• Environmental Ptote-*ion
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R03-92/152
July 1992
&EPA Superfund
Record of Decision:
Eastern Diversified Metals, PA
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NOTICE
The appendices listed in the index that am not found in this document have been removed at the request of
the issuing agency. They contain material which supplement but adds no further appicafate Information to
the content of the document Ail supplemental material is, however, contained in the administrative record
forthisstte.
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50272-101
REPORT DOCUMENTATION
r-AGE
1. REPORT Mtt
EPA/ROD/R03-92/152
4. TMeendl
SUPERFUND RECORD OF DECISION"
Eastern Diversified Metals,. PA
Second Remedial Action - Subsequent to follow
07/02/92
9. PMtanafevOrgelnMonNMiteadAddree*
ML PralMtrrMk/WoifcUnMNo.
12.
•rinaf
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Type* Report *
800/000
PB93-96391A
18. Abettci(LMt:200«ofds)
The 25-acre Eastern Diversified Metals site is a former metal processing plant located
in a sparsely populated area in Rush Township, Schuylkill County, Pennsylvania. Land
use in the area is predominantly open land with mixed residential, commercial, and
industrial use. From 1966 to 1977, Eastern Diversified Metals operated a processing
plant that reclaimed copper and aluminum from wire and cable. An estimated
150 million pounds of waste insulation material, or fluff, was disposed onsite in a
swale behind the plant. This fluff, which contains polyvinyl chloride, polyethylene
insulation chips, fibrous material, paper, soil, and metals, is contained in a
7.5-acre pile onsite. In 1971, in response to an application for an industrial
landfill permit, a state inspection revealed leachate from the waste pile flowing to
the Little Schuylkill River. In 1974, a leachate collection and treatment system was
installed onsite. In 1979 and 1980, residents complained of odors and expressed
health concerns over conditions at the site. In 1985, an investigation detected PCBs
and lead in the waste pile and metals in a downgradient monitoring well.- In 1987, a
security fence was installed around the property. A previous ROD addressed areas of
(See Attached Page)
17. Do
mtAneJyete a. Deecripton
Record of Decision - Eastern Diversified Metals
Second Remedial Action - Subsequent to follow
Contaminated Medium: Debris
Key Contaminants: Organics (Dioxins, PCBs), and metals (Lead)
EnoBa Twins
e. COSATI RetoVGroup
18. AveilebiMy Sutement
19. Security Ctaee fThie Report)
None
20. Security Clue (This Pige)
None
21. No. of Page*
84
22. Price
(See ANSI-Z39.18)
See /netructfone on Ae wree
OPTIONAL FORM 272 (4-77)
(Formerty NT1S-35)
D0pw BiiQiil of Coirwmi o
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EPA/ROD/R03-92/152
Eastern Diversified Metals, PA
Second Remedial Action - Subsequent to follow
Abstract (Continued)
fluff, soil/'sediment, and ground water contaminated with PCBs, dioxin, and metals. This
ROD addresses a final remedy for the remainder of the fluff onsite. Future RODs will
address soil contamination following analysis of soil samples taken as part of this
remedy and deep ground water contamination. "The primary contaminants of concern for
leaching from the fluff are organics, including dioxin and PCBs; and metals, including
lead.
The selected remedial action for this site includes onsite recycling of fluff into one of
two forms—a "Final Product" that requires no further offsite processing, or a "Non-Final
Product," such as plastic pellets, which will undergo further offsite processing; testing
recycling residuals for RCRA hazardous waste characteristics, with offsite disposal of
non-RCRA wastes and onsite treatment of RCRA wastes using a technology to be determined
based on a treatability study; disposing of the treated wastes offsite; testing soil
underlying the fluff; and implementing erosion and sedimentation controls. The estimated
total present worth cost for this remedial action ranges from $13,100,000 to $21,900,000,
which includes a total O&M cost of $6,900,000.
PERFORMANCE STANDARDS OR GOALS: There are no specific performance standards for any of
the contaminants. The recycling products and the residuals will be tested for RCRA
hazardous waste characteristics prior to use of the product or disposal of non-recyclable
residuals.
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RECORD 0V D1CI8IOM
BISTERM DXVBRSXrXBD MBTALS BIT1
- <
operable Unit Three
DBCUkRJkTXOM ~
am mm HID
Eastern Diversified Metals Sit*
Hometown, Schuylkill County, Pennsylvania
This decision document presents the selected remedial action for
th« Third Opsrabls Unit (OU3) at th« Eastern Diversified Metals
Sit* loeatsd in Homstown, Schuylkill County, Pennsylvania (Sits),
which was chosen in accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended (CERCIA) and, to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP), 40 C.F.R. Part 300. This decision document explains
the factual and legal bases for selecting the remedy for this site
and is based on th* Administrative Record for this Site.
The Commonwealth of Pennsylvania concurs with the selected remedy.
.,^;:Cf ; ,7 •• • • -•• -
ASSK8
Actual or threatened-releases of hazardous substances, pollutants,
or contaminants from this Site, 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.
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OF
The Site to date has been divided into three operable units (OUs)
in order to effectively address the complex contamination problems
present in the various environmental media » The divisions are as
follows:
OUl • "Hotspot" areas: those areas of fluff and soils
contaminated with PCBs and dioxin above target
levels
• Sediments and soils contaminated with metals
above target levels
• Miscellaneous debris
OU2 • Ground water
OU3 • Remainder of the fluff at 'the Sit*
A remedy for the first and second operable units was selected in
the Record of Decision of March 1991. The selected remedy in this
Record of Decision for Operable Unit 3 include* the following
actions:
1. All fluff at the sit* (wast* insulation material consisting
primarily of polyvinyl chloride and polyethylene chips;
fibrous material; and pap*r, soil, and metal on the surface of
the sit* other than that to be remediated pursuant, to the
March 1991 ROD) will be recycled onsite within fifteen (15)
year* of th* date EPA issues this Record of Decision and in
accordance with th* following: -
(a) Recycling of th* fluff into a form that will be used
without further processing ("Final Product11) off site
(e.g., floor mats, plastic lumber, . or bumpers) shall
ensur* that th* hazardous substances, pollutants, and
contaminant* within th* Final. Product ar* inseparable
from th* Final Product by physical forces attending
ordinary us* of th* Final Product; or
(b) Recycling of th* fluff into a form that will undergo
further processing of fsit* in order to produc* a usable
product ("Non-Final Product") (e.g., plastic pellets)
shall ensur* that (1) th* Non-Final Product does not
exhibit RCRA hazardous characteristics, and (2) the
hazardous substances, pollutants, and contaminants within
any Final Product produced therefrom ar* inseparable from
th* Final Product by physical force* attending ordinary
us* of th* Final Product.
2. Recycling residuals including, but not limited to, debris
within the fluff, will be tested to determine whether such
residuals exhibit RCRA hazardous characteristics. Recycling
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residuals that do not exhibit RCRA hazardous characteristics
will be disposed of in an offsite landfill.
3. Treatability tests shall be performed on recycling residuals
that do exhibit RCRA hazardous characteristics so that EPA can
determine the most appropriate method of treatment prior to
disposal. These materials will then be treated so that such
materials no longer exhibit RCRA hazardous characteristics and
will be disposed of in an offsite landfill.
4. Soils underlying the fluff shall be sampled and analyzed as
approved by EPA to determine the nature and extent of
contamination of such soils by hazardous substances,
pollutants, and contaminants.
5. Erosion and sedimentation controls approved by EPA shall be
implemented to control drainage and minimize erosion of
exposed soils at the Site.
Response actions to address soil contamination, if any, will be
selected by EPA in a subsequent Record of Decision following
analysis of the soil samples taken as part of this remedy.
8TMUTOBT D«CTBMIBATIOM«
The selected remedy for Operable Unit 3 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 their principal element.
Erielcson Date
//Regional Administrator
/ Region III
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Figure 1
Site Location
and Regional Topographic Map
Eastern Diversified Metals Site
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DHCISIOM SUMMARY
operable unit 3
BA8TBRM DZ7BRSZ7ZBD MBTALS 8ZTI
Z. 8ZTB HUB, LOCATION, AID DB8CRZPTZOM
The Eastern Diversified Metals (EDM) Superfund Site (Site) is
located in Rush Township, Schnylkill County, Pennsylvania,
approximately one mile northwest of the intersection of Routes 54
and 309 in the town of Hometown (Figure 1) . The site covers
approximately twenty-five acres of partially forested land, in a
deep east to west trending topographic valley. East-vest oriented
railroad tracks border the Site on the north valley ridge. The
Little Schuylkill River flows in a south-southeasterly direction
250 feet west of the property. A shallow stream flows westerly
along, the southern border of the Site in the valley bottom,
discharging into the Little Schuylkill River.
Waste insulation material, referred to as "fluff," is scattered
about the Site. Most of the fluff is contained within a 7.5 acre
pile which is approximately 250 feet wide by 1,500 feet long by 40-
60 feet high (main pile) (see Figure 2) . The fluff, which consists
of polyvinyl chloride and polyethylene insulation chips, and
fibrous material, paper, soil, and metal, is residual material from
the recycling of copper and aluminum communication and power wire
and cable. An estimated 150 million pounds of fluff are onsite.
Ground water at the Site occurs in shallow perched zones, the
overburden, joints, fractures, and in weathered zones in the
bedrock. Ground water in the overburden flows both vertically and
laterally; vertical downward flow recharges the upper bedrock and
lateral flow is .directed southwestward. across the Site towards the
intermittent^ stream and the Little Schuylkill River- Ground water
in the shallotrrHaedrock1- zone flows similarly in direction and
gradient- to the- lateral overburden flow, i.e. , it flows toward the
Little Schuylkill River, which; is the only regional discharge point
in the area* . . •'"""." '•—./- , . W:^ :
zz. am BZCTORY* BMFORCUUUR ACTIVITZBS, AMD CURRBMY USB
A.
Prior to 1966, the Site property was owned by a manufacturing
company engaged in the extrusion of aluminum for hospital
furniture. Pre-1966 activities were confined to a single building
on the property, with the remainder of the Site left vacant. The
manufacturing company disposed of wooden wire reels, wooden
pallets, and similar debris and trash onsite.
In or around September 1966, Greater Tanaqua Industrial Development
Enterprises conveyed the Site property to Eastern Diversified
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Metals Corporation (EDMC). EDMC operated at the Site, reclaiming
copper and aluminum front wire and cable in a processing building on
Lincoln Avenue, from approximately 1966 through 1977. The EDM
plant received wire from numerous sources. Plastic insulation
surrounding metal cable and wire was mechanically stripped and
separated from the metal using gravitational separation techniques.
This process involved chopping the wire, stripping the plastic
coating from the wire with steel blades, and separating the wire
from the plastic coverings through the use of air and water
clarifiers.
The metal reclaimed by EDMC was either sold or returned to the
sources. EDM disposed of the waste insulation material on the
ground in the topographic swale area behind the plant at the site.
The fluff which currently exists is a direct result of this
disposal practice. -
B. Enforcement Activities and History of Regulatory Involvement
In 1971, EDMC submitted an application to the Pennsylvania
Department of Health (DOB) for a permit to operate a 25 acre
industrial landfill. DOB inspected the EDM Site in February 1972,
and noted that EDMC warn in violation of the Pennsylvania Clean
Streams Lav because the waste pile was creating leachate that
flowed into the Little Schuylkill River via a small intermittent
tributary running through the EDM Site.
In February 1973, the Pennsylvania. Department- of Environmental
Resources (PAOER) inspected the Site. PADER's inspection report
noted that there were two separate but adjacent disposal areas on
the EDM Site; mixed waste was disposed on the extreme western
portion, while shredded insulation material was dumped in the north
central portion. The "mixed waste" consisted of cardboard, paper,
-wooden pallets and reels, steel wire and general waste. The report
also noted that scrap metal and 55-gallon steel drums were stored
onsite. • •• •'• ' '' """• •
in December 1973,' the Pennsylvania Division of Solid Waste
Management, determined that EDMC would have to provide a permitted
leachate collection and treatment system and a groundwater
monitoring: system before a landfill disposal permit could be
issued.
In 1974, EDMC submitted an application for a Water Quality
Management Permit. Pursuant to a consent order with PADER,
Theodore Sail, Inc. (Sail) installed a leachate collection and
treatment system onsite in order to monitor, collect, and treat
leachate emanating from the fluff pile. Due to the high BOO
concentrations in the leachate at that time. Sail designed and
installed a secondary treatment system which is currently
operational. The secondary treatment plant uses clarification,
aeration, and activated sludge biological treatment to bring the
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Figure 2.
SITE FEATURES
Eastern Diversified Metals Site
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effluent within the limits allowed by its PAOER National Pollutant
Discharge Elimination System (NPDES) permit. The effluent
discharge enters the intermittent stream tributary to the Little
SchuylJcill River. Daily flows average approximately 3,000 gallons.
The treatment plant is part of a leachate management system which
also includes an equalization lagoon, erosion control measures,
surface water diversion ditches, and two shallow ground water
interceptor trenches which convey some shallow leachate to the
leachate treatment plant. •
The equalization lagoon is located approximately 300 feet to the
northeast of the treatment plant, at the base of the main fluff
pile. The lagoon is lined with 30 mil polyvinyl chloride and feeds
leachate influent to the treatment plant. .
The leachate diversion ditches at the. Site parallel the northern
and southern boundaries of the main fluff pile. The southern
diversion ditch conveys leachate to the treatment plant via an
equalization lagoon. The northern (interior) diversion ditch
terminates at the runoff lagoon, where runoff either evaporates or
infiltrates to shallow ground water. Some of this ground water is
intercepted by the secondary ground water collection trench and
pumped to the treatment plant.
The main ground water interceptor trench is located along almost
the full east-west length of the main fluff pile, between the
southern leachate diversion ditch and the intermittent stream. At
the southwest end of the main fluff pile, a secondary collection
trench runs approximately north-south to collect shallow subsurface
leachate at the western edge of the pile. The trenches are
approximately six to ten feet deep. The leachate from the main
trench discharges into the wastewater treatment plant; the leachate
from the secondary trench is conveyed to a sump just southwest of
the treatment plant, from which it is pumped directly to the plant
for treatment.
In or around 1977, BDMC terminated operations at the Site and,
subsequently, transferred ownership of the Site to Theodore Sail,
Inc. ["Sail"]. In June and November, 1979, the Hometown Fire
Company responded to reports of fires at the Site; the fires were
extinguished with fire retardant and water. The area where
smoldering fires were noted is limited to a portion of the main
fluff pile in the vicinity of the secondary leachate seep
(southeast side of the pile). Sail excavated the burned areas in
an effort to ensure that the fire was extinguished and installed
temperature sensors to detect elevated temperatures within the
pile. Laboratory testing estimated that a critical temperature of
approximately 29O* Fahrenheit may cause this material to smolder.
Sail reports that temperature monitoring conducted since that time
has shown that temperatures do not approach those which would be
required for the material to smolder.
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In 1979 and 198O, the Rush Township Board of Supervisors wrote
letters to Diversified Industries, Inc., EDHC and Sail's parent
company, on behalf of area residents, complaining of odors from the
EDM Site and expressing health concerns. In 1983 and 1984, PADER
conducted chemical and aquatic biological investigations of the
Little Schuylkill River (LSR) and all of its tributaries and point
source discharges. These studies included sampling of the
intermittent stream at the EDM Site and the effluent from the
leachate treatment plant. PADER' stated that under the acid-
impacted conditions found in the LSR, "the confirmed complete
absence of any aquatic macrobenthic community is expected." This
report concluded that an evaluation of the effects of the EDM Site
on the LSR could not be made due to the prevailing acid mine
drainage degradation in this section of the LSR.
In 1985, Todd Giddings and Associates, Inc. completed a Site
evaluation report for Sail. This evaluation included sampling and
analysis of surface water, leachate, ground water, fluff, and
sediment. These investigations determined that the fluff contained
polychlorinated biphenyls (PCBs) and failed the Extraction
Procedure Toxicity test for lead. Additionally, various metals
were detected in the downgradient monitoring well.
In 1985, EPA sampled the Site's surface soil, surface water, stream
sediment, leachate, leachate runoff path sediment, and ground water
to provide data in order to further assess the site. EPA proposed
the Site for inclusion on the CERCLA National Priorities List (NPL)
in June, 1986. EPA finalized the Site on the NPL in October, 1989
(2sft 54 £fid. fitfl. 41O36 (Oct. 4, 1989)).
In August 1987, EPA issued an administrative order pursuant to
section 106 (a) of CERCLA, 42 D.S.C. f 9606(a), to Diversified
, industries, Inc. and Sail directing those entities to install a
security fence around the Site. The fence was subsequently
installed by those parties.
In October 1987, Sail and AT&T Nassau Metals Corporation signed an
administrative order on consent with EPA for the performance of a
Remedial Investigation/Feasibility Study (RI/PS) at the Site. The
purpose of the RZ/F8 was to determine the nature and extent of
contamination and to evaluate remedial alternatives for
implementation at the Site. Samples were collected and analyzed
from fluff, air, soils, sediments, ground water, and surface water.
A majority of these samples were taken in and around the fluff pile
area.
On March 29, 1991, EPA issued a Record of Decision selecting a
final remedy for OD1 and an interim remedy for OU2. The
Commonwealth of Pennsylvania concurred on that ROD. The Remedial
Action selected by EPA for OU1 and OU2 calls for, among other
things, the following actions to be undertaken:
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OU1 • Excavate and incinerate, either onsite or offsite,
fluff and soils containing dioxins and PCBs in
concentrations exceeding target levels.
• Treat (if necessary) and dispose of incinerator
residuals, miscellaneous debris, and
soils/sediments contaminated with metals above
target levels.
OU2 • Enhance the existing or construct a new shallow
ground water collection and treatment system.
• Study further the practicability of deep ground
water restoration.
In September 1991, AT&T petitioned EPA to reopen the March 1991
ROD, claiming that PCS analytical results reported and relied on in
the RI/FS were inaccurate. Attached to the petition were recent
analytical data shoving that PCBs were present at much lower
concentrations in the hotspot area than indicated by the original
analyses (see AT&T petition in the Administrative Record for this
ROD). In December 1991, EPA sampled the fluff material and is
currently analyzing the samples using analytical techniques which
were unavailable at the time the original analyses were conducted.
The current analyses will more precisely define the types of
contaminants and the concentration* at which they are present in
the hotspot area. Once the analytical results are received, EPA
will evaluate the data and determine whether a hotspot exists and,
if so, whether the remedy component selected to address the hotspot
in the March 1991 ROD (incineration) is still appropriate.
In September 1991, EPA issued a Unilateral Administrative Order
(Order) to AT&T Nassau Metals Corporation and Sail to implement
.portions of the remedy described in the March 1991 ROD which did
not pertain to the remedy for the hotspot area. The Order directed
AT&T and Sail, among other things, to remove the miscellaneous
debris from the Site, repair the fenc* surrounding the Site, and
conduct additional -ground water studies. A Remedial Design Work
Plan has been reviewed and approved by EPA and a Remedial Action
work Plan and Design Report is currently undergoing EPA review.
Miscellaneous debris is expected to be removed from the site during
Fall 1992. Ground water studies are scheduled for completion by
the end of 1992. A final decision regarding the need for ground
water remediation is expected in late 1993.
C. Current Site Use-
Presently, the Site is unused. The wastewater treatment plant
continues to be operated by Sail under its NPDES permit from the
PADER Bureau of Water Quality. The property is overseen by a sail
employee who is responsible for the daily operation and general
maintenance of the wastewater treatment plant, recording
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temperatures from the pile sensors, and general security. The
caretaker is present onsite for approximately half of the day for
five days each week.
ZZZ. COMKOnTY PABTXCXPATXOM
In accordance with Sections 113 (Jc) (2) and 117 of CERCIA, 42 U.S.C.
Sections 9613(k)(2) and 9617, on April 16, 1992, EPA placed a
quarter page advertisement in the Lehiahton Tinea Neva announcing
the 3O-day comment period on the Proposed Plan for the third
operable unit of the Eastern Diversified Metals Site. Also
announced was the availability of the Proposed Plan and RI/FS
reports as part of the Administrative Record in the site
information repository at the Rush Township Municipal Building.
The public comment period began April.16, 1992 and ended May 16,
1992.- A public meeting was conducted on April 30, 1992 in order to
facilitate receiving the public's comments and concerns regarding
the proposed action for the third operable unit at the Site. Local
citizens comments centered on potential health impacts to workers
and the surrounding community from an onsite recycling facility.
Specific comments and concerns raised by the local community are
addressed in the Responsiveness Summary attached to this Record of
Decision.
XT. SOOn AXD BOLB OF O9HULBLB OMITS
As described above, EPA divided the Eastern Diversified Metals Site
into operable units, or site components, in order to effectively
address the complex contamination problems present in the various
environmental media. The divisions to date are as follows:
OU1 • "Hotspot" areas (those areas of fluff and soils
contaminated with PCBs and dioxin above target
levels)
• Sediments and Soils contaminated with metals
above target levels
• Miscellaneous Debris
ous • Ground Water
our • Remainder of the fluff
In March, 1991, EPA signed a Record of Decision which documented
the selection of a final remedy for OU1 and an interim remedy for
OU2, as described above. EPA will advise the public if that
portion of the OU1 remedy currently being reviewed as a result of
AT&T's petition changes in any significant or fundamental way.
This Record of Decision selects a remedy for OU3, the remainder of
the fluff at the Site. This ROD does not, however, address
remediation of soils underlying the fluff at the Site. EPA will
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announce whether, and to what extant, further response actions are
necessary in this regard in a subsequent Record of Decision
following analyses of soil samples performed as part of this
response action.
V. SUMMARY OF SIT! CHARACTERISTIC*
A. Environmental Betting and Climate
The Site is located in a sparsely populated rural area in Hometown,
Schuylkill County, Pennsylvania. Nearby towns include Tamaqua,
which is approximately 2.5 miles to the southeast. Land use
surrounding the Site includes open and residential lands to the
north, west, and south/southeast, and several business and
industrial facilities to the east. Specifically, the Site is
bordered by a residence and privately-owned forest land to the
north-. Adjacent to the eastern border of the Site is the Lincoln
Avenue building which was used to process the EDK fluff. This
building is presently partially occupied by a trailer home assembly
operation, other commercial operations near the site along Lincoln
Avenue include a shipping facility (United Parcel Service), an auto
parts/junkyard operation, a heavy freight depot (Yellow Freight),
and a pigments manufacturer (Siberline Company). state Game Lands
are located to the west along the banks of the Little Schuylkill
River.
Land use in Schuylkill County is primarily agricultural (82.7
percent). Approximately 5.3 percent of the area is residential,
4.5 percent is used for manufacturing, commercial, or mining
applications, and the remaining 7.5 percent is undeveloped.
B. Regional geology.
1. soils
Soils on the Site- have formed in colluvium, along drainage ways and
in depressed areas. The, soils are deep, poor to moderately well-
drained with slow to moderately slow permeability and medium
runoff. The lower part of the subsoil layer (which begins
approximately 2O to 4O inches from ground level) contains a firm
and brittle fragipan that restricts vertical water flow and
facilitate* lateral flow of shallow subsurface waters. Depth to
bedrock may be 6O to 96 inches or more from the ground surface.
2. Geology
Bedrock beneath the Site is the middle member of the Mississippian
Age Mauch Chunk Formation. The Mauch Chunk is generally described
as predominantly composed of grayish-red siltstones and shales, and
grayish-red-purple sandstones. The Mauch Chunk Formation is
overlain by the Pottsville Formation, and underlain by the Pocono
Formation. Both contacts are considered to be transitional, and
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8
both the Pottsville and Pocono Formations are characterized by
coarse-grained yellow and gray sandstone and conglomerate
lithologies. Topographically, the Mauch Chunlc tends to be a
valley-former due to the greater resistance to erosion which
typifies the more massive Pottsville and Pocono formations.
3* Hydropeo1ooy
Water is transmitted through the 'Mauch Chunlc primarily through
fractures, joints, and along permeable bedding zones. The
formation has low to moderate infiltration capacity and probably
low to moderate aquifer potential. In general, the Mauch Chunlc is
described as yielding small to moderate supplies of good quality
water. Mauch Chunk ground water in the Schuylkill River Basin area
is reported to have a median pH value of 7.7 and a median specific
conductance value of 120 micro mhos/cm.
Shallow ground water occurs in limited quantities under both
perched and water table conditions in the overburden. Dynamics of
ground water flow in the overburden are basically those of porous
media flow, where primary permeability dominates and the system is
assumed to be essentially homogeneous (despite the obvious presence
of certain inhomogeneities). Perched water in the main fluff pile
was encountered in the eastern pile piezometer. Perched flow
occurs in some areas due to the presence of fragipans in the-
colluvial soil. This flow component carries leachate from the
pile, some of which is intercepted by the existing interceptor
trench system and conveyed to the leachate treatment plant.
Underlying the perched flow zone, a local ground water system is
present in the overburden. The overburden is dry in some areas and
saturated in others, with classical porous media flow possible only
in the southwest section of the Site, near the headwaters of the
intermittent stream. The ground water quality data collected in
the RI indicates that the overburden flow system recharges the
upper bedrock; thus vertical downward flow occurs, as well as
lateral flow.
Horizontally, flow in the overburden is directed southwestward
across the> Site at approximately O.11-O.13 feet per foot. However,
it should be noted that much of the ground water which enters the
overburden likely recharges the bedrock rather than flowing
laterally, as evidenced by the extensive dry seasonal conditions
above the bedrock. It appears that the only substantial lateral
flow in the Site overburden may occur in the southwestern portion
of the site, where wells MW-3/O and MW-6/O contain water year-
around. Based on constructed piezometric surfaces, the overburden
flow system recharges the intermittent stream along its lower
length. Since the lower reach of the stream is known to flow year-
round, it is evident that this flow is sustained by the shallow
system in the southwest portion of the Site. This is consistent
with the saturated conditions at MW-3/O and MW-6/O, verifying
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sustained lateral flow through the overburden in the southwest
corner of the Site.
Most ground water at the Site occurs in joints, fractures,
permeable interbeds, and weathered zones in the bedrock. .Water was
present in multiple thin zones separated by two to several tens of
feet during the monitoring well installations. Commonly, ground
water conditions in bedrock of this type are complex due to
intricate localized lithological and structural controls. Thus,
ground water may be under confined permeability, and possibly
unconfined conditions in permeable vertical fractures or extensive
near-surface weathered zones.
The vertical head conditions (varying from strong downward to
slight upward) at the Site verify the complexity of ground water
conditions. However, it can be observed that the water levels
measured reflect the potential for hydraulic connection among the
three aquifer zones monitored.
Flow in the shallow bedrock zone is similar in direction and
gradient to the overburden. Hater level elevation contours
indicate that flow occurs below the elevation of the intermittent
stream bed, in a direction towards the Little Schuylkill River.
Thus the direct discharge point for the shallow bedrock ground
water flow appears to be the Little Schuylkill River, which is the
only regional discharge point in the area. The lateral hydraulic
gradient in the intermediate bedrock aquifer also indicates flow
toward the Little Schuylkill River.
An inventory of ground water usage was completed for the EDM site
vicinity. Figure 3 shows the locations of water wells identified
during the RZ. All of the wells identified are topographically
upgradient of the Site. Hell depths range from 9O feet to 6OO
feet. A number of resident* ._ have reported flowing, artesian
conditions, indicating a possible recharge area to the north, i.e.,
the Still. Creek Reservoir Area. Hater quality was reported to be
good in most cases, although some wells had taste, odor, and
sediment problems unrelated to the Site.
4.
This part, ot the Schuylkill River Basin receives an annual average
rainfall of 45 inches. Basin maxima for runoff (3O inches) and
rainfall (49 inches) occur near Tamaqua and decrease from north to
south. Peak runoff occurs during the period from February to
April. The runoff low point is generally during August to October,
although at Tamaqua, low runoff typically occurs in July.
Surface runoff from the Site flows predominantly in a west-
southwesterly direction, to the small unnamed intermittent stream
which flows west along the southern border of the Site and drains
into the Little Schuylkill River.
-------
Figure 3
Ground Water Wells
1 Mile Radius
Eastern Diversified Metals
Remedial Investigation
•1-22 Door-to-Ooor Survey
tooo 2000 .134-787 USGS 4 PA Well Data Base
(Data on Table 4-9)
Scat* in F««t Source; USGS Topographic Quadrangles; D«l«no, PA and Tamaq'ui.
-------
10
VI.- HATDRB AMD BZTOT OF COMTAMIXATIOV ;
A. R*»adi,al Investigation fan
The RI field activities and analytical program were designed to
define the extent of environmental contamination, identify
migration pathways, and provide data to support a Feasibility study
of potential remedial actions. The scope of the RI included
sampling and analysis as necessary to fill data gaps in the
historical database. Leachate/seeps, surface soils, subsurface
soils, surface waters, stream bed sediments, bioassays, air, and
ground water sampling were conducted to characterize the quality of
these media (sampling locations are shown in Figures 4 through 9).
In addition to sampling and analyses, limited studies of the
hydrogeology and hydrology of the Site were conducted through field.
mapping and aquifer testing. _
A summary of the results from previous investigations and from the
RI sampling program are shown below.
1. ZUiII
a) PCB concentrations ranged from 1.7 to 556O milligrams per
kilogram (mg/)cg). The highest concentration was T-1O from the
vicinity of the Main Leachate Seep. In order to further delineate
this area of elevated PCB concentrations, an additional six samples
were subsequently collected in the vicinity of T-1O. The T-1O
sample cluster (T-1O, T-10R, T-1OSW, T-10SE, T-10NB, T-10NW, T-
10RC) as shown on Figure 8, is defined as the PCB "hotspot" area of
the fluff pile. This area represents approximately five percent of
the pile and has an estimated volume of 4,74O cubic yards.
Slightly elevated PCB concentrations of 4O mg/kg were also found at
T-26. Mean PCB concentrations in the fluff were 15.7 mg/kg,
excluding the three highest values from the hotspot area.
b) Total lead concentrations ranged fro* 149O mg/kg to greater
than 4O,OOO mg/kg throughout the fluff. The mean concentration was
11,45O mg/kg. Borehole results indicate that lead concentrations
are fairly consistent with depth. Lead was a probable constituent
of insulation fillers in the form of lead phthalate.
c) Concentrations of dioxin and dibenzofurans with a calculated
Toxicity Equivalence (TE) to 2,3,7,8-tetrachloro-p-dibenzodioxin of
18.5 micrograms per kilogram (ug/kg) resulted from analysis of a
composite sample of fluff from the area where fires had occurred
previously. This area is on the southern rim of the main pile
between the secondary leachate seep and the main leachate seep; the
sampling location is shown as SFD-1 on Figure 8. This area is
referred to as the dioxin "hotspot" area and EPA suspects that this
sample represents conditions in only a very limited area of the
-------
Figure 4
Air Sampling Locations
Eastern Diversified Metals Site
Remedial Investigation
LEGEND :
A MR MOMIOHMC
4 WSION MR SAWPUMC IOCAMNS
(4MWOJUMATE)
*win«r> IM »«XM (M MI n«» «s IWIM imi
OIM* KMS MB W» Ml HPfUHNI . MuWM, WMr
OAIE Or PHOTOCRAPHY - APRIL 19. 1989
CONTOUR INTERVAL - NCVQ 1929
-------
Figure 5
Soil Sampling and
Investigation Locations
Eastern Diversified Metals Site
Remedial Investigation
LEGEND :
A
5
N
SUWACC SOL SAMPU
suWACt SOL COMPOSIIC SAUMIS ft*
sot Kftuc/wur* IMI
itsi OOM HOLE
icsi PII
CONIOUR INICRVAL - NOVU
DATE Of PHOrOCRAPHT - APRIL 19. I9B9
-------
Figure 6
Surface Water, Bioassay,
Stream Bed Sediment, and
Leachate/Seep Locations
Flow Measurement Locations
Eastern Diversified Metals Site
Remedial Investigation
a SUWACC _
B UACHMC MAIM souRCC
rOM SCUUCNI UACHMC ItSI
IB SUWACC MICN SCOMCNI
* MASSAt SAMPtC
I
UAO4AIC SUP SAMPU
IM HOHtn IM JHIMN ON Mi n«K MS IMUH IMU
OMM fUM 00(S KOI MHMiKl • MUWMf luntl.
DATE or PHOIOC«
-------
Figure 7
Location of Little Schuylkill River Fluff Survey Stations
Eastern Diversified Metals Site
Remedial Investigation
Schuylkill
County
-------
N
Figure 8
Fluff Sampling
and Investigation Locations
Eastern Diversified Metals Site
Remedial Investigation
C*C WMWC
• SOU) WASIt SUHTACC
Q KM HU MMMC LOCATION
O ICM RANDOM PK.C SAMAf
(«M>NOiaM/>IE Aflt* nrSON. ltt»)
A SUMTAGf SAMPlf rOM OMIM
IHC prarfin IMC IHOMI OH Ml n/w
-------
11
fluff where these fires occurred. The volume of dioxin-
contaminated fluff is estimated at 5OO cubic yards.
d) Volume estimates for the hotspot areas of the fluff, with the
exception of two pile borings and four backhoe pits, are based on
sampling which was limited to a depth of three feet.
2. Leachate
*
a) The stream bank seeps issue from unconsolidated overburden
material. Seeps at the base of the main pile are related to the
saturated zones from within the pile, above the overburden.
b) TCE was detected at 44 micrograms per liter (ug/1) at LS-1, a
seep in the north bank of the intermittent stream adjacent to the
equalization lagoon (reference Figure 6). Bis(2-ethylhexyl)
phthalate (DEHP) at 14O ug/1 and di-n-octylphthalate (DNOP) at 27
ug/1 were detected in LS-2, the main leachate seep. PCBs at 2.6
ug/1 and 6.O ug/1 were detected in LS-2 and LS-4, respectively.
c) Copper, lead, zinc, iron, and manganese were present at
elevated levels in all seeps. Maximum levels detected.were 6,39O
ug/1 copper; 1,O8O ug/1 lead; and 8,05O ug/1 zinc in LS-2, the main
leachate seep; 93,6OO ug/1 iron in LS-3; and 12,40O ug/1 manganese
in LS-4. Both LS-3 and LS-4 are downgradient of the waste water
treatment facility*
3. soil*
a) Bis (2-ethylhexyl) phthalate (DEHP) at 1,10O-3,30O mg/kg and
Di-n-octyl phthalate (DNOP) at 19O-72O mg/kg were detected in
surface soil samples.
b) PCBs were detected in 21 of 27 samples, with an average
concentration of 2O mg/kg. The northwestern side of the main pile
along the northern drainage ways (reference Figures 2 and 5) showed
the highest concentrations at 63-24O mg/kg.. The volume of soils
contaminated with PCBs above target levels is approximately 42O
cubic yards. The source of the high level PCBs may be due to
migration from the "hotspot" found in the center of the fluff pile.
c) Composite surface soil samples for dioxin and dibenzofuran
analysis had a Toxicity Equivalence (TE) of O.OO3 ug/kg for the
sample obtained adjacent to the past fire area and 7.1 ug/kg TE for
the downwind sample. The results indicated that off site transport
of dioxins by wind-aided transport of particles is not of concern
at the Site.
d) Maximum concentrations for Site-related metals detected were
1O8,OOO mg/kg for copper and 1,92O mg/kg for lead. The highest
levels are associated with the northern drainage ways (reference
Figures 2 and 5). The volume of soils contaminated with lead above
-------
Figure 9
Ground Water
Monitoring Well Locations
Eastern Diversified Metals Site
Remedial Investigation
n-j
OvcmuMKN
»UIUM MOftOCK
MKMUOMK KONOCX
«**MMMO Hi JIlMO Mti
M nunurr UM MM> « M> K/yi M IMUM mm
0KB fUM «>• MCI KOf MMUWI A MUWW
CONTOUR INTERVAL - NCVt) 1929
OAIE OF PHOTOGRAPHY - APRIL 19. 1989
-------
12
target levels is approximately 480 cubic yard*. Concentrations of
zinc and cadad.ua at 1,230 ing/ kg and 7 mg/kg, respectively, were
elevated above background levels of 7O mg/kg for zinc and the
detection limit for cadmium.
4. fitjfrgurf aca Soils
a) DEHP, DNOP, and PCBs were detected at lover concentrations than
in surface soil samples with maximum concentrations of 620 mg/kg,
2OO mg/kg, and 7 mg/kg, respectively. Copper and lead were present
at 65O and 266 mg/kg, respectively, at less than 12 foot depths.
5. Surface Water
a) Equalization lagoon samples totaled 15,7OO ug/1 of phenols, the
only semi-volatile compounds detected, in surface water. Maximum
concentrations of copper at 38 ug/1, lead at 4.5 ug/1, iron at 776
ug/1, manganese at 2,78O ug/1, and zinc at 369 ug/1 were elevated
above standards of 4 ug/1 for copper, O.6 ug/1 for lead, 3OO ug/1
for iron, SO ug/1 for manganese, and 36 ug/1 for zinc.
b) Samples downgradient of the junction of the intermittent stream
and the north-south drainage ditch (location SW-6, post- treatment) ,
reflect iron (776 ug/1) and manganese (1,O5O ug/1) levels which are
ten times greater than those in the intermittent stream upgradient
of the wastewater treatment facility (reference Figure 6) . Lead
and zinc at this point were present at 2.2 ug/1 and 369 ug/1,
respectively.
6.
a) Small quantities of fluff particles were seen in sediments 23
miles downstream of the Site. DEHP at 24-4, OOO mg/kg and ONOP were
the only organic compounds detected. Highest concentrations were
in the equalization lagoon with generally diminishing results
downstream (reference Figures 2 and 5).
b) PCBs at 0. 51-8 .4 mg/kg were detected in the intermittent stream
but not the Little Schuylkill River.
c) Copper at 3,O9O mg/kg; lead at 1,3OO mg/kg; zinc at 7,85O
mg/kg; iron at 54,8OO mg/kg; and aluminum at 3O,5OO mg/kg
concentrations were present in sediments. The volume of metals
contaminated sediments above target levels requiring remediation is
approximately 12O cubic yards.
7. Ground Water
a) Specific conductance readings indicate that the main pathway
for leachate migration from the fluff occurs in the western portion
of the site, where the overburden sustains a ground water flow
system.
-------
13
b) The same suit* of volatile compound* were identified in the
analyses from both rounds of ground water sampling. The prevalent
compounds were 1,1,1-trichloroethane and trichloroethene (TCZ).
The highest individual compound concentration reported was 91 ug/1
of TCE in MW-3/O (reference Figure 9). Total concentrations of
volatile organic compounds ranged from non-detected to 119 ug/1 in
MW-3/O. The samples with the highest levels of volatile organic
compounds were from MW-3/O, MW-2/I, MW-2/S, MW-5/S. All four wells
are located along the southern perimeter of the main fluff pile, oh
the downgradient edge of the Site.
c) Calcium, magnesium, and manganese were elevated above
background downgradient of the main pile. These results suggest
the leaching of major ionic species from the main pile, and
possibly the mobilization of natural manganese under slight
reducing conditions in the fluff leachate.
8. Air
a) Neither the volatile nor phenolic air analyses performed
detected any organic compounds.
9. Miscellaneous P^brjft
a) In general, the fluff is a homogeneous mixture of the chopped
insulation. However, some debris piles, including some select
areas within the main fluff pile, contain other miscellaneous
rubble, such as unstripped wire and cable, metals, and wooden cable
spools totaling approximately 14,OOO cubic yards. This total is
roughly estimated to be comprised of 3O% fluff; 30% wire and cable;
30% wood, soil, and miscellaneous materials; and 1O% fine-grained
iron. Locations of the miscellaneous debris piles are shown on
Figure 1O.
10.
A number of elements and compounds related to the presence of the
fluff were detected in each of the Site media, including:
a) Bis-(2-ethylhexyl) phthalate (DEEP) - present in surface soils,
subsurface^ soils, stream bed sediment and leachate, but not in
ground water or surface water.
b) Polychlorinated biphenyls (PCBs or Aroclors) - detected in the
fluff, surface soils, subsurface soils, sediments, and leachate but
virtually absent in surface water samples.
c) Trichloroethene (TCE) - in ground water monitoring wells and
one ground water seep from the Site overburden.
d) Dioxih and dibenzofurans - detected at low levels in fluff and
soils adjacent to a burned area of the main fluff pile.
-------
14
e) Copper, lead, zinc, iron and calcium were elevated above
background concentrations in all solid and aqueous media.
f) Manganese in ground water monitoring wells.
C. Principal Conclusions
1. Due to the low solubility of phthalates, it is possible that
the detection of these compounds is a result of the inclusion of
fluff particles in soil samples rather than phthalates transported
from the fluff to the soil in water. This conclusion is supported
by the fact that phthalates were found only in solid, not aqueous,
media.
2. PCBs, like phthalates, are also low solubility compounds which
would be expected to adhere to soil -particles or remain in the
plastic matrix. It is suspected that PCBs were used as
plasticizers or additives to plastics in the past.
3. Like phthalates and PCBs, lead is probably bound in large part
in the fluff material, although it fails TCLP. Lead was used as a
stabilizer in the form of lead salts and in insulation fillers in
the form of lead phthalate. These were added during the plastics
manufacturing process.
4. The principal conclusions regarding the dynamics and extent of
migration of Site-related constituents are as follows:
a) The main mechanism of migration at the Site is physical
transport by runoff and erosion. Particulate fluff material is
eroded from the main pile, and deposited in onsite surface soils
and offsite in stream bed sediments.
b) Metals accumulated in the intermittent stream sediments may
dissolve in the stream water to levels which are toxic to aquatic
life.
c) A secondary mechanism of migration at the Site is seepage and
overland runoff of leachate during wet periods, where the leachate
diversion ditches may be insufficient to carry all of the flow.
These leachate discharges enter the stream directly by overland
runoff.
d) Transport of contaminated ground water is a potential migration
route.
e) Another secondary mechanism of migration at the Site is wind
erosion, as the finer particulates are carried during strong winds
and deposited in onsite and offsite surface soils.
-------
Figure 10
Miscellaneous Waste Pile
Locations
Eastern Diversified Metals Sit*
Remedial |nvwtigatlon
>M MM "01
CONTOUR INltHVAL - NCVD 1929
iCMt •> K
DA re or
- APRM. 19. *.9H9
•00 100
-------
15
VII. SUMMARY 07 8ZTB RX8U
A. SyjMffBri Assessment BummexT
The goal of the exposure assessment is to determine the type and
magnitude of human and environmental exposure to the contaminants
present at, and migrating from, the Eastern Diversified Metals
Site. The exposure assessment was conducted to estimate the risk
imposed by the Site if no remedial action was taken.
To determine if human and environmental exposure to the
contaminants of concern might occur in the absence of remedial
action, an exposure pathway analysis was performed. An exposure
pathway is comprised of four necessary elements:
1) a source and mechanism of chemical release;
2) an environmental transport medium;
3) a human or environmental exposure point; and
4) a feasible human or environmental exposure route at the
point of exposure.
The potential for completion of exposure pathways at the Eastern
Diversified Metals Site is described in the following sections.
1. Exposure Points
The potential points of exposure to compounds associated with the
EDM site are described below: . -
. Air exposure to fugitive dust from the fluff in the
Site vicinity (no volatile compounds were found in air
testing done at the Site);
. Ground water exposure from a, hypothetical potable well
near the Site boundary;
Sediment .exposure in the intermittent stream;
Surface water exposure at the leachate seeps onsite, the
intermittent stream, and/or the Little Schuylkill River;
. Exposure tb the fluff and to the soils around the fluff at
th« Site. -.,..._.....- ,
. Exposure to contaminants in edible fish tissue.
2. Potentially Exposed Hirnmn Popul.ati.Qne
The potential population categories evaluated were children ages 2-
6; children ages 6-12; and adults, including onsite maintenance
workers, offsite residents, offsite workers, and hunters and
fishermen. It is important to note that the dermal contact and
ingest ion exposures with leachate, fluff, and soil for children are
calculated according to a "fence down" scenario which assumes that
there is no fence to restrict Site access. It is also important to
point out that risk estimates were based on continuous (or chronic)
lifetime exposure to the Site. The calculated risk for each
-------
16
population was based on contact with the exposure point
concentrations in the various media during the entire time an
individual within an age group falls within that age range (i.e. 4
years for Age 2-6, 6 years for Age 6-12, and 58 years for Adults -
total lifetime assumed to be 7O years). It is unlikely that any
one individual will be exposed to the Site in all of the ways that
are assumed here for his or her entire lifetime. A summary of the
potential Site-related exposures tq affected populations analyzed
in this assessment is shown in Table 1.
3. Eypoauira Point Concentrations
The Site-related exposure point concentrations were determined once
the exposure scenarios and potentially affected populations were
identified. If the transport of compounds associated with a site
is under steady-state conditions, monitoring data are adequate to
determine potential exposure concentrations. If no data are
available or if conditions are transient (such as fugitive dust in
air or a migrating plume in ground water), models are used to
predict concentrations. In lieu of an established trend in
historical data indicating the contrary* the EDM site was
considered to be in steady-state with its surroundings.
The only pathway for which modeling was considered appropriate was
the fugitive dust pathway. Receptors for the surface water and
sediment contact pathways were either expected to be present,
although infrequently, in the area in which samples, were taken or
the concentrations found during the RI were used as a deliberately
conservative estimate of potential concentrations downstream.
Thus, all exposures, except via the air pathway, were expected to
be represented by the concentrations found in the samples taken on
the Site. -
To describe the air pathway, average and maximum concentrations of
the indicators for which, the fluff had been analyzed were used as
input for a fugitive dust screening model. The models used were
EPA's Industrial Source Complex Short Term (ISCST) and Industrial
Source Complex Long Term (ISCLT) Dispersion Models. This was a
conservative approach-, as the airborne dust particles are likely to
contain much lower levels of lead and PCBs than the larger size
plastic fraction which makes up most of the fluff. Assumptions
were mad* regarding meteorological and Site conditions based on
established screening criteria and first-hand observation of site
conditions.
Exposures were estimated for the maximum and average concentrations
for each indicator chemical in each medium at the Site. The air
screening model output was used to develop similar data for the air
exposure points. Dioxin Toxicity Equivalents (TEs) were used to
describe the dioxin content of soil and fluff. When calculating
the average concentration, half of the detection limit was used as
the concentration in a given sample for indicators which were not
-------
17
detected in that sample. For ground water, only dovngradient veils
were used for the calculations, i.e., upgradient veil MW-l was
omitted from the calculations. The measured and calculated values
are presented in Table 2. The lead concentrations vere omitted
since these intakes vere considered separately due to the absence
of a Reference Dose (RfO). The major assumptions about exposure
frequency and duration that vere included in the exposure
assessment are shown on Table 3.
•
B. ToxioitT Assessment Summary
The toxicity evaluation of the indicator chemicals selected for the
EDM site vas conducted to identify relevant carcinogenic potency
slopes and/or chronic reference doses against which exposure point
intakes could be compared in the risk characterization of the Site.
Indicator compounds are those which are the most toxic, prevalent,
persistent, mobile, and which contribute the major potential risks
at the Site. Indicator compounds selected for this Site classified
as noncarcinogens are lead, copper, zinc, and manganese.
Potentially carcinogenic indicator compounds selected for this Site
are PCBs, trichloroethylene, bis (2-ethylhexyl) phthalate, and
polychlorodibenzo-p-dioxin. A summary of toxicological information
for the indicator chemicals is shown in Table 4. Important fate
and transport processes for the indicator compounds are shown in
Table 5.
In a CERCLA risk assessment, the potential exposure point
concentrations are expressed only in terms of the indicator
compound concentrations during the exposure assessment. Another
acceptable approach is to use the concentrations of similar
compounds to represent the effect of the entire chemical group,
i.e., the total mass of a chemical group is used as the mass of the
indicator compound representing that group. This conservative
assumption allows for exposures to entire chemical families to be
incorporated in the risk calculations. In the risk assessment,
this approach was considered necessary only for dioxins because of
the high toxicity attributed to this group of compounds. Multiple
related cogeners of dioxins and the chemically similar furans vere
grouped together for evaluation. The concentration of each isomer
was multiplied by a toxicity equivalency factor (TEE) which
converts thet concentration of the isomer to a concentration of
2,3,7,8-tatrachlorodibenzo-p-dioxin (2,3,7,8-TCDD) that is
toxicologically equivalent. The total of all the concentration-TEF
products vas then used as if it were the concentration of 2,3,7,8-
TCDD in intake and carcinogenic risk calculations.
Carcinogenic Potency Slopes (CPSs) have been developed by EPA'a
Carcinogen Risk Assessment Verification Endeavor (CRAVE) for
estimating excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. CPSs, which are expressed in
units of (mg/kg-day)-l, are multiplied by the estimated intake of
a potential carcinogen, in mg/kg-day, to provide an upper-bound
-------
Tahfe 1
Adute
WatarContact
Ml/Fluff Contact
fnddantal Surface Watar
Incidental Sod/Fluff
i (Ftoh bujnden)
Children aft 8-13 FUfOwOu* SurtetWittrConttet
(Flab tafartan)
(Ftah bUMQaa)
Adult*
Children «gi».ia Batttfnf
Batttnf
OitnldagWa
Drtnkmg Water
DitoldngWatar
-------
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-------
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ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
BRM.
3.67E*00
aorefoa
l.60e*02
a.40E«00
3.22E*03
3.01 E*03
Y.60E«02
ERM. 1080
ERM. 1080
ERM. I080
ERM. 1080
ERM. 1080
IXild used aa Input lo screening ntmkl; mudcttnf Inbmwllon to Indioktl •• MI apitcnOU (Appciidu C|.
-------
CftUUMXT
TABLB 3
AKDQITA0
Avenge Body Weight
Avenge Slda Surface Ana
Avenge Ufrane
Avenge Number of Yean Cxpoaurc la Ufeome
Retenoea Rate aflahaled Air
Abeorpomi Rate of Inhaled Air
Frequency of FugUM Duct Inhalaaoo
• On-ene maintenance worken
• Off-sit* nMdem*
- Off-ell* we rt en
- Huaten and FUhenaaa
• Casual Ttvpoaecn
Dunoon of Fugitive Duet Inhalarten
- On-*ite maintenance worfcen
- Off-ette roMdcatt
• Off-die worken
- Hunten aad FtaaenoeA
Amount of Water lageeted DeUy
Percent of Dttaldag Water "net Home Source
Percentage of Stan Surface Ana
Volume of Water Uead While
VOiUOX Of SbOWIa^KAil
Length of Time Spent ta Bathroom After
Volume of Bathroom
Amount of Sediment lageeted Incidentally
Frequency of Sediment Contact
•G*Sattl**J (nBpettOtfit
DSa^£52Sc"u*
Pcrecnugt of Sk» Ana Contacted by imnunt
Slda Abeorpaoa Attt of COBBBMBB*
Amouat of Wttar lagaatae} laddajBttfl^f
• Huntar* end Flehcrflaa
Frecjueacy of Surftoe Water Cscvjct
• Hunten and FUbennaa
- CbJJdrca Flaylag
Dunnon of Surface Water Contact
- ChUdrea Playtag
- Children Plavtna'
(al
(al
(al
(«
(f.dl
n
(dl
(dl
(dl
Idl
(dl
(dl
(d)
(dl
(dl
(dl
(dl
(0
M
(0
M
(U
M
• M
(0
(dl
(dl
(dl
(d
8
(d)
(dl
(dl
(dl
(d)
70kg
18. 190 ana
70 yn
0.83m3/br
4
100%
196 daye/yr
389daye/yr
260daya/yr
14daya/yr
2 an/day
8hn/day
4 an/day
2oten
79%
20 mn.
100%
200Uten
3m3
lOmta.
10 m3
. —
—
—
20%
0.08
0.2 ttten
14 daye/yr
4hn/day
18%
29kg
10.470 ana
0.44 m3/br
79%
100% :
aoStfaya/yr
28daya/yr
24 an/day
lar/day
2 ttten
79%
20 *tto*
100%
200 ttten
3m3
lOoaa.
10 m3
100 mg
28 daye/yr
Ihr/day
20%
0.13
O.OSUten
28dv«/yr
Ihr/day
16%
16kg
6980 ana
0.25m3/hr
75H
100%
369dayi/yr
24 hn/day
2Uten
79%
20mm.
100%
ZOOIlten
3m3
10 mm.
10 m3
...
...
„
._
—
...
...
_
—
-------
7.148-03
I.008«OB
I.47K«03
BRM.
BWI. I860
BUM. 1060
EMM. iaa»
BUM. I MO
BUM. 1080
-------
Table 4
Summary of Toxlcologlcal Information
For the Indicator Chemicals
EDII Site,
Indicator Chemical
Oral RID*
rag/kg/day
Inhalation RID*
nig/kg/day
Oral CPF*»
1 /nig/ kg/day
Inhalation CPF*»
I /ing/kg/day
EPA Carcinogen
Classification
Reference
Copper 3.70E-02 I.OOE 02 MA . NA
Lead withdrawn withdrawn NA NA
I''* ' ' •
Manganese 2.0QE-01 3.00E 04 NA NA
Zinc 2.10E01 l.OOE-02 NA NA
Dkudns NA NA 1.56E+05 1.56E+05
Bls(2-ethyUiexyUphthalale 2.00E-02 NA I.40E-02 NA +
Polychlortnatcd Blphenyb (PCBs) NA NA 7.70E+OO 7.70E+00
; i ; I
TrtclUorclhcne NA NA 1.10E-02 1.30E-02
•Noncarclnogenlc effects
••Carcinogenic effecta
*No Inhalation pathway; therefore, use of Oral CPF for Initiation CPF Is not needed.
RID - Reference Dose !
CPF - Carcinogenic Potency Factor
NA-Not Available
IRIS - EPA's On-Uiic Integrated Risk Information System accessed 7/89.
SPHEM • Superfund Public Health Evaluation Manual 10/86.
D
B2
D
D
B2
D2
D2
B2
SPHEM
IRIS
SPHEM
SPHEM
SPHEM
IRIS
IRIS
IRIS
-------
TABS 3
M ro* CALCCLKHOCI or
ANDDRAIB
AwTlVlll CUAnWh*4AMMIA*^^ |vAAUAB9V|
Amount of Flab Cooauaad Daily
Amount of Sod tafetted Incidentally
Amount of Fluff InfaMad laddenully
Frequency of Sett/Fluff Contact
•On-»ue maintenance worker*
•Caaual iztspaaacra
Oundoa of Soil/Fluff Contact
-f*m,nl u^eapaaacm
Peicauace of Slda Am Contacted by Sotl/ Fluff
. Skin Abaorpoon Rate of Compound*
In Soil/Fluff
XATTXIAL OUlUCTBaSIIOB
Oust Adherence. SaU
Dust Adherence. Fluff
Soil Maau COect
Maaa Flu* Rate (water-baaed)
aiocoNcztmunoN FACTO**
• Lead
Manaanaa*
Copper :
Zinc
CHXaOCAL 0VCXFIC AMOWIUM VACTOM
Otoxin (in fluff and aoth injunnn ontyj
PCBa (in ndirmnt. Ouff. ant aoik tnfaMieo only)
Lead (In •eotntht and Mil: infauua onty^
10
(0
(0
Id)
(d)
Id)
(«
ttOL/kf
47Uk«
OJ •"
OJ "•
OJ
0.2T ImoK prebabk tntakd
A ^ l*Tn*ifiFifn tmihui*
a • Andenm. K,. Browne. W- Oulelaky. 8.. wam,T..
Exposure Aaanummii'. PB SS-a42g4y/AS. US EPA, Ortee of Health
contansnated bouaehotd watar.* pasarpraaaBtadatihatyiBpoatuaof tha
c • J.K. HawJey. •Aaaaaacoaat of
d-ERM ~~ '
e - Lepow. MX- BrudBMO. U'ClUeaau M. Markowta. S. Robmaw H. Kaptah.J.
Envtretunem of Urban ChfldnoT. EavMeBBenial naaearch 10:415^3*. 1979.
Standart Faeton Uwd in
ta'Cnniia «miar rioaian. ISHovt
. Wak AnaJfai Voki Mo. 4. IMS
ISHovtober 1986.
Lepow. Mi..
Lead in HarUort ChUdncT. ti
f-SuperfundPubttc Health
• Superlund Ecpoiun
KtmbreughR.FafliH,
eontairttnaOon of
ft:!
S* CUktu.il. Kaptth. J.. TWa of Atttotm Lead in
" 101. l«74
eT Lead In the
Body Burden at
19»4. "Healthtopocaflonaof X3.7.S-UUaUOuiuaibmau p^toadnfTCPDI
aoUT. Journal of Ttedcotoey and Envtrurunental Hatfth 14:47-93.
IwlthKOOi
t-Upaky.O. 1989. Health Haaarda Aaenrtaiert with PCOO and PCDFI
Hazarda.O.J. Paaiaianbach. cdV. New Yorto John WUey and Sena. pp. 631
J • Beck. BJ}. S. Hate BJ. Murphy. 19M. Evahtadoa of Sett tnfnaon Ratea. Caabrtdaa. MA: CradtentCorp,
k• U.S. EPA.-Health 'i"r-Timnunimani farManaamaaf. EPA600/»-«*Ol3F. 19M.
l-Human Health Cmhuaan Manual. July 19M.
t of Envtroamnul
•0.31 mg/cn3 vma-uaed to ealcuUta dermal contact tn aoO. becauaa the aod at the COM Mat tatht anna ftmnl
soil type aa in the Ltpow. ct al naaareh atudy (ntfemct d. I** duat adhtrenca value wma dcnvtd froa lha reeovwy rmtea «nd
uca of the stoh dual collector ueed la U» atudy.
"1 .45 ma/cia2 waa uaed to ealcuUta dennal contact tn the Buff due to lack at OBI* apecUte rerutta (or duat adhetwce
used far ealcuUaaa of ocpaeun
POOR QUALITY
ORIGINAL
-------
18
estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The tent "upper bound" reflects the
conservative estimate of the risks calculated from the CPS. Use of
this approach makes underestimation of the actual cancer risk
highly unlikely. Cancer potency slopes are derived from the
results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty
factors have been applied.
•
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to chemicals
exhibiting noncarcinogenic effects. RfDs, which are expressed in
units of mg/kg-day, are estimates of lifetime daily exposure levels
for humans, including sensitive individuals that are likely to be
without an appreciable risk of adverse health effects. Estimated
intakes of chemicals from environmental media (e.g., the amount of
a chemical ingested from contaminated drinking water) can be
compared to the RfD. RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors have been
applied (e.g., to account for the use of animal data to predict
effects on humans). These uncertainty factors help ensure that the
RfDs will not underestimate the potential for adverse
noncarcinogenic effects to occur.
C. Risk CharaeteriKatipp Summary -
The National Contingency Plan (NCP) directs hazardous substance
response and establishes acceptable levels of carcinogenic risk for
Superfund sites at between 1 in 10,000 and 1 in 1,000,000
additional cancer cases if no cleanup actions are taken at a site.
Expressed using scientific notation, this translates to an
acceptable risk rang* of between 1 x 10"* and 1 x 10'*. This means
that one additional person per ten thousand or one additional
person in one million, respectively, could develop cancer given a
lifetime (70 years) of exposure to contaminants at a site.
In addition to carcinogenic risks, the baseline RA calculates risks
to humans of contracting other, non-carcinogenic health effects
from substances associated with a site. The calculation is made by
dividing the "worst case" human exposure estimates associated with
a site by exposure levels that are determined by EPA to be
acceptable* The ratios are added to represent exposures to
multiple contaminant*. Any result of this calculation (known as
the Hazard Index) which is greater than 1.0 is considered to
present an unacceptable risk.
When reviewing the quantitative information presented in the tables
in this section, values greater than 1 x 10"* to 1 x 10"* for
carcinogenic risk, and chronic hazard index values greater than 1.0
for noncarcinogenic risk, indicate the potential for adverse health
impacts*
-------
TaOM 5 SDM Sit*
Indieatar
Compound
Transport P
CTirmiral spfnattnn
Compiriitlon
OnrHtvm
Polychlortnated Blphenyta (PCBc)
BUMO
ipOon
i (<4 eblortoe per molecule)
Sorpdon
PhnrnrhrmJol tranatomat
TrtchJotDetbenc fTCEJ
Ondittnn
Copper
Sorptioa
Sorptkm
Sorptioa
\
-------
pea*
•.66*40
•.•7*13
3.77*47
•••7*13
1.13*47
i .cocoa
•96*06
KB*
7.63B4*
7.02* l>
741*47
total
1.61*4*
1.40*13
3.18*48 NA
702* 13 NA
• •4*47 1.00*03
74IK06
1.13146
I. II
NA
MA
• MCO&
4.34*47 NA
1.40* 13 NA
1.78*47 1.00*48
NA
1.76*46
4.WC47
423*41 200*41
§.16*44 1.06*43 NA
I.7IK44 •.66*04 370*43
0.12144 3.62*43 3.10*41
I.70C-04 •.43*44 3.00*41
4.47K4I
NA
4.49C43
4^4*43
&43I-07
IJOTM
4.IOK-40
S
I.7IK-4M
3.70143
XIOR4I
NA
I.S6K43 NA
c§
NA NU A|i|iUt:jUc
SctwylhlNR
•ntrWicnMa
S.47K4C
BCIB4*
•.04K47
1.01*46
1.38*47
1.34*4*
300*41
3.70*43
9.10*41
1.06* 44 3.0SK44 3.00*41
I.TKOt 4.I6COS 3.70*03
163*46 404C4& 210*41
T«tel IMMVA. IM* •»»•••«•
NA
&c
•.MEM
4.67*41
1.731-06
167*08
3A6E08
6.23C-04
4.74C-OS
•.66* OS
417M44
NA
6.65*47
•.MC-47
a.ne«oo
NA
3.3IC-O3
1.72*03
4.22*-m
NA
4.63*46
3.44*06
NA
NA
NA
605*06
373*08
8.36*08
1.62*03
1.13*44
I.O3C44
1.1
-------
19
1. Moneareinoqenie Risk " ~
The Hazard Index (HZ) Method im used for assessing the overall
potential for noncarcinogenic effects posed by the indicator
compounds. Potential concern for noncarcinogenic effects of a
single contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the HZ can be generated. The
HZ provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a single
medium or across media.
Tables 6-8 present the calculated hazard indices for each age group
evaluated. These tables calculate the hazard indices associated
with each of the exposure points, exposed populations, and routes
of exposure identified previously. Most probable and maximum
hazard indices have been calculated, using the most probable and
maximum intakes calculated previously. Most probable intakes are
calculated using average exposure point concentrations of the
indicator chemical; maximum intakes are calculated using maxim™
exposure point concentrations. All other exposure parameters are
identical in the calculation of the types of-intake*.
Exposures to multiple sources of contamination through several
routes of exposure may occur. Therefore, the sum of all hazard
indices for each single age group and exposed population is given.
Hazard indices were calculated separately for the three age groups.
Both most probable and maximum lifetime hazard indices were
calculated and are presented in Table 9.
Manganese in the ground water is the compound responsible for
driving the hypothetical downgradient well exposure point over the
hazard index of one. Onsite worker exposure to copper in surface
soils also exceeds*the hazard index of one.
Since the- RfD for lead has been withdrawn, the hazard or risk
associated with lead could not be estimated by standard risk
assessment methods. For this reason, alternate methods were chosen
and lead was not included on the tables showing the noncarcinogenic
hazard estimates for the Site. An action level of 15 ppb for lead
was used to screen Site data for ground and surface water for
evidence of potential hazard due to lead. The action level was
used directly as a guideline to assess ground water as a
hypothetical source of drinking water while it was adjusted for
intake volume for the surface water incidental ingestion scenario.
Since the standard drinking water scenario assumes two liters of
water is . ingested daily but the incidental ingestion scenario
assumes only O.O5 liters per hour of exposure, the action level was
adjusted by the relative volume associated with each specific
-------
On-«Me
rca*
I.OU40 9J0E-OS
|jOOC-l9 I.OOBI9
I.UB-4M I.9&B-M
NA
I HEM
1.1II
I3SC-M
Of-tftt
KBi
I.OIB-O7
• 908 19
HA
NA
NA
• 7MC-06
4IU44
a.OOB-01
4.798-09 NA
9.0SB-O9 3708-03
9.108-01
1.SIB-O4 1.108-09 9.00E-OI
I.4SB4M S.4MC-0* NA
4JOB47 9.40B4M 3.70E O9
9.6CB4M I.OIBOB 9. IDE 01
owr
Inddcnlal b^cttoa
-a
O
OO
-^ 73
QD
"Z '—
9J2K-06 I.SSK-04 2.00C-OI
IJSE-07 9.MC47 NA
9.7K46 I.04K4M 9.70(09
V.44B4M I.4IBM »IOC 01
I4MC46 9.SIBW 9.00C4B
XOIB44 C.ISB04 XOOC-OI
1MB 07 f.iaB-07 NA
I.47B-04 B.46B04 9.70B 03
9.MB46 7.MB45 9. IOC 01
5MB OS I.MB-04 9.00B O9
fctttrl iTJIm'. Ikte ••>•••>• jihti
l.oactoo
NA
I.I9B-09
I06B-09
I.9SB-09
NA
I.90E-OS
I.99B-OS
1.1
I.9IE-04
NA
•.A4E-06
•.I
B.I9B*4»
NA
6.69E-O9
6.8IE-09
NA
• 49COS
NA
On-iUe
9.00C-OI
IMcfabmthcn*
Zinc
I.9U-06 9.6SB 05
1.MB-OB I.99B-OB
9.K7E-08 •.06K08 NA
9MB01 I.9IBOS 3.70B09
•.MB-M I.MC-OK 9.IOCOI
9 WE 07 9BOe07 90OCO9
I few*. iMckato. (U* «Bf««wa petal)
9.MB-OS
&.9MC-04
I.OOC-09
NA
9.06C-09'
I.ME-04
9.77E-09
•.4«B-M
•.4IC06
NA
NA
0O6COS
4.07EOS
I.44EOS
9.IMMM
7.77B-04
NA
9.aiB-09
• 71C OS
I.74B-M
4MB 09
NA
1.478 09
9S9E04
091809
I.9SB-04
NA
NA
3S6C04
I.44COS
*.7«K04
NA - Not
-------
Cafe
TJ
O
CO
yg 7O Hole: IOO a^c-oa
7.4M4M
I.MC4M
I.MKIO
S.4SCM
4.MB4M NA
S.Mt-04 i. IOC 01
&74E-0*
•.•IK 06
SMC 04
i.ioc-oa
7.I7C-O9
IJ
•.i«c-oa
I.OTC-09
•.ISC-Ot
&.96COI
I.IOC 03
S.44I4*
10
MOB 01
I.IK-04
4.47B4M
T.aac-04 Lioc-oi
o^ac-oa
a.T4C-09
NA
NA
I.70C«00
i!oicoi
»g»«illlH'"•"*•>
I.40K-01
».l4C-«t
taw m> iMMl to the lou
-------
T.M. 8
•*•
ByrMhMto
•.tficia
8U
I4MB-U
I.OOB-04
1.1
I.MB-04
I40K«00 a.OOK-01
•.OOC-03 NA
i.ioi-01
icns-oa
I.MIB-U
i.aaeoi
T.GCKCQ
I.T4C-M
.BOK4M
NA
NA
I.I3C-OI
untai
I.MK-OI
ItlK^U
l.ftlB-M
7.0MOO
NA
T.7WOK
&7M06
•.44B*0»
6.6SCOI
4.MB-OI
1.1
•o
08
-------
•fa 7 |CMltlMM4|
a.llB-4M
I.7IB-09
IJM-O4
a.l«C-O4
IMI-4M
a.ooc-oi
aflOB-07
I.I7B-04
I47B4M
S.4IB-04 aOOEOI
4.C7B-M S.70BM
4.B3B-W HOBO!
7.I7I-4N
I.TU-OI
a.ft7BO»
S.44C-M
6.MC04
•.SIB-Oft
•.73B-46
T.4
I.O7B-OI
I ME 01
I.7IE03
I ME 04
I.MB4M
a.l3E-OI
4.60E-03
i.asE-oa
7.IIB4M
•JOB-M
S.4IB-M
&IOB-OI
I^TB-Oa NA
4.MB-4W HA
i.UB-04 a.lOB-01
NA
NA
I.I7KO3
1.4SB03
HA
NA
a.ME-oa
On-tM
1.7
I.7W-M •
IJI7BM
I.7IC-M
•47B4*
4.BIB-06
a.S4B-M
•MB-09
17K-0* aiOBOl
IA4B-04 a.OOB08
a.aiB-04
•.SW-O5
I.UC-OS
•.40B06
I JOB 10
I.47B03
4.C3B4H
I.TOE 00 HA
a«SE09 3.70C09
a.ooB-04 a.ioB-oi
a i IB 04
a.asc-04
NA
HA
3 sacra
a.aoc-04
00IE03
a.lOE-04
I.37E-OI
a.74B04
7.72E 09
I.IOEOa
7.I7E-OI
I.44EOJ
4.0SB49
T«tol >•••>*. •• **f*
|.3IK«00
•.MK*00
Kulc: 100 n
itf lnfiLblkHi ol l»u U c Mill OIM! H.UI kw iiiiuliiHiin U|IIMIWC; MI* UK wu»M u( UK l«w> «»» «"««l to ll»e lulul in.i«limuii Iwwid Ciikul^lKm.
-------
20
exposure scenario for incidental ingestion of surfaca water.
For soil and fluff, tha potential for hazard dua to laad was
assessed by comparing datactad concentration* to the interim
guidelines for soil lead cleanup levels established by EPA (OSWER
Directive I9355.4-O2). The range given in the referenced guidance
is 5OO to 1,000 ppm total lead for soil in residential areas. Lead
levels within the fluff greatly exceed the upper-bound level of
1,000 ppm and therefore present a potential hazard.
2. Carcinogenic Risk
For potential carcinogens, risks are estimated as probabilities.
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency slope and expressing the
result in scientific notation. An excess lifetime cancer risk of
1 x 10"* indicates that, as a plausible upper bound, an individual
has a one in one million chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime under
the specific exposure conditions at a site.
Tables.1O-12 present the calculated potential carcinogenic risks
for each age group of the potentially exposed populations. Both
most probable and maximum carcinogenic risks (using most probable
and maximum intakes) have been calculated for each carcinogen found
at the identified points of exposure.
The indicators responsible for the potential risk levels associated
with the fluff and the onsite soil are PCBs and dioxin. PCBs may
be bound within the fluff materials, and therefore, their
bioavailability may be limited. The assumptions in the intake
calculations, however, assume a bioavailability equal to that found
with similar compounds in soil.
The indicator responsible for the risk associated with the
hypothetical scenario for residential use of ground water is
trichloroethylene, which may be ingested and also- volatilized
during bathing* and-subsequently inhaled.
Total maximum; and most probable case risks associated with actual
and hypothetically applicable exposure points were calculated.
These total worst case and most probable case risks are shown in
Tables 1O-12. Lifetime estimates of risk are presented in Table
13. These have been calculated for offsite residents, following
the same procedure used to calculate lifetime hazard indices.
3. Environmental Risk
The major ecosystem of the EON site and surrounding ridges is the
eastern deciduous forest. The wetland community is limited to the
small flood plain of the intermittent stream and the LSR and
several small emergent wetlands. All of these wetland areas.
-------
EOM Site Eadaafi
itA<
rat
Theoretical Iffoncarcinogeaio Baaard Indies*
Most Probable
Adolta. off-site
Children, age
Children, age 3*4)
«««»™i ' ~~—m~
Hacard
bides
5.14E-01
1.31E*00
Haaaid
Index
2.31E+00
6.55C*00
Ifotet -
TTie ocposure ptthwty* taduded In UMM edeukdom at* Bated bdov.
AD ages: off-site ftigtttv* du»t (predicted by air node0
fbh tngwdon (tbcantlcal bkMceuinulatlan)
UMaT hypothetical
Adults: additional off-sttB ftigtttve duat exposure aa bunten and ft
Adulta,
Children S-12: off-site reereadonal expoaurt to ttrtr
Children 6-12: off-site recreational opoaura to Intenntttent straam water and sediment
nn altn mrrannmil fflr]nTTiint tir nirfiirt ttrtl fluff inrl Inarhaf* (firnrar
It should b> noted that soma of then pathways am hypothetical and do not nepreaent actual
ocposurea urolff cmrcpt cnnnlltflfHi
-------
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t; Mily Ihc wonl of ItM two •>•• uncd In Mw lalnl mailimiai (tab cakubllon.
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-------
TsU* 13
EDM Site Eadaafen
Calculation of Theoretical TeUi Lifetime Carcinogenic Risk
Contribution to
If ost Probable
Lifetime Risk
Adult*. off-site resident*
Children, ago 6>12
Children, if •
iarncAL TOTAL MOST PKOBABIX
5.16E-OS
8.01EV05
S.64E-OS
1.37kV04
Centrlbatlon to
jfAjdmiun
Llfetto* Rl«k
2.05E-04
7.17E-04
2.22E-05
1CAL TOTAL UAZDIUM
9.44E-04
IfoUl
The hypothettcml aqpocure «Mumpdon> Included la thcM ««I««I«H««I« are listed below.
AD ageK off-Ute ftiguttw di»t at retidence (predicted by •* modeO
nvidenUai UM of hypothetical downgrmdknt veil wmtet
Adults: addittoiMi off-«ite Aiglttw dust expomov •• hunten and fishermen
Children 6-12i olT-atte reemd
on*ait*
idonal exposure to surface sod. flufL sad tnarhatf (fence-
Total cardnogenle rtak,
on-slte maintenance work
(30 yn. exposure)
Total carcinogenic rtsk,
off-site workers
(30 yn. exposure)
total carcinogenic risk.
hunten and flali
Most Probable
Rlak
1.4E-03
l.SE-07
8.2E-09
Lifetime Rlalc
1.6E-02
1.6E-06
9.6E-08
(58 ytm. exposure)
-------
Ml. 12
•o
08
?3 73
So
ZG
-------
21
except on* small emergent wetland, are located off site. No rare or
endangered species have been reported or observed on or near the
Site. Although an intensive ecological risk assessment was not
conducted, some indication of potential risk to wildlife and the
environment can be assessed from the toxicity testing (bioassays) ,
field assessment, and human health risk analysis and Site
conditions .
The lack of suitable habitat on or near the Site and the Site fence
discourages wildlife utilization of the Site. Large mammals are
prevented from easily entering by the Site fence, small animals,
birds, and soil invertebrates are limited by lack of habitat.
The intermittent stream currently supports little aquatic life,
most likely due to elevated contaminant levels. Direct discharge
of contaminated overburden ground water and contaminated seeps into
the intermittent stream have resulted ih contaminated sediments and
surface water in the stream. Federal and state surface water
standards are exceeded for copper, lead, zinc, manganese, and iron
in this stream. The results of the intermittent stream bioassays
indicate possible Site-related toxicity to aquatic life in the
intermittent stream due to metals.
The Little Schuylkill River does not support resident aquatic life
for approximately 5 miles downstream due to its acid mine degraded
condition. Transport of sediment does not seem to have a
significant effect on metals concentrations because sediment
samples collected from the Little Schuylkill River both upstream
and downstream of the tributary' did not significantly differ for
metals.
D. fliflni ificaflt Sources o£ Uncertainty
Discussion of general limitations inherent in the risk assessment
process as well as the uncertainty related to some of the major
assumptions made in this assessment are included below.
1. The Risk Assessment is based upon the data collected during the
RI and use* RI sampling . results and predictive^ modeling to
represent environmental concentrations over large areas. This
extrapolation contributes to, the uncertainty of the Risk
Assessment:. Also, air and emissions modeling is used rather than
actual sampling to predict the exposure concentrations due to
fugitive dust emissions from the Site.
2. The potential human exposure to ground water is probably not
very substantial. No existing ground water users are present in
areas hydraulically downgradient of the Site. Also, no downstream
use of the Little Schuylkill River water (which is the discharge
point for, ground water from the Site) for residential water
supplies, has been identified in the vicinity of the Site at this
time. However, aquatic life is exposed to contaminated ground
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22
water via direct discharge and seepage to the intermittent stream.
3. The onsite exposures for children ages 6-12 are based on the
assumptions that the fence around the Site is not in place and that
no remediation has occurred.
4. Lead, phthalates, and PCBs nay be chemically bound in the
plastic matrix of the fluff and, therefore, fluff (and soil) may
not be as bioavailable as assumed in the risk assessment.
5. Due to the limitations of the risk assessment process itself
and to conservative assumptions made specific to the EDM site, the
risk levels calculated are considered to be estimates of worst-case
risk.
6. The CPSs and reference doses contain uncertainties resulting
from extrapolating from high to low doses and from animals to
humans. Protective assumptions were made to cover these
uncertainties.
I. Risk ^§§e,syMent Conclusions
1. Exposure of adult onsite maintenance workers to copper in the
surface soil and exposure to a hypothetical downgradient well (on
the Site or state game lands) for all age groups were significant
(hazard index greater than one) noncarcinogenic hazards for
individual pathways and populations at the Site. Actual exposures
for children age 2-6 also presented a significant noncarcinogenic
risk.
2. Exposure to the fluff and onsite surface soil by onsite
maintenance workers, and (for fluff only) children age 6-12
trespassing on the EDM site presented significant carcinogenic
risks greater than 1 x 10'*. The potential risks associated with
these exposures are related to PCBs and dioxin in fluff material
and Site soils.
3. Residential use of ground"' water from a hypothetical well
located downgradient of the Site exceeded 1 x 10*4 for maximum
estimates of carcinogenic risk. The risk is driven by the presence
of trichloroethylene in ground water.
4. The estimated "most probable" lifetime carcinogenic risk for
off site residents is above the potentially acceptable range. Under
the "maximum* lifetime carcinogenic risk scenario, the risk to
offsite residents also exceeds 1 x 10~*.
5. The intermittent stream currently supports little aquatic life,
most likely due to elevated contaminant levels. Direct discharge
of contaminated overburden ground water and contaminated seeps into
the intermittent stream have resulted in contaminated sediments and
surface water in the stream. The results of the intermittent
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23
stream bioassays indicate possible Site-related toxicity to aquatic
life in the intermittent stream due to metals. Federal and state
surface water standards are exceeded for copper, lead, zinc,
manganese, and iron. Due to acid mine degradation in the Little
Schuylkill River, it is extremely difficult to measure Site impacts
on that river.
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.
VIII. D88CBIPYXOV OF AX.TBBMATXVBft'
In accordance with Section 300.430 of the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 4O C.F.R. S
3OO.43O, a list of remedial response actions and representative
technologies were identified and screened to meet the remedial
action objectives at the Site. The technologies that passed the
screening were assembled to font remedial alternatives. The
Feasibility Study (FS) evaluated a variety of technologies used in
the development of alternatives for addressing the fluff. Upon
further analysis, the technologies and approaches contained in the
following alternatives were determined to be the most applicable
for OU3 of this Site.
Bfif flit* Action Alternative 1 - MO ACTXOM
The NCP requires that EPA consider a "No Action* alternative for
every site to establish a baseline for comparison to alternatives
that do require action. Under this alternative, no action would be
taken to remove, remediate, contain, or- otherwise address
contamination at the BOM Site.
Because this alternative would neither eliminate nor reduce to
acceptable levels the threats to human health or the environment
presented by contamination at OU3, this alternative serves only as
a baseline for comparison to other alternatives.
Capital Cost: $ O
Annual Q&M. Present Worth? S Q
TOTAL COST $ O
R+sedial Action Alternative 2 — OM1TB KBCYCUM0 OF FLUFF?
DISPOSAL OF MOM-RBCYCLABLfta AMD RBCTCLXK BJUXDUALIf SOIL SAMFLXHa
A. Description
Under this alternative, all recyclable fluff (waste, insulation
material consisting primarily of polyvinyl chloride and
polyethylene chips; fibrous material; and paper, soil, and metal on
the surface of the Site other than that to be remediated pursuant
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24
to the March 1991 ROD) would be recycled to prevent further release
of hazardous substances into the environment from this material.
All non-recyclable materials within the fluff and recycling
residuals (wastes resulting fro* the recycling process) would be
tested for RCRA hazardous characteristics. Hazardous materials and
residuals would be treated and disposed of in an offsite landfill.
Non-hazardous materials and residuals would be disposed of in an
offsite landfill as well. Soils underlying the fluff would be
sampled and analyzed to determine 'the nature and extent of soil
contamination, if any. Erosion and sedimentation controls would be
developed and implemented to control drainage and minimize erosion
of exposed soils at the Site.
Among the most common recycling techniques for material like the
fluff at the Site are Bulk Processing and Separation Processing.
These techniques are described below:_
1. Bulk Processing
Bulk Processing would convert the fluff as is with minimal cleaning
or separation into products with a solid plastic mass. This
process would involve the application of heat, pressure, and
optional chemical additives to fuse the fluff together.
Implementation would result in virtually complete elimination of
the fluff material with minimal unrecyclabla residual. Because the
fluff consists of a mixture of plastics and other non-plastic
materials such as fiber, paper, soil, and metals, the bulk process
would produce low-grade plastic products.. The fluff could be used
as the sole feed for certain products, or as partial feed with
other plastic to enhance product quality.
In addition to significantly reducing the amount of fluff waste by
recycling, the Bulk Process could recover' full potential value of
the fluff material as a resource* Bulk recycling has been
commercialized successfully in Europe, and limited recycling
currently occurs in/the U.S. Products made using the Bulk Process
include mats, tiles, fenders, cushions, and fillers.
2. Separation Processing
Separation Proceeeing would separate the- polyethylene (PE),
polyvinylchloride (PVC), and other components of the fluff. The
recovered plastics could be sold as a raw material to plastics
manufacturers. Several manufacturers nationwide are currently
recycling wire and cable scrap using Separation Processing and are
selling the plastics pellets for use as a raw material in plastics
products or as an additive to blacktop or concrete, or are
manufacturing products for resale at their facilities.
Beneficial reuse of the plastic and other components of the fluff
through Separation Processing would significantly reduce the volume
of the waste pile. The fluff may contain as much as 60 percent
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25
reusable PB and PVC. The scrap metal (principally copper and
aluminum) component of the fluff would also be recoverable as
would, potentially, the fiber and paper component. Considering
that many of the fluff components are recyclable, the fluff volume
could be reduced from 60 to 95 percent through use of the
Separation Process.
Separation and recovery would involve a series of mechanical
processes for separating the plastics, fiber, paper, dirt, metals,
and rubber which comprise the fluff material. Mechanical
separation has been commercialized by several sources and standard
processing machinery such as grinders, screens, sieves, air and
water separators and clarifiers would be used. Dirt, fibers,
metals, and rubber can be removed by processing the fluff over
water-washed screens. The PVC and PE fractions could then be
separated by density difference in a_ water clarifier. Metals
could be separated from the PVC component of the plastic by
electrostatic separation. The separated materials would then
require drying; and possibly grinding and pelletizing for shipping.
The recycling process, including either the Separation or Bulk
Processing techniques, is similar to stabilization in that
contaminants are encapsulated and thereby bound in the. plastic
matrix. After recycling, the contaminants would be encapsulated in
the plastic matrix, thereby becoming immobilized. The surface area
of the recycled product will be significantly less than that of the
fluff material which also aids in immobilizing the contaminants.
Existing plastics specifications regarding product uses are very
stringent. Food and Drug Administration (FDA) regulations
regarding food additives would preclude the use of recycled fluff
in food packaging. Other stringent requirements of organizations
such as the Consumer Products Safety Commission would discourage or
prohibit use of the recycled materials in products with the
potential for significant human contact and in many structural
applications. However, there are numerous other potential uses for
the recycled products,- -
B. Hon— RecyclE**!*- Materials • Recycling Residuals* and
Hoi. la Maaaqemeftte^ i - ...... •• ••••-•± • -....•r...(»c . ~. •_-.::••.,;•
All non-recyclable; materials (determined through Pilot studies
during Remedial Design) and recycling residuals (wastes resulting
from the recycling process) which may include soil, paper, fiber,
and debris, would be disposed in an off site landfill. After
reduction of the total volume of waste by recycling, the estimated
maximum volume of residual waste remaining would be approximately
100,000 cubic yards or 45 percent of the total potentially
recyclable fluff volume. The residual waste volume could be
significantly less if the Bulk Process or the Separation Process
with multi-component separation and recovery is used.
Non-recyclable materials and recycling residuals would be tested
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26
for hazardous characteristics. Hazardous materials would be
treated before being disposed in an offsite municipal or hazardous
waste landfill; treatment methods would be determined following
treatability testing. If a stabilization technology were used to
treat the residuals, the volume would increase, but the waste would
become non-hazardous. Other potential treatment technologies, such
as washing of the residuals, would not result in a volume increase.
Soils underlying the fluff would be sampled and analyzed to
determine the nature and extent of soils contamination, if any.
Erosion and sedimentation .controls would be developed and
implemented to control drainage and minimize erosion of exposed
soils at the Sits. EPA would determine whether, and to what
extent, further response actions (not within the scops of this
•Operable Unit) are necessary to address soil contamination
following analyses of the soils samples performed as part of this
response action.
Pilot studies conducted during Remedial Design would determine the
types and percentage of fluff materials which could bs reused, the
most feasible recycling method, optimal number of machines and the
recycling rats, and whether recycling residuals will require
treatment. Fluff recycling would take approximately 5-10 years for
completion depending upon the number of separation and/or recycling
machines placed onsite. Fluff recycling, whether conducted using
the Bulk or Separation Process, would require, among other things,
the following steps:
• Development of * fluff recycling implementation plan, including
process descriptions, an operation plan, a health and safety
plan, a production schedule, and contractual agreements with
recycling- contractors.
• Construction of recycling facility warehousing and purchase and
transport of recycling machinery to the site.
• Selective removal*of fluff from the. fluff pile in portions
equivalent to the desired recycling feed rate while taxing
precautions to prevent erosion;
• Recycling fluff material creating raw materials and/or plastics
products**
Although the small onsite emergent wetland would not be in the
direct path of excavation activities, care would need to be taken
when conducting any construction and excavation activities near
this area, and possible impacts would need to be minimized and
mitigated in accordance with EPA policy.
D. SjflBJUEX
Onsite recycling of fluff materials and offsits disposal of non-
recyclable materials and recycling residuals would reduce the risks
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27
to human health and the environment presented by OU3 by preventing
direct contact with fluff materials and preventing further release
of hazardous substances from fluff materials into soils, sediments,
surface water, and ground water at the Site. Recycling the fluff
material would prevent future exposure and reduce mobility by
encapsulating the contaminants in a plastic matrix (the recycled
product) . Volume would be reduced by approximately 40-60 percent
and, ultimately, part or all of the fluff material could be removed
from the Site. Treating, if necessary, and disposing of residuals
through offsite landfilling would prevent exposure via dermal
contact, inhalation, and ingestion.
B. IHUkBf Iff**
Major ARARs under this alternative include:
1. fflnfaififtl-Specifie ARARs
(a) 25 PA Code Chapter 261 and 40 C.F.R. § 261.24 for
identification of characteristic hazardous wastes ;
(b) the National Ambient Air Quality Standard* (NAAQS) set
forth at 4O C.F.R. Part 5O;
(c) the Pennsylvania Air Pollution Control Act, 25 PA Code
Chapters 123 and 127;
2. Action-Specific ARAB*
(d) 25 PA Code Chapter 1O2, which pertain* to erosion control
requirements related to excavation activities*
(e) RCRA and Department of Transportation regulations governing
the generation and transportation of hazardous wastes, 25 PA Code
Chapters 262 and 263; 49 C.F.R. Parts- 107, 171-179;
(f) 25 PA Code Chapter 264- and 40 C.F.R. Part 268 regarding the
storage, disposal, and treatment of hazardous wastes;
(g) 40 C.F.R. Part 266, SubPart C relating to recyclable
materials used -in * manner constituting -disposal* -- - -
(h) National Pollution Discharge* Elimination System require-
ments, 40 C.F.R. Part. 122 regarding wastewatere;
(i) OSHA. standard* for worker's protection, 29 C.F.R. Parts
19O4, 1910Y and 1926f
3. Location-Specific ARARs
(j) The Clean Water Act, 33 U.S.C. li 1251 e£ ABO*.; 40 C.F.R.
Part 403 relating to the discharge of wastewaters to a publicly-
owned treatment works;
4. To Be Considered
(k) Executive Order 11988, 4O C.F.R. S 6, Appendix A,
concerning federal wetland* policies;
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28
(1) PA Proposed Residual Waste Regulations to be codified at 25
PA Code Parts 287-299 (requirements will be considered during
remedial design);
(m) Draft Interim Guidance on Establishing Soil Lead Cleanup
Levels at Superfund Sites (OSWER Directive No. 9355.4-02 (June 13,
1989)).
Capital $ 6,200,000 to $15,000,000
O & M $ 6,900,000 to $ 6,900,000
Total Present Worth$13,100,000 to $21,900,000
Costa and timeframes will vary depending on which recycling
technology is implemented, the number of machines onsite,
contractual agreements between owners and recyclers, the volume of
non-recyclables and recycling residuals, and whether the residuals
are hazardous and need treatment.
Alternative a -
A. Description .
Under this alternative, the fluff (wast* insulation material
consisting primarily of polyvinyl chloride and polyethylene chips;
fibrous material; and paper, soil, and metal on the surface of the
Site other than that to be remediated pursuant to the March 1991
ROD) would be capped to prevent direct contact, reduce leachate
production by minimizing precipitation that infiltrates and
percolates through th* fluff pile, and prevent transport of fluff
via wind and/or surface runoff erosion. Capping of the fluff pile
would contain,the),-.approximately 220,000 cubic yards of fluff
material which will remain onsite after treatment and removal of
the principal, threat, hotspot- areas, and. miscellaneous debris
(Operable Unit 1). The fluff pile would be confined beneath a
multi-layer engineered cover system (cap) similar to those used to
close hazardous waste landfills.
The essential components of the capping remedy are as follows:
• Consolidate fluff onto main pile;
• Regrade the main pile for placement of a final cover;
• Cap the fluff pile with a multi-layer cap meeting RCRA and FADER
requirements;
• Conduct, long-term maintenance and monitoring.
Regrading of the fluff pile would be required to achieve stable
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29
pile slopes prior to installation of the cap. Based on direct
shear test results for the fluff, regraded maximum slope ratios of
3 horizontal to 1 vertical are expected to be stable. This would
increase- the footprint area of the pile from its current 7 acres to
10 acres.
A multi-layer cap would be placed over the regraded pile. The cap
would be based on RCRA cap guidance and PADER landfill closure
requirements. A typical RCRA cap consists of the following
components:
Vegetated surface
2 feet cover soil
1 foot sand drainage layer
20-mil or thicker flexible membrane
2 feet of clay bedding soil .
A vegetated surface would be used for erosion control of the cover
topsoil. A drainage layer of sand and/or synthetic materials and
low permeability layers such as a combined synthetic membrane and
soil liner system would be used. A synthetic geotextile would be
incorporated into the cap between the fluff and bedding soil to
lend structural integrity in areas where differential settlement of
the underlying material may be a problem. An internal leachate
drain would be constructed to facilitate the removal of residual
leachate from the pile. The leachate would discharge to the
upgraded equalization lagoon. Surface runoff control features
would also be constructed. Deed restrictions would be imposed on
the Site to protect the integrity of the cap.
The cap would be designed to meet RCRA cap performance standards to
the extent practicable under Site conditions, but the configuration
may deviate from the typical RCRA cap due to site- and waste-
specific conditions. Some conditions which will have to be
accounted for include 1) the granular and resilient nature of the
fluff material which may make-it difficult to compact clay to
achieve 10*7 cm/see permeability 2) the steep pile slopes which may
make it difficult 'to obtain an acceptable friction angle between
the flexible- membrane liner and sand- drainage^ layer 3) the
addition of a geonet to expedite drainage from the surface of the
liner. The actual cap configuration would be determined during the
final design phase.
Although the small onsite emergent wetland would not be in the
direct path of excavation activities, care would need to be taken
when conducting any construction and excavation activities near
this area, and possible impacts would need to be minimized and
mitigated in accordance with EPA policy.
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30
C.
Multi-layer capping is a reliable technology for isolating wastes
from the above-ground environment and significantly mitigates the
effects of contaminants on human health and the environment. Soil
and synthetic materials for capping are readily available and
equipment used for implementation is primarily standard road
construction equipment. Although, capping significantly reduces
contaminant mobility, it does not reduce the toxicity or volume of
the waste and requires long-term maintenance and monitoring for
continued effectiveness.
D. ARARs ip.4 TBC*
Major ARARs under this alternative includes
1. eh^frtffffl-Speeifie ARARs
(a) 25 PA Code Chapter 261 and 40 C.F.R. f 261.24 for
identification of characteristic hazardous wastes;
(b> the National Ambient Air Quality Standards (MAAQS) set
forth at 40 C.F.R. Part SO;
(c) the Pennsylvania Air Pollution Control Act, 25 PA Code
Chapters 123 and 127;
2. Action-Specific ABAS*
(d) 25 PA Code Chapter 1O2, which pertains to erosion control
requirements related to excavation activities;
(e) 25 PA Code | 264.310 relating to closure and post-closure
care;
(f) OSHA standards- for worker's protection, 29 C.F.R. Parts
1904, 1910, and 1926;
3. Location— Specific ARARs-- • •-•• ••' —
(g) The Clean Water Act, 33 U.S.C. f§ 1251 fi£ seo. r 40 C.F.R.
Part 403 relating to the discharge of wastewaters to a publicly-
owned treatment works;
4. To Ba Considered
(h) Executive Order 11988, 4O C.F.R. f 6, Appendix A,
concerning federal wetlands policies;
(i) PA Proposed Residual Waste Regulations to be codified at 25
PA Code Parts 287-299 (requirements will be- considered during
remedial design) ;
(j) Draft Interim Guidance on Establishing Soil Lead Cleanup
Levels at Superfund Sites (OSWER Directive No. 9355.4-02 (June 13,
1989)).
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31
Capital $14,000,000
O 4 M $ 1,000,000
Total Present Worth$15,000,000
Costs and implementation times are estimated.
Alternative 4 - XVCXXBRATXOV; SOIL 8AMPLXW
A* Description
This alternative involves the complete, excavation and incineration
of the fluff (waste insulation material consisting primarily of
polyvinyl chloride and polyethylene chips; fibrous material; and
paper, soil, and metal on the surface of the Site other than that
to be remediated pursuant to the March 1991 ROD). Incineration is
an effective, proven technology for remediating organic
contaminants at hazardous waste sites and would completely destroy
the PCS and other organic contaminants in the fluff. The volume of
contaminated media would be reduced by 80 percent. Incinerator ash
and residual*-would be tested for RCRA hazardous characteristics.
Residuals would be treated (if necessary) and disposed of in an
off site landfill. Soils underlying the fluff would be sampled and
analyzed to determine-the nature'and extent of1-soil contamination,
if any. Erosion and sedimentation controls would be developed and
implemented to control drainage and minimze erosion of exposed
soils at the Site.
An onsite mobile or-transportable incinerator would be the most
implementable choicer because of* the availability of these units and
the fact that th** fluff pile would not need to be transported
off site for treatment^ Approximately one year would be required to
retain a mobile" incinerator *-for^the Site. - Offsite incineration
facilities would most likely be unavailable because few facilities
are permitted to accept PCB-contaminated waste. The demand is very
high for these facilities and they can afford to be selective with
regard to the type* of wastes they receive. Most facilities would
not accept the fluff material because of the expense and
inconvenience involved with retrofitting their incinerators to meet
fluff incineration requirements.
The onsite incinerator would have to meet all hazardous waste
(RCRA) and PCB (TSCA) performance standards. Due to the presence
of PCBs, the incinerator would be required to achieve 99.9999%
destruction of all organic hazardous constituents pursuant to 4O
C.F.R. § 264.343(a)(2). During the Remedial Design, pollution
-------
32
control devices would be selected and a test burn and other
treatability studies would be conducted as necessary to optimize
and refine incinerator operating conditions and pollution control
equipment performance. Throughout actual operation, incinerator
feed rates and operating conditions would be continuously monitored
and controlled to ensure compliance with the performance standards.
Continuous monitoring would ensure that emissions were below levels
which would be harmful to human health and the environment.
Incinerator emission estimates would also be evaluated to ensure
that they would not adversely affect attainment of any National
Ambient Air Quality Standards (NAAQS) promulgated under the Clean
Air Act, particularly the NAAQS for lead, 4O C.P.R. Part so,
Appendix G.
Soils underlying the fluff would be sampled and analyzed to
determine the nature and extent of soil contamination, if any.
Erosion and sedimentation controls would be developed and
implemented to control drainage and minimize erosion of exposed
soils at the Site. EPA would determine whether, and to what
extent, further response actions (not within the scope of this
Operable Unit) are - necessary to address soil contamination
following analyses of the soil samples performed as part of this
response action.
Although the small onsite emergent wetland would not be in the
direct path of excavation activities, care would need to be taken
when conducting any construction and excavation activities near
this area, and possible impacts would need to bet minimized and
mitigated in accordance with EPA policy.
Because the plastic fluff primarily consists of oxidizable organic
constituents, the quantity by weight of ash after incineration is
estimated to be approximately 2O percent of the original feed.
The ash and other incinerator residuals would be tested for RCRA
hazardous characteristics. If these media were determined to be
hazardous, they would be treated by stabilization to render them
non-hazardous before being disposed, in an offsite municipal or
hazardous, waste landfill.
Stabilization using a cementitious or pozzolanic reagent mixture is
an effective and proven technology for immobilizing contaminants
such as the metals which would most likely remain in the ash and
residuals after incineration. Stabilization reduces the toxicity
and mobility of contaminants by chemically and/or physically
binding them in the stabilization matrix. The stabilization
process would result in a volume increase, but the residual would
no longer be classified as a hazardous waste. Because onsite
landf illing of residuals would not meet State ARARs and because of
space and hydrogeological limitations with regard to an onsite
landfill, offsite residuals disposal is necessary.
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33
O.
Incineration would eliminate the toxicity and nobility of organic
contaminant* and reduce the total volume of contaminated media.
stabilization of the incinerator residuals, if necessary, would
reduce the toxicity and mobility of inorganic contaminants by
chemically and/or physically binding them in the stabilized matrix.
Volume would increase somewhat after stabilization. Disposal of
the residuals offsite would prevent human and environmental
contact. The fluff feed rate Into the incinerator would be very
low in order to achieve optimal performance of the pollution
control equipment in capturing lead and other inorganic
contaminants. Therefore, incineration of the fluff would take from
nine to eighty-seven years.
Major ARARs under this alternative include:
1. Chemical-Specific ARARs
(a) 25 PA Code Chapter 261 and 40 C.F.R. S 261.24 for
identification of characteristic hazardous wastes;
(b) the National Ambient Air Quality standards (NAAQS) set
forth at 4O C.F.R. Part SOi
(c) the Pennsylvania Air Pollution Control Act, 25 PA Code
Chapters 123 and 127;
2. Action—Specif to XBAR« •--•.-.:
(d) 25 PA Code Chapter 1O2, which pertains to erosion control
requirements related to excavation activities;
(e) 25 PA Code Chapter 264, subchapter O - Pennsylvania
regulations for hazardous waste incineration;
(f) the EPA TSCA regulation* for incineration of PCB materials,
4O C.P.R. f 761.7O; -
(g) RCRA incineration standards set forth at 4O C.F.R. Part
264, subpart O; •,.. ~- - - •".
(h) 25 PA Cod* Chapter 264 and 40 C.F.R. Part 268 regarding
storage, disposal, and treatment of hazardous wastes;
(i) RCRA. and Department of Transportation regulations governing
the transportation of hazardous wastes, 25 PA Cod* Chapters 262 and
263 and 49 C.F.R. Parts 1O7 and 171-179, respectively;
(j) OSHA standard* for worker's protection, 29 C.F.R. Parts
1904, 1910, and 1926;
3. Location-Specific ARARs
(k) The Clean Water Act, 33 U.S.C. if 1251 e£ fifiOi.; 40 C.F.R.
Part 403 relating to the discharge of wastewaters to a publicly-
owned treatment work*;
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34
4. To Be Considers^
(1) the EPA Guidance on Metal* and Hydrogen Chloride Controls
for Hazardous Waste Incinerators (EPA Office of Solid Waste, August
1989) ;
(m) Executive Order 11988, 4O C.F.R. § 6, Appendix A,
concerning federal wetlands policies;
(n) PA Proposed Residual Waste Regulations to be codified at 25
PA Code Parts 287-299 (requirements will be considered during
remedial design) ;
(o) Draft Interim Guidance on Establishing Soil Lead Cleanup
Levels at Superfund Sites (OSWER Directive No. 9355.4-02 (June 13,
1989)).
F. Costs
Total Present Worth $150,000,000 to $636,000,000
Cost estimates vary widely depending on the type of incinerator
used (mobile or transportable) incinerator is used and allowable
fluff feed rates which would be determined during additional
modeling and pilot testing. Incinerator operational costs are
included in the total present worth estimate.
xx. cojma&vxvB AMALYIIS o» ALTBSATXVM
The four remedial action alternatives described above were
evaluated under the nine evaluation criteria as set forth in the
NCP at 40 C.F.R. f 300.430(e) (9) . These nine criteria are
organized according to the following categories as set forth at 40
C.F.R. f 300.430(£)(1):
• Overall protection of human health and the environment
• Compliance with applicable or relevant and appropriate
requirements (ARARs)
PRIMARV AWCIKG CRITERIA
Long-term effectiveness
Reduction of toxicity, mobility, or volume through treataont
Short-term effectiveness
Implementability
Cost
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35
MODIFYING CRTTBRIA
• Community acceptance
• State acceptance
Threshold criteria must be satisfied in order for a remedy to be
eligible for selection. Primary balancing criteria are used to
weigh major trade-offs between remedies. state and community
acceptance are modifying criteria formally taken into account after
public comment is received on the Proposed Plan. The evaluations
are as follows:
A. Overall Protection of Human Health and the Bnviyonm+pt
A primary requirement of CERCZA is that the selected remedial
action be protective of human health and the environment. A remedy
is protective if it reduces current and potential risks to
acceptable levels under the established risk range posed by each
exposure pathway at the site.
Alternatives 2 (Recycling), 3 (Capping), and 4 (Incineration) would
prevent exposure through dermal contact, inhalation and ingest ion,
and further release of hazardous substances from fluff materials
into soils, sediments, surface water, and ground water at the site.
These alternatives would also reduce the risk at the Site to below
or within the acceptable risk rang* of 1 x 10** to 1 x 10'*.
Alternative 2 (Recycling) would reduce: current and potential risks
by preventing future exposure and reducing mobility by
encapsulating the contaminants in a plastic matrix (the recycled
product). Recycling would provide a high level of protection
because the fluff would be converted to a non-hazardous fora and
most likely removed from the Site through distribution of the
resultant recycled product and through residuals disposal.
Residuals would be treated if necessary to be rendered
nonhazardous. The volume of the main fluff pile would be reduced
from 60-95% percent.
Alternative 3 (Capping) would reduce current and potential risks by
capping the> contaminated media. This remedy would prevent exposure
through dermal contact, inhalation and ingestion, and further
release otT hazardous substances from fluff materials into soils,
sediments, surface) water, and ground water at the Site. The fluff
pile would be confined beneath a multi-layered engineered cover
system which would minimize infiltration and percolation of
precipitation and prevent fluff transport via wind and erosion.
However, no treatment would be employed and the cap would require
long-term maintenance; therefore, it is a less desirable option
than Alternative 2.
s
Alternative 4 (Incineration) would reduce current and potential
risks by incinerating the fluff pile, thereby destroying the
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36
organic contaminant*. Inorganic contaminants in the incinerator
ash and residuals would be treated to immobilize them before being
disposed offsite. Although Alternative 4 would reduce Site risks
to an acceptable level, implementation would take significantly
longer and cost significantly more than Alternatives 2 and 3, which
achieve the same objectives of protecting human health and the
environment.
Alternative 1 (No Action) allows risk to remain in the unacceptable
range and therefore does not provide overall protection of human
health and the environment. Fluff would continue to erode,
leachate would continue to migrate, and risks to humans and the
environment would remain.
•B« Compliance with Applicable, oy Relevant and App
This criterion addresses whether or not a remedy will meet all of
the applicable or relevant and appropriate requirements of other
environmental statutes and/or provides grounds for invoking a
waiver. A full discussion of ARAB* for the selected remedy is set
forth in Section XI, below.
Alternatives 2 (Recycling) , 3 (Capping), and 4 (Incineration) could
meet all ARARs. Major ARARs involved with Alternative 2 pertain to
offsite landfilling. Major ARARs involved with Alternative 3
pertaining to onsite capping of hazardous wastes. Capping would
meet action-specific ARARs by employing a multi-layer cap with
performance equivalent to a RCRA closure cap. Major ARARs involved
with Alternative 4 pertain to hazardous waste incineration and
offsite landfilling.
Alternative 1 (No Action) would provide no remediation of
contaminated media" and therefore would not meet the chemical-
specific ARARs.
C« Lena—Ter»
Long-tent effectiveness and permanence addresses the long-term
protection of human health and the environment once remedial action
cleanup requirements have been achieved, and focuses on residual
risks that will remain after completion of the remedial action.
Alternative 2 (Recycling) would achieve a high level of long-term
effectiveness and permanence as removal of the fluff pile would be
permanent and irreversible. Recycling the fluff would encapsulate
the contaminants in a plastic matrix (the recycled product) which
would prevent exposure and virtually eliminate mobility of the
contaminants from such matrix. The encapsulated fluff would likely
be removed from the Site through distribution of the recycled
product. 'Residuals would be treated if necessary before disposal
offsite which would permanently remove any hazardous
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37
characteristics.
Alternative 3 (Capping) provides a moderate level of long-term
effectiveness and permanence by providing an engineered cover
system to prevent exposure to and transport of contaminants. A
vegetated surface on the cover would protect the cover soils from
being eroded and thus ensure longevity of the cover system. This
would effectively prevent constituent migration by wind erosion,
surface water erosion, or leachate generation as long as the cap is
properly maintained. Thus, the Site would require post-closure
inspection and operation and maintenance to ensure that the closure
remains effective. This alternative is not as desireable as
Alternative 2 because the fluff pile would remain onsite
permanently and its long-term effectiveness would require ensured
long-term maintenance. Regular inspection of the cap for signs of
erosion, settlement, or subsidence would be necessary. A five-year
review would be required.
Alternative 4 (Incineration) would provide long-term effectiveness
by permanently destroying the organic contaminants in the fluff.
Inorganic contaminants in the residual would most likely need to be
treated to immobilize them before they were disposed offsite.
ultimately, all contaminated media would be removed from the Site
except for the soils underlying the fluff pile which would be
studied further. Air emissions controls would need to be installed
and continuously monitored for the entire time of operation, which
could take from nine to eighty-seven years. Because of the length
of time that continuous monitoring would need to be performed, this
alternative is less desirable than Alternative 2.
Alternative 1 (No Action) does not employ any additional measures
to provide long-term effectiveness and permanence and therefore is
unacceptable. All waste materials would remain onsite and exposed
to current means of contaminant transport. Thus the pathways of
contaminant transport and migration, as well as the risks posed by
exposure to SitoF contaminants, would remain unchanged.
D. Reduction of ToxloltT. Mobility.' and Volume •
This evaluation 'criterion addresses the degree to which a
technology or remedial alternative reduces the toxicity, mobility,
or volume! of a hazardous substance. Section 121(b) of CERCIA, 42
U.S.C. S 9621(b), establishes a preference for remedial actions
that permanently and significantly reduce the toxicity, mobility,
or volume of hazardous substances over remedial actions which will
not result in such reduction.
Alternative 2 (Recycling) provides significant reductions in
toxicity, mobility, and volume. By immobilizing contaminants in
the recycled plastic product, recycling reduces the toxicity and
mobility of contaminants. Permanent volume reductions of
hazardous materials from 60% to potentially 95%, depending on which
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38
recycling technology is used, would also be achieved. Toxicity
would be reduced through the treatment of any hazardous residuals
to remove the characteristic by which they are hazardous. If a
stabilization process were used/ the residuals could potentially
double in volume; however, the resulting treated media would not be
hazardous.
Alternative 3 (Capping) does not reduce toxicity or volume.
Mobility, however, is significantly reduced. Capping would isolate
the fluff and underlying soils thus minimizing the mobility of the
contaminants. Capping of the fluff pile would reduce leachate
production by minimizing precipitation that infiltrates and
percolates through the fluff and soil and prevent transport of
fluff via wind and/or surface runoff erosion. Risks that remain
include any loss of structural integrity over the long-term, which
would allow leachate production and contaminant transport to
resume.
Alternative 4 (Incineration) reduces toxicity by destroying organic
contaminants in the fluff material; fluff volume would be reduced
by 80 percent. Inorganic contaminants present in the incinerator
residuals would be treated to remove the characteristics by which:
they are classified as hazardous, thereby reducing toxicity.
Treatment through stabilization of the incinerator residuals would
reduce the toxicity and mobility of contaminants by chemically
and/or physically binding them in the stabilization matrix.
Stabilization would increase the residuals volume, but they would
become inert and non-hazardous.
Because both Alternatives 2 and 4 reduce toxicity, mobility, and
volume, these alternatives are more desirable than Alternative 3,
which reduces only mobility and Alternative 1, which provides for
.no reductions in toxicity, mobility, or volume* -
B. Short-Term •ffeotiveness
Short-term effectiveness addresses the period of time needed to
achieve protection of- human health and the environment, and any
adverse impacts that may be posed during the construction and
operation period until cleanup goals are achieved.
During implementation of Alternative 2 (Recycling) the fluff would
be disturbed for loading and hauling to the onsite processing
facility. Possible fugitive dust emissions during material
handling could be minimized by controlled wetting of the fluff.
Monitoring would be performed to ensure that processing emissions
were at safe levels for onsite workers and the community.
Pollution control devices would b« fitted to machinery as
technically feasible and necessary. Site workers both inside and
outside of the processing building would be protected from dust
inhalation and dermal contact by wearing appropriate protective
equipment. Completion of fluff recycling would take approximately
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39
5-10 years*
Alternative 3 (Capping) would require vetting the fluff to control
possible fugitive dust emissions during fluff regrading. Site
workers would be further protected from dust inhalation and dermal
contact by wearing appropriate protective equipment. Completion of
capping would take approximately 2-3 years from design through
construction. Because of the speed by which Alternative 3 could be
implemented to achieve protection of human health and the
environment, it would most likely be more effective in the short-
term than Alternative 2.
Alternative 4 (Incineration) would require that the fluff be
disturbed for loading and hauling to the incinerator. Possible
fugitive dust emissions during materials handling could be
minimized by controlled wetting of the fluff. Site workers both
inside and outside the processing building would be protected from
dust inhalation and dermal contact by wearing appropriate
protective equipment. Air emissions controls would be installed on
the incinerator and continuous monitoring would be performed to
ensure that incinerator exhaust emissions are below levels harmful
to human health and the environment. The fluff feed rate into the
incinerator would be very low in order to achieve, optimal
performance of the pollution control equipment in capturing lead
and other inorganic contaminants. Therefore, incineration of the
fluff could take from nine to eighty-seven years depending on the
type of incinerator used and the allowable fluff feed rates, which
would be determined during design. Because of the long
implementation time period, this alternative is less desirable than
Alternatives 2. or 3 with regard to short-term effectiveness.
Alternative 1 would not provide any short-term effectiveness.
F. IlPlfMB
Implementability refers to the technical and administrative
feasibility of a remedy, including the 'availability of materials
and service* needed to implement the chosen solution.
Alternative 2 (Recycling) is highly implementable with regard to
technology. This alternative would use readily available standard
processing- machinery such as sieves, grinders, and ciarifiers to
sort the fluff. Recycling machinery such as various types of
extruders would be used to create a product. The marketability of
the product is more questionable; however, several wire and cable
recycling companies nationwide are currently finding markets for
their recycled products. EPA has identified companies that recycle
and successfully sell over one million pounds per month of recycled
wire and cable scrap products. Most have been operating for a
minimum of five years. Consequently, it is expected that
appropriate markets could be found for the recycled fluff products.
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40
Alternative 3 (Capping) would involve standard construction
technologies, materials, and equipment which are readily available.
Although capping has been proven to be highly implementable, it is
less desirable than Alternatives 2 (Recycling) and 4 (Incineration)
because it neither treats the waste nor reduces its volume.
Alternative 4 (Incineration) would require a mobile incinerator and
typical earth moving equipment which is commercially available.
However, advance scheduling (an estimated 2 years) is necessary to
secure a mobile facility. The application of incineration for site
remediation has been successful at other sites where feed has been
reasonably uniform, as is the case for this Site. Approximately
one acre of the Site would be required to house an incinerator
system, operator facilities, laboratory, pre-processing systems,
and storage areas for ash and excavated solid media. Incineration
would require installation of utilities including natural gas,
power and potable water. A test Burn would be necessary to
demonstrate compliance with hazardous waste incineration
performance standards and to evaluate the performance and
compatibility of emissions control systems. Although this
alternative is more difficult to implement than Alternative 3, it
is more desirable because it destroys and/or treats the fluff
contaminants. However, it is less desirable than Alternative 2;
Alternative 2 may be easier to implement.
CERCLA requires selection of a cost-effective remedy that protects
human health and the environment and meets the other requirements
of the statute. Project costs include all construction and
operation and maintenance costs incurred over the life of the
project. Capital costs include those expenditures necessary to
implement a remedial action.
Because Alternative 2 (Recycling) is an innovative alternative,
cost estimates are more variable than those for other alternatives
which have been implemented previously. Cost estimates will vary
depending on which recycling process is used, the number of
machines placed onsite, contractual arrangements between owners and
recyclers, the- volume of non-recyclables and recycling residuals,
and whether the residuals are hazardous and need treatment.
Estimates of costs are as follows:
Capital $ 6,200,000 to $15,000,000
O ft M $ 6,900,000 to $ 6,900,000
Total Present Worth$13,100,000 to $21,900,000
Alternative 3 (Capping) costs can be reliably estimated since
capping has been implemented many times before. Estimated costs
are as follows:
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41
capital $14,000,000
O ft M $ 1,000,000
Total Present Worth$15,000,000
A rang* of costs is provided for Alternative 4 (Incineration)
because the expected operation and maintenance time nay vary
between nine and eighty-seven years, depending on the allowable
feed rate and whether a mobile or transportable incinerator is
used. Incinerator operational' costs are included in the total
present worth estimate. Estimated costs are as follows:
Total Present Worth $150,000,000 to $636,000,000
The estimated cost of Alternative 2 is within the same range as
Alternative 3, and significantly "less than Alternative 4.
Alternative 2 provides a higher degree of certainty that this
remedy will be effective in the long-term due to the significant
reduction of the toxicity and volume of the wastes achieved through
recycling that would not occur through Alternative 3. Alternative
2 achieves a greater degree of protectiveness and effectiveness
proportional to its costs than Alternatives 3 or 4.
H.
A public meeting on the Proposed Remedial Action Plan proposing
selection of Alternative 2 (Recycling) was held on April 30, 1992,
in Hometown, Pennsylvania. Most comments received at that meeting
centered on health concerns related to worker and community safety
with regard to an onsite recycling facility. Comments received
during the meeting and comment period are discussed in the
Responsiveness Summary attached to this ROD.
At the public meeting* EPA received many comments pertaining to
Alternative 2 (Recycling). Most comments related to concerns about
pollution emissions from a recycling facility and the corresponding
impacts to onsit* workers and the surrounding community. EPA
explained at the meeting that emissions control monitoring would be
performed and pollution control devices would be fitted to the
recycling machinery if necessary. Workers would be provided with
personnel protection health and safety equipment as necessary.
Alternative 3 (Capping) received several unfavorable comments. The
community did not want the fluff to remain in their neighborhood.
Many members of the community expressed vehement opposition to
Alternative 4 (Incineration) because of health concerns. EPA
explained that air emissions controls would be installed on the
incinerator and monitored continuously to ensure that incinerator
exhaust emissions were below levels harmful to human health and the
environment. No Alternative emerged during the public comment
period as a clear community favorite.
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42
X. state Acceptance
The Commonwealth of Pennsylvania has concurred with this selected
Remedial Action.
As set forth above, EPA must evaluate a proposed remedy with regard
to these nine criteria which have been set forth in detail, and
balance the criteria in selecting a remedy.
Z. 81LBCTBD BBMBOT AMD FBRVOK*JUICB
Following extensive review and consideration of the information
contained in the Administrative Record file, the requirements of
CERCLA and the NCP, and public comment, EPA selects Alternative 2
(Recycling) as the most appropriate remedy for Operable Unit 3 of
the Eastern Diversified Metals Site. The selected remedy repre-
sents the best balance among the nine evaluation criteria and
satisfies the statutory requirements of protectiveness-, compliance
with ARARs, cost effectiveness, and the utilization of permanent
solutions and treatment to the maximum extent practicable.
The following actions will be conducted and the following
performance standards attained under this alternative:
l. All fluff at the site (waste insulation material consisting
primarily of polyvinyl chloride and polyethylene chips; fibrous
material; and paper, soil, and metal on the surface of the Site
other than that to be remediated pursuant to the March 1991
ROD) will be recycled onsite within fifteen (15) years of the
date EPA issues this Record of Decision and in accordance with
the following:
(a) Recycling of the fluff into a form that will be used
without further processing ("Final Product*) off site
(e.g. , floor mats, plastic lumber, or bumpers) shall
ensure that the hazardous substances, pollutants, and
contaminants within the Final Product are inseparable
from the Final Product by physical forces attending
ordinary use of the Final Product; or
(b) Recycling of the fluff into a form that will undergo
further processing offsite in order to produce a usable
product ("Non-Final Product") (e.g., plastic pellets)
shall ensure that (1) the Non-Final Product does not
exhibit RCRA hazardous characteristics, and (2) the
hazardous substances, pollutants, and contaminants within
any Final Product produced therefrom are inseparable from
the Final Product by physical forces attending ordinary
use of the Final Product.
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43
2. Recycling residuals including, but not limited to, debris
within the fluff, will be tested to determine whether such
residuals exhibit RCRA hazardous characteristics. Recycling
residuals that do not exhibit RCRA hazardous characteristics
will be disposed of in an offsite landfill.
3. Treatability tests shall be performed on recycling residuals
that do exhibit RCRA hazardous characteristics so that EPA can
determine the most appropriate method of treatment prior to
disposal. These materials'will then be treated so that such
materials no longer exhibit RCRA hazardous characteristics and
will be disposed of in an offsite landfill.
4. Soils underlying the fluff shall be sampled and analyzed as
approved by EPA to determine the nature and extent of
contamination of such soils by hazardous substances,
pollutants, and contaminants.
5. Erosion and sedimentation controls approved by EPA shall be
implemented to control drainage and minimize erosion of exposed
soils at the Site.
Response actions to address soil contamination, if any, will be
selected by EPA in a subsequent Record of Decision following
analysis of the soil samples taken as part of this remedy.
Costs associated with this remedy are shown below. Costs and
timeframes will vary depending on which recycling technology is
implemented, the number of machines placed onsite, the volume of
non-recyclables and recycling residuals, and whether the residuals
are hazardous and need treatment. A more detailed analysis of
costs for the selected remedy are shown in Tables 14 and 15.
Capital $ 6,200,000 to $15,000,000
O & M $ 6,900,000 to $ 6,900,000
Total Present Worth$13,100,000 to $21,900,000
Minor changes may be made to the remedy as a result of the remedial
design anftconstruction process. Such changes, in general, reflect
modification* resulting from the engineering design process.
XX. STATUTORY DITBIUIZBATZOm
Section 121 of CERCLA requires that the selected remedy:
. be protective of human health and the environment;
. comply with ARARs;
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Table 14
SELECTED REMEDY LOW-END COSTS
(5% Residual)
ITEM
Pilot Studio*
Site Preparation .;
Mobilliatlon/DoMbilliatlon
Staging Area Construction,.
Electrical ant Pluablng -.
Oacon ATM Preparation °
Clewing, erubDlng, and Road Upgrade*
Trailer* and Hookups
General ConditIone (Security, Phones,
Sanitary, Docuaantatlon)
Recycling Machinery
Analytical Work - TOP and Sofia Stapling
"Residuals Treata*nt
Reelduala Transport
•"Residuals Disposal In Offalte landfill
Surface Runoff Controls .
•era
Oltchea
TOTAL DIRECT CONSTRUCTION COST (TOCC)
INDIRECT COSTS
Legal
Health and Safety
Engineering
Insurance
Construction Nanageawit
CONTINGENCY 8 SOX TOCC
TOTAL CAPITAL COST
10-YEAR OtM PRESENT VORTN 8 SX
ESTIMATED TOTAL PROJECT COST
QUANTITY
3 Studies
Ea
Ea
Lot
Ea
Lot
Lot
Lot
•2 Lines
100 Saaples
B.SOO Ions;
MO Loads i
a.500 TOM
3.400 Cy
3.600 Ft
1 Lot
1 Lot
1 Lot
1 Lot
1 lot
UNIT COST
S 3.300 / study
50,000 / Ea
100.000 / Ea
100.000 / Lot
50,000 / Ea
25.000 / lot
75,000 / lot
100.000 / lot
S1.000.000/ line
S 1.000 / Saaple
* 35.00 / Ton
t 300.00 / load
S 65.00 / Ton .
S 13.00 / Cy
9 4.00 / ft
S 100.000 / lot
S 400.000 / lot
t 500,000 / Lot
t 100.000 / lot
t 400,000 / lot
S
S
S
S
S
S
S
S
S
S
S
S
S
10,000
50.000
100.000
100,000
50,000
25.000
75.000
100.000
2.000.000
100.000
300.000
110.000
550.000
44.200
14.400
100.000
400,000
500,000
100,000
400.000
INSTALLED COST
S 10.000
S 500,000
S 2,000,000
S
S
S
S
S
100.000
300.000
110.000
550.000
60.000
S 3.630,000
t 1.500.000
S 1.090,000
S 6,200,000
S 6,900.000
* SIS.100.000
•One tine Includes a screening Machine, grinding Mchine. front end loader.
•tectrostetic separator, u*ch tank, secondary Mash systeai, PE and PVC extruder
••Attunes resldusls are hsxerdous and need treatawnt (conservative coat assuaption).
•••Aesunes disposal In an offsite non-hezardous residual waste landfill.
t Ooea not Include profit frost potential sale of recycled products.
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Table 15
SELECTED REMEDY HIGrtEND COSTS
(40% Residual)
ITEM
Pilot Studio*
Sit* Preparation
Nobl I Isation/DesMbl Illation
Staging ATM Construct Ion
. Electrical and
Decon ATM Preparation
Clearing, Grubbing, and toad Upgradta
Trailer* and Hookups
General Condition* (Security. Phone*,
Sanitary, Documentation)
Recycl Ing Machinery
Analytical Work - TClP and Soil* Saapllng
"Reaiduel* Treatment
Residual* Transport
••••eslduel* Dlapoaal in Off site landfill
Surface Runoff Control*
•era)
Oitchea
TOTAL DIRECT CONSTRUCTION COST (TDCC)
INDIRECT COSTS
Legal
Health and Safety
Engineering
Insurance
Conetructlon Management
COHTINGENCV 8 MX T0CC
TOTAL CAPITAL COST
10-TEAR 0(N PRESENT UORTH 8 5X
ESTIMATED TOTAL PROJECT COST
QUANTITY
1 Studia*
Ea
Ea
Lot
Ea
Lot
Lot
Lot
•2 Line*
100 Maple*
68.640 Ton*
2.930 Loada
68,640 Ton*
3.400 Cy
1.600 Ft
Lot
Lot
lot
Lot
Lot
UNIT COST
$ J.300 / *tudy
50.000 / Ea
100,000 / Ee
100.000 / lot
50,000 / Ea
25,000 / Lot
75.000 / Lot
100.000 / Lot
S1.000.000/ Una
S 1.000 / Saaple
$ 15.00 / Ton
S 500.00 / Load
• 65.00 / Ton
S 11.00 / Cy
S 4.00 / ft
S 100.000 / Lot
S 400.000 / Lot
S 500.000 / lot
S 100.000 / lot
8 400.008 / lot
10.000
50.000
100,000
100.000
50.000
25.000
75.000
100.000
S 2.000.000
S 100.000*
S 2.400.000
S 880.000
S 4.460.000
S 44.200
S 14.400
S
S
S
S
S
100.000
400.000
500.000
100.000
400,000
INSTALLED COST
$ 10,000
S 500,000
S 2,000,000
S 100.000
S 2,400,000
S 880.000
S 4,460,000
S 60,000
S10.410.000
S 1.500.000
S 3,120,000
$15.000.000
S 6,900,000
t S21.900.000
•One line Include* screening Mchlne, grinding machine, front end loader,
electro*t*tlc separator, wash tank, secondary wash system. PE and PVC extruder
"Assumes residuals are hazardous and need treatment (conservative coat assumption).
"•Assume* disposal in an offait* non-heierdout residual waste landfill.
I Doe* not Include profit from potential aal* of recycled product*.
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. be cost-effective;
. utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable; and
. address whether the preference for treatment as a
principal element is satisfied.
A description of how the selected remedy satisfies each of the
above statutory requirements is provided below.
A. Protection of BUmaji Health and the BuyiroBgeHt
'The selected remedy for OU3 protects human health and the
environment through onsite recycling of, fluff materials and of f site
disposal of residuals. Recycling reduces the risks to human health
and the environment by encapsulating fluff contaminants in a
plastic matrix (the recycled product) thereby preventing exposure
through dermal contact, inhalation, and ingestion. The recycling
process also decreases contaminant mobility and prevents further
release of hazardous substances from fluff into soils, sediments,
surface water, and ground water. Volume will be reduced by
approximately 40-60 percent and, ultimately, part or all of the
recycled material may be removed from the Site through distribution
of the recycled product. Treatment, if necessary, and disposal of
recycling residuals through landfilling will decrease mobility by
preventing additional leachate production and will prevent exposure
via dermal contact, inhalation, and ingestion. Implementation of
the selected remedy will not pose unacceptable short-term risks or
cross-media impacts to the Site, the workers, or the community.
B. compliance with ABABs
All applicable or relevant and appropriate requirements (ARARs)
pertaining to the selected remedy will be attained. The ARARs are
presented below.
1. Thenieal-Snaeif ie ARAB*
(a) 25 PA Cod* Chapter 261 and 40 C.F.R. § 261.24 for
identification of characteristic hazardous wastes;
(b) the. National Ambient Air Quality standards (NAAQS) set
forth at 4O C.F.R. Part SO;
(c) the Pennsylvania Air Pollution Control Act, 25 PA code
Chapters 123 and 127;
2. Action-Specific ARABs
(d) 25 PA Code Chapter 1O2, which pertains to erosion control
requirements related to excavation activities.
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45
(•) RCRA and Department of Transportation regulation* governing
the generation and transportation of hazardous wastes, 25 PA code
Chapters 262 and 263; 49 C.F.R. Parts 107, 171-179;
(f) 25 PA Code Chapter 264 and 40 C.F.R. Part 268 regarding the
storage, disposal, and treatment of hazardous wastes;
(g) 40 C.F.R. Part 266, SubPart C relating to recyclable
materials used in a manner constituting disposal;
(h) National Pollution Discharge Elimination System require-
ments, 40 C.F.R. Part 122 regarding wastewaters;
(i) OSHA standards for worker's protection, 29 C.F.R. Parts
1904, 1910, and 1926;
3. Location-Specific ARARa
(j) The Clean Water Act, 33 U.S.C. if 1251 «t »»a.i 40 C.F.R.
Part 403 relating to the discharge of wastewaters to a publicly-
owned treatment works;
4. To Be Considered
(k) Executive Order 11988, 4O C.F.R. § 6, Appendix A,
concerning federal wetlands policies;
(1) PA Proposed Residual Wast* Regulations to be codified at 25
PA Code Chapters 287-299 (requirements will be considered during
remedial design);
(m) Draft Interim Guidance on Establishing Soil Lead Cleanup
Levels at Superfund Sites (OSWER Directive Mo. 9355.4-02 (June 13,
1989)).
.C. Coat-Effectiveness
>.
The estimated present worth; cost for the selected remedy is
$13,100,000 - $21,900,000. Costs will vary depending upon the
recycling technology used, the number of machines placed onsite,
contractual arrangements between owners and recyclers, the volume
of non-recyclable* and recycling residuals, and whether the
residuals are hazardous and need treatment. The remedy is cost-
effective in mitigating the risks posed by OU3 of the Site in a
reasonable period of time and meets all other requirements of
CERCLA. The estimated cost of Alternative 2 (Recycling) is within
the same range as Alternative 3 (Capping), and significantly less
than Alternative 4 (Incineration). Alternative 2 provides a higher
degree of certainty that this remedy will be effective in the long-
term due to the significant reduction of the toxicity and volume of
the wastes achieved through recycling that would not occur through
Alternative 3. Alternative 2 provides the best balance among the
nine criteria and achieves a greater degree of protectiveness and
effectiveness proportional to its costs than Alternatives 3 or 4.
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46
D. ntlligatiott of Permanent solution* *afl ftl^eraatlve Tgea**»^nt
T+chpolyiies to the Maximum Bxteat Practicable
The selected remedy for OU3 utilizes permanent solutions and
treatment technologies to the maximum extent practicable While
providing the best balance among the other evaluation criteria.
It achieves the best balance of , tradeoffs with respect to the
primary balancing criteria of long-term effectiveness and
permanence; reduction in toxicity, mobility, and volume through
treatment; short-term effectiveness; implementability; and cost;
while also considering the statutory preference for treatment as a
principal element and State and community acceptance.
The selected remedy provides a high degree of long-term
effectiveness and permanence as the removal of the fluff pile
through the recycling process would be~ permanent and irreversible.
Recycling the fluff would encapsulate the contaminants in a plastic
matrix (the recycled product) which will prevent exposure and
reduce mobility. Any residuals would be treated which would
permanently remove any hazardous characteristics, and then removed
and securely contained off site. Capping the fluff would achieve
only a moderate level of long-term effectiveness and permanence as
the fluff would remain onsite permanently and its long-term
effectiveness would require ensured long-term maintenance. Onsite
incineration could achieve a moderate to high level of long-term
effectiveness and permanence because destruction of the fluff
would be permanent and irreversible; however, large quantities of
ash and residuals would need to be treated and disposed and the
implementation time period could be excessive.
The selected remedy provides significant reductions in toxicity,
mobility, and volume by immobilizing contaminants in the recycled
product and achieving significant volume reductions. Capping
provides no reduction in toxicity or volume. Incineration would
destroy organic contaminants and require treatment to stabilize the
inorganic contaminants for ultimate disposal. - The selected remedy
is less effective than capping in the short-term, but significantly
more effective than incineration which could take anywhere from
nine to eighty-seven years to achieve protect iveness. The selected
remedy may/ be slightly less implementable than capping due to the
uncertainties with regard to recycling markets, but is probably
more easily implementable than incineration. With regard to cost,
the selected remedy may be less expensive than capping and would be
less expensive than incineration.
rence fog Trea^**M>t as a Principal Bl*™^**t
By recycling the fluff material, contaminants would be encapsulated
in the recycled product reducing toxicity, mobility, and volume.
Residuals' would be treated if necessary to reduce toxicity before
disposal. Therefore, the statutory preference for remedies that
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47
employ treatment am a principal element is satisfied.
ZZZ. BXPLAHATIOM OF BIOMITICJUfT CRAWM
The Proposed Remedial Action Plan (Proposed Plan) identifying EPA'a
Preferred Remedial Alternative for OU3 of the Eastern Diversified
Metals Site was released for comment on April 16, 1992. The
selected remedy described in this ROD differs from the remedies in
the Proposed Plan with regard to the following:
1. No Contingency Remedy
The remedy selected in this Record of Decision was identified as
the Preferred Remedial Alternative in the Proposed Plan. The
Proposed Plan also identified a Preferred Contingency Alternative
which would have been implemented under circumstances identified in
that document. EPA determined that a contingency alternative is
unnecessary since research conducted as part of the RI/FS indicates
that recycling is both technically feasible and implementable.
2. Residuals Management
In the Proposed Plan, onsite capping or landfilling of recycling
residuals were included as potential residuals management options
along with offsite landfilling. Because onsite capping would not
meet State ARARs it was deleted as a potential residual management
option. After further review of onsite landfilling space and
hydrogeological requirements, EPA also deleted onsite landfilling
as an option. Consequently, recycling residuals will be treated
(if necessary) and disposed in an offsite landfill.
3. Soils Management
In the Proposed Plan, soils underlying the fluff pile exceeding
target levels were to be either capped or landfilled. In this
Record of Decision, soils underlying the fluff will be sampled and
analyzed to determine the nature and extent of soil contamination,
if any. Erosion and sedimentation controls will be developed and
implemented to control drainage and minimize erosion of exposed
soils at the> Sit*. EPA will determine whether, and to what extent,
further response^ actions are necessary to address soil
contamination in a subsequent Record of Decision following analyses
of the soil samples performed as part of this remedy.
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