United States        Office of
          Environmental Protection   Emergency and
          Agency           Remedial Response
EPA/ROD/R03-92/157
September 1992
SEPA    Superfund
          Record of Decision:
          Route 940 Drum Dump, PA

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                                          NOTICE

The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement but adds no further applicable information to
the content of the document All supplemental material is, however, contained in the administrative record
for this site.

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50272-101
 REPORT DOCUMENTATION
        PAGE
1. REPORT NO.
   EPA/ROD/R03-92/157
                                                                     3. Recipient's Accession No.
 4. Title and Subtitle
   SUPERFUND RECORD OF DECISION
   Route 940 Drum Dump,  PA
   First Remedial Action - Final
                                            5. Report Date
                                             09/28/92
 7. Authors)
                                                                     8. Performing Organization RepL No.
 9. Performing Organization Name and Address
                                                                     to. Projectnask/WorkUnitNo.
                                                                     11. Contract(C)orGrant(G)No.

                                                                     (C)

                                                                     (G)
 12. Sponsoring Organization Name and Address
   U.S.  Environmental Protection Agency
   401 M Street,  S.W.
   Washington, D.C.   20460
                                            13. Type of Report & Period Covered

                                              800/000
 15. Supplementary Notes
   PB93-963912
 16. Abstract (Limit 200 words)

  The  2.5-acre Drum Dump site is a grass-covered clearing in  the Tobyhanna Township,
  Monroe County,  Pennsylvania.   This site and adjacent land area is presently zoned  as  a
  commercial/light-industrial area.  The site is currently inactive with several
  stockpiles of soil and some open excavations on  the surface.   The site is bordered on
  all  four sides  by a pine-oak woodland with few nearby residences; however,  based on
  aerial surveys,  approximately 4,000 people who live within  a  3-mile  radius of the  site
  use  the aquifer beneath  the site as their source of potable water.   Between 1974 and
  1978,  approximately 600  drums of unknown contents from an unknown source were stored  in
  the  southeast corner of  the site.  In 1978, approximately 2 years after the sale of the
  site by the J.E.M. Partnership to LandMark, one  of the partners of the J.E.M.
  Partnership arranged for the removal  of the drums from the  site at the request of
  LandMark.   From 1983 to  1987,  several investigations,  monitoring events,  and interim
  measures were completed  at  the site.   It was concluded that some drums may have been
  buried onsite and that the  contents of some of the drums stored there  previously may
  have been dumped onto the ground.  Current onsite investigations revealed that any

   (See Attached Page)
 17. Document Analysts a. Descriptors
   Record of Decision - Route 940 Drum Dump, PA
   First Remedial  Action  -  Final
   Contaminated Media:   None
   Key Contaminants:  None
   b. Identifiers/Open-Ended Terms
   c. COSAT1 Reid/Group
 18. Availability Statement
                                                      19. Security Class (This Report)
                                                                None
                                                      20. Security Class (This Page)
                                                      	Krone"
                                                       21. No. of Pages
                                                         64
                                                                                 22. Price
(SeeANSI-Z39.1S)
                                       See Instructions on Reverse
                                                       OPTIONAL FORM 272 (4-77)
                                                       (Formerly NTB-35)
                                                       Department of Commerce

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EPA/ROD/R03-92/157
Route 940 Drum Dump, PA
First Remedial Action - Final

Abstract (Continued)

previously identified site contaminants now have been reduced to levels that no longer
pose a significant direct health threat or any threat from potential migration in ground
water; and thus, the site does not warrant any further remediation.  Therefore, there are
no contaminants of concern affecting this site.

The selected remedial action for this site is no action with future ground water
monitoring.  There are no costs provided for this no action remedy.

Performance Standards or Goals:  Not applicable.

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                        RECORD OF DECISION
                     ROUTE 940 DRUM DUMP SITE

                            DECLARATION
 SITE NAME AND LOCATION

 Route 940 Drum Dump Site
 Tobyhanna Township
 Monroe County,  Pennsylvania


 STATEMENT OF  BASIS AND PURPOSE

 This decision document presents  the selected remedial action for
 the  Route 940 Drum Dump Site  (the  "Site)  in Tobyhanna Township,
 Monroe County,  Pennsylvania,  developed and chosen in accordance
 with the  Comprehensive Environmental Response,  Compensation,  and
 Liability Act of  1980,  as  amended,  (CERCLA)  42  U.S.C. §§ 9601 et
 seq.  and  to the extent practicable,  the National Oil and
 Hazardous Substances Pollution Contingency Plan (NCP),  40 C.F.R.
 Part 300.  This decision is based  on the  Administrative Record
 for  this  Site.

 The  Commonwealth  of Pennsylvania,  Department of Environmental
 Resources agrees  with  the  Environmental Protection Agency's
 (^.- :'±j uhoic-:  c~  a ''No \ctior.':  c.-ic .s_or;  ;.'or this Site,  but  na.
 not  concurred with the Record of Decision (ROD),  as  written,
 because of fundamental differences with the EPA interpretation of
 the  NCP and CERCLA.
ASSESSMENT OF THE SITE

The determination has been made that no Remedial Action is
necessary at this Site.  Therefore, the Site now qualifies  for
inclusion in the "sites awaiting deletion"  subcategory of the
Construction Completion category of the National Priorities List.
As specified in Section VI Summary of  Site  Risks,  there are no
site-related risks that warrant a remedial  action  of  any kind.


DESCRIPTION OF THE REMEDY

The selected alternative for the Route 940  Drum Dump  Site is No
Action with future ground water monitoring.  Under this
alternative, no Remedial Action will be taken at this Site.  The
ground water in the vicinity of the Site will be monitored  once a
year for at least the next five years.

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 STATUTORY DETERMINATIONS

 Pursuant to duly delegated authority,  I  hereby determine,
 pursuant to Section 106 of CERCLA,  42  U.S.C.  S 9606  that the
 selected alternative is protective  of  human health and the
 environment.   No remedial action will  be taken, however, ground
 water quality in the vicinity of the Site will be reviewed within
 five years in consideration of Section 121(c)  of CERCLA, 42
 U.S.C.  § 9621(c)  to ensure that human  health  and the environment
 continue to be adequately protected.
                                                     SEP 28 1992
Edwin B. Erickson
Regional Administrator
Region III
Date

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                        RECORD OF DECISION
                        TABLE OF CONTENTS
I.        SITE NAME, DESCRIPTION, AND LOCATION              1

II.       SITE HISTORY AND ENFORCEMENT ACTIVITIES           2

III.      COMMUNITY RELATIONS SUMMARY                       4

IV.       SCOPE AND ROLE OF THIS RESPONSE ACTION            5

V.        SUMMARY OF SITE CHARACTERISTICS                   5

VI.       SUMMARY OF SITE RISKS                             41

VII.      DESCRIPTION OF THE NO ACTION ALTERNATIVE          54

VIII.     RESPONSIVENESS SUMMARY                            56

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                       RECORD 07 DECISION
                     ROUTE  940 DRUM DUMP  SITE
                        DECISION SUMMARY

             I.  SITE MAME. LOCATIOM MID DE8CRIPTIOM
     The Route 940 Drum Dump Site is located in Tobyhanna
Township near Pocono Summit, Pennsylvania (Figure 1).  Both
Tobyhanna Township and Pocono Summit are located in Monroe
County.  The Site is located approximately 20 miles southeast of
the Wilkes Barre-Scranton area.

     The Site is a grass-covered open clearing consisting of
approximately 2.5 acres located in Tobyhanna Township.  The Site
is approximately 4000 feet east of the intersection of Routes 314
and 940 in the easternmost section of the township.

     Adjacent land is used commercially.  A machine shop is
located northwest of the Site, and a former automobile transfer
facility (currently utilized by Pocono Limousine) is located
south of the Site.  A laminated cabinet shop is located east of
the Site across Township Road 643.  A gas station, a restaurant,
a law office and other commercial buildings are located nearby
along Route 940.  The Site is presently zoned as a commercial/
light-industrial area.  It is possible that the Site's zoning
could be changed in the future, and subsequently be zoned as a
residential area.

     The Site is bordered on all four sides by a pine-oak
woodland with few human inhabitants nearby.   Based on aerial
surveys, approximately 4,000 people within a 3-mile radius of the
Site utilize the aquifer beneath the Site as their source of
potable water.  The Site straddles the ridge which forms the
Pocono Plateau.  Currently, no one lives on the eastern slope of
the plateau in the area between the Site and Indian Run Creek,
situated 4000 feet southeast of the Site.  The northwestern
slope, 1,200 feet northwest of the Site, is more heavily
populated with the community of Pocono Summit.  The community
uses Focono Summit Lake, situated 3,000 feet northwest of the
Site, for recreational activities.  Summit Point Subdivision is
located approximately 1,000 feet east of the Site.

     The Site is fenced on all four sides by a six-foot-high wire
fence.  The Site is accessed from Township Road 643 by an opening
in the woods that is controlled by a locked gate.  The land is
currently idle with several stockpiles of soil and several open
excavations on the surface.

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           POOR QUALiii'
             ORIGINAL
1 LOCATION MAP

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      The history of  waste disposal at the  Site  is  summarized
 below:

 HISTORY OP WASTE DISPOSAL

      LandMark  International  ("LandMark") purchased a  13-acre
 tract in 1976  from the J.E.M. Partnership  which had owned the
 property since 1974.

      Between 1974  and 1978,  approximately  600 drums of unknown
 contents from  an unknown source were stored in  a clearing
 consisting of  approximately  2.5 acres.  The drums  were stored in
 the southeast  corner of the  clearing.

      In 1978,  approximately  2 years after  the sale of the Site by
 the J.E.M. Partnership to LandMark, one of the  partners of the
 J.E.M.  Partnership arranged  for the removal of  the drums from the
 Site  at the request  of LandMark.


 RESPONSE ACTIONS

      In  1985,  the U.S. Environmental Protection Agency ("EPA")
 proposed the Site  on the National Priorities List  ("NPL") under
 the provisions  of  the Comprehensive Environmental  Response,
 Compensation, and  Liability Act ("CERCLA") as amended by the
 Superfund Admendments and reauthorization  Act of 1986.   The NPL
 listing was promulgated in September 1987.  From 1983 until it's
 final listing on the NPL in  1987, several  investigations,
 monitoring events, and interim- remedial measures were completed
 at the  Site by  the Pennsylvania Department of Environmental
 Resources ("PADER"), EPA and, subsequently, LandMark.


RESPONSE ACTIONS BY EPA AMD PAPER

     In  early 1983, PADER learned that some drums may have been
buried  on the Site and that the contents of some of the drums
previously stored  there may have been dumped on the surface of
the ground on the  Site.  PADER,  with assistance from  EPA
 initiated an investigation of the Site.  The following is a
summary  of the  events which occurred during the PADER
 investigation.

Soil Tranches and  Borings

     Representatives of EPA and PADER completed trenching and
shallow  boring  operations in April 1983.   The rusted  remains of
several  crushed 55-gallon drums were found in shallow trenches
along with a very  small number of crushed  drums.   (Excavated

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 drums were collected in a dumpster and later manifested and
 removed from the Site to a secure facility by a licensed waste
 hauler).   No intact drums, liquid pools or solid masses of
 chemical materials were found.

 Special Container Investigation

      Approximately 125 small containers resembling "lab packs"
 were found in a packed drum resting on the surface near the south
 corner of the Site.   Laboratory analyses,  conducted subsequently,
 revealed that the containers contained no  hazardous materials.
      Following  EPA and  PADER's  response  actions  at  the  Site,
 LandMark hired  BCM Consultants  in May 1983  to undertake further
 investigations  and actions at the Site.  The following  summarizes
 the  efforts done  by Landmark and their consultant:

 Excavation and  Post-Excavation  Sampling  cf  Pits  A.  B.and c

      Soils, which were  previously identified during a soil
 sampling program  conducted by BCM as  being  contaminated with
 organic solvents  were excavated at three locations: Pits A, B,
 and  C (Figure 2).   Each of these areas was  excavated until all of
 the  soil found  to be contaminated had been  removed.  A  licensed
 hazardous waste hauling contractor handled  the disposal of 300
 tons of contaminated soil from  the Site.  The soils were
 manifested and  disposed of in accordance with PADER and EPA
 requirements.

 Area H - Test Pit and Excavation

      In January 1987, excavation began in Area H (Figure 2} where
 chemical contamination  had been detected in May  1985.    All
 material was excavated  and stockpiled.   The contaminated soil
 stockpile contained between 4,000 and 4,500 cubic yards.
 While the final portion of Area H was being excavated,  six
 additional crushed, rusted, drum remnants were encountered.  The
 drums were stored  onsite until  proper disposal was  arranged.
 The  soil that was  excavated during the drum removal was added to
 the  soil stockpile.

 Soil Shredding Pilot Study and  Results

     On April 20,   1987, a pilot soil  shredding operation was
 conducted at the Route  940 Site.  The purpose of the operation
was to quantify the reduction of volatile organic compounds
 ("VOCs")  that could be  expected.  The soil  shredding operation,
done in conjunction with applicable Federal and  State air
emission laws, was designed to  enhance the  volatilization of the
VOCs within the soils.

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     Soil samples were taken at random out of the loader bucket
before the soil was shredded.   After the soil had been shredded
and exposed to the air for 24 hours, a set of samples was taken
at random from the material that had been run through the
shredder twice and spread out.   Analysis of the soils showed an
average 98-percent reduction in VOCs.  Of the five samples taken
before the soil had been shredded, three samples had total
purgeable halocarbons and purgeable aromatics ranging from 203 to
559 mg/kg (parts per million).  The post-treatment samples had
low residual concentrations.  The purgeable halocarbons and
purgeable aromatics totals ranged from 2.3 mg/kg to 10.6 mg/kg.

RI/PS INVESTIGATION

     In 1985, the Site was proposed for inclusion on the National
Priorities List ("NPL"), 40 CFR Part 300, and was finalized in
July 1987.  In November 1987, Landmark entered into a Consent
Order with PADER to undertake a Remedial Investigation/
Feasibility Study ("RI/FS") for the entire Site.  In 1990, the
Consent Order ("Order1*) between Landmark and PADER was suspended
by FADER due to non-compliance with the Order by Landmark.  PADER
returned the Site back to EPA;  EPA then initiated a fund-lead RI
and also performed a Risk Assessment (HRAM) for the Site.

     During the course of the RI, EPA undertook a Potentially
Responsible Parties ("PRP") investigation to determine those
parties which would be responsible under CERCLA for undertaking
the Remedial Design/Remedial Action ("RD/RA").   This
investigation included reviewing documents in EPA, State and
local governmental agency files, sending and reviewing CERCLA §
104(e) information request letters, reviewing title search
documents and researching corporate history and status.  As of
the issuance date of this ROD,  EPA has identified several
parties whom it believes to be PRPs for the Route 940 Drum Dump
Site.

                III.

     In accordance with Sections 113 and 117  of CERCLA, 42
U.S.C. §§ 9613 (k)(2)(B)(i-v) and 9617, EPA, in conjunction with
PADER, issued a Proposed Plan to present the preferred remedial
alternative.  The Proposed Plan and draft RI and draft RA reports
were made available to the public by maintaining copies in the
administrative record.  The Administrative Record is kept at the
two locations listed below:

                       Public Reading Room
                          EPA Region III
                       841 Chestnut Street
                        Philadelphia, PA

                               and

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              Tobyhanna Township Municipal Building
                           State Avenue
                    Pocono Pines, Pennsylvania

No FS Report was  undertaken for the Site based on the findings  of
the RI and RA.  An  announcement of the public meeting, the
comment period, and the availability of the RI/RA was published
in the Pocono Record, on August 10, 1992.

     EPA held a public comment period from August 10, 1992 to
September 9, 1992.   A public meeting was held on August 20, 1992
to present information, accept oral and written comments and
answer questions  from the public regarding the Site and potential
remedial alternatives.  A transcript of the meeting was
maintained in accordance with Section 117 (a) (2) of CERCLA, 42
U.S.C. § 9617 (a) (2).  Responses to both the oral and written
comments received during the public comment period are included
in the attached Responsiveness Summary.  This decision document
presents the selected remedial action for the Route 940 Drum Dump
Site chosen in accordance with CERCLA, and to the extent
practicable, the  NCP.

     All documents  considered or relied upon in reaching the
remedy selection  decisions contained in this Record of Decision
are included in the Administrative Record for the Site and can  be
reviewed at the information repositories.

           IV.  SCOPE AND ROLE OP THIS RESPONSE ACTION
     EPA's goal for the RI/FS was to determine the nature and
extent of contamination, to identify risks posed by che Site; and
to develop remedial alternatives to address those risks.  There
were no principal threats identified at this Site.  Principal
threats are those source materials considered to be highly toxic
or mobile, generally cannot be contained, or would present a
significant risk -fee human health or the environment should
exposure occur.  This Site was not divided into any operable
units, therefore this ROD is the final ROD for the Site.


               V.  SUMMARY OF SITE CHARACTERISTICS
A.   surface Water Hydrolocry

     Surface water bodies in the vicinity of the Site include
Indian Run Creek and Swiftwater Creek.  Both streams are located
a significant distance from the Site and therefore, it is not
expected that they would be adversely affected by any
contaminants which may potentially migrate from the Site.  No
other surface water bodies are known to exist within the

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 potential influence of surface water  runoff  from the Site.

 Onsite Surface Water Drainage

      The Site is located  on the  southeastern flank of a  broad
 northeast-southwest trending ridge.   The  Site is approximately
 1500  feet south of  the ridgeline and  is 10 feet  lower in
 elevation.   The ridge forms a surface water  divide.   The land to
 the north of the ridge slopes gently  to the  northwest, while  land
 to the south of the ridge slopes gently at first and then steeply
 toward the southeast.   Surface water  north of the ridge  flows
 westward to the Lehigh river.  The surface water south of the
 ridge flows eastward into Indian Run  Creek and Swiftwater Creek
 and ultimately into the Delaware River.

 B.    Geological Setting

      The project Site is  situated near the Focono Plateau
 escarpment that separates the Pocono  Plateau and Glaciated Low
 Plateau sections of the Appalachian Plateau's Physiographic
 Province.   The Pocono Plateau escarpment  represents  the  westward
 and northwestward limit of erosion by the Delaware River drainage
 and is upheld by rocks significantly  more resistant  to erosion
 than  underlying rocks  exposed east of the escarpment.  Although
 somewhat ill-defined in the Site vicinity, the. Pocono escarpment
 is expressed locally by steep slopes  and  low,  near cliff faces
 that  occur  immediately south and southeast of the Site.


 C.    Hvdroge o1ogv

      The groundwater in the vicinity  of the  level portion of  the
 Site  is found at a  depth  of 20 to 30  feet below  ground surface.
 The groundwater in  this area generally occurs in the fractured
 bedrock below the base  of  the glacial till.   However, water
 levels  may  rise above the  glacial till/bedrock contact during
 seasonally  high water  level conditions or in areas where the
 glacial till  is sufficiently thick to intercept  the  water table
 surface.  The Site  is not  located within  the floodplain  of any
 nearby  river.   Localized areas of perched groundwater, may also
 exist within  the glacial till where lenses of lower  permeability
material impede the  downward flow of water.   Based on
 observations  during  the RI,  the  groundwater  flow direction in the
 Site vicinity is toward the southeast.

      Immediately southeast  of the Site, where a  drop-off in
 surface topography  occurs  at the contact  between the Polar Gap
and Packerton Sandstones,  the depth to groundwater increases  to
 65 to 75 feet below  ground  surface.  Five-hundred feet further
southeast of  the Site in the vicinity of  the former  Conrail
automobile  transfer  facility, the depth to groundwater is
generally 40  feet below the  ground surface.   No  groundwater was

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encountered  in the glacial till in these areas.

     Within  the  Site vicinity, ground water is used as a source
of potable water for private residences and municipal supply
purposes.  The majority of private wells located within the Site
area are located hydraulically upgradient or cross-gradient.
Only three wells were identified as being dowgradient from the
Site.

     Because it  is currently being used as a source of drinking
water for local  residents, the bedrock aquifer system exhibits
the characteristics of a Class II-A aquifer according to the EPA
Groundwater  Protection Strategy (USEPA, 1986).


D.   NATURE  AND  EXTENT OF CONTAMINATION

Site Characterization

     The nature  and extent of chemical contamination at the Route
940 Drum Dump Site was characterized through extensive sampling
of surface and subsurface soils, ground water monitoring wells,
and surface  water.  In addition, sample data from residential
wells were also  reviewed.  Samples taken initially were analyzed
for U.S. EPA Target Compound List (TCL) and Target Analyte List
(TAL) constituents.  For the organic analyses, this also included
searches for non-target compounds.  In later sampling rounds, the
list of constituents tested for were reduced to those which were
previously detected or were suspected to be present.   The data,
with required sampling and analysis procedures, underwent a
rigorous quality assurance review to ensure compliance, validity,
and usability of the results. .

     All analytical data obtained in the course of the RI was
compiled, sorted by environmental medium, evaluated with respect
to analytical qualifiers (including sample specific minimum
quantification limits),  analyzed statistically to generate upper
95 percent confidence limits of the average concentration of each
chemical in  each medium; and examined in comparison to naturally
occurring background levels in accordance with U.S. EPA
guidelines.   Environmental media evaluated individually include
surface water, surficial and subsurface soils, and ground water.
The following summarizes the results of the investigation and
lists the various chemicals of concern which were identified
during the investigation of the various media.

Surficial Soil Contamination

     o    A  total of 22 surficial soil borings were taken from
          various locations both on and off the Site to
          characterize the Site surface soil contamination and to
          determine the background levels for naturally occurring

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          compounds in the Site surface soils.  The boring
          locations were based on:  a review of a soil gas survey
          which was conducted prior to the soils investigation;
          review of historical evidence of previous waste
          disposal; information from previous excavations of
          contaminated soils; and from locations which were not
          considered influenced by any of the previous factors
          and would serve as background sampling points.  Figure
          3 shows the location of the sample points for the soil
          samples.  Samples were taken from the upper 2 feet of
          the soils.  All of the samples were analyzed for
          complete Target Compound List ("TCL") Volatile Organic
          Analysis ("VGA").  Sixteen of the samples were analyzed
          for the complete Target Analyte List ("TAL") including
          metals, pesticides, PCBs and cyanides.

     o    Surface soil contaminants and their maximum
          concentrations which were detected at the Site and are
          considered contaminants of concern are:  Chloroform, 4
          parts per billion ("ppb11); Toluene, 4 ppb; Phenol, 54
          ppb; 4-methylphenol, 45 ppb; Pentachlorophenol, 160
          ppb; Endrin aldehyde; 0.28 ppb; Alpha-BHC, 0.24 ppb;
          Endrin, 1.7 ppb; Heptachlor, 0.53 ppb; Heptachlor
          epoxide, 0.24 ppb; Endosulfan, 0.8 ppb; Dieldrin, 0.51
          ppb; DDE, 2.0 ppb; Endosulfan sulfate 0.59 ppb; DDT, 1
          ppb; Methoxychlor, 3.4 ppb; Endrin ketone, 0.38 ppb;
          and Alpha-chlordane, 0.31 ppb.  Inorganic contaminants
          of concern detected in the shallow soils include:
          Arsenic 8.7 ppb; and Beryllium 0.59 ppb.

     A summary of contaminants detected in the surficial soil
samples and their range of concentrations is shown in Table 1.
                                8

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            TABLE 1
SUMMARY OF ANALYTICAL RESULTS
    SURFACE SOIL SAMPLES(1>
      ROUTE 940 DRUM SITE
  POCONO SUMMIT, PENNSYLVANIA
Chemical
Frequency
of Detec-
tion^)
Range of
Quantita-
tion
Limits
Range of
Positive
Detections
Background
Levels <3>
Organios (ug/kg)
1,1,1-
Trichloroethane
Chloroform
Methylene chloride
Toluene
4-Methyl-2-
pentanone*6*
Phenol
4 -Me thy Ipheno 1
Pentachlorophenol
4,4' -DDE
Heptachlor epoxide
1/24
4/24
1/24
3/24
1/3
1/16
1/16
1/16
5/16
3/16
6.0 - 14.0
6.0 - 14.0
6.0 - 14.0
6.0 - 14.0
10 - 200
360 - 830
360 - 830
860 - 4000
3.5 - 40
1.8 - 20
l.OJ
U - 4J
0.5J
0.9J - 4.0J
19
54J
45J
160J
0.43J -
2.0J
0.22J -
0.24J
NR«>
NR
NR
NR
NR
NR
NR
NR
NR
NR
Regulatory
Standards
or
Guidelines

NA<5>
NA
NA
NA
NA
NA
NA
NA
NA
NA

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chemical
Endosulfan I
Methoxychlor
Alpha-BHC
Endrin
Endrin ketone
Endrin aldehyde
Heptachior
Dieldrin
Endosulfan sulfate
Alpha-chlordane
4,4' -DDT

Aluminum
Arsenic
Frequency
of Detec-
tion*^
2/16
2/16
1/16
1/16
1/16
1/16
2/16
1/16
1/16
1/16
1/16
Range of
Quantita-
tion
Limits
1.8 - 20
18 - 200
1.8 - 20
3.5 - 40
3.5 - 40
3.5 - 40
1.8 - 20
3.5 - 40
3.5 - 40
1.8
- 20
3.5 - 40
inorganics
16/16
16/16
4.3 - 5.25
0.23 -
0.50
Range of
Positive
Detections
0.75J -
0.80J
1.9J - 3.4J
0.24J
1.7J
0.38J
0.28J
0.19J -
0.53J
0.51J
0.59J
0.31J
l.OJ
(mg/kg)
9430 -
14100
2.6L - 8.7
Background
Levels <3>
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Regulatory
Standards
or
Guidelines
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

0.7 - >10 (5.0)
<0.1 - 73
(19.7)
NA
NA
10

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Chemical
Barium :
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Frequency
of Detec-
tion^
16/16
12/16
2/16
15/16
16/16
16/16
16/16
16/16
16/16
16/16
16/16
5/16
Range of
Quantita-
tion
Linits
0.23 -
0.63
0.23 -
0.25
0.67 -
0.75
2.1 - 6.0
0.71 -
1.25
0.71 -
1.25
0.45 -
0.50
0.95 - 1.5
0.24 -
0.63
5.24 - 6.0
0.23 -
0.25
0.06 -
0.13
Range of
Positive
Detections
15. 9K -
46. 3K
0.25 -
0.59K
0.75K -
0.83K
22.4 - 2470
11.9 - 17.7
4.4 - 15.5
8. IK -
21. 4K
19700 -
25700
10.4 - 28.1
545 - 1150
210 - 1240
0.07 - 0.11
Background
Levels <3>
10 - 1500
(143.1)
<1.0 - 7.0
(1.3)
0.1 - 7.0
0.01 - 28
(0.15)
1 - 1000 (30)
<0.3 - 70 (10)
<1.0 - 700 (15)
0.01 - >10
(1.5)
<10 - 300
(47.1)
0.005 - 5
(0.26)
<2.0 - 7000
(700)
0.01 - 3.4
(0.1)
Regulatory
Standards
or
Guidelines
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
11

-------
Chemical
Nickel •
Potassium
Selenium
Sodium
Vanadium
Zinc
TOC

Aluminum
Barium
Calcium
Chromium
Iron
Lead
Frequency
of Detec-
tion^
13/16
16/16
2/16
1/16
16/16
16/16
4/4
1
3/3
3/3
3/3
1/3
3/3
3/3
Range of
Quantita-
tion
Limits
2.26 -
2.50
69.0 - 155
0.45 -
0.50
7.4 - 46.3
0.71 -
1.25
0.90 - 1.0

norganics - '
20.0
10.0
500
5.0
25.0
1.0
Range of
Positive
Detections
6.4 - 25.4
363 - 981
0.62L -
0.80L
452K
13. 1L -
22.1
27.7 - 37.6
0.168 -
1.04
rCLP (ug/L)
622 - 964
151 - 194
614 - 17300
6.5
55.2 - 213
2.2K - 7.3K
Background
Levels <3>
<5.0 - 700 (15)
0.005 - 3.7
(1.1)
<0.01 - 3.9
(0.5)
<0.05 - 5 (0.7)
<7.0 - 300
(40.3)
<5.0 - 2900
(74)
NR

HR
NR
NR •
NR
NR
NR
Regulatory
standards
or
Guidelines
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
12

-------
Chemical
Manganese
Potassium
Thallium
Vanadium
Zinc
Frequency
of Detec-
tion^)
3/3
2/3
3/3
1/3
3/3
Range of
Quantita-
tion
Limits
2.0
1000
2.0
5.0
10.0
Range of
Positive
Detections
238J -
2690J
1070 - 1700
2.5L - 4.6L
5.2
21.7 - 63.8
Background
Levels (3>
NR
NR
NR
NR
NR
Regulatory
Standards
or
Guidelines
NA
NA
NA
NA
NA
13

-------
1 Summary of analytical results  for samples RN-GBH-01-2, RN-GBH-02-o, RN-GBH-01-02A,
  RN-GBH-03-0,  RM-GBH-04-0,  RN-GBH-16-0,  RN-GBH-15-0,  RN-GBH-13-0,  RN-GBH-14-0,  RN-
  GBH-20-0, RN-GBH-21-0, RN-GBH-22-0,  RN-GBH-12-0,  RN-GBH-06-0,  RN-GBH-11-0, RN-GBH-
  05-0, RN-GBH-16-0, RN-GBH-17-0, RN-GBH-18-0, RN-GBH-18-2, RN-GBH-19-0, RN-GBH-07-0,
  RN-GBH-09-0,  RN-GBH-08-0, RN-GBH-10-0.  Only results  for analytes with at  least one
  positive detection are reported.

2 Number of positive detections/total number of samples.

3 Regional background  levels and  arithmetics mean for northeastern Pennsylvania as
  reported in  Element  Concentrations  in  Soils  and Other Surficial  Materials of the
  Conterminous United States.  U.S. Geological Survey Professional Paper 1270.  1984.
  The background levels and  arithmetic means for aluminum,  calcium, iron, magnesium,
  potassium,  and sodium are reported as percentages.

4 NR - Background levels not reported.

5 NA - Regulatory standard/guideline not available for this chemical in this matrix.

6 J - Analyte present.   Reported value may not be accurate or precise.

7 K - Analyte present.   Reported value may be biased high. Actual value is expected to
  be lower.

8 L - Analyte present.   Reported value may be biased low.  Actual value is expected to
  be higher.

9 Analyzed by  Toxic Characteristic Leaching Procedure  (TCLP).   Positive results are
  given in aqueous units (ug/L).
                                        14

-------
Subsurface Soil  Contamination

     o    A total  of 22 subsurface soil borings were taken from
          various  locations both on and off the site to
          characterize any contamination which may exist below
          the surface area which could: (1) serve as a
          contaminant source;  (2) migrate into the groundwater;
          or  (3) be exposed during any type of Site excavation.
          Sample locations were selected on the same criteria as
          listed above for the surface soil sampling points.   A
          total  of 47 samples taken from various depths ranging
          from 4 to 25 feet below the Site surface were taken for
          analysis.  All 47 samples taken were analyzed for TCL
          VOCs with 30 of the samples analyzed for the complete
          TAL including metals, pesticides, PCBs and cyanides.


     o    Subsurface soil contaminants and their maximum
          concentrations which were detected at the Site and are
          considered contaminants of concern are:  Chloroform, 3
          ppb; Toluene, 2 ppb; 4-methylphenol, 58 ppb;
          Pentachlorophenol, 290 ppb; Endrin aldehyde, 0.93 ppb;
          Beta-BHC, 0.71 ppb; Endrin, 0.19 ppb; Heptachlor, 0.33
          ppb; Endosulfan I, 0.69 ppb; DDE, 0.75 ppb; DDT, 2.1
          ppb; Methoxychlor, 29 ppb; Carbon disulfate, 2.0 ppb;
          Total  Xylenes, 2 ppb; Gamma-BHC, 2.6 ppb; and Gamma-
          chlordane, 0.28 ppb.  Inorganic contaminants of concern
          detected in the subsurface soils include:  Arsenic 8.9
          ppb; and Beryllium 0.75 ppb.


     A summary of contaminants detected in the subsurface soil
samples and their range of concentrations is shown in Table 2.
                                15

-------
            TABLE 2
SUMMARY OF ANALYTICAL RESULTS
   SUBSURFACE SOIL SAMPLES<1>
      ROUTE 940 DRUM SITE
  POCONO SUMMIT, PENNSYLVANIA
Chemical

Carbon disulfide
Chloroform
Toluene
Total xylenes
4-Methyl-2-
pentanone(4)
4 -Methy Ipheno 1
Pentachlorophenol
Gamma -BHC
Endrin aldehyde
4,4' -DDE
Beta-BHC
Endrin
Frequency
of Detec-
tion]2)

1/47
5/47
5/47
1/47
2/6
1/30
1/30
1/30
1/30
5/30
1/30
2/30
Range of
Quantita-
:flOH-fe
Limits
Organios
5.0 - 14.0
5.0 - 14.0
5.0 - 14.0
5.0 - 14.0
10 - 100
350 - 760
870 - 3700
1.7 - 18
3.4 - 36
3.4 - 36
1.7 - 18
3.4 - 36
Range of
Positive
Detections
(ug/kg)
2J
U - 3J
0.6J - 2J
2J
21 - 23
58J
290J
2 . 6 J
0.93J
0.26J - 0.75J
0.71J
0.17J - 0.19J
Background
Levels <3>

NR<5>
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Regulatory
Standards
or
Guidelines

NA<6>
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
               16

-------
Chemical
Methoxychlor
Gamma-Chlordane
Heptachlor
4,4'-DDT
Endosulfan I

Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Frequency
of Detec-
tion<2>
2/30
2/30
1/30
2/30
2/30

30/30
26/30
30/30
30/30
4/30
22/30
30/30
30/30
Range of
Quantita-
tion
Limits
17 - 180
1.7 - 180
1.7 - 18
3.4 - 36
1.7 - 18
inorganics
4.0 - 5.3
0.21 -
0.49
0.22 -
0.63
0.21 -
0.25
0.64 -
0.76
2.0 - 6.1
0.67 -
1.27
0.67 -
1.27
Range of
Positive
Detections
4.6J - 29J
0.26J - 0.28J
0.33J
0.47J - 2.1J
0.34J - 0.69J
(mg/xg)
7870 - 23100
0.87L - 8.9
15. 5K - 60. OK
0.28 - 0.75K
0.72K - 0.85K
17.1 - 984
8.7 - 18.2
7.2 - 27.7
Background
Levels<3>
NR
NR
NR
NR
NR

0.7 - >10
(5.0)
<0.1 - 73
(19.7)
10 - 1500
(143.1)
<1.0 - 7.0
(1.3)
0.01 - 7.0
0.001 - 28
(0.15)
1.0 - 1000
(30)
<0.3 - 70 (10)
Regulatory
Standards
or
Guidelines
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
17

-------
Chemical
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Vanadium
Frequency
of Detec-
tion^)
30/30
30/30
29/30
30/30
30/30
2/30
28/30
30/30
1/30
1/30
30/30
Range of
Quantita-
tion
Limits
0.43 -
0.51
0.89 -
1.52
0.22 -
0.64
4.9 - 6.1
0.21 -
0.25
0.05 -
0.12
2.14 -
2.54
64.7 -
157.5
0.43 -
0.51
6.92 - 47
0.67 -
1.27
Range of
Positive
Detections
2.6K - 21. 4K
17700 - 27800
2.9 - 19.2
539 - 2440
360 - 3390
0.11 - 0.13
7.2 - 26.4
571 - 1070
0.53L
52. 7K
10. 3L - 21.4
Background
Levels <3)
<1.0 - 700
(15)
0.01 - >10
(1.5)
<10 - 300
(47.1)
0.005 - 5
(0.26)
<2.0 - 7000
(700)
0.01 - 3.4
(0.1)
<5.0 - 700
(15)
0.005 - 3.7
(1-1)
<0.01 - 3.9
(0.5)
<0.05 - 5.0
(0.7)
<7.0 - 300
(40.3)
Regulatory
Standards
or
Guidelines
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
18

-------
Chemical
Zinc :
TOC
Frequency
of Detec-
tion^
30/30
3/6
Range of
Quantita-
tion
Limits
0.86 -
1.02

Range of
Positive
Detections
21.2 - 62.8
0.071 - 0.347
Background
Levels <3>
<5.0 - 2900
(74)
NR
Regulatory
standards
or
Guidelines
NA
NA
inorganics - TCLP (ug/L)
Aluminum
Barium
Calcium
Chromium
Cobalt
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Thallium
Zinc
6/6
6/6
6/6
1/6
1/6
5/6
6/6
6/6
6/6
1/6
6/6
5/6
6/6
20.0
10.0
500
5.0
5.0
25.0
1.0
500
2.0
20.0
1000
2.0
10.0
808 - 1040
170 - 236
551 - 35200
11.6
80.8
25.8 - 96.1
1.5K - 8.2K
534 - 838
657J - 3440J
; 35.9
1210 - 3520
2.0 - 3.9L
25.5 - 95.3
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
19

-------
1 Summary of analytical  results  for samples RN-GBH-02-18, RN-GBH-02-8, RN-GBH-01-16,
  RN-GBH-01-8,  RN-GBH-03-16, RN-GBH-03-10,  RN-GBH-04-8, RN-GBH-16-6, RN-GBH-06-14, RN-
  GBH-15-8, RN-GBH-15-12,  RN-GBH-13-5,  RN-GBH-13-5C, RN-GBH-13-10,  RN-GBH-14-5, RN-
  GBH-14-10, RN-GBH-20-4,  RN-GBH-20-10,  RN-GBH-20-20,  RN-GBH-21-5, RN-GBH-21-12, RN-
  GBH-22-10, RN-GBH-12-4,  RN-GBH-12-13,  RN-GBH-06-8, RN-GBH-11-8,  RN-GBH-11-14, RN-
  GBH-05-10, RN-GBH-05-18, RN-GBH-16-8,  RN-GBH-16-10, RN-GBH-16-18, RN-GBH-17-10, RN-
  GBH-17-10A,  RN-GBH-17-18, RN-GBH-18-6,  RN-GBH-18-14, RN-GBH-19-15, RN-GBH-19-25, RN-
  GBH-07-10, RN-GBH-07-15, RN-GBH-09-11, RN-GBH-09-15, RN-GBH-08-8, RN-GBH-08-8A, RN-
  GBH-08-15, RN-GBH-10-6,  RN-GH-10-14,  RN-GBH-15-8, RN-GBH-15-12.   Only results for
  analytes with at least one positive detection are reported.

2 Number of positive detections/total number of samples.

3 Regional  background levels  and arithmetic mean for northeastern  Pennsylvania as
  reported  in  Element Concentrations in Soils  and Other  Surficial  Materials of the
  Conterminous United  States.  U.S. Geological Survey Professional Paper 1270.  1984.
  The background  levels  and arithmetic  means for aluminum, calcium, iron, magnesium,
  potassium, and sodium are reported as percentages.
4 Analyzed by  Toxic Characteristic Leaching Procedure  (TCLP)
  given in aqueous  (ug/L) units.
                                         Positive results  are
5 NR - Background levels not reported.

6 NA - Regulatory standard/guideline not available for this chemical in this matrix.

7 J - Analyte present.  Reported value may not be accurate or precise.

8 K - Analyte present.  Reported value may be biased high.  Actual value is expected to
  be lower.
9 L - Analyte present.
  be higher.
Reported value may be biased low.   Actual value is expected to
                                         20

-------
Pit  Surface Water and Soil Contamination

      Both soil and water samples were taken from the three pits:
B, C,  and H.   The results  of that sampling is  discussed in the
following:

      o    A total of five  surface water samples  were taken from
           the three pits combined.   One from pit C  and two each
           from pits B and  H.   The surface water samples were
           analyzed for the complete TAL/TCL.

      o    The laboratory analysis of the five  surface water
           samples found that there were no VOCs  present at any of
           the detection limits.   One pesticide,  Delta-BHC  was
           found at a level of 0.12  ppb  in one  sample.   All
           inorganics,  that were  detected exist at levels which
           would be considered to be within naturally occurring
           background levels.

      o    A total of 21 soil  samples were taken  from the three
           pits.   Seven of  the 21 samples were  analyzed for full
           TCL/TAL and the  other  14  were analyzed for TCL (VOA).

      o    The laboratory analysis of the 21 soils samples  found
           that there were  low level volatile compounds contained
           in  the samples taken from the pits.  The  following
           compounds were found in the samples  taken with their
          maximum concentration  listed:   1,2-Dichloroethane, 4
          ppb;  2-wButanone,  31 ppb;  1,1,1-Trichloroethane,  5 ppb;
          Toluene,  4 ppb;  Total  Xylenes,  83 ppb;  Phenol, 190 ppb;
           2,4,5-Trichlorophenol,  370 ppb;  Bis(2-
          ethylhexyl)phthalate,  410 ppb.   None of the compounds
          detected at their respective  quantities exceeded any
          regulatory levels for  soils or sediment.   Some of the
           inorganics which were  detected were  found at levels
          which exceed what could be considered  naturally
          occurring background levels.   Those  were;  Calcium,
           1,260 ppm;  Copper,  50,300 ppm;  Iron, 39,000  ppm;
          Magnesium,  1,730  ppm;  and Potassium, 1,560 ppm.


     A summary of contaminants detected in the surface water and
soils  from the pits and their range of  concentrations  is shown in
Tables 3 and  4.
                                21

-------
            TABLE 3
SUMMARY OF ANALYTICAL RESULTS
      TEST PIT SAMPLES (1)
      ROUTE 940 DRUM SITE
  POCONO SUMMIT, PENNSYLVANIA
Chemical
Frequency
of
Detection
Range of
Quantita-
tion
Limits
Range of
Positive
Detections
Background
Levels <3>
Regulatory
Standards
or
Guidelines
organioa (ug/kg)
1 , 2-Dichloroethene
2-Butanone
1,1, 1-Tr ichloroethane
Toluene
Total xylenes
Phenol
2,4, 5-Trichlorophenol
Bis(2-
ethylhexyl) phthalate
1/22
2/22
1/22
1/22
2/22
1/7
1/7
3/7
6.0 - 9.0
12.0 -
17.0
8.0 - 9.0
6.0 - 9.0
6.0 - 9.0
770 - 1100
3700 -
5500
770 - 1100
4J
9J - 31J
5J
4J
9J - 83
190J
370J
200J -
410J
NR<5>
NR
NR
NR
NR
NR
NR
NR
NA<4>
NA
NA
NA
NA
NA
NA
NA
Inorganics (ng/kg)
Aluminum
8/8
4.3 - 5.85
10400 -
23800
0.7 - 710 (5.0)
NA
               22

-------
Chemical
Arsenic
Barium
Beryllium.
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Frequency
of
Detection
8/8
8/8
8/8
1/8
8/8
8/8
8/8
8/8
8/8
8/8
8/8
8/8
Range of
Quantita-
tion
Limits
0.48 -
0.65
0.24 -
0.33
0.24 -
0.33
0.72 -
0.98
2.15 -
2.93
0.72 -
0.98
0.72 -
0.98
0.59 -
0.81
0.96 - 1.3
0.24 -
0.33
5.3 - 7.2
0.24 -
0.33
Range of
Positive
Detections
6.2J -
13. 4 J
32. 5K -
64. OK
0.36 -
0.78
1.1
209 - 1260
14.8 -
31.7
10.2 -
22.5
22. 7K -
50. 3K
20500 -
39000
13.3 -
30.6
733 - 1730
427 - 1090
Background
Levels <3>
<0.1 - 73
(19.7)
10 - 1500
(143.1)
<1.0 - 7.0
(1.3)
0.01 - 7.0
0.01 - 28
(0.15)
1.0 - 1000 (30)
<0.3 - 70 (10)
<1.0 - 700 (15)
0.01 - >10
(1.5)
<10 - 300
(47.1)
0.005 - 5
(0.26)
<2.0 - 7000
(700)
Regulatory
standards
or
Guidelines
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
23

-------
Cbemioal
Mercury
Nickel
Potassium
Vanadium
Zinc
Cyanide
Frequency
of
Detection
3/8
8/8
8/8
8/8
8/8
1/8
Range of
Quant ita-
tion
Limits
0.12 -
0.16
2.4 - 3.3
69.4 -
94.3
0.72 -
0.98
0.96 - 1.3
0.59 -
0.81
Range of
Positive
Detections
0.14 -
0.70
9.4 - 20.2
848K -
1560K
15.4 -
31.9
37L -
86. 1L
1.9
Background
Levels<3>
0.01 - 3.4
(0.1)
<5.0 - 700 (15)
0.005 - 3.7
(1.1)
<7.0 - 300
(40.3)
<5.0 - 2900
(74)
MR
Regulatory
Standards
or
Guidelines
NA
NA
NA
NA
NA
NA
24

-------
1  Summary of analytical results for samples RN-GEX-01-0, RN-GEX-01-1, RN-GEX-01-2, RN-
   GEX-01-3, RN-GEX-01-4, RN-GEX-02-0, RN-GEX-02-1, RN-GEX-02-1A, RN-GEX-02-2, RN-GEX-
   02-3, RN-GEX-02-4, RN-GEX-03-2-01,  RN-GEX-03-2-02,  RN-GEX-03-2-03,  RN-GEX-03-2-04,
   RN-GEX-03-0-01, RN-GEX-03-0-02,  RN-GEX-03-0-03,  RN-GEX-03-1-01A, RN-GEX-03-1-02, RN-
   GEX-03-1-03, RN-GEX-03-1-04,  RN-GEX-03-1-01.   Only results  for analytes  with at
   least one positive detection are reported.

2  Number of positive detections/total number of samples.

3  Regional  background  levels  and arithmetic  mean  for northeastern  Pennsylvania as
   reported  in  Element  Concentrations in  Soils and Other Surficial Materials of the
   Conterminous United States.  U.S. Geological Survey Professional Paper 1270.   1984.
   The background  levels and  arithmetic  means for aluminum,  calcium, iron, magnesium,
   potassium, and sodium are reported as percentages.

4  NA - Regulatory standard/guideline not available for this chemical in this matrix.

5  NR - Background levels not reported.

6  J - Analyte present.   Reported value may not be accurate or precise.

7  K - Analyte present.   Reported value may be biased high. Actual value  is  expected  to
   be lower.

8  L - Analyte present.   Reported value may be biased low.  Actual value  is  expected  to
   be higher.
                                          25

-------
           TABLE 4

SUMMARY OF ANALYTICAL RESULTS
   SURFACE WATER SAMPLES0'
     ROUTE 940 DRUM SITE
 POCONO SUMMIT, PENNSYLVANIA
Cheaical
Frequency of
Detection"'
Range of
Quantitation
Limit*
Range of
Positive
Detections
Background
Levels«>
Regulatory
Standards or
Guidelines"'
Organic* (ug/L)
Delta-BHC

Aluminum
Barium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganeae
Nickel
Potassium
Sodium
Thallium
Vanadium
1/5

5/5
5/5
5/5
4/5
3/5
5/5
5/5
S/5
5/5
3/5
5/5
5/5
1/5
4/5
0.05
Inorganic! •
18.0
l.Q
9.0
3.0
2.0
4.0
1.0
22.0
1.0
10.0
290.0
31.0
2.0
3.0
0.12
NR<5>
NA<6>
- Total (ug/L)
555 - 11200
4.6 - 36.9
3190 - 13400
8.8 - 13.8
33.7 - 60.8
1210 - 15200
3.1 - 22.2
250 - 1200
85.3 - 446
15.4 - 81.1
859 - 3040
394J - 2770J
2.1
8.1 - 14.0
<5.0 - 1000
10 - 500
1000 - 150000
<1.0 - 5.0
<1.0 - 30
10 - 10000
<15
1000 - 50000
<1.0 - 1000
<10 - 50
1000 - 10000
500 - 120000
NR
<1.0 - 10
NA
NA
NA
33000/1700
1300/18
NA
50/82
NA
NA
610/1400
NA
NA
1.7/NA
NA
              26

-------
Chemical
Zinc

Aluminum
Arsenic
Barium
Calcium
Iron
Magnesium
Manganese
Potassium
Frequency of
Detection*2'
5/5

3/5
1/5
5/5
5/5
4/5
5/5
5/5
5/5
Range of
Quantitation
Limits
4.0
Inorganic* - 1
18.0
2.0
1.0
9.0
4.0
22.0
1.0
290.0
Range of
Positive
Detections
27.1 - 126
dissolved (ug/L)
133 - 258
2.3
46. OJ - 92. 9 J
3050 - 11900
162 - 450
245 - 609
4.4 - 37.9
555 - 1680
Background
<10 - 2000

<5.0 - 1000
<1.0 - 3.0
10 - 500
1000 - 150000
10 - 10000
1000 - 50000
<1.0 - 1000
1000 - 10000
Regulatory
Standards or
Guidelines"1
NA/120

NA
0.018/360
NA
NA
NA
NA
NA
NA
27

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l  Summary of analytical results for samples RN-GSW-oi, RN-GSW-02, RN-GSW-03-i, RN-GSW-
   03-2,  and RN-GSW-03-2A.   Only  results  for  analytes  with  at least  one positive
   detection are reported.

2  Number of positive detections/total number of samples.

3  Regional background levels as reported in The Soil  Chemistry  of Hazardous Materials.
   Hazardous Materials Control Research Institute.  1988.

4  Regulatory standards and/or guidelines as reported  in Drinking  Water Regulations and
   Health Advisories.   U.S.  Environmental Protection  Agency,  November 1991.  Reported
   as Ambient Hater Quality  Criteria for: protection of human  health/protection of
   aquatic organisms.

5  NR - Background levels not reported.

6  NA - Regulatory standard/guideline not available for this chemical in this matrix.

7  J - Analyte present. Reported value may not be accurate or precise.
                                          28

-------
Ground Water Contamination
          The deep and shallow monitoring wells at the Site shown
          on Figure 4 were sampled on three different occasions
          during the RI.  The first sampling event occurred
          during a preliminary hazardous substance inventory
          ("HSI") which was done in order to identify
          contaminants of concern prior to installation of
          additional wells and a full round of sampling.  This
          round was completed in December 1990.  Three existing
          wells MW-1, MW-4, and MW-5 were selected as sampling
          wells since they had historically exhibited the highest
          concentration of volatile contaminants.  The three
          samples were all submitted for full TCL/TAL analysis
          including total and dissolved metals, pesticides,  PCBs,
          and cyanides.

          A review of the results from the HSI sampling indicated
          that there were no VOC's present above a level of
          concern,  however, due to detection of Vinyl Chloride
          during a soil gas investigation a second round of
          sampling was done using Method 524 to analyze the
          samples.   Method 524 has a lower detection limit for
          vinyl chloride than Method 601/602,  which was used
          during the initial sampling round.  MW-1,  MW-3,  MW-4,
          and MW-ll were sampled during this second round.  These
          samples were taken from March 27,  1991 to April 2,
          1991.

          A final and comprehensive round of groundwater sampling
          of both existing and new wells took place between April
          29,  1992  and May 7,  1992.   A total of 25 samples were
          taken from the shallow and deep monitoring wells.   The
          samples were analyzed for the full TAL/TCL including
          total and dissolved metals,  pesticides, PCBs,  and
          cyanide.
          The analysis of  the monitoring well  samples  was  broken
          down into two groupings  so as to  examine the shallow
          bedrock aquifer  and the  intermediate/deep aquifer.   The
          laboratory analysis results of the deeper aquifer will
          be  discussed in  the next section.  A total of 18
          samples including duplicates were taken   from the
          shallow bedrock  wells, numbers MW-1,  MW-2, MW-3, MW-4,
          MW-5, MW-8A, MW-10A, MW-12A, MW-14A,  MW-15A, and MW-
          16A,  and were analyzed for the complete  TCL  with 14 of
          the 18  samples being analyzed for total  and  dissolved
          metals,  pesticides, PCB's and cyanide.   The  results of
          the TCL analysis detected 1,1,1-Trichloroethane  in  5 of
          the 18  samples in concentrations  ranging from 0.5  -
          2.0 ppb,  1,1-Dichloroethane in 1  sample  at a

                               29

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        FIGURE 3

  Shallow Monitoring Wells
Inorganic Chemicals of Concern

ROUTE 940  SUPERFUND SITE

    POCONO SUMMIT, PA

-------
                                   FIGURE 4

                              Deep Monitoring Wells
                          Inorganic Chemicals of Concern
                           ROUTE  940 SUPERFUND  SITE

                               POCONO  SUMMIT, PA
200
100
409
500

-------
    FIGURE 5

    Private Well
 Inorganic Chemicals
    of Concern

    ROUTE  940
  SUPERFUND SITE

POCONO SUMMIT, PA
         •

         I
  Wr  IN MM INI In* Ml I
  " " '  1*MhH BMH " ~
      iMi Nm

-------
concentration of 0.6 ppb, Cis-l,2-dichloroethene  in 2
samples at a concentration ranging from 0.5  - 2.0 ppb,
Trichloroethene in 10 samples ranging  in concentration
of 0.3 - 4.0 ppb, Total Xylenes in 1 sample  at a
concentration of 1.0 ppb and Dimethylphthalate in 2
samples ranging in concentration from  5.0 -  32 ppb.
For total metals, (samples which are unfiltered prior
to analysis) some of the samples had concentrations
which exceeded levels which would normally be
considered maximum background levels.  Those metals
with the maximum concentration found in any  one sample
were: Aluminum, 64,000 ppb; Arsenic, 9.0 ppb; Barium,
531 ppb; Cadmium, 8.1 ppb; Chromium, 97.5 ppb; Cobalt,
159 ppb; Copper, 449 ppb; Iron, 122,000 ppb; Lead, 366
ppb; Manganese, 24,000 ppb; and Nickel, 150  ppb.  For
dissolved metals, (samples that are filtered prior to
analysis) Manganese at 12,100 ppb was  found  at a  level
higher than would be expected for background
conditions.
A total of 7 samples including duplicates from the deep
bedrock wells, numbers MW-6, MW-7, MW-9, MW-11, MW-13,
MW-16B, and MW-16C, were analyzed for the complete TCL
with 6 samples being analyzed for the complete TAL
including total and dissolved metals, pesticides, PCBs
and cyanides.  The Volatile 1,1,1-Trichloroethane was
found in all samples with concentrations ranging from
0.65 - 1.0 ppb.  Also found were Cis-l,2-dichloroethene
in 5 samples in concentrations ranging from 0.7 -2.0
ppb, Trichloroethene* in six samples ranging from 0.6 -
4 ppb, and Toluene in 1 sample at a concentration of
0.6 ppb.  For total metals, (samples which are
unfiltered prior to analysis)  some of the samples had
concentrations which exceeded levels which would
normally be considered maximum background levels.
Those metals with the maximum concentration found in
any one sample were: Aluminum, 1,690 ppb; Arsenic, 15.0
ppb; Cadmium, 2.4 ppb; Chromium, 12.1 ppb; Iron, 82,200
ppb; Lead, 21.7 ppb; Manganese, 1,200 ppb; and Nickel,
150 ppb.  For dissolved metals, (samples that are
filtered prior to analysis), there were no samples
which exceeded any level which would be considered
above a background level.
A total of 10 residential wells were sampled as part of
the RI.  The wells selected were wells which had
previously been sampled by BCM in 1987 in addition to
three additional wells of  citizens who reside near the
Site and had requested that sampling be done.  The

                      30

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           veils  selected were  located upgradient cross-gradient
           and downgradient  of  the  Site.   The residential well
           locations  closest to the Site  are shown on  Figure  5.  A
           total  of 11  samples  were taken from the wells.   Both
           total  and  dissolved  metal analyses were done  on  all
           samples in addition  to full TCL VOC analysis.


      o     The analysis of the  residential wells  found that in 7
           of  the samples 1,1,1 Trichloroethane was present in a
           range  of 0.8 - 3.0 ppb.   This  amount is well  below the
           established  Maximum  Contaminant Limit  of 200  ppb as
           established  by the Safe  Drinking Water Act, 42 U.S.C.
           §S  300f-300j .  The  analysis also found that  several of
           the residential wells have total metals exceeding  what
           would  normally be  considered background levels.  Those
           metals with  their  maximum concentration are:  Copper,
           459  ppb; and Manganese,  1110 ppb.  Neither  of these
           metals has any applicable health-based levels which
           apply.  For  dissolved metals,  the same two  metals
           Copper, 488  ppb, and Manganese 1,240 exceeded the
           expected maximum background levels.  It should be  noted
           that Thallium, another metal,  was found in  wells
           upgradient and downgradient of the Site at  1.0 ppb in
           both the total and dissolved phases analysis and while
           there  is no  background level reported  for Thallium for
           this region, there is a proposed Federal Maximum
           Contaminant  Limit  ("MCL"  of 2  ppb for  Thallium under
           the  Safe Drinking  Water Act.

     A summary of contaminants  detected  and their range of
concentrations found in the  ground water samples  is shown  in
Tables 5-7.  Figure  3 shows the levels of inorganic chemicals
found in the various shallow monitoring  wells.   Figure 4 shows
the levels of  inorganic chemicals in  the deep monitoring wells.
Figure 5 shows the levels of inorganic chemicals  found in  the
residential wells.
                               31

-------
             TABLE 5
  SUMMARY OF ANALYTICAL RESULTS
SHALLOW MONITORING WELL SAMPLES(1)
       ROUTE 940 DRUM SITE
   POCONO SUMMIT, PENNSYLVANIA
Chemical
Frequency of
Detection

1, 1, 1-Trichloroethane
1, 1-Dichloroethane
Cis-1 , 2-dichloroethene
Trichloroethene
Total xylenee
oimethylphthalate
5/18
1/18
2/18
10/18
1/18
2/14
Range of
Quantitation
Limits
Range of
Positive
Detections
Organics (ug/L)
1.0
1.0
1.0
1.0
1.0
.10.0
0.5J - 2.0
0.6J
0.5J - 2.0
0.3J - 4
1.0
5.0J - 32
Background
Levels'3*
Regulatory
Standards or
Guidelines'4'

NR<5>
NR
NR
NR
NR
NR
200
NA<6>
70
5
10000
NA
Inorganics - Total (ug/L)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
cobalt
Copper
iron
14/14
3/14
5/14
14/14
7/14
2/14
14/14
10/14
11/14
6/14
14/14
11.0 - 18.0
6.0 - 22.0
2.0
1.0 - 2.0
1.0
2.0 - 3.0
6.0 - 9.0
3.0
3.0
2.0 - 11.0
4.0 - 7.0
228 - 64000
180K - 205K
2.5 - 9.0
10.1 - 531K
;i.6 - 6.3K
3.4 - 8.1
2350 - 32400
3.1 - 97.5
3.2 - 159
30.4 - 449K
334 - 122000
<5.0 - 1000
NR
<1.0 - 3.0
10 - 500
<10
<1.0
1000 - 150000
<1.0 - 5.0
<10
<1.0 - 30
10 - 10000
NA
10
50
2000
1
5
NA
100
NA
NA
NA
                32

-------
Chemical
Lead
Magnesium ;
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
Frequency of
Detection
10/14
14/14
14/14
3/14
9/14
11/14
2/14
14/14
11/14
9/14
Range of
Quant it at ion
Limit*
1.0
9.0 - 22.0
1.0
0.2
3.0 - 10.0
60.0 - 290.0
2.0 - 4.0
13.0 - 31.0
2.0 - 3.0
3.0 - 4.0
Range of
Positive
Detections
1.1J - 366J
830 - 24100
61.3 - 24400L
0.23 - 0.44
7.9 - 150K
650 - 7650
2.4L - 3.0
3160 - 19300
2.3 - 90K
14.9 - 383
Background
<15
1000 - 50000
<1.0 - 1000
<1.0
<10 - 50
1000 - 10000
<5.0
500 - 120000
<1.0 - 10
<10 - 2000
Regulatory
Standards or
Guidelines"'
15
NA
NA
2
100
NA
200
NA
110
9000
Inorganic* - Dissolved (ug/L)
Aluminum
Barium
Calcium
Cobalt
Iron
Magnesium
Manganese
Nickel
Potassium
Sodium
2/14
9/14
14/14
3/14
4/14
14/14
13/14
5/14
8/14
14/14
11.0 - 18.0
1.0 - 2.0
6.0 - 9.0
3.0
4.0 - 7.0
9.0 - 22.0
1.0
3.0 - 10.0
60.0 - 290.0
13.0 - 31.0
23.6 - 24.9
37.1 - 124
2580 - 17800
6.3 - 8.6
48.8 - 117
787 - 2400
60. 5 J - 12100
3.0 - 8.6
433 - 1720
3680 - 22000
<5.0 - 1000
10 - 500
1000 - 150000
<10
10 - 10000
1000 - 50000
<1.0 - 1000
<10 - 50
1000 - 10000
500 - 120000
NA
2000
NA
NA
NA
NA
NA
100
NA
NA
33

-------
Chenical
Thallium
zinc
Frequency of
Detection
1/14
9/14
Range of
Quantisation
Limit*
1.0 - 2.0
3.0 - 4.0
Range of
Positive
Detections
2.2
22.6 - 51.0
Background
Levels"'
NR
<10 - 2000
Regulatory
Standards or
Guidelines*4'
2
9000
1  Summary of analytical results for samples RN-GMW-08A-21, RN-GMW-15A-35, RN-GMW-12A-62, RN-GMW-14A-13,
   RN-GMW-10A-62, RN-GMW-01-19, RN-GMW-04-17,  RN-GMW-04-17A,  RN-GMW-02-18,  RN-GMW-05-21,  RN-GMW-03-15,
   RN^GKW-16A-36, RN-GMW-16A-36A,  RN-GMW-16B-11^ RN-GMW-1,  RN-GMW-1A,  RN-GMW-3,  and RN-GMW-4.   Only
   results for analytes with /it;!least on6 positive detection are reported.
2  Number of positive detections/total number of samples.

3  Regional background  levels as  reported in The  Soil Chemistry  of  Hazardous Materials.
   Materials Control Research Institute.  1988.
Hazardous
4  Regulatory  standards  and/or  guidelines  as  reported  in  Drinking  Water  Regulations  and  Health
   Advisories.  U.S. Environmental Protection Agency, November 1991.

5  NR - Background levels not reported.

6  NA - Regulatory standard/guideline not available for this chemical in this matrix

7  J - Analyte present.  Reported value may not be accurate or precise.

8  K - Analyte present.  Reported value may be biased high. Actual value is expected to be lower.

9  L - Analyte present.  Reported value may be biased low.  Actual value is expected to be higher.
                                                 34

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           TABLE 6
SUMMARY OP ANALYTICAL RESULTS
   DEEP MONITORIMO WELLS*1'
     ROUTE 940 DRUM SITE
 POCOMO SUMMIT, PENNSYLVANIA
ChMical

1,1, 1-Trichloroethane
Cia-1, 2-dichloroethene
Trichloroethene
Toluene
Frequency of
Detection*21
Range of
Quantitation
Limits
Range of
Positive
Detections
Background
Levels"'
Regulatory
Standards or
Guidelines"'
Organic* (ug/L)
7/7
5/7
6/7
1/7
1.0
1.0
1.0
1.0
0.65J - 1.0
0.7J - 2.0
0.6J - 4
0.6J
NR<5>
NR
NR
NR
200
70
5
1000
Inorganics - Total (ug/L)
Aluminum
Antimony
Arsenic
Barium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
6/6
1/6
1/6
5/6
1/6
6/6
1/6
2/6
2/6
6/61
4/6
11.0 - 18.0
6.0 - 22.0
2.0
1.0 - 2.0
2.0 - 3.0
6.0 - 9.0
3.0
3.0
2.0 - 11.0
4.0 - 7.0
1.0
115 - 1690
23.2
15.0
14.9 - 87.5
2.4
_^270 - 37600
12.1
3.9 - 5.1
12.9 - 14.5
792 - 82200
1.1J - 21. 7 J
<5. 0-1000
NR
<1.0 - 3.0
10 - 500
<1.0
1000 - 150000
<1.0 - 5.0
<10
<1.0 - 30
10 - 10000
<15
NA<6>
10
50
2000
5
NA
100
NA
NA
NA
15
              35

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Chemical
Magnesium
Manganese
Nickel
Potassium
Sodium
Vanadium
Zinc
Frequency of
Detection'2'
6/6
6/6
3/6
4/6
6/6
3/6
4/6
Range of
Quantisation
Limits
9.0 - 22.0
1.0
3.0 - 10.0
60.0 - 290.0
13.0 - 31.0
2.0 - 3.0
3.0 - 4.0
Range of
Positive
Detections
1620 - 4350
148L - 1200L
6.9 - 16.3
613 - 1070
4870 - 21300
2.5 - 9.3
19.1 - 194
Background
Levels'3*
1000 - 50000
<1.0 - 1000
<10 - 50
1000 - 10000
500 - 120000
<1.0 - 10
<10 - 2000
Regulatory
Standards or
Guidelines"*
NA
NA
100
NA
NA
110
9000
Inorganic! - Dissolved (ug/L)
Barium
Calcium
Iron
Magnesium
Manganese
Nickel
Potassium
Sodium
Zinc
3/6
6/6
2/6
6/6
6/6
1/6
3/6
5/6
3/6
1.0 - 2.0
6.0 - 9.0
4.0 - 7.0
9.0 - 22.0
1.0
3.0 - 10.0
60.0 - 290.0
13.0 - 31.0
3.0 - 4.0
19.1 - 126
4220 - 36700
131 - 1090
1380 - 4140
39.5 - 468 J
4.1
497 - 935
7050 - 23000
60.8 - 182
10 - 500
1000 - 150000
10 - 10000
1000 - 50000
<1.0 - 1000
<10 - 50
1000 - 10000
500 - 120000
<10 - 2000
2000
NA
NA
NA
NA
100
NA
NA
9000
36

-------
1 Summary of analytical results for samples RN-GMW-06-47, RN-GMW-li-29, RN-GMW-13-48,
  RN-GMW-09-28,  RN-GMW-07-51,  RN-GMW-16C-187,   and  RN-GMW-11.    Only  results  for
  analytes with at least one positive detection are reported.
2 Number of positive detections/total number of samples.
3 Regional background levels as reported in The  Soil Chemistry of Hazardous Materials.
  Hazardous Materials Control Research Institute.  1988.
4 Regulatory standards and/or guidelines as reported in Drinking Water Regulations and
  Health Advisories.  U.S. Environmental Protection Agency,  November 1991.
5 NR - Background levels not reported.
6 NA - Regulatory standard/guideline not available for this chemical in this matrix.
7 J - Analyte present.  Reported value may not be accurate or precise.
8 K - Analyte present.  Reported value may be biased high. Actual value is expected  to
  be lower.
9 L - Analyte present.  Reported value may be biased low.  Actual value is expected  to
  be higher.
                                         37

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           TABLE 7

SUMMARY OP ANALYTICAL RESULTS
 RESIDENTIAL WELL SAMPLES"*
     ROUTE 940 DRUM SITE
 POCONO SUMMIT, PENNSYLVANIA
Cheaieal

1, 1, 1-Trichloroethane

Aluminum
Barium
Calcium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Potassium
Sodium
Thallium
Zinc
Frequency of
Detection"*

7/11

1/11
7/11
11/11
1/11
9/11
5/11
8/11
11/11
11/11
11/11
11/11
3/11
5/11
Range of
Quantitation
Limits
Range of
Positive
Detections
Background
Levels"*
Regulatory
Standards or
Guidelines'4*
Organic* (ug/L)
1.0
0.8J-3.0
Inorganics - Total (ug/L)
11.0
2.0
6.0
3.0
11.0
7.0
1.0
9.0
1.0
60.0
13.0
1.0
2.0
330
15.1-83.1
2060-22500
6.5
14.9-459
371K-2230K
2.3-7.5
1350-2320
2.8-1110
378-1800
5310-76200
l.OL
27.4-1390
NR<5>
200

<5.0 - 1000
10 - 500
1000 - 150000
<10
<1.0 - 30
10 - 10000
<15
1000 - 50000
<1.0 - 1000
1000 - 10000
500 - 120000
NR
<10 - 2000
NA<»
2000
NA
HA
NA
NA
15
NA
NA
HA
NA
2.0
9000
Inorganics - Dissolved (ug/L)
             38

-------
Cheaical
Aluminum
Barium
Calcium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Potassium
Sodium
Thallium
Zinc
Frequency of
Detection"1
1/11
7/11
11/11
1/11
9/11
3/11
5/11
11/11
11/11
2/11
10/11
11/11
4/11
3/11
Range of
Quantitation
Limits
11.0
2.0
6.0
3.0
11.0
7.0
1.0
9.0
1.0
0.2
60.00
13.0
1.0
2.0
Range of
Positive
Detections
398
29.6-62.6
2090-23200
7.3
14.7-448
271-488
1.6-5.7
1450-2400
2.5-1240
0.29L-0.31L
397-1900
5150-81300
1.0-l.OL
42.6-1340
Background
Levels"'
<5.0 - 1000
10 - 500
1000 - 150000
<10
<1.0-30
10 - 10000
<15
1000 - SOOOO
<1.0 - 1000
<1.0
1000 - 10000
500-120000
NR
<10-2000
Regulatory
Standards or
Guidelines"'
NA
2000
NA
NA
NA
NA
15
NA
NA
2.0
NA
NA
2.0
9000
39

-------
l  summary of analytical results for samples RN-GRW-01, RN-GRW-02, RN-GRW-03-i, RN-GRW-
   04,  RN-GRW-05, RN-GRW-06, RN-GRW-06A,  RN-GRW-07,  RN-GRW-08,  RN-GRW-09,  and RN-GRW-
   10.   Only results for analytes with at least one positive detection are reported.

2  Number of positive detections/total number of samples.

3  Regional background levels as reported in The Soil Chemistry of Hazardous Materials.
   Hazardous Materials Control Research Institute.  1988.

4  Regulatory standards and/or guidelines as reported in  Drinking Water Regulations and
   Health Advisories.   U.S.  Environmental Protection Agency,  November 1991.  Reported
   as Ambient  Water Quality Criteria for: protection of  human health/protection of
   aquatic organisms.

5  NR - Background levels not reported.

6  NA -, Regulatory standard/guideline not available for this chemical in this matrix.

7  J - Analyte present.  Reported value may not be accurate or precise.

8  K - Analyte present.  Reported value may be biased high.  Actual value  is expected to
   be lower.

9  L - Analyte present.  Reported value may be biased low.   Actual value  is expected to
   be higher.
                                          40

-------
 Contamination Migration Paths


      Based on the information developed during the RI,  it can be
 stated that the previously known  Site contaminants have been
 reduced to levels which do not pose  any significant adverse
 health effects.   Therefore, while the ground water would be  a
 potential pathway for contamination  migration,  the level of
 residual contaminants remaining within the  soils  and ground  water
 media are not considered significant enough that  their  migration
 would pose a threat  to human  health  or the  environment.

 Estimated Contaminant Quantity

      Based on an analysis of  historical photographs of  the Site,
 it was estimated that approximately  600 drums  of  unknown origin
 and  content at one time occupied  the Site.  As  the majority  of
 these drums were removed prior to EPA and PADER involvement  at
 the  Site,  their  contents and  total volume was  never determined.
 The  remaining crushed drums that  were found later on the Site by
 EPA  and PADER did not provide any information  as  to their
 contents.   Based on  the analysis  of  the contaminants which were
 found in the soils and ground water, it can only  be surmised that
 the  drums housed some type of materials containing various VOCs.
 The  amount of contaminated soil caused by the  leaking and crushed
 drums cannot be  determined with certainty because a majority of
 the  soil estimated at 300  tons was removed  prior  to the RI/RA.
 The  onsite shredded  soil piles, consisting  of approximately  4,000
 cubic yards,  were likely contaminated with  the  same chemicals as
 the  soils  removed from the Site.  Based on  the  results  of the RI,
 the  remaining soils  on the Site are  not contaminated to any
 significant level.
                    VI.   SUMMARY OF SITE RISKS

A.  Human Health Effects of Site Contamination

     As part of the RI performed for the Route 940 Drum Dump
Site, an RA was conducted to evaluate the potential impacts of
the Site on human health and the environment.  In the RA, a set
of chemicals of potential concern were selected for detailed
evaluation based on the RI sampling results.  Contaminants of
concern were selected separately for three environmental media;
ground water, surface water, and soil.

     The RA then evaluated the potential human health risks
associated with exposure to these chemicals of concern for each
media.
                                41

-------
Exposure Analysis

     Exposure pathways considered for the purpose of evaluating
Site risks include:  (1) incidental ingestion and dermal
absorption from direct contact with contaminated surface soils;
and (2) future consumption of contaminated ground water which may
be utilized as a potable supply.  Other potential pathways of
exposure such as inhalation of organics during showering or
washing were found to have very low levels of contaminants which
would not pose a threat to human health at any time period.

     The next step in the exposure analysis process involved
quantification of the magnitude, frequency and duration of
exposure for the populations, and exposure pathways selected for
evaluation.  Generally, exposure point concentrations of
chemicals of concern were based upon the 95 percent upper
confidence limit of the average, so as to produce an estimate of
reasonable maximum exposure (RME).   Intake factors (e.g., amount
of soil ingestion, rate of dermal contact, exposure frequency,
and duration) were selected in accordance with EPA risk
assessment guidance so that the combination of all variables
conservatively results in the maximum exposure that can be
reasonably expected to occur at the Site.

Toxicity and Risk Characterization

     Projected intakes for each risk scenario and each chemical
were then compared to acceptable intake levels for carcinogenic
and non-carcinogenic effects.  With respect to projected intake
levels for non-carcinogenic compounds, a comparison was made to
risk reference doses (RfDs).  RfDs have been developed by EPA for
chronic (e.g. lifetime) and/or- subchronic (less than lifetime)
exposure to chemicals based on an estimate that is likely to be
without an appreciable risk of deleterious effects.  The chronic
RfD for a chemical is an estimate of an acceptable lifetime daily
exposure level for the human population, including sensitive
subpopulations, without an appreciable risk of deleterious
effects.  The potential for non-cancer health effects is
evaluated by comparing an exposure level over a specified time
period with the RfD derived by the EPA for a similar exposure
period.  This ratio of exposure is called the hazard quotient.

     The non-cancer hazard quotient assumes that there is a
threshold level of exposure (i.e.  RfD) below which it is unlikely
for even the most sensitive populations to experience adverse
health effects.  If the exposure level exceeds the threshold,
(i.e., the hazard quotient exceeds a value greater than 1.0)
there may be concern for potential non-cancer health effects.
The more the value of the hazard quotient exceeds one, the
greater the level of concern for potential health impacts.

     To assess the overall potential for non-cancer effects posed

                                42

-------
by multiple chemicals, a Hazard Index (HI) is derived by summing
•the individual hazard quotients.  This approach assumes
additivity of critical effects of multiple chemicals.  This is
appropriate for compounds that induce the same effect by the same
mechanism of action.  EPA considers any HI exceeding one to be an
unacceptable risk to human health.

     For carcinogens, risks are estimated as the incremental
probability of an individual developing cancer over a lifetime as
a result of exposure to a potential human carcinogen.  The EPA's
Carcinogen Assessment Group has developed carcinogen potency
factors (CPFs) for suspected and known human carcinogens which
are used to convert daily intake averaged over a lifetime of
exposure directly to incremental risk.  The CPF is generally
expressed in units of risk per milligram chemical per kilogram
body weight per day of exposure (i.e., risk units per mg/kg/day).
The CPF or slope factor is the upper 95th percentile confidence
limit of the extrapolation (slope) from high-dosed animal data to
very much lower doses in humans.  The use of the upper limit
produces a risk estimate that has a 95 percent probability of
exceeding the actual risk, which may actually be zero.  For
exposure to multiple carcinogens,  the upper limits of cancer risk
are summed to derive a total cancer risk.  Cancer risks beyond
the generally acceptable risk range of 1 X 10E-4 to 1 X 10E-6
(i.e. a 1.0 X 10E-6 level indicates one additional chance in
1,000,000 that an individual will develop cancer) are considered
an unacceptable risk to human health.

     In the baseline RA, the following exposure scenarios were
considered; ingestion of chemicals in drinking water; dermal
contact with chemicals in water during bathing; inhalation of
volatile chemicals while showering or bathing; and ingestion of,
or dermal contact with chemicals in soil.

     Contaminants of concern for residential well water include
the following metals:  barium; cobalt; copper; manganese;
thallium; and zinc.  The only organic contaminant of concern
identified for the residential  well water was 1,1,1-
trichloroethane.  Contaminants of concern in the monitoring well
water include the same metals as in the residential well water
and the following organics:  1,1,1-trichloroethane; cis-1,2,-
dichloroethene; trichloroethene; toluene; and total xylenes.

     Contaminants of concern for the onsite soils at the Site
include the metals:  aluminum; arsenic; barium; beryllium;
cadmium; chromium; cobalt; copper; manganese; selenium; vanadium;
and zinc.  The following organics and pesticides are contaminants
of concern for onsite soils: chloroform; pentachlorophenol;
toluene; 4-methylphenol; endrin; endrin aldehyde; endosulfan I;
endosulfan sulfate; dieldrin; alpha-BHC; beta-BHC; gamma BHC;
heptachlor; heptachlor epoxide; dieldrin; DDE; DDT; gamma
chlordane; and alpha chlordane.

                                43

-------
      The following summarizes the risk evaluation for the various
 exposure pathways that were done.  It was determined that
 ingestion,  inhalation, and dermal contact with groundwater,  and
 ingestion and dermal contact with Site soils are the only
 pathways where significant exposure could occur.   These tables
 show,  for the groundwater and soils media,  population targeted,
 and the chemicals of concern (chemicals which posed an increased
 cancer risk of 10E-6 or greater or an individual hazard index
 greater than 1) ,  their RME which is the upper 95th percentile
 confidence interval (CI)  of their average concentration,  the base
 risk posed by the chemicals of concern,  a clean-up level (based
 on  a health-based standard)  and the residual risk level remaining
 after attaining that clean-up level.

 Media/Population:  Suxfieial Soils/Adults
Concentration i
Chemical Units/Basis*
mg/kg
Arsenic RME 6.54
Beryllium RME 0.42
n Base Risk/ Clean-up <
HI Level
8.41E-6 N/A1
1.34E-6 N/A1
Slean-up Risk/
HI
N/A2
N/A2
a/ RME -  95% CI  of  the mean unknown.
I/ No clean level exists  for this contaminant in soils.
2/ No clean-up level residual risk determined as no clean-up
level designated.

      Media/Population: Surficial soils/Children
Concentration in Base Risk/
Chemical Units/Basis* HI
mg/kg
Arsenic
Beryllium
RME 6.54
RME 0.42
1.35E-5
2.15E-6
Clean-up Clean-up .Risk/
Level HI
N/A1
N/A1
N/A2
N/A2
a/ RME = 95% CI of the mean unknown.
I/ No clean level exists for this contaminant in soils.
2/ No clean-up level residual risk determined as no clean-up
level designated.

      Media/Population: Subsurface Soils/Adults


           Concentration in  Base Risk/  Clean-up  Clean-up Risk/
Chemical     Units/Basis'       HI        Level          HI
                 mg/kg                    mg/kg
Arsenic       RME 7.93        1.06E-5     N/A1          N/A2
Berylium      RME 0.59        1.88E-6     N/A1          N/A2

                                44

-------
 a/  RME =  95%  CI  of the mean  unknown.
 I/  No  clean level exists  for this contaminant  in  soils.
 2/  No  clean-up level residual risk determined  as  no  clean-up
 level  designated.

       Media/Population: Subsurface Soils/Children

Chemical

Arsenic
Beryl ium
Concentration in
Units/Basis*
mg/kg
RME 7.93
RME 0.59
Base Risk/
HI

1.70E-5
3.01E-6
Clean-up <
Level
*g/*g
N/A1
N/A1
3 lean-up Risk/
HI

N/A*
N/A2
a/ RME = 95% CI of the mean unknown.
I/ No clean level exists for this contaminant in soils.
2/ No clean-up level residual risk determined as no clean-up
level designated.

     Media/Population: Groundvater /Monitor ing Wells/ Adults
Chemical
Manganese
Concentration in
Units/Basis*
ug/kg
RME^i2 , 100
Base Risk/
HI
3.32
Clean-up
Level"
N/A1
Clean-up Risk/
HI
N/A2
a/ RME = 95% CI of the mean unknown.
I/ No clean level exists for this contaminant in groundwater.
2/ No clean-up level residual risk determined as no clean-up
level designated.

      Media/Population: Groundvater/Monitoring Wells/Children
Concentration in Base Risk/ Clean-up Clean-up Risk/
Chemical Units/Basis' HI Level HI
ug/kg
Manganese RME 12,100 15.5 N/A1
Thallium RME 2.2 3.52 2.03
N/A2
N/A4
a/ RME = 95% CI of the mean unknown.
I/ No clean level exists for this contaminant in groundwater.
2/ No clean-up level residual risk determined as no clean-up
level designated.
3/ Proposed MCL
4/ No clean-up level determined as RME less than clean-up level.
                                45

-------
      Media/Population: Groundvater/Residential Wells/children


           Concentration in  Base Risk/  Clean-up  Clean-up Risk/
Chemical

Copper
Manganese
Thallium
Units/Basis*
ug/kg
RME 218.94
RME 419.09
RME 0.75
HI



1.2
Level
»g/*g
N/A*
N/Aj
2.03
HI

N/A*
N/A*
N/A4
a/ RME = 95% CI of the mean unknown.
I/ No clean level exists for this contaminant in groundwater.
2/ No clean-up level residual risk determined as no clean-up
level designated.
3/ Proposed MCL
4/ No clean-up level determined as RME less than clean-up level.


     It was found during the RA that the HI exceeded 1.0 for
several exposure scenarios.  The majority of these occurrences
were for ingestion of groundwater either from a Site monitoring
well or residential wells.  The reason for the HI exceeding 1.0
in all of the exposure scenarios was caused by the naturally
occurring elements: copper, manganese and thallium which were
found in the groundwater from wells located on the Site,
upgradient, crossgradient and downgradient from the Site.  Even
wells which were located a minimum of one-half mile upgradient
from the Site show the same levels of these compounds existing in
the groundwater.  The review of the available data indicates that
the background levels for these compounds are normal for this
geographical region.

     In calculating the risks at the Site, the exposures
evaluated assume more extensive contact with the Site
contaminants than is currently occurring, or is likely to occur
in the future, and as such are conservative.

     The following tables, numbers 8-11, summarize the various
risk scenarios and the total risk number associated with each
exposure scenario.  Based on the baseline risk assessment, there
is no exposure scenario which would pose an increased cancer risk
above a 1 X 10E-4 risk factor.  (This is the level of increased
cancer risk which EPA considers to be unacceptable and would
therefore warrant some type of remediation to lower or eliminate
the risk posed).  The total increased risk for cancer for an
adult exposed to surface soils and groundwater from the
monitoring wells is 1.18 X 10E-5, which is an acceptable risk
level.  For children the same exposure scenario poses a risk of
1.69 x 10E-5.  The total lifetime exposure cancer risk is 2.44 X
10E-5.  For non-carcinogenic risks, there are no health hazard
indices above 1.0 for any exposure scenarios involving Site
soils.  For groundwater however, the health hazard index exceeds

                                46

-------
                                          TABLE 8
                                      Risk Summaiy Tabta
                        TOTAL RISKS AT THE ROUTE 940 DRUM DUMP SITE
                                    FUTURE USE SCENARIO
                                   NONCARCINOGENIC RISK


                                     ADULTS        CHILDREN       LIFETIME SEGMENT

INORGANIC SOILS TOTAL               7.02E-02         5.63E-01          6.19E-01
ORGANIC SOILS TOTAL                 3J9E-03         Z87E-02          3.16E-02
SURFACE SOILS TOTAL                 738E-02         5.92E-01          6J1E-01
MW INORGANIC TOTAL                 4.17E+00        1.95E+01          N/A
MW ORGANIC TOTAL                   1.15E-02         Z57E-02          N/A

MONITORING WELLS                   4.18E+00        1.95E+01          N/A

TOTAL                               4.26E+00        2.01E+01          6.51E-01


                                   CURRENT USE SCENARIO
                                   NONCARCINOGENIC RISK


                                 ADULTS          CHILDREN          LIFETIME SEGMENT

INORGANIC SOILS TOTAL           2.40E-03           1.93E-02            2.12E-02
ORGANIC SOILS TOTAL             1.23E-04           9.84E-04            1.08E-03
SURFACE SOILS TOTAL             Z52E-03           2.03E-02            Z23E-02
MW INORGANIC TOTAL             4.17E+00          1.95E+01           N/A
MW ORGANIC TOTAL               1.15E-02           157E-02            N/A

MONITORING WELLS               4.18E+00          1.95E+01           N/A

TOTAL                           4.18E+00          1.9SE+01           i23E-02


                                    FUTURE USE SCENARIO
                                     CARCINOGENIC RISK


                               ADULTS              CHILDREN      LIFETIME SEGMENT

INORGANIC SOILS TOTAL         9.75E-06               1-S7E-OS         135E-05
ORGANIC SOILS TOTAL           374E-07               5.97E-07         8.97E-07
SURFACE SOO^ TOTAL           1.01E4B               1.63E-05         2.44E-05
MW INORGANIC TOTAL           1.66E-06               6J2E-07         N/A
MW ORGANIC TOTAL             N/A                  N/A           N/A

MONITORING WELLS             1.66E-06               6J2E-07         N/A

TOTAL                         1.18E-05               1.WE-OS         2.44E-05


                                   CURRENT USE SCENARIO
                                     CARCINOGENIC RISK


                            ADULTS            CHILDREN         LIFETIME SEGMENT

INORGANIC SOILS TOTAL      335E-07             535E-07            8.03E-07
ORGANIC SOILS TOTAL        1.28E-08             105E-06            3.07E-08
SURFACE SOILS TOTAL        3.48EXT7             5J6E-07            834E4T7
MW INORGANIC TOTAL        1.66E-06             6.52E-07            N/A
MW ORGANIC TOTAL          N/A                N/A               N/A

MONITORING WELLS          1.66E-06             6J2E4T7            N/A

TOTAL                      2.01E-06             1^1E-06            834EX»7
                                             47

-------
             PATHWAY SUMMARY TABLES
             RESIDENTIAL WELLS
             CURRENT AND FUTURE USE SCENARIOS

             NONCARCINOGENIC RISK

      1NCIDENTIAL INOESTION

                                   GRW-1
                            GRW-2
                                        TABLE 9
                                                                                    GRW-3
                                                                                                             ORW4
INORGANIC CONTAMINANTS
ORGANIC CONTAMINANTS
 ADULTS

 9.52E-01
 1.52E-05
                                          CHILDREN   ADULTS
                             CHILDREN   ADULTS
                                                                                             CHILDREN   ADULTS
     4.46E+00
     7.10E-03
TOTAL                        9.52E-01      4.46E+00

      INHALATION DURING SHOWERING AND BATHING

                               GRW-1
     2.67E-01
     3.04E-04

     2.67E-01
                                                          GRW-2
       1.25E+00
       1.42E-03

       1.25B+00
      3.03E-01
      3.04E-04

      3.05E-01
                                                                                   GRW-3
INORGANIC CONTAMINANTS
ORGANIC CONTAMINANTS
TOTAL
 ADULTS
 N/A
 Z81E-OS

 2.81E-05
     CHILDREN
     N/A
     187B-OS

     2.87E-05
     ADULTS     CHILDREN  ADULTS
     N/A        N/A         N/A
     5.62E-04     5.7SE-04     S.62E-04
      DERMAL CONTACT DURING BATIiING (CHILDREN)
                                GRW-1
                                                      5.62E-04
                           GRW-2
                                                                 5.75E-04
                                                                             5.62E-04
       1.43E+00
       1.42E-03

       1.43E+00
                              CHILDREN
                              N/A
                              5.7SE-04

                              5.75E-04
                                                      GRW-3
      2.89E-01
      9.13E-04

      2.90E-01
                                   GRW-4

                               ADULTS
                               N/A
                               1.68E-03

                               1.68E-03
                                                                                                          GRW-4
     CHILDREN

     1.35E+00
     4.26E-03

     1.35E+00
                              CHILDREN
                              N/A
                              1.72E-03

                              1.72E-03
INORGANIC CONTAMINANTS
ORGANIC CONTAMINANTS
ADULTS  CHILDREN  ADULTS    CHILDREN   ADULTS
TOTAL
 N/A
 N/A
N/A
9.85E-05
N/A
N/A
N/A
1.97E-03
N/A
N/A
                            O.OOE+00   9.85E-05      O.OOE+00    1.97E-03   .  O.OOE+00

             COMBINED NONCARCINOGENIC RISKS FOR RESIDENTIAL WELLS

                                GRW-1                    GRW-2

                            ADULTS   CHILDREN   ADULTS    CHILDREN  ADULTS
INORGANIC CONTAMINANTS    9.S2E-01    4.46E-KK)     2.67E-01
ORGANIC CONTAMINANTS     4.33E-05    1.98E-M      8.66E-04

TOTAL                      9.52E-01    4.46E+00     2.68E-01
                                1.25E+00
                                3.97E-03

                                1.25+00
                                   48
                                   3.05E-01
                                   8.66E-04

                                   3.06E-01
                                               CHILDREN    ADULTS
N/A
1.97E-03

1.97E-03
                                                      GRW-3
N/A
N/A

O.OOE+00
CHILDREN

N/A
5.91E-03

5.91E-03
                                                                              GRW-4
                                                         CHILDREN   ADULTS
                                   1.43E+00
                                   3.97E-03

                                   1.43E+00
                                    2.89E-01
                                    2.59E-03

                                    2.92E-01
                                    CHILDREN

                                    1.3SE+00
                                    1.19E-02

                                    1.36E+00

-------
TABLE 9 (continued)
GRW-5
ADULTS
4.48E-01
3.04E-04
4.48E-01
GRW-5
ADULTS
N/A
5.62E-04
5.62E-04
GRW-5
ADULTS
N/A
N/A
O.OOE+00
GRW-5
ADULTS
4.48B-01
8.66E-W
GRW-6
CHILDREN
2.10E+00
1.42E-03
2.10+00

CHILDREN
N/A
5.75E-03
5.75E-03

CHILDREN
N/A
\.91E-03
1.97E-03

CHILDREN
2.10E+00
9.14E-03
ADULTS
2.66E-01
1.52B-04
2.66E-01
GRW-6
ADULTS
N/A
2.81 E-04
2.81E-04
GRW-6
ADULTS
N/A
N/A
O.OOE+00

ADULTS
2.66E-01
4.33E-04
CHILDREN
1.25E+00
7.10E-04
1.25E-I-00

CHILDREN
N/A
2.87E-04
2.87E-04

CHILDREN
N/A
9.85E-04
985E-04
GRW-6
CHILDREN
1.25E+00
1.98B-03
GRW-7
ADULTS
7.91E-01
3.04E-04
7.91E-01
GRW-7
ADULTS
N/A
5.62E-04
5.62E-04
GRW-7
ADULTS
N/A
N/A
O.OOE+00

ADULTS
7.91E-01
8.66B-04

CHILDREN
3.70E+00
1.42E-03
3.70E+00

CHILDREN
N/A
5.75E-03
5.75E-03

CHILDREN
N/A
1.97B-03
1.97E-03
GRW-7
CHILDREN
3.70E+00
9.14E»03
GRW-8
ADULTS
3.47E-01
3.04E-04
3.47E-01
GRW-8
ADULTS
N/A
S.62E-04
5.62E-04
GRW-8
ADULTS
N/A
N/A
OOE+00

CHILDREN
1.62B-00
1.42E-03
1.62E-4-00

CHILDREN
N/A
5.75E-03
5.75E-03

CHILDREN
N/A
1.97E-03
1.97E-03
GRW-9
ADULTS
4.27E-01
2.44E-04
4.27E-01
GRW-9
ADULTS
N/A
4.49E-04
4.49E-04
ORW-9
ADULTS
N/A
N/A
O.OOE+00
GRW-8
ADULTS
3.47E-01
8.66E-04
CHILDREN
1.62E400
9.14E-03
ADULTS
4.27E-01
6.93E-04

CHILDREN
2.00B+00
1.14E-03
2.00E+00

CHILDREN
N/A
4.60E-04
4.60B-04

CHILDREN
N/A
1.58E-03
1J8E-03
GRW-9
CHILDREN
2.00B+00
3.18E-03
4.49E-01
2.11E+00
2.66E-01        1.2SB+00
                                                             7.92E-01
                                                             3.71E+00
3.48E-01
1.63E+00
                              4.28E-01
                                             2.00E+00
                                                                         49

-------
                                                             TABLE 9 (continued)

       ORW-10


ADULTS       CHILDREN

2.45E-01       U5B+00
1J2E-04       ?!lOE-04

2.45E-01       1.15E+00

       GRW-10
ADULTS       CHILDREN                 ''   '
N/A           N/A
2.81E-04       2.87E-04

2.81E-04       2.87E-04

       ORW-10

ADULTS       CHILDREN

N/A           N/A
N/A           9.85E-04

O.OOE+00       9^5E-04

       OR3-10

ADULTS       CHILDREN

2.4SE-01       1.15-1-00
4.33E-04       1.98E-03

2.4SE-01       1.15E+00
                                                                    50

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                                TABLE 10

                        PATHWAY SUMMARY TABLES
                           MONITORING WELLS

                      CURRENT AND FUTURE USE SCENARIOS

                      NONCARCINOGENIC RISK
                INCIDENTIAL INGESTION
                            ADULTS                CHILDREN

INORGANIC CONTAMINANTS     4.17E+00                1.95E+01
ORGANIC CONTAMINANTS      3.76E-03                1.75E-02

TOTAL                      4.17E-00                1.95E+01
                INHALATION DURING SHOWERING AND BATHING

                            ADULTS                CHILDREN

INORGANIC CONTAMINANTS     N/A                    N/A
ORGANIC CONTAMINANTS       7.74E-03                 &12E-03

TOTAL                      7.74E-03                 8.12E-03


                DERMAL CONTACT DURING BATHING (CHILDREN)

                           ADULTS                CHILDREN

INORGANIC CONTAMINANTS    N/A                   N/A
ORGANIC CONTAMINANTS      N/A                   156E-05

TOTAL                     O.OOE+00                2^6E-05


                COMBINED NONCARCINOGENIC RISKS FOR MONITORING WELLS

                           ADULTS                CHILDREN

INORGANIC CONTAMINANTS    4.17E+00                1.95E+01
ORGANIC CONTAMINANTS      1.15E-02                2J6E-02

TOTAL                     4.18E+00                1.95E+01
                                  51

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                                        TABLE 11

                                PATHWAY SUMMARY TABLES

                    MONITORING WELL CARCINOGENIC RISK SUMMARY TABLE

                    CURRENT AND FUTURE USE SCENARIOS

                    INGESTION OF GROUNDWATER



                                ADULTS                     CHILDREN

INORGANIC CONTAMINANTS         N/A                         N/A
ORGANIC CONTAMINANTS           4.26E-07                      3.98E-07

TOTAL RISK                      4.26E-O7                      3.98E-07

                    INHALATION OF VOLATILES DURING BATHING AND SHOWERING


                                ADULTS                     CHILDREN

INORGANIC CONTAMINANTS         N/A                         N/A
ORGANIC CONTAMINANTS           1.23E-O6                      Z53E-07

TOTAL RISK                      1.23E-06                      i53E-07


                    DERMAL INTAKE DURING BATHING


                                ADULTS                     CHILDREN

INORGANIC CONTAMINANTS         N/A                         N/A
ORGANIC CONTAMINANTS           N/A                         7.28E-10

TOTAL RISK                      O.OOE+00 -                    7.28E-10

TOTAL CARCINOGENIC RISK         1.66E-06                      «2E-07
                                          52

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1.0 for  incidental ingestion from several of the onsite
monitoring wells and all of the residential wells that were
sampled.  The health hazard index for use of groundwater from the
monitoring wells selected  in the RA ranged from 4.18 for adults
to 19.5  for children.  For the residential wells, the health
hazard indices ranged from 1.15 to 4.46 for children dependent
upon which well was utilized as a source.  Based upon review of
the sampling data for all  wells during the RI, it was found that
the concentrations all the natural occurrence of the metals:
maganese, copper, and thallium are the basis for the health
hazard indices exceeding 1.0.  These compounds were found in
wells that were located upgradient, crossgradient and
downgradient.  In addition these compounds have been previously
found at similar background levels at other Superfund Sites
within the same geographical region.  Tobyhanna Army Depot, for
example, is a nearby Superfund site which has high levels of
these same inorganic compounds in onsite monitoring wells.  It
was therefore concluded that these metals are occurring on a
regional basis and are not Site related contaminants.

     It should be noted that while the HI for the ingestion of
the groundwater from either the monitoring wells onsite or
residential wells offsite  does exceed 1.0, the potential health
risks posed by the ingestion are based on conservative
estimations.  EPA's policy is to be protective-of human health
and the environment and therefore, EPA is very conservative when
calculating risk analysis.  For example, while the assumed
concentration of manganese used in the RA to determine the HI
could cause potential adverse health effects, the potential
receptors near the Site would most likely not consume any water
with such concentrations of manganese as used in the risk
calculation; this level of manganese would discolor the water and
cause a distasteful flavor.  Therefore while the HI for the
various wells sampled exceeds 1.0, due to the conservative nature
of EPA's assumptions which were used in doing the RA, the
potential for adverse health risks would likely be several
magnitudes less than indicated by the HI.  A more detailed
discussion of the risk analysis conducted for the Site is
contained in the RA and is part of the Administrative record.

     Upon review of the baseline RA, it has been determined that
under the various risk scenarios evaluated for contaminants of
concern for the Site, the  Site contaminants do not pose any risks
or threat to human health  or the environment which would warrant
EPA undertaking a remedial action.  It should be noted that while
there are naturally occurring background levels of metals, which
at the concentrations detected in the groundwater samples could
potentially pose a health  threat to those who use it as a
drinking water source, EPA can take no action.  Pursuant to
CERCLA, and particularly the NCP at 40 CFR S 300.400(b)(1), EPA
is unable to address any risks that are posed by naturally
occurring elements within  an area except in conjunction with the

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 remediation of Site-related contamination that  is  not naturally
 occurring.


 B.   Environmental Impact of Site  Contamination

      An ecological assessment of  the Site was done in conjunction
 with the Remedial Investigation.  No significant adverse  impacts
 to  any environmental  receptor were found  on or  near the Site  and
 based on the results  of the RI, it was determined  that the
 remaining levels  of contaminants  in the soils and  groundwater
 should not  pose any type of threat to any environmental receptor.
 There are no endangered species in the immediate vicinity of  the
 Site.

 C.   Uncertainty in the Risk Characterization

      In order to  quantitatively estimate  the potential risks  to
 human health which may occur as a result  of exposure  to
 contaminants in ground water at the Site,  numerous  assumptions
 regarding exposure parameters were required.  Within  each
 exposure parameter there is an inherent uncertainty.


         VII.  DESCRIPTION  OF THB  "NO ACTION" ALTERNATIVE

      The "No Action" Alternative selected for implementation  at
 the Route 940  Drum Dump Site is described in the following:

     Under the "No Action Alternative,  EPA will not undertake any
 type of  remedial  action since there are no Site related risks
 which would  warrant EPA to  implement a remedial action.  It has
 been determined through the RI that previous removal  actions
 which were completed by EPA, PADER, and LandHark have
 sufficiently remediated the Site so that  the residual risk posed
 by the Site  is  below health-based standards.  Therefore the Site
 does not warrant  any further remedial action.   However, as there
 is evidence  of  low-level concentrations of organic contaminants
 remaining in the  Site soils  and monitoring wells, EPA will still
 review the Site within five years in accordance with  CERCLA § 121
 (d)  to assure  that changes  have not occurred which would pose a
 risk to human  health or the  environment.   In order to facilitate
this review, a  groundwater monitoring program will be implemented
to enable EPA to meet this  requirement and to ensure  Site
conditions do  not  change so as to pose an unacceptable risk.


O&M REQUIREMENTS

Ground Water Monitoring

     Ground water monitoring shall be conducted for at least  five

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 (5) years.  During the first five years, sampling shall be
conducted annually.  This data will be evaluated by EPA,  in
consultation with PADER, to determine the monitoring needs for
future if needed.  Parameters to be monitored include but are not
limited to the following: volatile organic compounds, semi-
volatile organic compounds, and TAL inorganics  (metals).  The
number of the existing monitoring wells which will be used will
be determined by EPA during the O&M workplan development  to
maximize the monitoring of the ground water migration from the
Site.


Documentation of Significant Changes

     The alternative originally identified in the Proposed Plan
is also the alternative selected in the ROD.  There were  no
significant changes made to the selected alternative in the time
period between the issuance of the Proposed Plan on August 10,
1992 and the signing of the ROD approximately eight weeks later.
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