted ground
water trickling down through the packed column are vaporized into
air flowing up through the column. Carbon treatment of the
effluent air stream from the column is the second stage of
treatment. This involves passing the air stream through
activated charcoal which adsorbs the hydrocarbons. Eventually,
the carbon becomes saturated with contaminants and must be
disposed and the effluent air stream must be periodically
monitored to make sure the carbon is functioning. About four
tons per year of spent carbon would be regenerated at a RCRA
permitted facility or disposed of off-site as a hazardous waste
in accordance with RCRA regulations.
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The treated ground water would be discharged to the Northern
Tributary (figure 2-Appendix B) via the current outfall under the
current NPDES permit if possible. If a modified permit is
required, during the design of the ground water treatment system,
specific discharge criteria will be established by the FADER.
The system would continue to operate until non-zero MCLGs and
MCLs in ground water are reached throughout the plume.
On^Plant Alternative 4 - Attempted Aquifer Restoration
Capital Cost $ 3,164,955
Annual O&H $ 177,000 to $ 136,100
Present Worth $ 5,630,220
Months to Implement 24
This alternative would extract ground water from numerous
wells located at the source areas, near the property boundaries,
and parallel to the centerlines of the shallow and deep plume.
As part of this process, a portion of the treated ground water
would be re-injected into several wells upgradient of the plumes
in an attempt to create a "flushing" affect of contaminated
ground water, and the remaining treated ground water would be
discharged to the Northern Tributary via the current outfall.
The pumping system would be designed to capture all contaminated
ground water at the Plant property technically practicable, as
approved by EPA during Remedial Design. Additionally, this
alternative attempts to capture and treat as much contaminated
ground water as soon as possible in order to minimize the time
required to effect total aquifer remediation. However, the time
for aquifer restoration may only be shortened for the
downgradient, more dilute portions of the aquifers, and not for
the portions near the source areas.
Ground water would be treated on-Plant using air stripping
and carbon adsorption of contaminants in the air stream. The
first stage of ground water treatment consists of air stripping
in a packed column on the Plant Site. In air stripping, the
volatile organic hydrocarbon contaminants in extracted ground
water trickling down through the packed column are vaporized into
air flowing up through the column. Carbon treatment of the
effluent air stream from the column is the second stage of
treatment. This involves passing the air stream through
activated charcoal which adsorbs the hydrocarbons. Eventually,
the carbon becomes saturated with contaminants and must be
disposed and the effluent air stream must be periodically
monitored to make sure the carbon is functioning. About five
tons per year of spent carbon would be regenerated at a RCRA
permitted facility or disposed of off-site as a hazardous waste
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in accordance with RCRA regulations.
The treated ground water would be discharged to the Northern
Tributary (figure 2-Appendix B) via the current outfall under the
current NPDES permit if possible. If a modified permit is
required, during the design of the ground water treatment system,
specific discharge criteria will be established by the PADER.
The system would continue to operate until non-zero MCLGs and
MCLs in ground water are reached throughout the plume.
Off-Plant Alternative 1 - No Action
Capital Cost $ 0
Annual O&M Cost $ 37,700
Present Worth $ 635,240
Months to Implement 0
The no action alternative for off-Plant ground water assumes
that no remedial actions will occur except for quarterly ground
water monitoring and annual sampling and analysis of residential
wells for 30 years. This alternative relies on natural
environmental attenuation mechanisms such as dispersion and
degradation to decrease maximum VOC concentrations to below MCLs
with time. Evaluation of this alternative is required by the
National Contingency Plan.
Off-Plant Alternative 2 - Limited Action/Institutional Controls
Capital Cost $ 1,339,663
Annual O&M Cost $ 39,400
Present Worth $ 2,001,040
Months to Implement 6
This limited action/institutional controls alternative for
off-Plant ground water assumes that alternate water supplies are
extended to certain residents between the Site and Rock Creek,
ground water monitoring would be performed quarterly for the
30-year project life, residential wells will be sampled and
analyzed annually for the 30-year project life, and ground water
use restrictions may be implemented.
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Off-Plant Alternative 3A - MM Ground water Extraction
with Aqueous Phase Carbon Adsorption Treatment
Capital Cost $ 1,573,265
Annual O&M Cost $ 118,150
Present Worth $ 3,473,350
Months to implement 24
Contaminated ground water would be removed by extraction
wells and treated off-Plant by aqueous phase carbon adsorption.
The off-Plant extraction well system will be designed so that all
contaminated ground water leaving the Site will be contained, as
techically practicable, but the capture zone of the network will
not be designed to fully extend to the Plant property to avoid
drawing the highly contaminated ground water off-Plant. The
actual extent of the capture zone would be approved by EPA during
the Remedial Design.
The extracted ground water would be pumped through a bed of
activated charcoal, which would adsorb the volatile organic
hydrocarbons. Eventually, the carbon becomes saturated with
contaminants and must be disposed of properly and the effluent
water must be periodically monitored to make sure the carbon unit
is functioning adequately. About two hundred pounds per year of
spent carbon would be regenerated at a RCRA permitted facility or
disposed of off-site as a hazardous waste in accordance with RCRA
regulations.
The treated ground water would be discharged to the Northern
Tributary (figure 2-Appendix B) via a new outfall. An NPDES
permit would be required, and during the design of the ground
water treatment system, specific discharge criteria will be
established by the PAOER. The system would continue to operate
until non-zero MCLGs and MCLs in ground water are reached
throughout the plume.
This alternative is intended to capture off-Plant
contaminated ground water for treatment and discharge and to
remediate the off-Plant ground water.
Off-Plant Alternative 3B - MM Ground water Extraction with
AirStripping Treatment and Carbon Adsorption
Capital Cost $ 1,580,055
Annual O&M Cost $ 118,500
Present Worth $ 3,486,890
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Months to Implement 24
Contaminated ground water would be removed by extraction
wells and treated off-Site using air stripping and treatment of
the air stream by carbon adsorption. The off-Plant extraction
well system would be designed so that all contaminated ground
water leaving the Site will be contained, as technically
practicable, but the capture zone of the network will not be
designed to fully extend to the Plant property to avoid drawing
the highly contaminated ground water off-Plant. Since
contaminants are in dissolved form and since the ground water is
not expected to be in contact with DNAPLs, this pumping system
should clean up the off-Plant ground water. The actual extent of
the capture zone would be approved by EPA during the Remedial
Design.
Ground water would be treated on-Plant using air stripping
and carbon adsorption of contaminants in the air stream. The
first stage of ground water treatment consists of air stripping
in a packed column on the Plant Site. In air stripping, the
volatile organic hydrocarbon contaminants in extracted ground
water trickling down through the packed column are vaporized into
air flowing up through the column. Carbon treatment of the
effluent air stream from the column is the second stage of
treatment. This involves passing the air stream through
activated charcoal which adsorbs the hydrocarbons. Eventually,
the carbon becomes saturated with contaminants and must be
disposed and the effluent air stream must be periodically
monitored to make sure the carbon is functioning. About two
hundred pounds per year of spent carbon would be regenerated at a
RCRA permitted facility or disposed of off-Plant as a hazardous
waste in accordance with RCRA regulations.
The treated ground water would be discharged to the Northern
Tributary (figure 2-Appendix B) via a new outfall. An NPDES
permit would be required, and during the design of the ground
water treatment system, specific discharge criteria will be
established by the FADER. The system would continue to operate
until non-zero HCLGs and MCLs in ground water are reached
throughout the plume.
This alternative is intended to capture off-Plant
contaminated ground water for treatment and discharge and to
remediate the off-Plant ground water to health based levels
(MCLs/HCLGs).
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Off-Plant Alternative 4 - Aquifer Restoration
Capital Cost $ 4,728,811
Annual O&M Cost $ 173,740 to 137,640
Present Worth $ 7,183,730
Months to Implement 24
Ground water would be extracted from wells located parallel
to the centerlines and extremities of the shallow and deep
off-Plant plumes. Alternative 4 includes several reinjaction
wells that would attempt to develop a flushing effect in the
aquifer both on-Plant and off-Plant. This alternative attempts
to capture and treat as much contaminated ground water as soon as
possible in order to minimize the time required to effect total
aquifer remediation. It would achieve the same objectives as
alternatives 3A and 3B, but would achieve them sooner.
The extracted ground water would be pumped through a bed of
activated charcoal, which will adsorb the volatile organic
hydrocarbons. Eventually, the carbon becomes saturated with
contaminants and must be disposed of and the effluent water must
be periodically monitored to make sure the carbon is functioning.
About four hundred pounds per year of spent carbon would be
regenerated at a RCRA permitted facility or disposed of off-Site
as a hazardous waste in accordance with RCRA regulations.
The treated ground water would be discharged to the Northern
Tributary (figure 2-Appendix B) via a new outfall. An NPDES
permit would be required, and during the design of the ground
water treatment system, specific discharge criteria will be
established by the PADER. The system would continue to operate
until non-zero MCLGs and MCLs in ground water are reached
throughout the plume.
This alternative is intended to capture off-Plant
contaminated ground water for treatment and discharge and to
remediate the off-Plant ground water.
Site-Wide Alternative 1A - Site-Wide Extraction System with
On-Site Peroxidation/UV Catalysis Treatment
Capital Cost $ 3,099,843
Annual O&M Cost $ 507,430
Present Worth $ 11,003,060
Months to Implement 24
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This alternative consists of two separate capture zones for
the on-Plant and off-Plant ground water. "Capture Zone 1"
consists of an area where ground water flows to the on-Plant
pumping wells where it is collected. The pumping system would be
designed to capture all contaminated ground water at the Plant
property technically practicable as approved by EPA during
Remedial Design. A second set of extraction wells will be placed
near the edge of the contaminant plume (Figure 8 - Appendix B)
and in the path of natural ground water flow from the Plant.
Pumping rates in this set of extraction wells will be designed so
that "Capture Zone 2" does not fully extend to the other capture
zone. The off-Plant extraction well system would be designed so
that all contaminated ground water leaving the Site will be
contained, as technically practicable, but the capture zone of
the network will not be designed to fully extend to the Plant
property to avoid drawing the highly contaminated ground water
off-Plant. A zone of slow moving water (Stagnation Zone)
between the capture zones will result, but the pumping rates of
the two systems can be varied to move the stagnation zone
periodically so that the ground water in this zone is collected
by the extraction wells. Any contaminated ground water escaping
the on-Plant wells should flow to the off-Plant extraction wells.
The systems would be designed to try to capture all contaminated
ground water and to remediate off-Plant ground water.
Extracted off-Plant ground water would be pumped to the
Plant through a piping system and treated with the on-Plant
ground water in a common treatment system.
Extracted ground water would be treated on-Plant by the
peroxidation/UV catalysis process. This process involves the use
of the strong oxidizing chemical hydrogen peroxide to convert
undesirable chemical species by addition of oxygen. The process
reduces the carbon in the aliphatic hydrocarbon chains, breaking
down carbon-hydrogen and carbon-halogen bonds. Ultra-violet (UV)
is used as a catalyst in the peroxidation process. As a result,
complex and resistant chemical species can either be fully
degraded to basic components such as carbon dioxide and water, or
broken down to simpler, more easily degradable molecules. The
discharged water would be periodically monitored for contaminants
at a frequency determined by EPA during Remedial Design.
The treated ground water would be discharged to the Northern
Tributary (figure 2-Appendix B) via the current outfall under the
current NPDES permit if possible. If a modified permit is
required, specific discharge criteria will be established by the
PADER during the Remedial Design. The system would continue to
operate until non-zero MCLGs and MCLs in ground water are reached
throughout the plume. This alternative captures most of the
on-Plant VOCs for on-Plant treatment and disposal.
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Site-Wide Alternative IB - Site-Wide Extraction System with
On-Site Air-Strippina Treatment and Carbon Adsorption
Capital Cost $ 2,119,710
Annual O&M Cost $ 141,930
Present Worth $ 4,403,730
Months to Implement 24
This alternative consists of two separate capture zones for
the on-Plant and off-Plant ground water. "Capture Zone l"
consists of an area where ground water flows to the on-Plant
pumping wells where it is collected. The pumping system would be
designed to capture all contaminated ground water at the Plant
property technically practicable as approved by EPA during
Remedial Design. A second set of extraction wells will be placed
near the edge of the contaminant plume (Figure 8 - Appendix B)
and in the path of natural ground water flow from the Plant.
Pumping rates in this set of extraction wells will be designed so
that "capture Zone 2" does not fully extend to the other capture
zone. The off-Plant extraction well system would be designed so
that all contaminated ground water leaving the Site will be
contained, as technically practicable, but the capture zone of
the network will not be designed to fully extend to the Plant
property to avoid drawing the highly contaminated ground water
off-Plant. A zone of slow moving water (Stagnation Zone) between
the capture zones will result, but the pumping rates of the two
systems can be varied to move the stagnation zone periodically so
that the ground water in this zone is collected by the extraction
wells. Any contaminated ground water escaping the on-Plant wells
should flow to the off-Plant extraction wells. The systems would
be designed to try to capture all contaminated ground water and
to remediate off-Plant ground water.
Extracted off-Plant ground water would be pumped to the
Plant through a piping system and treated with the on-Plant
ground water in a common treatment system.
Ground water would be treated on-Plant using air stripping
and carbon adsorption of contaminants from the air stream. The
first stage of ground water treatment consists of air stripping
in a packed column on the Plant property. In air stripping, the
volatile organic hydrocarbon contaminants in extracted ground
water trickling down through the packed column are vaporized into
air flowing up through the column. Carbon treatment of the
effluent air stream from the column is the second stage of
treatment. This involves passing the air stream through
activated charcoal which adsorbs the hydrocarbons. Eventually,
the carbon becomes saturated with contaminants and must be
disposed and the effluent air stream must be periodically
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monitored to make sure the carbon is functioning. About four
tons per year of spent carbon would be regenerated at a RCRA
permitted facility or disposed of off-Site as a hazardous waste
in accordance with RCRA regulations.
The treated ground water would be discharged to the Northern
Tributary (figure 2-Appendix B) via the current outfall under the
current NPDES permit if possible. If a modified permit is
required, during the design of the ground water treatment system,
specific discharge criteria will be established by the PADER.
The system would continue to operate until non-zero MCLGs and
MCLs in ground water are reached throughout the plume.
VIII. Comparative Analysis of Remediation Alternatives
In this section the five on-Plant, five off-Plant, and two
Site-wide remediation alternatives are compared to each other
using the nine criteria that EPA uses in the decision making
process.
Overall Protection of Human Health and the Environment:
The best alternatives for overall protection of human health
and the environment are on-Plant Alternatives 3A and 3B,
off-Plant Alternatives 3A and 3B, and Site-Wide Alternatives
1A and IB. These on-Plant alternatives and the on-Plant
component of the Site-Wide alternatives prevent the
migration of highly contaminated ground water off-Plant and
will eventually remediate the on-Plant ground water. The
off-Plant alternatives 3A, 3B and the off-Plant components
of the site-wide alternatives will prevent migration of
moderately contaminated ground water from the area served by
the water line and will clean up the off-Plant ground water.
The accelerated aquifer restoration alternatives (on-
Plant/ off-Plant 4) have a slightly lower ranking for this
criterion than the other treatment alternatives, because the
reinjection of ground water might spread contamination in
unpredictable directions. These alternatives could also
draw contaminated ground water off-Plant spreading the on-
Plant highly contaminated plume. On-Plant Alternative 2 was
rated poor because VOC-impacted ground water will continue
to migrate off-Plant. Off-Plant Alternative 2 was rated as
fair because of the extension of an alternative water supply
to potentially affected residences. Alternatives that are
not protective of human health and the environment include
on-Plant Alternative 1 and Off-Plant Alternative 1, the no
action alternatives.
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Compliance with ARARs:
Only the aquifer remediation alternatives 4 might comply
with the FADER ARAR to actively remediate on-Plant ground
water to background. EPA plans to waive this ARAR on the
basis of technical impracticability and presenting a greater
risk to human health and the environment. The appropriate
cleanup level will be set by non-zero MCLGs and MCLs.
Both the federal and state Safe Drinking Hater Acts set
minimum standards for drinking water supplied by municipal
wells called Maximum Contaminant Levels (MCLs), which are
enforceable federal standards. Maximum Contaminant Level
Goals (MCLGs) are usually lower levels than MCLs that EPA
attempts to achieve if possible. The ground water at the
Plant Site is considered a Class IIA aquifer and non-zero
MCLGs and MCLs are exceeded for both on-Plant and off-Plant
ground water. The no action alternatives would not comply
with the state standards as set forth in 25 PA Code, Chapter
109 Subchapter B) or the federal standards (40 C.F.R. Part
141.61). Off-Plant and on-Plant alternatives 2 would also
not comply with these regulations since contaminants would
still escape from the Site and would continue to exceed
MCLs. EPA normally takes action when MCLs are exceeded in a
Class IIA aquifer. All other on-Plant and off-Plant
alternatives would comply with this ARAR.
All of the Alternatives except the no action alternatives
will discharge treated ground water to the northern
tributary and would comply with the Water Quality criteria
(25 PA Code, §S93.l, through 93.9) or obtain a waiver from
the State
All of the Alternatives except the no action alternatives
will have air emissions from the carbon adsorber and would
comply with the requirements set forth in 25 PA Code S
127.12(a)(5), which requires that emissions be reduced to to
a minimum through Best Available Technology as defined in 25
PA Code S 121.1). The alternatives would also comply with
RCRA requirements of Subpart AA (Air Emission Standards for
Process Vents) of the federal RCRA regulations, 40 C.F.R.
264.1032 are relevant and appropriate for the air stripping
operations under the selected remedy. Under this ARAR,
total organic emissions from the carbon adsorber must be
less than 1.4 kg/hr (3 Ib/hr) and 2800 kg/yr (3.1 tons/yr).
These alternatives would also comply with the TBC OSWER
Directive 9355.0-28 which requires control of hydrocarbon
emissions in excess of 15 pounds per day in ozone non-
attainment areas.
All of the Alternatives except the no action alternatives
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would discharge treated ground water to a stream (Northern
Tributary) and would comply with the NPDES Regulations (25
PA Code, §§ 92.31, 92.41 and 92.55). These regulations give
design, discharge and monitoring requirements for the
stripper discharge. On-Plant alternative 3A might have
difficulty complying with the NPDES permit because some
compounds are resistent to UV oxidation.
On-Plant ground water is above the TCLP level (500 ppb) (25
PA Code Chapter 261 Subchapter C and 40 C.F.R. § 261.24) and
must be managed as a hazardous waste.
All of the alternatives except the no action alternatives
and on-Plant alternative 3A would produce treatment
residuals (spent carbon) that must be managed as a RCRA
hazardous waste. A scoping estimate of the amount of carbon
disposed is about four tons per year. These residuals must
be managed in compliance with applicable sections of the PA
Solid Waste Act, 35 P.S. §§ 6018.101 through 6018.1003,
which follow: 25 PA Code Part 262 Subparts A (relating to
hazardous waste determination and identification numbers), B
(relating to manifesting requirements for off-site shipments
of spent carbon or other hazardous wastes), C (relating to
pre-transportation of hazardous waste requirements ), and
with respect to operations at the Site generally, with the
substantive requirements of 25 PA Code 264 Subparts B-D, I
(in the event that hazardous waste generated as part of the
remedy is managed in containers), J (in the event that
hazardous waste is managed, treated or stored in tanks).
The alternative implemented will also comply with the RCRA
Land Disposal Restrictions set forth at 40 C.F.R. Part 268.1
to 268.5 related to the management of hazardous wastes
(including spent carbon from air stripping) generated as
part of the remedy.
All of the alternatives evaluated except the no action
alternatives require additional wells. Wells shall be
constructed as provided in 25 PA Code chapter 107.
Long-Tern Effectiveness and Permanence: Long-term
effectiveness and permanence is achieved in its highest
degree with off-Plant and on-Plant Alternatives 3A and 3B
and the Site wide alternatives. For these alternatives the
plumes are contained, VOCs are removed and destroyed in the
treatment processes, and on-Plant deed restrictions, which
would abate the risks posed by use of ground water, will be
put in place. On-Plant and off-Plant Alternatives 4 rank
slightly lower for this criteria because injection could
spread contamination to unexpected areas. Alternatives that
do not fully address long-term effectiveness and permanence
include the no action alternatives (on and off-Plant
alternative 1) and the limited action/institutional controls
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38
alternatives (on and off-Plant alternative 2).
Reduction of Mobility, Toxicity or Volume Through Treatment:
This criterion addresses the statutory preference for
remedies that employ treatment as a principal element of the
alternative. All alternatives except for the no action
involve some aspect of reduction of mobility, and toxicity.
On-Plant Alternative 3A involves the destruction of
volatiles with ozone and peroxide. Some compounds such as
TCA are resistant to this technology. Carbon adsorbs and
reduces the mobility of the volatiles and when regenerated,
the volatiles are ultimately destroyed reducing their
toxicity. All alternatives except Alternatives 1 (no
action) and on-Plant 3A use some form of carbon adsorption
which is proven, simple and reliable. On-Plant and off-
Plant alternatives 1 (no action) will not satisfy this
requirement.
Short-Tern Effectiveness: On-Plant and off-Plant
Alternatives 2 can be implemented more quickly than on-Plant
and off-Plant alternatives 3 and the Site wide alternatives,
but some contaminants will still escape from the Site.
The remainder of the alternatives present minimal
construction and community risks if work proceeds according
to the OSHA standards. Off-Plant Alternative 4 could be
delayed by the large number of wells that would be placed on
a large number of different properties. This could present
severe access problems and community resentment.
Alternatives that do not meet the requirements for
short-term effectiveness include on-Plant and off-Plant
Alternative 1. With these alternatives, VOCs can still
travel from on-Plant to off-Plant affected areas or from
off-Plant to further off-Plant areas that are presently
unaffected by VOCs.
Implementability: The implementability criterion relates to
the technical and administrative feasibility of an
alternative. Off-Plant Alternative 4 was rated lower for
this criterion because of the potential administrative
problems with obtaining additional property easements and
increased technical difficulty during operations.
Technically, the reinjection (flushing) aspect of this
alternative will probably be difficult to achieve because of
the variable permeabilities of the aquifers. The amount of
off-Plant property construction required for this
alternative could also hinder its implementation. On-Plant
Alternative 4 has a better rating because it is assumed
on-Plant activities will be much easier to implement than
off-Plant activities. A potential minor issue that could be
considered when comparing off-Plant Alternatives 3A and 3B
relates to the physical structure of the treatment unit.
The off-Plant air-stripper tower, required by Off-Plant
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Alternative 3B, could result in minor aesthetic impacts and
some minor operational and security concerns. An off-Plant
carbon adsorption treatment unit, off-Plant Alternative 3A,
should be less obtrusive. The Site-Hide Alternatives 1A and
IB are superior to the off-Plant alternatives because no
treatment facility would be built and operated off-Plant;
therefore, aesthetic impacts might be improved and no
additional treatment discharge outfall to the North
Tributary would be needed. The best alternatives for
implementability are on-Plant Alternatives 1 and 2 and
off-Plant Alternative 1. The major component of these
alternatives is monitoring ground water, which should be
easily implemented. On-Plant Alternative 2 does include
operation of the existing interim air stripper with
modifications and on-Plant deed restrictions, but
implementability problems for these elements of on-Plant
Alternative 2 are assumed to be minor.
Services and materials are readily available for all of the
evaluated alternatives.
Cost: The preliminary total costs developed, include
capital costs and operation and maintenance costs for a
30-year project life. One on-Plant alternative along with
one off-Plant alternative would be combined to formulate an
acceptable Site-wide alternative. Note that On-Plant
Alternative 4, Aquifer Restoration, must be combined with
Off-Plant Alternative 4, Aquifer Restoration, because of
synergistic effects, and costs much more than the other
alternatives($ 13 million). An alternative to combining
off-Plant /on-Plant alternatives would be to select one of
the already-developed Site-wide alternatives. The estimated
costs of these Site-wide alternatives have been rated by
comparing their total costs to the total costs of combined
on-Plant and off-Plant medium-specific alternatives. The
total estimated cost of the Site-wide alternatives is
$11,003,060 for Site-Wide Alternative 1A and $4,403,730
for Site-Wide Alternative IB. A combination of On-Plant
Alternative 3B with either Off-Plant Alternative 3A or 3B
would achieve the same objectives and would have a total
estimated cost of approximately $5,712,000.
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Westinghouse Plant
Remedial Alternative Costs
Alternatives
on-Plant i
No Action
On-Flant 2
Limited Action
On-Plant 3A - SC/MM
UV Peroxidation
On-Plant 3B - Air
Stripping/Carbon
On-Plant 4 -
Aquifer Remediation
Off-Plant 1 -
No Action
Off-Plant 2 -
Limited Action
Off-Plant 3A - MM
Aq. Carbon Ads.
Off-Plant 3B - MM
Air strip/ Carbon Ad
Off-Plant 4 -
Aquifer Remediation
Capital
0
$ 171,000
$ 910,000
$ 410,000
$ 3,164,000
$ 0
$ 1,339,000
$ 1,573,000
$ 1,580,000
$ 4,728,000
0 & M
$ 22,500
$ 113,000
$ 251,480
$ 113,180
$ 177,000
$ 37,000
$ 39,000
$ 118,000
$ 118,500
$ 173,000
Present Worth
$ 401,000
$ 2,035,000
$ 4,858,000
$ 2,238,000
$ 5,630,000
$ 635,000
$ 2,001,000
$ 3,473,000
$ 3,486,890
$ 7,183,000
Site Wide SC/MM - UV
Peroxidation
Preferred
Alternative
Site Wide SC/MM -
Air Stripping/Carbon
$ 3,099,000
$ 2,120,000
$ 507,000
$ 141,000
$ 11,000,000
$ 4,404,000
SC = Source Control MM = Management of Migration
STATE ACCEPTANCE:
The Commonwealth of Pennsylvania does not concur with the
Selected Alternative.
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COMMUNITY ACCEPTANCE:
EPA believes that the community is generally supportive of
the selected remedy. The only written comments received on the
Proposed Plan were from the Commonwealth of Pennsylvania and the
Westinghouse Electric Corporation. No comments were made in
opposition to the preferred alternative at the public meeting and
the comments from Westinghouse's contractor were also supportive.
Community Acceptance is addressed in more detail in the
Responsiveness Summary (Appendix D).
IX. THE SELECTED ALTERNATIVE
General Decription and Selection Rationale
Since the hydrogeology at the Site is so complicated, the
EPA Site hydrogeologist consulted with several other EPA
hydrogeolegists and an expert on the Gettysburg geological
formation, Mr. Charles Wood (U.S. Geological Service), during the
review of the Remedial Investigation. The hydrogeologists
consulted recommended placing wells in the center of the
contaminated ground water plume if EPA decided to pump and treat
the aquifer. The hydrogeologists also warned against trying to
actively remediate the entire plume, because the wells in the
more dilute portions of the plume could draw water from the
center of the plume and spread the contamination.
The Selected Alternative for the contaminated ground water
at the Westinghouse Plant Site is Site-wide alternative IB. The
conceptual design is shown in figure 8-Appendix B. The remedial
concept is to pump and treat the very contaminated ground water
in the center of the plume, on Plant property, in accordance with
the advice given by the hydrogeologists. This is shown as
"Capture Zone 1" in figure 8 (Appendix B) and represents an area
where ground water is drawn to the on-Plant pumping wells where
it is collected. A second set of extraction wells will be placed
near the edge of the contaminant plume (Figure 8 - Appendix B) in
the path of natural ground water flow from the Plant. Pumping
rates in this set of extraction wells shall be designed so that
"Capture Zone 2" shown on figure 8 does not fully extend to the
other capture zone to avoid drawing the more heavily contaminated
ground water under the Plant property. A zone of slow moving
water (Stagnation Zone) between the capture zones will result,
but the pumping rates of the two systems will be varied to move
the stagnation zone periodically, at an interval and rate to be
determined by EPA, during remedial design, so that the ground
water in this zone is collected by the extraction wells. Any
contaminated ground water escaping the Capture Zone 1 wells
should flow to the Capture Zone 2 wells.
Extracted off-Plant ground water shall be pumped back to a
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common treatment Plant located on the Plant property. The
preferred alternative shall remove contaminants from the
extracted ground water by air stripping, and capture them from
the effluent air stream using carbon adsorption. Spent carbon
will be handled as a hazardous waste and will be sent for
treatment or disposal at an off-Plant permitted RCRA facility.
The treated ground water shall be discharged to the Northern
Tributary (figure 2-Appendix B) via the current outfall under the
existing NPDES permit if possible,- or a modified NPDES permit if
necessary.
The Commonwealth of Pennsylvania requires that contaminated
ground water be actively remediated to background (25 PA Code
Sections 264.90-264.100 and in particular, 264.97(i), (j), and
264,100(a)(9)). When EPA chooses active remediation, EPA must be
able to design a system that can accomplish the performance
standard in a reasonable and finite time frame. EPA can not
actively remediate the contaminated ground water plume to
background, and thus waives the background ARAR, for two reasons:
1. compliance with this requirement is technically impracticable
from an engineering perspective, and 2. compliance with this
requirement will result in greater risk to human health and the
environment. The presence of DNAPLs in the fractured bedrock
under the Plant property prohibits active remediation to
background. Accordingly, the on-Plant extraction wells must
contain the plume within the Plant property (Capture Zone 1)
until non-zero MCLGs and MCLs in on-Plant ground water are
reached. Since the contaminants in the off-Plant portion of the
ground water plume (Capture Zone 2) have been transported in
solution, it might be possible to reach a background level in a
reasonable but indefinite timeframe in that Capture Zone.
However, the relatively high pumping rates needed to actively
remediate all off-Plant ground water would probably draw
contaminated ground water and possibly DNAPLs to the off-Plant
area, thereby creating a greater risk to human health and the
environment. Accordingly, the off-Plant extraction wells
(Capture Zone 2) must contain the off-Plant plume within the area
served by the water lines until non-zero MCLGs and MCLs are
reached.
This alternative also includes the installation of
additional monitoring wells, ground water monitoring quarterly
for two years and annually afterwards, annual residential well
sampling and analysis, and deed restrictions that prevent use of
ground water on the Westinghouse property.
The remedy is cost effective and would take advantage of
existing stripper capacity at the Site. The remedy is
implementable and avoids the potential problems of off-Plant
alternative number 4 created by the large number of properties
which would be involved in the construction of this remedy. The
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selected remedy will take advantage of the existing NPDES permit
which may require some modification. Public acceptance is good
since relatively few residents (compared to off-Plant alternative
4) would be adversely impacted by the remedy and since the remedy
is merely an expanded version of an existing actions being taken
at the Plant.
The capital cost is about $2,119,000; the operations and
maintenance cost is about $142,000 anually; and the Present Worth
of the selected alternative over 30 years is about $4,400,000.
The major capital cost elements of the selected remedial action
are shown below, and the details of the scoping estimate are
contained in Appendix B of the Feasibility Study which is
available in the administrative record. The selected alternative
can be implemented in about 24 months.
WESTINGHOUSE ELECTRIC-PLANT SITE
GETTYSBURG, PENNSYLVANIA
SITE-WIDE ALTERNATIVE IB
GROUNDWATER EXTRACTION & ONSITE AIR STRIPPING
Summary of Equipment, Piping ft Instrumentation, and Foundation/Structural & Electrical Costs
Item
Equipment
Piping & Instrumentation
Foundation/Structural ft Electrical
Subtotal
Burden @ 1 396 of labor con
Labor @ 15% of labor con
Material @ 5% of material COM
Subcontract @ 10% of subcontractor cott
Total Direct COR
Indirect @ 25% of total direct labor con
Profit @ 10% total direct COR
Total Field Con
Contingency @ 30% of total field COB
Engineering @ 15% of total field con
Total Capital Con
Sub. Mat. Labor Equip.
SI 15,90040 $20,000.00 $89.600.00 $0.00
$040 $207,190.59 $92,864.55 $15,019.44
$0.00 S628.670.00 $746.00 $0.00
SI 15,900.00 $855,860.59 $183,210.55 $15,019.44
$23,817.37
£27,481.58
$42,793.03
S11.S90.00
S127.490.00 S898.6S3.62 $234,509.50 $15,019.44
$58,627.38
Total
$225,500.00
$315,07438
$629,416.00
$1,169.99038
$23,817.37
$27,48138
$42.793.03
$11,590.00
$1,275,67236
$58,62738
$127.56726
$1,461,86720
$438,560.16
$219.280.08
$2,119,707.43
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Performance Standards
The performance standards for each component of the selected
remedy are described in turn:
Ground Water Cleanup Levels: The cleanup level for each
contaminant of concern in the ground water shall be the non-zero
MCLG if one exists, the MCL for that contaminant (the federal
ARAR for public drinking water supplies under the Safe Drinking
Water Act). The incremental risk of cancer from full domestic
use of ground water once these levels are reached should be less
than 3 x 10"6 based on EPA's current understanding of toxicology
and site conditions.
Area of Attainment: The well systems shall be designed to capture
all ground water, contaminated with COI above non-zero MCLGs and
MCLs, to the extent that it is technically practicable, as
determined by EPA, and to remediate the off-Plant ground water as
quickly as possible considering the limitations previously
discussed.
On-Plant extraction veils: Ground water shall be extracted using
multiple extraction wells, the exact location, extraction rate
and number of which shall be determined by EPA, during the design
of the ground water recovery system. The system shall be designed
to capture all on-Plant ground water contaminated with COI
volatile organic hydrocarbons above non-zero MCLGs and MCLs to
the extent practicable as determined by EPA. The extraction wells
shall operate until such time as EPA determines that the cleanup
level for each contaminant (non-zero MCLGs, MCLs) in the ground
water has been achieved to the extent technically practicable
throughout the entire on-Plant area of ground water
contamination.
Off-Plant extraction veils: Ground water shall be extracted
using multiple extraction wells, the exact location, extraction
rate and number of which shall be determined by EPA, during the
design of the ground water recovery system. The system shall be
designed to capture all off-Plant ground water contaminated with
volatile organic hydrocarbons above non-zero MCLGs and MCLs to
the extent practicable as determined by EPA. The well system
shall be designed to clean up the off-Plant ground water as
rapidly as possible within the limitation of the requirement that
the capture zone of the system shall not extend to the on-Plant
ground water. The extraction wells shall operate until such time
as EPA and the PADER determine that the clean up level (non-zero
MCLGs, MCLs) for each contaminant in the ground water has been
achieved to the extent technically practicable throughout the
entire off-Plant'area of ground water contamination.
Monitoring Wells: A sufficient number of monitoring wells shall
be installed, as determined by EPA, to verify the performance of
the remedial action. The wells shall be sampled quarterly for
the first two years and semi-annually thereafter until samples
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45
have reached non-zero MCLGs and MCLs. Once these levels have been
reached, these wells shall be sampled for twelve consecutive
quarters and if contaminants remain at this level, the operation
of the extraction system shall be shutdown. Semi-annual
monitoring of the ground water shall continue for five years. If
subsequent to an extraction system shutdown, monitoring shows the
ground water concentrations of any contaminant of concern to be
above non-zero MCLGs or MCLs the system shall be restarted and
continued until the levels have once more been attained for
twelve consecutive quarters. Semi-Annual monitoring shall
continue until EPA and the PADER are convinced that contaminants
have reached stable levels below non-zero MCLGs and MCLs.
Air Stripper: Extracted ground water shall be treated using a
packed column air stripper. Flow rates and air stripper
dimensions and effluent water contaminant levels shall be
determined by EPA and the PADER, during the remedial. Since the
treated ground water shall be discharged to the Northern
Tributary under an NPDES permit, the specific discharge criteria
shall be established by the PADER during the Remedial Design of
the remedy. The stripper must be designed to at least achieve
these levels subject to EPA approval.
Carbon Adsorber: Contaminants in the effluent air from the
stripping unit shall be captured by a carbon adsorption unit, the
dimensions of which shall be determined during the remedial
design and subject to EPA and PADER approval. The air stripping
tower must reduce emissions to the minimum attainable level
through the use of the Best Available Technology (BAT), 25 PA
Code S 127.12(a)(5).
Deed Restriction: A deed restriction shall be placed on the
Westinghouse Plant property that will prevent any use of Plant
ground water until EPA and the PADER have determined that the
Plant ground water has reached non-zero MCLGs and MCLs.
Remedy Implementation: Prior to installation of the off-Plant
extraction wells, additional monitoring wells shall be installed
to the east of the Plant to define the extent of the contaminant
plume in that direction, and additional wells to the east of the
existing wells shall be installed to define the width of the
plume to the north and the south. The number and location of
these wells shall be approved by EPA.
Five Year Review: Because DNAPLs will remain on-Plant as a
source of future ground water contamination, Five Year Reviews
shall be conducted after the remedy is implemented to assure that
the remedy continues to protect human health and the environment
until all performance standards have been met as determined by
EPA.
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X. STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In addition,
Section 121 of CERCLA established several other statutory
requirements and preferences. These specify that when complete,
the selected remedial action for a site must comply with
applicable or relevant and appropriate environmental standards
established under Federal and Stats environmental laws unless a
statutory waiver is granted. The selected remedy must also be
cost-effective and utilize treatment technologies or resource
recovery technologies to the maximum extent practicable.
Finally, the statute includes a preference for remedies that
permanently and significantly reduce the volume, toxicity, or
mobility of hazardous wastes.
Protection of Hi""a.a Health and the Enviro^*1""**^
The selected remedy will be protective of human health and
the environment by eliminating the threat posed by hazardous
substances at the Westinghouse Elevator Co. Plant Site. These
hazardous substances currently pose a threat to human health due
to potential exposure to ground water at the Site.
Implementation of this remedy would effectively eliminate the
potential risk to human health which may result from exposure to
ground water from the Site and will eventually restore ground
water at the Site to beneficial uses. Because the selected
remedy would result in hazardous substances remaining on-Site
(DNAPLs), 5-year site reviews, pursuant to Section 121(c) of
CERCLA, 42 U.S.C. §9621(c), would be required to monitor the
effectiveness of this alternative.
The Selected Remedy will control risks from domestic use of
the highly contaminated on-Plant drinking water by the
implementation of a deed restriction on the use of ground water.
The Selected Remedy will also control the migration of the
contaminants to off-Plant residential wells using extraction
wells to create a capture zone that will prevent or substantially
reduce the movement of ground water from the Plant property.
The Selected Remedy will use extraction wells to prevent the
further migration of off-Plant ground water to areas not served
by the public water line and will remediate the off-Plant ground
water to non-zero MCLGs and MCLs. The extraction wells must
operate until these levels have been achieved for both on-Plant
and off-Plant ground water.
The selected remedy will not pose any unacceptable short- .
term risks or cross-media impacts to the Site, the workers, or
the community. The selected remedy will be readily
implementable.
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Compliance vith ARARs
The selected remedy will attain all applicable or relevant
and appropriate requirements for the Site except the Pennsylvania
ARAR requiring remediation of ground water to background levels.
These requirements are shown in Appendix A.
The Commonwealth of Pennsylvania requires that contaminated
ground water be actively remediated to background (25 PA Code
Sections 264.90-264.100 and in particular, 264.97(i), (j), and
264,100(a)(9)). When EPA chooses active remediation, EPA must be
able to design a system that can accomplish the performance
standard in a reasonable and finite time frame. EPA can not
actively remediate the contaminated ground water plume to
background, and thus waives the background ARAR, for two reasons:
1. compliance with this requirement is technically impracticable
from an engineering perspective, and 2. compliance with this
requirement will result in greater risk to human health and the
environment. EPA believes that DNAPLs in fractured bedrock will
continue to contaminate the on-Plant ground water for decades. A
limited on-Plant pump and treatment system has been in operation
intermittently at the Plant since 1984 and has produced only
limited reductions in contamination. Accordingly, the on-Plant
extraction wells must contain the plume within the Plant property
(Capture Zone 1) until non-zero MCLGs and MCLs in on-Plant ground
water are reached. Since the contaminants in the off-Plant
portion of the ground water plume (Capture Zone 2) have been
transported in solution, it might be possible to reach a
background level in a reasonable but indefinite timeframe in that
Capture Zone. However, the relatively high pumping rates needed
to actively remediate all off-Plant ground water would probably
draw contaminated ground water and possibly DNAPLs to the off-
Plant area, thereby creating a greater risk to human health and
the environment. Accordingly, the off-Plant extraction wells
(Capture Zone 2) must contain the off-Plant plume within the area
served by the water lines until non-zero MCLGs and MCLs are
reached. The off-Plant extraction system shall, however, be
designed to remediate the off-Plant ground water as quickly as
possible without spreading the contamination. EPA is waiving
this state ARAR not to avoid taking action for the on-Plant
ground water, but as a basis for selecting plume containment,
instead of active remediation with set standards, that must be
reached in a finite time period.
Cost Effectiveness
The capital cost of the Preferred Alternative is about 2.1
million dollars, the annual operations and maintenance is about
140 thousand dollars , producing a total Present worth cost of
about 4.4 million dollars.
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The selected alternative is the most cost effective of the
remedies that are adequately protective of public health and
which comply with ARARs. The selected remedy will take advantage
of the existing treatment system already in operation. If the
existing stripper does not have sufficent capacity to treat the
extracted ground water required by the remedial design, a second
stripper can be added in parallel with the existing stripper to
increase capacity while still using the existing equipment.
Utilization of Permanent Solutions and Alternative Treatment
Extent Practicable
EPA has determined that the selected remedial action
represents the maximum extent to which permanent solutions and
treatment technologies can be utilized while providing the best
balance among the other evaluation criteria. Of the alternatives
that are protective of human health and the environment and meet
ARARs, EPA has determined that the selected remedy provides the
best balance of trade-offs in terms of long-term effectiveness;
reduction in toxicity, mobility, or volume through treatment;
state and community acceptance; and the CERCLA preference for
treatment.
The selected remedy addresses the long-term, threats posed
by the site contaminants at the Westinghouse Elevator Co. Plant
site. The remedy is protective of human health and the
environment, meets ARARs, and is cost-effective. Treatment as a
principal element is provided for in the onsite treatment of
extracted ground water prior to discharge.
XI. EXPLANATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Westinghouse Elevator Plant Site
was released in April 1992. The Proposed Plan described the
alternatives studied in detail in the Feasibility Study, and EPA
reviewed all written and verbal comments submitted during the
comment period and at the public meeting. The only significant
change between the Proposed Plan and the ROD is a change in the
ground water contamination levels that.must be achieved before
the ground water remedy is considered completed. EPA waived the
Commonwealth's ARAR which requires all ground water to be cleaned
up to background levels. Although EPA waived this ARAR because
active remediation over a finite time frame is not possible, EPA
proposed containing the ground water plume until background is
reached. Additional legal review has been conducted since the
Proposed Plan was issued and EPA now believes that since the
Commonwealth's ARAR is waived, the appropriate cleanup levels
that must be achieved by the remedy are non-zero MCLGs and MCLs.
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The frequency of monitoring well analysis was changed during
the comment period from annual monitoring to semi-annual
monitoring to provide greater protection of the public and to
consider changes in contaminant concentrations due to seasonal
variations.
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APPENDIX A
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
WESTINGHODSE PLANT SITE
Chemical Specific ARARs
Relevant and Appropriate Requirements
1) State drinking water standards as set forth in 25 PA
Code Chapter 109, Subchapter B. These standards are
established pursuant to the authority of the PA Safe
Drinking Water Act of 1984, 35 P.S. §721.1 et sea.
2) Maximum Contaminant Levels for drinking water from
public supplies as set forth in 40 C.F.R. §S 141.12 and
141.61). These standards are established pursuant to the
authority of the Safe Drinking Water Act (42 U.S.C §§ 300f-
300J-26) .
3) Maximum Contaminant Level Goals (MCLGs) . Non-Enforceable
federal standards for drinking water from public supplies as
set forth in 40 C.F.R. §141.50.
To Be Considered
1) Pennsylvania Water Quality Criteria (25 PA Code §§93.1
through 93.9) as related to stripper discharge levels.
Surface water standards related to the use of surface water
for drinking and for drinking and consumption of fish from
the surface water. This criteria is established pursuant to
the Clean Streams Act, 35 P.S. 691.1 et
Location Specif ie ARARS
1) No location specific ARARs have been identified.
Action Specific ARARs
Applicable ARARs
1) Emissions Reduction from Stripper/ Adsorber. To the
extent that new point source air emissions result from the
implementation of the Remedial Alternative, 25 PA Code §
127. 12 (a) (5) is applicable, requiring that emissions be
reduced to the minimum obtainable levels through the use of
Best Available Technology (BAT) , as defined in 25 PA Code §
121.1.
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2) NPOES Discharge requirements as set forth in 25 PA Code
§§ 92.31, 92.41, and 92.55 include design, discharge and
monitoring requirements for the stripper discharge. These
requirements are established pursuant to the PA Clean
Streams Law, 35 P.S. §§ 691.1 et seq.
3} RCRA Requirements. The ground water collection and
treatment operations will constitute treatment of hazardous
waste. The ground water contains listed hazardous waste and
on-plant ground water is a characteristic for TCE hazardous
waste for TCE. Treatment will result in the generation of
contaminated treatment residuals including spent carbon.
The remedy to be implemented will comply with the applicable
requirements of 25 PA Code Part 262 Subparts A (relating to
hazardous waste determination and identification numbers), B
(relating to manifesting requirements for Off-site shipments
of spent carbon or other hazardous wastes), C (relating to
transporters of hazardous waste), and with respect to
operations at the site generally, with the substantive
requirements of 25 PA Code 264 Subparts B-D, I (in the event
that hazardous waste generated as part of the remedy is
managed in containers), J (in the event that hazardous waste
is managed, treated or stored in tanks).
On-Plant ground water is above the TCE level (500 ppb) that
qualifies for handling groundwater as a hazardous waste as
specified in 25 PA Code Chapter 261 Subchapter C and 40
C.F.R. S 261.24.
4) Land Disposal Restrictions set forth at 40 C.F.R. Part
268.1 to 268.5 related to the management of hazardous wastes
(including spent carbon from air stripping) generated as
part of the remedy.
5) The Pennsylvania ARAR for ground water for hazardous
substances is that all ground water be remediated to
"background" quality as specified by 25 PA Code Sections
264.90-264.100 and in particular by PA Code Sections
264.97(i), (j), and 264.lOO(a)(9). The Commonwealth also
maintains that the requirement to remediate to background is
also found in other legal authorities.
6) Regulations concerning well drilling as set forth in 25
PA Code Chapter 107. These regulations are established
pursuant to the Water Well Drillers License Act, 32 P.S. S
645.1 et seq.
Relevant and Appropriate Requirements
1) RCRA requirements of Subpart AA 40 C.F.R. 264.1032 (Air
Emission Standards for Process Vents) of the Federal RCRA
regulations, 40 C.F.R. are relevant and appropriate for the
-------
air stripping operations under the selected remedy. Under
this ARAR, total organic emissions from the carbon adsorber
must be less than 1.4 kg/hr (3 Ib/hr) and 2800 kg/yr (3.1
tons/yr).
To Be Considered
Pennsylvania's Ground Water Quality Protection Strategy,
dated February 1992.
Water Quality Toxics Strategy, 25 PA Code Chapter 16, for
water quality guidance=
EPA OSWER Directive 9355.0-28, Control of Air Emissions From
Superfund Air Strippers at Superfund Ground Water Sites.
PADER " Air Quality Permitting Criteria For Remediation
Projects Involving Air Strippers and Soil Decontamination
Units" Guidance Manual.
EPA's Ground Water Protection Strategy which is used to
classify aquifers based on their use.
-------
Figure 1
WEST1NGHOUSE
PLANT
FIGURE 1-1
SITE LOCATION MAP
WCSTINGHOUSC PLANT SITE RI/FS
CUMBERLAND TOWNSHIP. ADAMS COUNTY. PENNSYLVANIA
PREPARED
WESTINGHOUSE ELECTRIC CORPORATION
PITTSBURGH. PENNSYLVANIA
SCALE (MILES)
REFERENCE;
. U.S.C.S. TOPOGRAPHIC MAP
CETTYS8URC QUADRANGLE
SCALE: 1:24.000-PMOTOREVWED 1973.
rtol C Rtuo AwqcictM, lac
POOR ouXirrf
-------
WESTINGHOUSE ELEVATOR PLANT SUPERFUND SITE
RIDGEWOOO DRIVE
MAXIMUM EXTENT OF VOC CONTAMINATION
DETECTED DURING EPA REMEDIAL INVESTIGATION
(DEEP WELLS)
GROUNDWAlffl ROW DIRECTION
IMMM dint Atop:
Mm AMMMM, tac,
-------
,^f-ASPMAL
NATURAL CAS UNC
NESTWCHOUSE OEVATOM PLANT
MTAHID PIANS «AC ORA«M Al SCAU I'-SO
OLD WASTE MUU
STCMAOC AREA
PHASE I Rl
SOIL SAMPLING LOCATIONS
MESHNGHOUSE HAHf Slit M/TS
CUMKMJIMO 1O«MSHT. ADAMS COOHTY. FOMSTVVAM
fno-««o run
SAMTAMY SEWEM
WESTINCHOUSC ELECTRIC CORPORATION
PITTSBURGH, PENNSYLVANIA
-------
Gettysburg Formation Hydrogeology
FRACTURE
PROJECTION
POTENTIOMETRIC
SURFACE
Conceptual movement of purgeabla organic compounds ai density flows In ground water and In dilute
solution In ground water.
Purgeablo organic
compounds,
In bulk masses
Purgeable organic
compounds,
In solution
Ground water flow
direction
f
-------
%f^.(V ?p
l-/7'^<>^.
/ i '*. ***-%
~7 ^ -x^>-
MONITORING WELL
LOCATION
HtFIRCNCt
IMP pntPAwo » t/tsmw
co. OAITD IMY u. it*4.
SCMC; I" - IOO-
FIGURE 2-4
PHASE I AND 0
MONITORING WELL LOCATIONS
CSIMGHOUSC riMit sm m/rt
NWMS COUHTT.PCMNfn.VMA
PNCP«MCD ran
WESTINGHOUSE EUCTRIC CORPORATION
PinSBURGH. PENNSYLVANIA
DC-i
Pkul C
IM.
t
-------
i rJs!5j^
«*r*i»u - , ,,, . £.; ^^\
J -' 'L\C4 ^rOtF
ft ; ' i - v»- f '--jtv. T \ IK v
tr^*»
hV ]>. < ti /"'i. X-- ' I \ «r
\^(^ I . '':,-7:-v - r-r Hi."1
LEGEND:
or
IOMt younu
CMMMMCS M ilt/l.
1M
MOWIOMW wcu.
MM-12A MOWNG TOr/H. VOLATU
MOAMC OONCfWTIMnOM
M «t/l
NOTE:
ACfTONC AND HCIHniNC CHUMMK
ARE CONSIMMD tAKMMKMnr
MIWnKNCt AND AW NOf lAKCM
WIO CONSMJMAIIOH RMt IHt
coNsmuciiOM or IMS MAP
WfCHtMCC:
lOPOCHAPHtC IUP PMPANCO n CASICNN
tiffnn co. OAitO: UAY u. !*«.
SCAU: I* - 200
SCALE
400 0 400 MM ft£T
nCURE 4-3
TOTAL VOC CONCENTRATIONS
IN SHALLOW BEDROCK WELLS
(OCTOBER/NOVEMBER. 1990)
WCS1MCMOUSC KANT Sift M/TS
ADAMS couNrr.peNNsn.VANA
MtPANCD ri
Mn 1 n O 1 C. O
AHjyZJbj
TR(6 CORPORATIC
WCSTINCHOUSE ELECTRIC CORPORATION
PITTSBURGH. PENNSYLVANIA
ftul C Rln»
-------
LEGEND:
SW j
SO-1
SUWACI WATEK/SEOMCMt
SAUPUNC IOGAIMN
StOKU (MAIN SAMPUNC IOCAHON
MOOT sjummc IOCAIHW
HtfCHtNCt
IAMN fHOH HAP PMIPAMD B» HC1CALT *
tOOY. MAY 10. \»»J. SCAU: l'-4OO'.
SCALE
FIGURE 2-3
too net
PHASE I AND 0
SURFACE WATER/SEDIMENT. STORM
DRAIN. AND ROOT SAMPLING LOCATIONS
MS1MGHOUSC PtAHl Sill W/TS
OUUWMAMO fOUMSHW. ADAMS COUNTY. PCNNSYIVAMA
ran
WEST1NCHOUSE ELECTRIC CORPORATION
PITTSBURGH. PENNSYLVANIA
c
-------
WESTINGHOUSE ELEVATOR PUNT Sl|PERFUND SITE
SITE-WIDE ALTERNATIVE 1-fl
Conciptutl Modil
RIDGEWOOO DRIVE
CAPTURE ZONE 1|
WE8TIMGHOU8E
ELEVATOR PLANT
DMTNM WM10V NOTM WEU.
POTENTIAL «UUOW fUWWI
I STAGNATION ZONE |
raiaiML mtammimi
MOUMONHTEM RMIINICINN
I CAPTURE ZONE 21
PMI e. mm MMCMM. tot.
IMt
00
-------
Appendix C
-------
TABLE 4-4
SUMMARY OF ANALYTICAL RESULTS ABOVE QUANTITATION LIMITS
SURFACE WATER SAMPLES - PHASE I
SAMPLE DESIGNATION
(c)
PARAMETER
(a)
Conductivity °
Temperature
TAL Inorganics
Cyanide
Aluminum
Calcium
Iron
Magnesium
Manganese
Potassium
Sodium
Zinc
Lead
TCL VolaciLes
Trichloroethene
TCL SemivoLacil.es
UNITS
(b)
umhos/cm
8C
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
ug/l
Butyl Benzyl Phthalate ug/l
Di-n-octyl Phthalate ug/l
N-nitrosodi-n-propylamine ug/l
Bis-(2-ethylhexyl) ug/l
Phthalate
SW-1
SW-1
DUP
SW-2
SW-3
EQUIPMENT
BLANK
8.3
615
4.0
0.3
77
0.31
29
0.06
l.l
14
0.03
0.005
11
10
10
8.2
595
3.5
0.2
74
0.19
28
0.04
1.1
14
0.02
10
7.4
542
-0.5
0.006
1.6
68
0.96
19
0.02
1.8
14
0.02
40
6.9
223
1.6'
1.1
22
0.66
8.5
1.0
6.0
N/A
N/A
N/A
(e)
0.06
3000
TCL Pesticides/PCBs
ug/l
d.
e.
f.
Target Compound Lisc (TCL) parameters noc listed were not detected in the
samples above quantisation limits. Refer to Appendix E for a complete listing
of analytical results and quantitation limits.
"mg/l" indicates milligrams per liter or parts per million (ppm); "ug/l"
indicates micrograms per liter or parts per billion (ppb); and "umhos/cm" means
micromhos/cm; and "*C" indicates degrees cenitgrade.
Samples collected December 13 through 18, 1988 and January 16, 1989 by Rizzo
Associates personnel.
Reported values are field measurements.
"N/A" indicates sample was not analyzed for this parameter.
"" indicates parameter was analyzed for but was not detected in the sample
above quantitation limits. Refer to Appendix E for quantitation limits.
-------
TABLE 4-5
SUMMARY OF ANALYTICAL RESULTS OF ABOVE QUANT!TAT ION LIMITS
SURFACE WATER SAMPLES-PHASE II
PARAMETER
UNITS (b)
SU-4
SW-S
SW-6
SU-7
SU-70
COLLECTIOH DATE
iO/12/90
10/T2/90
10/12/90
10/12/90
10/12/90
FIELD PARAMETERS
PH
Specific Conductivity
Temperature
uWos/cm
C
7.77
US
24.9
7.S2
4S3
26.4
7.75
491
26.0
7.33
342
28.0
7.35
323
25.4
TCL volatile* (a)
Acetone
Carbon Tetraeftloride
Chloroform
ug/l
ug/l
ug/l
19*
17* (d)
18*
24-
22*
8
17
TCL Seffli-Volitiles
Bis (2-etnylhexyl) phthalate ug/l
NOTES:
a. The valstil* organic coapotaTds on the Target
sanplas abov* quantitiation liaritt. R«f«r to
results and quant
-------
TABLE 4-6
SUMMARY OF ANALYTICAL RESULTS^ ABOVE QUAMTITATIOH LIMITS
SEDIMENT SAMPLES - PHASE I
PARAMETERS(b)
TAL Inorganics
Cyanide
Aluminum
Barium
Beryllium
Cadmium
Calcium
Chromium
L'NITS
(c)
Copper
Iron
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
Arsenic
Lead
Selenium
Moisture
TCL Volatiles
Acecone
Mechylene Chloride
TCL Semi volatile*
Butyl Benzyl Phth»l*te
Di-n-octyl Phth*l*t«
Bis-U-echylhexyl)
phth*l«te
Naphthalene
2-Methyln«phth»len«
Acenaphthene
Dibenzofuran
Fluorene
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/ltg
mg/kg
mg/kg
mg/kg
Z by vt
ug/kg
ug/kg
mg/kg
mg/kg
mg/kg
mg/kg
rag/kg
mg/kg
mg/kg
mg/kg
SAMPLE DESICSAT:OSVU;
SD-l
_-(!>
16200
94
0.94
54200
42J
17
66J
28400
15700
1220
0.06J
22
722
235
38
391
6
60
36.3
SD-i
PUP
12600
110
1.1
41700
40J
22
77J
26300
23400
1320
0.11J
26
728
221
35
477
13
137
2
54.7
SD-2 53-3
0.07
17200
99
1.2
2660
40J
17
38J
39800
9540
1030
25
593
185
59
157
26
32
~
19.1
D.11
176CO
163
0.76
2200
35 J
13
20J
39800
5240
1320
20
687
70
67J
11
35J
34.5
16*
0.68
2.6
2.0
3.4
0.73
2.0
1.5
6.8
5.1
8.4
46*(f.)
11*
1.7J(g.)
1.3J
-------
TABLE 4-6
(Continued)
SAMPLE DESIGNATION
(d)
TCL SemivolacLies (:;n:.)
Phenanchrene
Anthracene
Fluoranthene
Pyrene
Benzo(a) Anthracene
Chrysene
Benzo(b) fluoranchene
3enzo(a) pyrene
Indeno (1,2,3-cd) Pyrene
Oibenzo (a,h) Anthracene
Benzo (ghi) PeryLene
TCL Pescicides/PCBs
SD-L
mg/kg
rag/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
41
6.0
47
46 .
17
22
31
17
11
2.6
5.1
110
23
125
103
46
56
74
41
26
5.0
24
SD-2
0.46
0.66
0.70
0.46
0.66
SD-3
f,
g-
Results are reported on a dry-weight basis. Dry weight = As
received value t D where D*(100-moisture content) * 100.
Target Compound List (TCL) parameters not Listed were not detected
in the samples above quantitation. Refer to Appendix E for a
complete listing of analytical results and quancitation limits.
"mg/kg" indicates milligrams per kilogram or parts per million
(ppm); "ug/lcg" indicates micrograms per kilogram or parts per
billion (ppb); and "umhos/cm" means micromhos/cm; and "*C" indicates
degrees centigrade.
Samples collected December 13 through 18, 1988 and January 16, 1989
by Rizzo Associates personnel.
"" indicates parameter was analyzed for but vas not detected in
the sample above limits. Refer to Appendix E for quantitation
limits.
"*" indicates this compound was detected on the method blank.
"J" indicates this value is an estimate.
-------
TABLE 4-7
SUMMARY OF ANALYTICAL RESULTS (a) ABOVE QUANT I TAT I ON LIMITS
SEDIMENT SAMPLES PHASE II
PARAMETER
Collect on date
Total Organic Carbon
Moisture
pM
UNITS (c)
mg/kg
X by -t
SO -4
10/12/90
11,000
26.9
7.05
SO-5
10/12/90
5,100
30.4
6.86
SO-SO
10/12/90
11,000
30.4
6.93
SO -6
10/12/90
8.400
21.7
7.28
SD-7
10/12/50
8.3CO
26.5
6.79
TCL volatile* (b)
Acetone
ug/kg
31- Ce)
34»
49"
24«
Semi-Volatile*
Bis (2-ethylhexyl) phthalate ug/kg
NOTES:
a. Results reported on dry-weight bMis. Dry-weight as-received value * 0, where D«(100-moisture content)-?100.
b. The volatile organic compounds on the Target Compound List (TCL) that are net listed, were not detected in
the sanples above quantitation limits. Refer to Appendix E for a complete listing of analytical results and
quantitation limits.
c. "ng/kg1* indicates illigraa» per kilogram or parts per illion, -ug/kg- indicates micrograaa per kilogram or
parts per billion.
d. "--" indicates paremeter was analyzed for but was net detected in the saaple above quantitation limits, liefer
to Appendix E for quantitation limits.
e. "" indcates this coMpeund MBS detected in the method blank.
-------
IMLE 49
tuouii or AMAidiCAi itsuii MOVE OUANIIIAMOM
UNI IS II CaOUMDUAIII SANFIIS
MANUU () Wllf (b)
OAlf
PM CO
Conductivity «| «*«/»
l**c*r«tur« let ° *C
IM Inorimlci
Alwiru* M/I
2*fr 5"
Cclcliai OMJ/I
Iron M_/|
l»9nt*lu> tg/l
N*na*n*t«. cgj/l
otntlui . M/I
Sodlui ZJi
line 5J,
ICl VolollUt
Action* ug/|
2-lutanon* ug/l
Cirbon OUullidt ug/l
CMorolora Uj/l
t,t-0ickloro*lkin* IM/|
1.2-OicMoratlkMM wy|
l.roicklorMihon* MJ/|
cli-l,2-0ickloroolhtn* wj/l
lr*rM-l.2-Olckloro*iMrMi wvl
Ncihylon* Oiler l i«/|
M^lllOlW IM^I
lolumt u|/l
1,1,1-lrlcklorotlhant wj/|
Irlcklorottkon* iij/|
1.2.1-lrlckloropropM ui/l
toaivoUiiU*
OllC2-*!kylk«iiyl)c«ittuUu u|/l
Mil
IM-I
1/20/09
ro
n*
. .Jrfl
mi
0.2
n.i
11!;
1.1
20.2
0.04
10
1,200
M
9
Itt
t.ooo
45.000
U
"
«u
MI-IA
U/ll/90
MO
ou
U.4
Alo)
M
M
IM
M
M
M
M
-
4
M
--
M
120
M
-
Mill Mil
Ml' II MU-IID
W/ll/90 10/11/90
Ml 2.27
" r7»
IM It. I
M M
MM.
Ml
M M
» M
M M
A M
M U
M M
MM*
A
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IS 09
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..
f
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11
HA HA
g M
M U
SI U
4*0 410
MA HA
20
Mil ^ Mil
"W-2A HM-a
OI/U/09 10/10/90
M 6.96
4«0 tt|
10.2 ».9
M
0.1 MA
41.4 M
0.06 MA
20.9 MA
IA
1.2 IA
I2.S MA
O.OS MA
""
..
--
10
M MA
" "
I* MA
ss
41
M MA
-.
um MII
MU-21 FMU 21
OI/ir/19 10/11/90
M MO
20 6U
9.9 U.O
MA
0.2 MA
61. f M
IA
26.8 MA
0.07 M
1.9 MA
14.1 MA
0.06 MA
..
16
MA DA
--
MA MA
98
21
MA MA
90
Mill Mil
nw-lA HH u
02/10/89 10/IO/VO
'.2 7.11
542 4/0
1.4 It.)
MA HA
MA HA
MM*
A
MA HA
MM*
M
IA IA
MA MA
MA HA
IA MA
21
MA HA
IA HA
MA HA
MA
Mil Mil
PHU 18 CHU 11
02/10/09 10/10/90
M 4.78
621 620
0.7 14.1
MA MA
MA HA
MA MA
MA MA
IA MA
MA MA
MA MA
MA MA
MA M
2J
"
" '
"A HA
"A HA
20 '.'
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MA
-------
FAUNfli* ()
Mil
C«nduc;lviiy (c)
(el
IM InortmUt
CtUlUB
Iron
todlia
line
ICl Void llci
Actlont
2-lulran*
Cirbon Oitulfld*
Cklorofofa
1.1-OlcMoroctk
UNI II (b)
1,1-llcklorMitMfW
cl>-l,2-OicMorMlkMW
trend, 2-Oicklor
-------
IMLf 4-9
(conllnutd)
AUMflll <0> UMIU (bl
Mil
f» CO
Conduct Ivlly (c> u*t*/cn
toaporttur* U> «c
IM. Inorimlct
Aluolnu. ,,
OwluB /|
C.lcl. 5J|
!l!l i ""
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N.ntOM.0 ,!
otMtlu* «/!
lodlu. ^,
line w(
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Action* ui/l
2-lultnon* I/I
Ctrbon Oitulfidt ug/|
Cktorofora ut/l
l.l-0lcklero*tktne u|/|
t.2-OlcMoro*tfc*n* ut/l
l.t-OlcMoro*intn* ui/|
clt-l.2-Olckloro*IK*n* U|/l
trm-l.l-OlckloroollMn* ut/l
Mtthylm* Cklorld* u|/l
Koplktltn* u)/|
Ulutm ui/i
I.I.MrlcMorooihuw ui/l
lrlc*l*ro*th*n* u|/|
l.2.1-lrlcklaroprop*nt wyl
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Hit Wtl
MM-M MW-M
1/U/ftf tt/lt»«9t
r» A .M.
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n.i u.i
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or M
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H HA HA
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mm HA
M M M
^ M
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II
..
n w
S.200 l.roo I.MO
» M «
an 490 m
M M M
1.200 1.200 1.100
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M M M
I A . M
Wll Ull Wu
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02/10/09 10/11/90 10/11/90
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10 4i
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M M M
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<» M 100
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M - MA
wm icti
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../.
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-/
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MU Utll
HV t M*
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19
. .
"
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PMI- ItA
10/10/90
r.oi
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it.]
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M/-
/
/I 0
A/-
/
"/
/
M/--
-------
t* 10
Conductivity
AluHfnuB
erfuB
Iron
lodlua
lint
ICl Volatile*
Action*
I-tulonon*
Carbon Oi*ultide
CklorolonB
I.l-Olckloroitkan*
1.2 Olckloroelhan*
l,|-*lcMoro*lkon*
<.ll-1.2-llckloro*lk*n»
trana-1,2-*lckloro*tlMna
Heihylen* Cklorld*
HoplkAlm
foluon*
l.l.l-lrlchloroatkant
IrlcklorMihon*
l.2.J-lrlcMoropropen*
toojivoUtlla*
IU(2-atkylkeiyl IpMkalei*
OKI:
*. lartel Compound t
b. */! Indicate* i
c. leported value*
IAIU 4-9
(continued)
inns (bi
uano*/CM
e
i/i
i/i
I/I
tvi
w/l
/I
I/I
I/I
J/l
M/l
Ul/l
ut/l
"/I
Ul/l
Ui/l
1M/I
t^fl
(/I
U|/l
ui/l
m/i
ui/i
ui/i
ui/l
Ul/l
It* Ug/l
Wit
Mr-Ill
tflUiM/Afll
IwrVv/W
0.9*
7AS
IM
HA
HA
HA
HA
HA
HA
HA -
HA
M
-/-
/
"/
ft*
i
HAS-
/
-/
HA/-
../.
-/
-/
HA/-
HA
Wtl
nw-ia
II/10/M
r.oi
S9I
tt.»
HA
HA
gll
HA
HA
HA
HA
M
HA
"
-
11
M
HA
16
170
HA
"
Wit Wll
Ml- 121 MM2M
11/10/90 10/10/90
f.20 Mo
4*2 U7
17.6 U.I
HA HA
HA HA
HA HA
M HA
HA IA
HA HA
HA HA
HA HA
IA HA
It »
"
..
7
HA HA
> *
HA HA
» 7
190 190
HA HA
..
Wtl
MI-I1A
10/09/90
4.96
SI9
17.1
IA
HA
HA
HA
IA
M
A
HA
HA
»
-/
/-
/
/
HA/--
/
/
HA/--
--/-
/
-/
HA/--
Utll
MM- 111
10/10/90
7 04
.29
16.1
HA
HA
HA
HA
HA
HA
A
HA
IA
17
/-
-/-
. . j. .
12/9.7
HA/2
/-
/
A/--
/
U/26
450/290
A/--
-
MEIl
mi M
10/09/90
.96
)IO
14.0
HA
MA
M
MA
M*
MA
A
NA
MA
»
../..
-/
6/4 2
«/
-/
-/
HA/-
7/6.6
11/10
BA/--
--
UCll
MM-1)
10/10/90
7. It
«7
19.2
HA
U
MA
g4
A
HA
HA
HA
20-
. . f..
/
/
/--
A/--
../..
/
HA/--
-/-
-/
-/0.9
HA/--
..
Mil
PHU-I6A
10/09/VO
7.11
7o6
14.0
HA
HA
HA
aA
Hi
HA
HA
HA
HA
* /
../..
--/-
/
kA/--
/o.e
HA/--
/
-/-
-/
A/1.4
Mil
PNU-I6I
10/09/90
7.i7
406
IS. 7
NA
HA
NA
HA
HA
HA
MA
HA
MA
12
--
/-
/I.I
/
6/5.1
HA/0.7
-/
/0.7
HA/--
7/7.7
210/2JO
HA/--
licit paraMleri not lifted weir* not delected in (applet abov* quantilAlion liaiil*. (tier to Append i« ( lor a complete lltlii«j ol the «vilyii«l results jnd n* «»« ...a^
J: ^: !±:!s Xfrr^^^'it^irpar-is:""1 -* '-nt'uti<10 "- '- -*»-«- »-»« -..
I. - indicate* paraMter MS lound In Ik* Ml hod blank.
H47.A.!,...!'" "'- '"""'" "'nd'"1 """"M "* "" '"" "*""* "M "«' «"""«: '- ««o. value i«,c , d.,«,,on ,
** indicate* In* taapl* Mt collected Iron the bolloa ol tke well.
inn lor lliiii cuiii
ii-nlignide.
-" !!.. I. IH« hcll.o.1
------- |