United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-93/164
March 1993
&EPA Superfund
Record of Decision:
Ohio River Park
Neville Island, PA
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO. 2
EPA/ROD/R03-93/164
4. Tttto and Subtltta
SUPERFUND RECORD OF DECISION
Ohio River Park Neville Island, PA
First Remedial Action - Final
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IS SuppJamaotary Notas
PB94-963909
1& Abstract (Unite 200 words)
The 32-acre Ohio River Park Neville Island site is located in the western end of
Neville Island, which is situated in the Ohio River, roughly 10 miles downstream from
Pittsburgh, Pennsylvania. The site is accessible via the Coraopolis Bridge. Land use
in the area is mixed industrial, commercial, and residential. The closest residence is
located approximately 450 feet from the site. The 1-acre bridge portion of the site is
located almost completely within the 100-year floodplain. In 1929, the Pittsburgh Coke
and Chemical Company (PC&C) , which was located on the eastern end of Neville Island,
produced coke and pig iron. In 1930, PCSC began cement operations, and between 1949
and 1955, the plant also manufactured pesticides. Records indicate that, although no
formal documentation that waste disposal occurred directly in the Bridge portion of the
site exists, it is possible that some of the waste may have still contaminated this
area. In 1977, the land was donated to the county and construction of an onsite park
began. During the construction phase, approximately 13,000 yd3 of waste was excavated,
then reburied. Park construction was then halted, and the site was returned to the
Neville Land Company. EPA has divided the site into two operable units for remediation.
This ROD addresses onsite soil contamination in the Bridge portion of the site, as OU2 .
A future ROD will address onsite ground water contamination, as OU1. Based on
(See Attached Page)
17. Doeumant Analysis a. Daacrlptera
Record of Decision - Ohio River Park Neville Island, PA
First Remedial Action - Final
Contaminated Medium: None
Key Contaminants: None
b. MantMara/Opan-Endad Tarme
c, COSATIFWoVCroup
ia AvaBabUltySUtarneot
19. SacurkyCtasa(TMsRapert) 21. NaotPsgaa
None 38
201 Security Oass (This Paga) 22. Pries
None
(SaaANSl-239.11)
SM aMtruction* on ftetwrc*
OPTIONAL F0«i 272(4-77)
(Formerly NTS-IS)
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EPA/ROD/R03-93/164
Ohio River Park Neville Island, PA
First Remedial Action - Final
Abstract (Continued)
information obtained during the baseline risk assessment, EPA has determined that there is
no exposure scenario which poses a risk above 10~4 level; and therefore, there are no
contaminants of concern affecting this site.
The selected remedial action for this site is no further action, since the site no longer
poses a threat to human health or the environment. There are no present worth or O&M
costs associated with this no action remedy.
PERFORMANCE STANDARDS OR GOALS:
Not applicable.
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RECORD Or DECISION '
BRIDGE PORTION OJ THE OHIO RIVER PARK SITE
OPERABLE UNIT TWO
NEVILLE ISLAND
ALLEGHENY COUNTY, PENNSYLVANIA
March 31, i»93
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RECORD Of DECISION
TABLE 07 CONTENTS
DECLARATION 1
DECISION SUMMARY 3
I. SITE NAME, LOCATION, AND DESCRIPTION 3
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 4
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 5
IV. SCOPE AND ROLE OF OPERABLE UNIT 6
V. PREVIOUS SITE INVESTIGATIONS 7
VI. SUMMARY OF SITE CHARACTERISTICS 8
VII. SUMMARY OF SITE RISKS 12
VIII. DESCRIPTION OF THE NO ACTION ALTERNATIVE 16
IX. EXPLANATION OF SIGNIFICANT CHANGES' 17
RESPONSIVENESS SUMMARY 18
TABLES ABO FIGURES 24
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RECORD 07 DECISION
BRZDGB PORTION 07 THE OHIO RIVES PARK SITE
DECLARATION
SZTE NAME AHO LOCATION
Bridge Portion of the Ohio River Par* site
Operable Unit Two
Neville Island
Allegheny County, Pennsylvania
STATEMENT OF BASIS AMD PURPOSE
This decision document presents a determination that no remedial
action will be taken for the soil contamination in the Bridge
Portion of the Ohio River Park Superfund Site in Allegheny
County, Pennsylvania. The entire Ohio River Park Superfund Site
of approximately 32-acres shall hereinafter be referred to as the
"Site"; the approximately one-acre portion of the Site (as
described in Section I of this Record of Decision) that is the
subject of this Record of Decision shall hereinafter be referred
to as the "Bridge Portion of the Site." The "No Action**
determination was developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980,
as amended (CERCLA), 42 U.S.C. SS 9601 e£ llfl., and to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 C.P.R. Part 300. This decision
document explains the factual and legal basis for the
determination that no remedial action will be taken for the soil
contamination in the Bridge Portion of the Site. The information
supporting this "No Action" decision is contained in the
Administrative Record for the Site.
The Commonwealth of Pennsylvania, Department of Environmental
Resource* (FADER) agrees with the united States Environmental
Protection Agency's (EPA's) choice of a "No Action* decision, for
the Bridge Portion of the Site, but has not concurred with the
Record of Decision (ROD), as written, because of fundamental
differences with the EPA interpretation of the NCP and CERCLA.
DESCRIPTION O7 TO NO ACTION ALTERNATIVE
•
The selected alternative for the Bridge Portion of the Site is
"No Action" with respect to the soil contamination. As specified
in Section VI, sum»|i^Y of site Risk, there are no site-related
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risks that warrant a remedial action of any kind with respect to
soil contaaination in the Bridge Portion of the site.
Ground water contamination will be evaluated separately and
addressed in the Remedial Investigation Report for the Site.
DKCLARATXOH 8TATBHEHT
No remedial action is necessary with respect to soil
contamination in the Bridge Portion of the site to ensure
protection of human health and the environment. Although no
remedial action will be taken to remediate the contamination of
soil in the Bridge Portion of the Site, ground water quality on
the Bridge Portion of the Site will be. included, in the Remedial
Investigation of the Site to ensure that human health and the
environment continue to be adequately protected.
Stanley L. Laskowski Date.
cting Regional Administrator
Region III
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RECORD OF DECISION
BRIDGE PORTION OF THE OHIO RIVER PARK SITE
DECISION SUMMARY
I. SITfl NAME. LOCATION AND DESCRIPTION
The Site consists of approximately 32 acres on the western
end of Neville Island, which is located in the Ohio River,
roughly 10 ailes downstream from Pittsburgh, Pennsylvania (Figure
l). The Site is accessible from the Town of Coraopolis via the
coraopolis Bridge (a/k/a the Neville Island Bridge) linking
Neville Island with the south bank of the Back Channel of the
Ohio River. The Coraopolis Bridge is closed when the temperature
drops below 32° F for more than 8 hours, which usually takes
place from December through March. When the Coraopolis Bridge is
closed, vehicular traffic must use the 1-79 Bridge and the
Sewickley Bridge located several miles away. Allegheny County
intends to build a new bridge to replace the existing Coraopolis
Bridge. The new abutments and approach roadway on Neville Island
for the proposed new replacement bridge will be located on the
southeast corner of the Site.
EPA has divided the Site into two components called Operable
Units. Operable Unit One (OU-1) consists of the entire Site,
other than soil contamination in the Bridge Portion of the site.
Operable Unit Two (OU-2) consists of soil contamination in the
Bridge Portion .pf,the Si^e.
The Bridge Portion of the Site is the area which will be
affected by construction of the new abutment* and approach
roadway for the proposed new bridge. It consists of an
approximately one-acre, grass-covered meadow which changes into a
band of shrubs and trees along the Ohio River Back Channel. The
Bridge Portion of the Site is bounded on the north and west sides
by Grand Avenue, on the south side by the Ohio River Back
Channel, and on the east side by a chain link fence (Figure 2).
There are two commercial buildings located to the east.
Land use on Neville Island is generally industrial .and/or
commercial. The western portion of the island includes the Site;
the middle section of the island, between the Site and the 1-79
Highway, is mostly residential and commercial; the east end of
the island is heavily industrialized. Most of the 930 Neville
Island residents live in the area between the Coraopolis Bridge
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and the 1-79 Highway. The nearest residence is located
approximately 450 feet from the Site. According to the 1990
census, the population of the surrounding communities located
within an approximately 4-mile radius of the Site is 18,058
people.
There are no wetlands on the Bridge Portion of the Site.
The 100-year flood elevation in the vicinity of the Coraopolis
Bridge is 717.5 feet, which is 11 feet above the ordinary high
water elevation of 706.5 feet. The Bridge Portion of the site is
located almost completely within the 100-year floodplain but
above the ordinary high water elevation. There are no streams,
rivers, lakes or other water resources on the Bridge Portion of
the Site. In addition, no wildlife refuges, state forests, or
state game lands are located on the Bridge Portion of the Site.
The only threatened or endangered species recorded as occurring
in the vicinity of the Site is the smooth softshell turtle. The
record, however, dates bacJc to before the turn of the century and
recent river turtle surveys have failed to verify the presence of
the smooth softshell turtle in Pennsylvania.
An Historic Structures survey was conducted to identify any
buildings within the Bridge Portion of the Site which could be
eligible for the National Register. The survey concluded that,
except for the Coraopolis Bridge itself, there are no properties
located in the Bridge Portion of the Site that are eligible for
the National Register.
II. flITB HISTORY AMD BKTORCEMBNT ACTIVITIES
HISTORY Of WASTB DIBPOflAL
The predominant land use in the Bridge Portion of the Site
was agricultural until 1929. In 1929, Pittsburgh Coke and
Chemical Company (PC&C), located on the eastern end of Neville
Island, produced coke and pig iron. One year later, PC&C opened
its cement operations. Available information does not indicate
that PC&C disposed of any waste in the Bridge Portion of the
site; however, PC&C disposed of coke oven by-products and cement
by-products in areas of the Site other than the Bridge Portion of
the Site. A gas station facility appears on the aerial photos of
the Bridge Portion of the Site taken from 1936 to 1938. It was
demolished to allow the construction Of Navy barracks in 1943 on
the Bridge Portion of the Site. In December 1970, the Navy
barracks were demolished and removed. Between 1949 and 1955,
PC&C's Agricultural Chemicals Division manufactured pesticides.
PC&C disposed of pesticides and industrial wastes in trenches in
areas of the Site other than the Bridge Portion of the Site.
Even though nous of th* 54 trenches, identified by aerial
photographs, was located in the Bridge Portion of the Site, some
of the waste may have contaminated the Bridge Portion of the
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Site. PC4C operations ceased in 1965-66.
In 1977, Neville Land Company donated the land comprising
the site to Allegheny County. Allegheny County began
construction of a park on the Site in 1977. During the course of
the work, approximately 13,000 cubic yards of various wastes were
excavated at the Site, and some of these materials were reburied
at the Site. Available data, as presented in Figure 3, identify
disposal trench locations only in areas of the Site other than
the Bridge Portion of the Site; however, some of the excavated
material may have been spread on the ground surface and
contaminated the Bridge Portion of the Site. When Allegheny
County determined in 1979 that hazardous wastes were present at
the site, the County halted construction of the park and returned
the land comprising the Site to Neville Land Company.
RESPONSE ACTIONS
EPA completed a Preliminary Assessment of the Site in
January 1979. Following further assessments performed in 1980
and additional related studies, EPA proposed the Site for
inclusion on the National Priorities List (NPL) of Superfund
sites on October 16, 1989. EPA placed the Site on the NPL on
August 30, 1990. In October 1991, EPA and Neville Land Company,
the owner of the site, entered into an Administrative Order by
Consent. Neville Land Company agreed in the Order to conduct a
Remedial Investigation/Feasibility Study, with EPA and PADER
oversight, of the entire Site in accordance with CERCLA. in
response to comments from Allegheny County, EPA carved out the
investigation of soil contamination in the Bridge Portion of the
Site as OU-2, in order to expedite the investigation of the area
and help resolve issues related to the Coraopolis Bridge
replacement project. EPA and Allegheny County entered into an
Administrative Order by Consent on February 2, 1992 requiring
Allegheny County to perform a Focused Remedial Investigation
(Focused RI) of soil contamination in the Bridge Portion of the
Site. The field work was completed in April 1992. Allegheny
County submitted the results of this investigation to EPA as the
Focused RI Report. EPA approved the Focused RI Report on
November 30, 1992. Following this study, EPA completed the site-
specific Focused Baseline Risk Assessment (BLRA).
ZZZ. HKPTt-TOHTS OT COMMUNITY PARTICIPATION
In accordance with Sections 113(k)(2)(B), 117(a), and
121(f)(l)(6) Of CERCLA, 42 U.S.C. 5S 9613(k)(2)(B), 9617(a), and
9621(f)(1)(G), EPA issued a Proposed Remedial Action Plan
(Proposed Plan) on January 15, 1993 to present the preferred
remedial alternative for addressing the soil contamination in the
Bridge Portion of the site. EPA prepared the Proposed Plan to
facilitate public participation in the decision-making process
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regarding remediation of the soils in the Bridge Portion of the
Site. EPA made the Proposed Plan/ Focused RI Report, BLRA, and
other site-related documents available to the public by placing
copies in the Administrative Record file. Copies of the
Administrative Record file are located in the information
repositories at the following locations:
Coraopolis Memorial Library
State and School Streets
Coraopolis, PA 15108
(412) 264 3505
U.S. EPA - Region III
Administrative Record Coordinator
Docket Room
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-3037
An announcement of a public meeting, a comment period, and
the availability of the Administrative Record file was published
in the "Allegheny Times" and the "Coraopolis Record" on January
15, 1993.
EPA held a public comment period from January 15, 1993 to
February 15, 1993. A public meeting was held on January 25, 1993
to present information, accept oral and written comments, and
answer questions from the public regarding the Bridge Portion of
the Site and the "No Action" Preferred Alternative. A transcript
of the meeting was maintained in accordance with Section
117(a)(2) of CERCLA, 42 U.S.C. S 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
soil contamination in the Bridge Portion of the 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
(ROD) are included in the Administrative Record for the Bridge
Portion of the Site and can be reviewed at the information
repositories.
IV. acopg XHD HOLB or OPBRABLB QUIT
EPA's goal for the Focused RI was to determine the nature
and extent of soil contamination in the Bridge Portion of the
Site, to identify risks posed by the soil contamination in the
Bridge Portion of the Site, and to develop remedial alternatives
to address those risks. There were no principal threats
identified with respect to the soil contamination in the Bridge
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Portion of the Site. Principal threats are those source
materials which are considered to be highly toxic or mobile,
generally cannot be contained, or would present a significant
risk to human health or the environment should exposure occur.
EPA divided the Site into two operable units. OU-1 consists
of the entire Site, other than soil contamination in the Bridge
Portion of the Site. This ROD addresses OU-2, which consists of
soil contamination in the Bridge Portion of the Site. This ROD
does not address groundwater contamination, which will be
addressed by the OU-1 investigation.
V. PREVIOUS SITE IHVBgTTCATIQMS
Four consulting firms, have conducted investigations of the Site
since the cessation of waste disposal activities in the mid-
1960s. A summary of the work performed and sample results is
presented below:
• Pittsburgh Testing Laboratory
The Pittsburgh Testing Laboratory conducted a study from 1972-73
which provided general information on physical parameters of
soils at the Site.
• Richardson, Oordon, and Associates, Ino. (R6A)
RGA conducted two field programs in 1977. The first program
resulted in a map of the Site showing conditions prior to
construction of the park by Allegheny county. The second program
included digging 69 test pits and collecting soil and waste
samples for physical and chemical analyses. • During this '
investigation, numerous disposal trenches were discovered in the
central portion of the Site. No disposal trenches were found in
the Bridge Portion of the.-Site..' Figure-3. shows-the locations of
the disposal trenches as determined by RGA and other studies.
•Fred c. Bart and Associates, Ino. (PCEA)
FCHA conducted a survey in 1979 which included the collection and
analysis of 28 wast* samples from the surface or near surface of
the Site to evaluate any threat to the general public. No
samples were collected from the Bridge Portion of the Site.
• Environmental Research and Technology, Inc. (ERT)
ERT performed a study of the Site from 1979 to 1982. It was
followed by a long-term monitoring program. ERT conducted
geophysical surveys of the Site in May 1989 to determine the
location of any curied debris. In 1990, ERT collected 458 soil
and waste samples. Six sample locations were in the Bridge
Portion of the Site. At one of these locations, the
concentration of toluene was 8,000 parts per billion (ppb) in the
first sample and 70 ppb in the second sample. The concentration
of benzene at this location was 5,000 ppb and the concentration
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of 2,4-D butyl ester (2,4-D) was 5.2 ppb. A sample from a
different location indicated concentrations of toluene at 70 ppm
and 2,4-0 at 1.2 ppb. The above concentrations of soil
contaminants are below EPA's oral Reference Doses (RfDs) for
these chemicals. A RfO of a contaminant is the average daily
lifetime dose believed to be without adverse effects in human
populations.
VX» SUMMARY Or SITB CHARACTERISTICS
A. TOPOGRAPHIC SETTING
Neville Island is a detached portion of a river terrace
deposited by an ancestral Ohio River. With the exception of the
immediate shoreline, western portions of the Site were excavated
and filled with soil, slag, foundry sand, and municipal and
industrial waste. These dumping activities caused the highest
elevation of the Site to rise 10 to 27 feet above the 1948 level
of the river banks. The southern two-thirds of the Bridge
Portion of the Site is a flat area previously occupied by Navy
barracks. The highest level elevation on the Bridge Portion of
the Site occurs at the existing Coraopolis Bridge abutment.
There is a drainage swale between the existing Coraopolis Bridge
abutment and the location selected for the new replacement bridge
abutment, in the area of the Bridge Portion of the Site that is
adjacent to the river, a steep slope exist* where elevations
abruptly change 20 feet. There is no evidence that the
topographic setting of the Bridge Portion of the Site was
artificially constructed in the same way as it was for the rest
of the Site. Moreover, no trenches with fill material were found
in the Bridge Portion of the Sit*.
B. HYPROggOLOOICAL SBTTIHQ
The geology beneath the Bridge Portion of the Site is
composed of approximately 60 feet of alluvium consisting of fine
sand, silt, clay, coarse sand, and gravel. The river bottom is
comprised of a less permeable silt underlain by coarse alluvium
and is approximately 13 to 28 feet thick. The bedrock under the
Bridge Portion of the Site is composed of micaceous fine
sandstone and dark-gray shale (argilite).
The depth to ground water is approximately 20 to 25 feet
below the ground surface. The saturated thickness of the
alluvial aquifer beneath Neville Island is approximately 35 to 40
feet. The geometry of the water table surface is dominated by an
elongated ground water mound. As a result, a ground water divide
has developed that bisects the island. Therefore, groundwater
flows radially froa the central portion of the mound toward the
Bridge Portion of the Site and to the Back Channel of the Ohio
River. The groundwater flow gradient beneath the Bridge Portion
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of the Site is 0.002 ft/ft.
Due to the surface topography and lack of drainage, the
predominant recharge pathways for the surficial aquifer beneath
the Bridge Portion of the Site are recharge from the Back Channel
of the Ohio River and precipitation. No water supply receptors
adjacent to the Bridge Portion of the site were identified.
There are three public water supplies in the vicinity of Neville
Island: Coraopolis, Moon Township, and Sewickley. Contaminants
identified at the Bridge Portion of the Site were not detected in
the public water supplies.
Surface water runoff is conducted across the flat southern
portion of the Bridge Portion of the Site in a southerly
direction by sheet flows which discharge into the Back Channel of
the Ohio River. Stormwater runoff from Grand Avenue is captured
by a 15-inch sewer which discharges into the Back Channel of the
Ohio River.
C. NATURE AND E1TEKT QV COMTXMIMATIOM
Allegheny County retained HDR Engineering, Inc. to conduct
the Focused RI pursuant to the Administrative Order by Consent
entered into by EPA and Allegheny County. The primary objective
of the Focused RI was to complete the characterization of soils
in the Bridge Portion of the Site that could potentially be
disturbed or exposed during construction of the approach roadway
and abutments for the new bridge. The Focused RZ included: a
buried drums investigation, a. geophysical survey, and soil
sampling and analysis. Some sections of the Focused RZ Report,
especially the geophysical survey, incorporated the results of
the survey performed by ERT in 1989 and 1990.
BPRIBD PEBRIB
In May 1989, ERT conducted geophysical surveys of the Site
to determine the location of any buried debris. An area of
magnetic disturbance was identified for further investigation.
Aerial photographs taken from 1936 to 1973 were then reviewed.
No evidence of disposal activity was found in the Bridge Portion
of the site. In order to continue exploration for possible
buried metal drums,.ERT conducted a penetrating radar survey at
the Bridge Portion of the Site, followed by hand auger borings,
an organic vapor screening^ and.exploratory trench excavations.
The survey did not indicate any'buried materials at the Bridge
Portion of the Site.
SOIL COKTXMIKATIOM
• surfieial Soil Samples
To characterize the surface soil contamination and
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determine the background levels, HDR performed two series of
sample collections in August 1991 and April 1992 during the
Focused RI. A total of 27 surficial soil borings were taken from
eight locations in the Bridge Portion of the Site, specifically,
in the areas where the abutments and approach roadway for the new
bridge will be located. The locations were chosen in areas where
workers involved in moving earth during construction of the new
bridge and its approach roadway could potentially be exposed to
soil contaminants. Background samples were collected from a
location on the Duquesne Power and Light Company property located
across the Back Channel from Neville Island and near the
Pittsburgh and Lake Erie Railroad yard. This background location
presented., area usage conditions (industrial and residential)
similar to those on Neville Island and was located outside of the
possible influence of dumping activities which had been conducted
on the island. A map showing the soil sampling locations is
presented as Figure 4. Surficial samples were collected from the
upper 1.5 feet of the soil in the proposed location for the new
bridge approach roadway and the upper 3.0 feet of the soil in the
proposed location for the new bridge abutments. Four samples
were analyzed for Volatile Organic Compounds (VOCs), Semi-
Volatile Organic Compounds (SVOCs), and substances included on
the Target Compound List (TCL); one round of samples was analyzed
for Herbicides/Pesticides and Oioxin; and two samples were
analyzed for Toxicity Characteristic Leaching Procedures (TCLPs).
• surfieial Soil ABe.lvsis Results infl Discussion
The surfieial soil sample laboratory results revealed the
possible presence of four. VOC* in the soil in the Bridge Portion
of the Site. For the purposes of this document, only the maximum
detected concentration is presented. The detected VOCs weret
methylene chloride, 13 ppb;. acetone, 6000 ppb; 2-butanone (MEK),
7 ppb; and carbon disulfide, 13 ppb. Because the concentrations
of methylene chloride and acetone were similar to the
concentrations presented in the field blank sample, these
compounds are regarded as non-detected. The other two VOCs,
2-butanone and carbon disulfide, are typical laboratory chemicals
and their presence; in low concentrations in the samples is
considered to be laboratory contamination and is not an
indication of soil contamination in the Bridge Portion of the
Site.
SVOCs and their maximum concentrations detected at the
Bridge Portion of the Site are: phenanthrene, 760 ppb; di-n-
butyl phthalate, 1200 ppb; fluoranthene, 930 ppb; pyrene, 760
ppb; benzo[a]anthracene, 760 ppb; chrysene, 500 ppb;
bis(2-ethylhexyl)phthalate, 240 ppb; benzofb]fluoranthene, 480
ppb; and benzo[a]pyrene, 430 ppb. These concentrations of SVOCs
indicate a pattern in which minor amounts of several polycyclic
aromatic hydrocarbon (PAH) compounds occur at all locations where
surface soils were sampled. The concentrations of SVOCs in the
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surficial soil samples were within the limits of normal
laboratory contamination or non-detected concentrations. The
total SVOC concentrations found in the surface soils in the
Bridge Portion of the Site ranged from 100 to 5,370 ppb; the
concentration of svocs in the background sample was 72,240 ppb.
Thus, the SVOC contamination in the surface soils in the Bridge
Portion of the Site was typical for soils in urban industrialized
settings and did not indicate a site-specific pattern.
The inorganic compounds found in the surface soils which are
considered contaminants of potential concern are: arsenic, 8
parts per million (ppm) ; cadmium, 8.7 ppm; chromium, 22.1 ppm;
cobalt, 15.2 ppm; lead, 301 ppm; mercury, 0.30 ppm; nickel, 22.6
ppm; and cyanide, 7.1 ppm. Apart from the inorganics specified
above, the majority of detected inorganic compounds are naturally
occurring rock and soil forming elements: aluminum, calcium,
iron, magnesium, manganese, and sodium. The concentrations of
Resource Conservation and Recovery Act (RCRA) metals (arsenic,
barium, cadmium, chromium, lead, mercury, and selenium) and
cyanide represented the same order of magnitude as background
samples collected from- the Ouquesne Power and Light. Company
property near the Pittsburgh and Lake Erie Railroad yard located
across the Back Channel . There are several possible explanations
for the presence of RCRA metals and cyanide in the soil in the
Bridge Portion of the Site; however, the most probable sources of
these contaminants are combustion of leaded gasolines and stack
emissions from blast furnaces, smelters and coking ovens.
Analysis of the surficial soil samples for polychlorinated
biphenyls (PCBs) and pesticides indicates the presence of trace
amounts of PCBs: aroclor 1254, 78 ppb; and aroclor 1242, 79 ppb;
and traces of chlordane and two chlorinated herbicides: 2,4-D
and 2,4,5-TP (silvex). PCBs are common contaminants in
electrical and hydraulic equipment. The action level for PCBs
for Superfund remediation ranges from 1 to 25 ppm. Chlorinated
pesticides were present in quantities below the detection limit.
The background surface soil samples obtained from- the
Duquesne Power and Light Company property located across the Back
Channel from the Site generally contained higher levels of soil
contaminants than those found in the Bridge Portion of the Site.
The higher levels in the background surface soil samples can be
explained by the proximity of the location of the background
samples to the Pittsburgh and Lake Erie Railroad yard, where
fueling spills, dust suppression and other industrial-like
activities can increase soil contamination. The soil in the
Bridge Portion of the Site, on the other hand, has not been
directly exposed to industrial use for more than thirty years.
• Intermediate Pepth floi.1,
Two sets of intermediate depth soil samples were collected
11
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from a depth of 3.0 to 9.0 feet below grade at two of the
proposed new bridge abutment locations. The samples were
initially screened with portable trace gas analyzers (OVA) .
Since -the instruments showed no response, only one set of svoc
Total Petroleum Hydrocarbons (TPH) was collected.
• Intermediate Depth Sojl Analysis and Discussion.
The laboratory analysis of the intermediate depth soil
samples showed traces of phenanthrene, 78 ppb; and pyrene, 82
ppb. These are products of combustion, typically found in soils
of urban industrialized settings. The trace levels in the .
intermediate depth soil samples are below the action levels for
these contaminants for Super fund remediation.
face Soil es
Subsurface soil samples were collected from a depth of 10.5
to 13.5 feet below grade. They were collected from the nine
boring locations to evaluate the soil at the proposed new bridge
abutment area where the maximum depth of the excavation is
anticipated to be 13 . 0 feet below grade and also from the deep
soils in the area proposed for the new. approach roadway. This.
contamination could (1) serve as a contaminant source; (2)
migrate into the ground water; or (3) be exposed during any type
of bridge or road construction. Sample locations were the same
as those selected for the surface soil samples. A total of 29
samples collected from nine locations have been analyzed: nine
samples for VOCs and SVOCs; ten samples for Contract Laboratory
Program (CLP) Target Analyte List (TAL) inorganics and cyanide;
and ten samples for CLP pesticides, PCBs, TPH, chlorinated
herbicides, organophosphorus pesticides, and dioxins.
• ytihaoffaoe Soil Analysis Results ens: Discussion
Subsurface soil contaminants and their maximum
concentrations which were detected in the Bridge Portion of the
Site and are considered contaminants of potential concern are:
di-n-butyl phthalate, 870 ppb; arsenic, 7.7 ppa; chromium, 13.9
ppm; cobalt, IS. 2 ppa; lead, 96.0 ppm, manganese, 1050 ppm;
mercury, 0.14 ppm; nickel, 19.7 ppa; cyanide, 0.97 ppa; PCBs
Aroclor 1254, 16 ppb; alpha chlordane, 13 ppb; gamma chlordane,
8.7 ppb; and petroleum hydrocarbons, 210 ppa.
Di-n-butyl phthlate is a common laboratory contaminant; the
other contaminants are below Reference Doses (RfDs) .
VTI. amoOXt Or SIM RISKS
«
Based on the Focused RI, EPA performed a Focused Baseline
Risk Assessment (BLRA) to quantify human health risks associated
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with contaainated soil in the Bridge Portion of the Site. The
specific purpose of the BLRA was to determine whether the
chemicals of potential concern associated with surface and
subsurface soil in the Bridge Portion of the Site pose a current
or future risk to human health.
Potential risks to human health were identified by
calculating the risk level for carcinogenic chemicals and the
hazard index (HI) for noncarcinogenic chemicals. Potential
carcinogenic risk is identified by the risk level (e.g.. a l.OE-
06 risk level indicates one additional chance in 1,000,000 that
an individual will develop cancer). Remedial action is generally
warranted at a site when the calculated carcinogenic risk level
exceeds l.OE-04. The HI identifies the potential for the most
sensitive individuals to be adversely affected by the
noncarcinogenic chemicals. If the HI exceeds one (1.0), there
may be concern for potential noncarcinogenic effects* As a rule,
the greater the value of the hazard index above 1.0, the greater
the level of concern.
Because it is expected that excavation and construction will
occur in the Bridge Portion of the Site, chemicals- of potential
concern were selected for soil, regardless of whether
contaminants were found in surface or subsurface soil layers.
Possible leaching and transport from contaminated subsurface
soils to ground water was not assessed. The OU-1 Remedial
Investigation of the entire Site will include an investigation of
ground water at the Site, including ground water in the Bridge
Portion of the Site.
Of the chemicals detected in the soil in the Bridge Portion
of the Site> chemicals of potential concern, as specified in
Table l and Table 2, were selected based on the following
considerations:
1. frequency of detection (Table 1 and Table 2); ...
2. relative percent contribution to total risk;
3. toxicity to humans;
4. role as a human nutrient; and
5. background concentration.
In general, contaminants that were confidently detected in
at least one sample and contributed 1 percent or more to the
total risk were selected as contaminants of potential concern and
evaluated in the BLRA. Exceptions were mads when a reported
chemical was found to have a low order of toxicity to humans, was
an essential dietary nutrient or was detected at levels similar
to ambient background concentrations; such chemicals were not
selected as contaminants of potential concern.
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Petantial.lv
For purposes of the BLRA, it was assumed that the potential
future land use of the Bridge Portion of the Site may be
occupational, commercial or residential. It should be noted,
however, that in the near future, it is expected that an abutment
and an approach roadway for the proposed new bridge will occupy
the Bridge Portion of the Site.
While many potentially exposed populations can exist at a
site, only those populations that may be significantly exposed
were evaluated (Table 3). Under the current land-use scenario,
exposure of young trespassers was assessed. For future potential
land-use, exposure to residents, long-term workers, and short-
term workers was evaluated. It should be noted that (1) the
residential and long-term occupational exposure scenarios are not
expected to occur in the Bridge Portion of the Site, and (2) the
short-term occupational exposure scenario is thought to be
representative of that which may be incurred by construction
workers involved in construction of the new bridge.
Methodology of Risk Assessment
The primary routes of exposure at the Bridge Portion of the
Site involve inhalation and ingestion of surface and subsurface
soils. The dermal route of exposure is considered to represent a
negligible risk, as compared to other pathways; therefore, it was
not assessed. With regard to a contact rate, a total exposure
was assumed, i.e.. contact with contaminated soil via the :
ingestion and inhalation routes were evaluated, concurrently and
presented as a single facto*-. Exposure estimates and toxicity
criteria for the contaminants of potential concern were combined
to estimate potential carcinogenic risks and noncarcinogenic
effects for the exposure pathway and routes identified for the
Bridge Portion of the Site. These estimates characterize the
potential human health impacts associated with the soil
contamination in the Bridge Portion of the Site, and are .
summarized in Tables 4 through 7. Soil is the only exposure
pathway of concern for OU-2. Because the exposure was evaluated
as one unit (ingestion plus inhalation), risks across exposure
routes were combined, thereby providing total risk estimates.
Risk Characterisation
A. Potential Risks to Trespassers
The contaminants of concern include the following Probable
Human Carcinogens: benzo(a]pyrene equivalents and beryllium
detected in surface and subsurface soil. The total carcinogenic
risk to trespassers posed by soil contamination in the Bridge
Portion of the Site is 2.71B-06 (Table 4). This is equivalent to
approximately 3 additional cancers per 1 million exposed
14
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individuals. This calculated risk level is within the acceptable
risk range for carcinogens of l.OE-06 to i.OE-04.
Potential noncarcinogenic hazards to trespassers who come
into direct contact with contaminated soil in the Bridge Portion
of the Site are presented in Table 4. The estimated Hazard
Index, which indicates the likelihood of a noncancer threat, is
less than unity (l) for trespassers; therefore, noncarcinogenic
effects are not expected to occur.
B. Potential Bisks to Future Residents
The contaminants of concern include the following Probable
Human Carcinogens: benzo[a]pyrene equivalents and beryllium
detected in surface and subsurface soil. The total carcinogenic
risk posed by soil contamination to potential future residents of
the Bridge Portion of the Site is 4.83E-05 (Table 5). This is
equivalent to approximately 48 additional cancers per 1 million
exposed individuals. This calculated risk level is within the
acceptable risk range for carcinogens of l.OE-06 to l.OE-04.
Potential noncarcinogenic hazards to potential future
residents who come into direct contact with contaminated soil in
the Bridge Portion of the Site are presented in Table 5. The
estimated Hazard Index, which indicates the likelihood of a
noncancer threat, is less than unity (1) for potential future
residents; therefore, noncarcinogenic effects are not expected to
occur.
C. Potential Risks to Long-term Workers
The contaminants of concern include the following Probable
Human Carcinogens: benzo(a]pyrene equivalents and beryllium
detected in surface and subsurface soil. The total carcinogenic
risk to potential future long-term workers posed by soil
contamination in the Bridge Portion of the Site is 4.04E-05
(Table 6). This is equivalent to approximately. 40 additional
cancers per 1 million exposed individuals. This calculated risk
level is within the acceptable risk rang* for carcinogens of
l.OE-06 to l.OE-04.
Potential noncarcinogenic hazards to potential future long-
term workers who come into direct contact with contaminated soil
in the Bridge Portion of the Site are presented in Table 6. The
estimated Hazard Index, which indicates the likelihood of a
noncancer threat, is less than unity (1) for long-term workers;
therefore, noncarcinogenic effects are not expected to occur.
O. Potential Risks to flhert-term Workers
This exposure represents that which construction workers
associated with the construction of the abutment and an approach
15
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roadway for the proposed new bridge are expected to encounter.
The contaminants of concern include the following Probable
Human Carcinogens: benzo[a]pyrene equivalents and beryllium
detected in surface and subsurface soil. The total carcinogenic
risk to potential future short-term workers posed by soil
contamination in the Bridge Portion of the Site is 2.77E-07.
This is equivalent to approximately 0.3 additional cancers per 1
million exposed individuals. This calculated risk is less than
EPA's acceptable risk range for carcinogens of l.OE-06 to l.OE-
04.
Potential noncarcinogenic hazards to potential future short-
term workers who come into direct contact with, contaminated soil
at the Bridge Portion of the Site are presented in Table 7. The
estimated Hazard Index, which indicates the likelihood of a
noneancer threat, is less than unity (1) for short-term workers;
therefore, noncarcinogenic effects .are not expected to occur.
VZIZ. DB8CRIPTIOM OF THB "MO ACTIOH** ALTgRHXTIVB
EPA has selected the "No Action1* Alternative for soil
contamination in the Bridge Portion of the Site. Under the "No
Action" Alternative, EPA will not undertake any type of remedial
action with respect to the soil contamination in the Bridge
Portion of the Site since there are no site-related risks to
human health and the environment associated with,.such soil
contamination which would warrant EPA to implement a remedial
action. In light of EPA's decision not to select a remedial
action, the requirements of Section 121 of CERCLA, 42 U.S.C.
S 9621, including the provisions of Section 121(d)(2) concerning
applicable or relevant and appropriate requirements (ARARs), are
not triggered; that section applies only in those cases where a
remedial action is selected.
EPA created 017*2 in order to expedite, the investigation of
soil contamination in the Bridge Portion of the Site and
completion of the related Focused Baseline Risk Assessment,
thereby providing information relevant to the proposed
construction of a new bridge to replace the existing Coraopolis
Bridge. The risk of exposure to the contaminants of concern was
assessed for potentially exposed populations: young trespassers,
future residents, long-time.workers and short-time workers. It
is expected that, after the new bridge abutments and the new
approach roadway are constructed, there will be no reason to
employ workers in the Bridge Portion of the Site and there will
not be enough space in the Bridge Portion of the Site between the
,new approach roadway and the Back Channel for future residential
development. Also, trespassers' exposure is very sporadic and
time-limited; therefore, it may be overestimated in the BLRA by
using "typical" exposure criteria. Even using the very
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conservative BLRA approach, the risk level for each of the
theoretically exposed populations is still within EPA's
acceptable risk range for carcinogens of l.OE-06 to l.OE-04. The
only population that will definitely be exposed to the soil
contaminants in the Bridge Portion of the Site are short-term
workers involved in construction of the new bridge. Their
exposure is significantly less than a l.OE-06 risk level.
Based on the BLRA, there is no exposure scenario which poses
an increased cancer risk above a l.OE-04 risk level. 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. In addition, based on the
BLRA, there is no exposure scenario which indicates increased
noncarcinogenic effects. EPA has selected the "No Action"
Alternative with respect to soil contamination in the Bridge
Portion of the site. Contamination of media other than soil in
the Bridge Portion of the Site, including contamination of ground
water at the entire Site (including in the Bridge Portion of the
Site), will be addressed during the Remedial Investigation/
Feasibility Study of the entire Site.
XX. KCPLAHXTIOH Of 8IQHIFICXNT CHANQBfl
The Proposed Plan for the soil contamination in the Bridge
Portion of the Site was released for public comment on January
15, 1993. The Proposed Plan identified "No Action" as the EPA
preferred alternative. EPA reviewed all written and oral
comments submitted during the public comment period. A summary
of the comments received during the public comment period is
included in the Responsiveness Summary section of this Record of
Decision. Based on the review of these comments/ it was
determined that no significant changes to the preferred
alternative, as it was originally identified in the Proposed
Plan, were necessary. .
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RECORD 07 DECISION
BRXDQI PORTIOM QT TBB OHIO RXVOL PARK SITE
RgflPQKfllVgMBgg SUMMARY
EPA established a public comment period froa January 15,
1993 to February 15, 1993, on the Focused RX, BLRA, the Proposed
Remedial Action Plan (which describes the "No Action" Preferred
Alternative) , and other site-related information for the Bridge
Portion of the Ohio River Park Site, Allegheny County,
Pennsylvania. The Focused RZ and other site-related documents
used by EPA to select the "No Action1* Preferred Alternative are
included in the Administrative Record file and have been
available to the public since the beginning of the public comment
period. A public meeting was held on January 25, 1993 and
approximately 40 people were in attendance. In addition, EPA
received one written statement and two written comments during
the public comment period.
The purpose of this Responsiveness Summary, is to summarize
significant comments, criticisms and new data received during the
public meeting or in writing, and to provide EPA's responses to
the comments. .
This community relations Responsiveness Summary is divided
into the following sections:
Section Z. Overviews A discussion of :m public's
response to the "No Act ion w alternative.
Section IZ. Background of Community Involvement and Concerns:
A discussion of the history of community interest
and concerns raised during remedial planning
activities at the Bridge Portion of the site.
Section IZZ. summary of Significant Co^n^nts Received during the
Public Comment Period and Agency Responses: A
summary of comments and responses categorized by
topics.
Section Z. Overview
Comments received from the public suggest that area
residents support the "No Act ion'0 Alternative. The residents
consider the approval of this alternative as a necessary
18
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condition to starting the construction of the new bridge that
will replace the existing Coraopolis Bridge. Their main concerns
were: to shorten the formal procedures, to be assured that the
decision will be final, and to be informed of the results of the
RI at the Site. The residents also wanted some assurance that
the contaminants found during the RI of the entire Site will be
cleaned up. They also wanted to know whether FADER shares EPA's
position on the "No Action" Alternative.
Section XX* Backoround of Co^fly.iiittv Involvement and Concerns
Since February 1988, when restrictions were imposed on using
the Coraopolis Bridge in winter, the Neville Island residents
have been very active with respect to replacement of the bridge.
A group of residents established the "Coraopolis-Neville Island
Bridge Committee," which has held bimonthly meetings and
published newsletters and public announcements concerning
replacement of the bridge. The meetings were attended by
interested residents and representatives of PADER, Allegheny
county, the Pennsylvania Department of Transportation, EPA, and
other public officials. The public was continually updated by
the Allegheny County Department of Engineering and Construction
on the status of the bridge replacement project. The primary
goal of Neville Island residents has been to provide a
replacement bridge as soon as possible.
Section XXX • Summary of Ma'ior Comments Received Paring the
Period and Agency Responses
Except as specifically noted, the following questions and
comments were raised at the public meeting held on January 25,
1993.
1. The schedule for the next action
A question was asked at the public meeting about the length
of time needed to start the construction of the new bridge
that vill replace the Coraopolis Bridge.
An EPA representative at the public meeting explained that
the Agency must follow the procedures required under CERCLA
for issuance of a formal decision on the Proposed Plan.
CERCLA requires a 30 day public comment period following the
issuance of the Proposed Plan. EPA explained that any
comments submitted during the public comment period will be
incorporated in the Responsiveness Summary which is a part
of the final decision document. EPA stated that the Agency
hoped to issue a final decision on the Proposed Plan 30 to
60 days from the date of the Public Meeting.
19
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2. Sehadule and budgeting for the construction of the new
bridge that will replace the Coraooolis Bridge
A question was asked at the public meeting about the
schedule, funds, and the position on the priority list for
the new bridge construction project.
Since the question related to the bridge construction
project and not to Operable Unit Two, EPA referred the
question to a representative of Allegheny County at the
public meeting. The representative of Allegheny County
stated that funding was currently available for the new
bridge construction project.
3. The schedule for the bridge construction project
Someone at the public meeting asked why, if soil
contamination in the Bridge Portion of the Site does not
have to be cleaned up, it will take 60 days to start the
bridge construction project.
An EPA representative explained that EPA cannot issue a
final decision on the preferred alternative described in the
Proposed Plan until the 30 day public comment period is
over. In addition, EPA must address any comments received
during the public comment period and at the public meting in
a Responsiveness Summary which will be part of EPA's final
decision document. EPA must prepare the final decision
document on remediation of soil contamination in the Bridge
Portion of the Site, and coordinate with the Commonwealth of
Pennsylvania, which must review the decision. EPA estimated
that it would issue its formal decision approximately 30 to
60 days from the date of the public meeting.
4. Final decision .
Someone at the public meeting asked who makes the final
decision on the "No Action* Preferred Alternative for the
Bridge Portion of the Site.
The decision will be made by the EPA Region IZZ Regional
Administrator in Philadelphia.
5. The organization of the EPA office
A citizen of Neville Island asked whether EPA had a
representative in Pittsburgh who could handle matters
relating to the Bridge Portion of the Site, instead of
having the EPA office in Philadelphia making the decisions
relating to the Bridge Portion of the Site.
An EPA representative explained that the Agency has ten
20
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••-3
regional offices nationwide and its headquarters in
Washington, D.C. The EPA regional office that handles
matters in Pennsylvania is located in Philadelphia. It
would be too difficult for EPA to manage offices in every
community; however, the EPA office in Philadelphia works
closely with PADER, which has an office in Pittsburgh. In
addition, the EPA Remedial Project Manager from the
Philadelphia office has visited the site often and worked
closely with the community.
6. The effect of the Remedial Investigation of the Site on the
Ohio River
Someone at the public meeting asked whether the remedial
investigation of the Site has any effect on the quality of
water in the Ohio River.
An EPA representative explained that the remedial
investigation currently being conducted on the entire site,
which is called OU-1, is being conducted to evaluate the
type and location of any contamination on the entire Site.
The final answer to this question will be possible when the
Remedial Investigation Report for OU-1, which will contain
the results of the remedial; investigation, is approved by
EPA. EPA expects to have the- results of the remedial
investigation of the entire Site by the end of 1993.
• * •. '•» . . - • •-
7. Following EPA's response to Question #6, the same person
asked whether; by tn* end of 1993, EPA will be able to tell
residents whether the-.remainder of the Site is clean enough
so that the Site can be\ opened, as a park.
EPA will be able to answer th-is. question after the- remedial
investigation, incluttijgg the Risk Assessment, of £he entire
Site (OU-1) is completed^ V: . .. »:""
8. Statement in the newspapers concerning: clean-up-of the Site
A resident of Neville Island at the public meeting asked
whether EPA knew that Mr. Hillman mad* a statement to the
newspapers that his company will take care of the drums and
contamination that are at the Site.
An EPA representative answered that the Agency is aware of
Mr. Hillman's statement to the newspapers. Neville Land
Company is currently conducting a remedial investigation of
the entire Site. After the remedial investigation and
feasibility study are completed, EPA expects to negotiate
with the company concerning the clean-up of the entire Site.
21
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9. Tfre role of PAPER and PAPER'S position on the "No Action"
Preferred Alternative
A resident of Neville Island asked about the role of PADER
a'nd the position of PADER on the "No Action" Preferred
Alternative.
A PADER representative explained that the role of the
Commonwealth is to provide EPA with technical assistance on
the Super fund project and "input so that the project can
move smoothly." The PADER representative stated that PADER
" agree [s] with EPA's — on their Mo Action Proposal. . . ".
The PADER representative also stated that there are "a few
more stringent State requirements/ but the State won't stop
the bridge replacement project."
10. . The decision-making process
A resident of Neville Island asked whether PADER' s
regulations supersede EPA's regulations and whether the
project can be delayed by additional decision-making.
An EPA representative responded that EPA administers the
Superfund Program and will issue the Record of Decision;
however, EPA works with the Commonwealth and will be seeking
PADER' s concurrence on this document. EPA will seek PADER' s
concurrence by the end of the public comment period.
11. Statement on behalf of Allegheny County
At the end of the public meeting, Mr. Higginbotham, the
representative of Allegheny County, presented, on behalf of
Allegheny county, a written statement expressing
appreciation to EPA for "the expeditious manner in which
[EPA]. . .carried out this investigation. . .". Mr.
Higginbotham stated that Allegheny County supports a No-
Action Record of Decision and its timely promulgation so
that construction of the new bridge may proceed. He also
stated that replacement of the Coraopolis Bridge will
continue to be the highest priority bridge project for the
Allegheny County Department of Engineering and Construction
until they are able to issue a notice to proceed for
construction .
No response required from EPA.
12. Coraopoli»— Neville Island Bridge Comm^tt^* Letter
The Committee sent a letter to EPA requesting "a speedy
review of the S.P.A. documents pertinent to the final
approval of the bridge site."
22
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EPA responded in writing to the letter, and stated that the
work on the Record of Decision for the Bridge Portion of the
Site has been proceeding in accordance with the approved
schedule.
13. Cfllflfflopwealth of Pennsylvania Department of Environmental
Resources Letter
FADER sent EPA a letter expressing concern over the Record
of Decision, and stated that although PADER "agrees with the
EPA's choice of a "No Action" decision for this site," PADER
"cannot concur with the Record of Decision, as written,
because of fundamental differences with the EPA
interpretation of the NCP and CERCLA." PADER believes the
National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) requires that "the risk range level point of
departure for remedial analysis is 1 x 10E-6." EPA
disagrees with PADER's analysis ofthis requirement as set
forth in the NCP. Section 300.430(e)(i)(A)(2) of the NCP,
40 C.F.R. S 300.430(e)(i)(A)(2), clearly states that "[f]or
known or suspected carcinogens, acceptable exposure levels
are generally concentration levels that represent an excess
upper bound lifetime cancerrisk to an individual of between
10"4 and 104...". The-riete level for the Bridge Portion of
the Site is, in its worst scenario, 4.83 x 10E-5 and,
therefore, within the acceptable risk range.
PADER's second concern is EPA's failure to provide an
analysis in the ROD of applicable or relevant and
appropriate requirements {ARARs). EPA has selected a "No
Action* alternative with regard to soil contamination in the
Bridge Portion of the Site which it finds to be protective
of human health and the environment. In light of EPA's
decision not to select a remedial action, the requirements
of Section 121 of CERCLA, 42 U.S.C. S 9621, including the
provisions of Section 121(d)(2) concerning ARARs, are not
triggered; that section applies only in those cases where a
remedial action is selected. As a result, the subject of
ARARs need not be addressed in the OU-2 ROD.
23
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COMMONWEALTH OF PENNSYLVANIA
^ - « DEPARTMENT OF ENVIRONMENTAL RESOURCES
? PENNSYLVANIA 3 SOUTHWEST REGION - FIELD OPERATIONS
- —^^— * ENVIRONMENTAL CLEANUP PROGRAM
" 400 Waterfront Drive
2-> 197M991JA Pittsburgh, Pennsylvania 15222-4745
(412) 442-4000 (answers 24 hrs.)
March 15, 1993
. Mr. Rorauald A. Roman, CIH
Remedial Project Manager
U.S. EPA. Region III
841 Chestnut Building
Philadelphia, PA 19107
RE: Record of Decision (ROD)
Non-Concurrence
Coraopolls Bridge Replacement Project
Ohio River Park Site
Neville TownsMj_
Allegheny County
Dear Mr. Roman:
The Record of Decision received by this office on March 5, 1993 for the
Coraopolls Bridge Replacement Project at Ohio River Park In Neville Township,
Allegheny County has been reviewed by the Department.
H
Although the Department agrees with the EPA's choice of a "No Action
decision for this site, we cannot concur with the Record of Decision, as
written, because of fundamental differences with the EPA Interpretation of the
NCP and CERCLA. '" ~~
The EPA has used 1 x 10E-4 as the acceptable risk range 1n this Record
of Decision, contrary to the language of the NCP Sections 300.430 (e) and (f),
which require that the risk range level point of departure for remedial analysis
be 1 x 10E-6. Section 300.430 (f) further states: "overall protection of human
health and the environmental and compliance with ARARs (unless a specific ARAR
1s waived) are threshold requirements that each alternative must meet in order
to be eligible for selection." Based upon this language, it is the
Commonwealth's position that In this circumstance EPA must use 1 x 10E-6 as the
initial protectlveness goal and EPA oust justify. 1n writing, why a 1 x 10E-4
final remediation goal 1s appropriate for the bridge portion of the Ohio River
Park Site. Not* that three exposure scenarios applicable to this site -
trespassers, potential future residents, and potential long-term workers - have
cancer risks above 1 x 10E-6.
The EPA has failed to provide an ARAR analysis. The Pennsylvania's
ARAR of Groundwater Protection Criteria for Virgin Fuel Contaminated Soil should
be considered. As Indicated in the Focused Remedial Investigation Report, the
soils at the bridge portion of the Ohio River Park Site were contaminated with
petroleum hydrocarbons at levels up to 1,500 ppm. The no action alternative in
this Proposed Plan falls to meet Pennsylvania's ARAR of Groundwater Protection
Criteria for Virgin Fuel Contaminated Soil. As stated above, the NCP requires
An Equal Opponuntty/Affirmativ* Action Employer Recycled Paper
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U.S. EPA, Region III - 2 - March IS, 1993
that for an alternative to be selected, It must meet two threshold requirements,
one of which requires compliance with ARARs. In the event EPA determines that
waiver of an ARAR Is appropriate, 1t must publish such findings together with an
explanation and appropriate documentation pursuant to CERCLA Section 121 (d)(4).
The Pennsylvania non-concurrence with this Record of Decision does not
waive the following rights of the Department which we hereby reserve and
request:
The Department reserves Its rights and responsibilities to take
Independent enforcement actions pursuant to state and federal law.
Under Pennsylvania law, persons responsible for pollution or soil and
groundwater contamination have a legal duty to abate all pollution on
the site notwithstanding the EPA's decision to take no action under
CERCLA. Pennsylvania specifically reserves Its right to take
enforcement action against any responsible person to remediate any
contamination on the site.
The Department also reserves Its right to require responsible persons
to comply with ARARs under CERCLA, consistent with the legal
requirements of 40 CFR 300.430 and CERCLA $121.
EPA will assure that the Department 1s provided an opportunity to fully
participate In any negotiations with the responsible parties and we
request that EPA provide .us with an opportunity to do so.
We request that the comments contained In this letter be made part of
the Administrative Record for the Coraopolls Bridge Replacement Project.
Further, we expect that the final ROD will reflect that the Commonwealth does
not concur with EPA's selected, remedy...
If you have any questions regarding this non-concurrence letter, please
do not hesitate to call me.
Sincerely,
Richard H. Baehr
Solid Waste Specialist
RHBrjC
cc: Region
Chron
Central
be: 0. Haluszczak
J. Shack
R. Baehr
E. Stokan
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SCALE: 1: 24 000
2000 4000 6000
8000 FEET
1/2
1
2 MILES
DATUM MEAN SEA LEVEL
REFERENCE:
Ambridgc, Pennsylvania
USGS 7.5 Minute Quadrangle
FIGURE 1
SITE LOCATION MAP
B««« m*p from RI Report
pr«p»r«d by EH8R
24
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..pii't
GRAVEL
ROAD
ASPHALT ROAD
ABANDONED
OIL
APPROXIMATE
WATER LINE
r-FENCE
ABANDONED
PARK
MAINTENANCE
BUILDING
M
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\
APPROXIMATE
WATER LINE
r-FENCE
ABANDONED
PARK
MAINTENANCE
BUILDING
ASPHALT ROAD
ABANDONED
OIL':
THB BRIDOS
PORTIOH
OF THB SITE
APP.WXIHATE BOUNDARY OF
HAM DISPOSAL THfNCH AREA
DISPOSAL TRENCH LOCAOON
NOJt
mis net'te MS pacfAHO) USING iwr RCPQRT ennnat:
ottCRianoN or /w NCMU «MW an.' AUGUST, tui. CRT.
FIGURE 3
DISPOSAL TRENCH LOCATION
Base map from RI Report
prepared by EN8R
MSH
CPS
•»••<••* 7/29/92
Pretaci
Nunkir*
4920-003
-------
,0*1°
ABAt.'OCKED
OIL DERRICK*"*:
APPROXIMATE
I WATER LINE
SCALE IN
FouHTH
ae-i
FZOURE 4
SOIL SAMPLING LOCATIONS
Base nap from FRZ Report
prepared by HDR
27
-------
IM1I I
MMMI M OMWIC CMNICM1 OillCUO IN Mil
CWMpttlt HIM! MOJICI
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I Ml I I
MMMI Of INOUMIIC CWNICMt Of IfCIIO III Mil
COMOMIII MIMf MONCI
COKIMIMNI
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llt«*l«d tecttround c«nc«nir«llgn* •! M«*nl ckwUcU *r« UMW|kl I* k* tlrlkulM* (• IntalrUI MUT«M In IW vUlnllr •! Ik* (lit.
-------
TABU 3
EXPOSUK MRAJCTOS
COMOPQL11 ttlOd PROJECT
Racaptor Paraaatar Valua
Contact Rata 300 ae/day
Comaraion Factor 16-06 kg/at
ficpoaira Fraquancy SO daya/yaar
Expoaura Duration 10 yaara
lady Ma1«nt* 50 k«
Avaraaina Tlaa
earelnogana 25550 daya
clnogana 3650 daya
Raaldant Contact lata 300 aa/day
Convaralon Factor U-06 kg/a«
bpaaura Fraquaney 350 daya/yaar
bmoaura Duration 30 yaara
•oay tttfgtit^ 59 kf
Avarailni Tloa
carcinooana 25550 daya
Lona-Taf* Uortar Contact lata 500 a«/day
Comaralon Factor 11-06 kg/a«
bmuaun Fraquaney 250 daya/yaar
topaaura Duration 25 yaara
•ody Mlaht 70 k«
Awaraglni Tlaa
Shorfrara Uorkar^* Contact lata 1000 ag/day
Corwaralon Factor 1E-06 kg/a*
bcpamra Fraquaney 10 houra/day
6daya/waak
CorNaralon Factor 1
bqaaura Duratliii**"1 60
My ttef UK 7Q k«
Tlaa
60
•Tha awaraaa body Mlfjtt of • cfcfW, fro* « yaara aid to 18 yaara old* aaa
uaatf.
••Tna inriaa taoaV aafakt of a paraon. frea 1 yaar aid to 30 yaara old. Mas
"*TUf« axpeaura icanarto fa thouoUt to ba rapraaantatlva of tha
bridga conatrvction prejaet.
aiioui duration of aarkar contact Mith potontialiy
oantaainatad aaila during tna propeart brldga canatruction projact
proridad by IM Enginaarlnf.
30
-------
IMlf 4
POIEN1IAL CMCIMGCNIC •IIKt AND NONCMCINOGtNIC IHMAH 10 IMSPASKM
COMfltom MINI MONCt
1
9SSUCI
COMIANIHAMT (a«/kf) (
•enio(o)Anthracon* .40
loniotbmuoranthan* .40
Mrylllu* 1.97 S
CMCIMOtNIC HONCMCHKNINIC
IHTAKI IH1AKI
t*«/M/d*y) (atykayday)
.741-00 .32E-07
.7«f-OB .331-07
.701-00 .SM-07
.671-00 .271-07
.631-08 .141-07
.621-00 .241-07
t.311-07 1.621-06
!••••••••••••••••
CMCINOMNIC
•ISK
4.19E-M
3.S6C-M
2*.OSE-07
7.07C-00
3.13E-07
1.941-06
HOMCAICIHOCEHIC THMAI .
(HAZARD QUOTIIHI)
HA
• HA
HA
HA
HA
HA
3.2*1-0*
OMUUIIVEl 2.711-06 3.24C-04
lit* Canew Potency factor* and RtO» u*«d to calcuUto carcinogenic rltkt and mncarclnoganlc throat* can bo found In tabu j.
uhtn available. Inhalation tonic I ty crltorlo nor* applied to rlak calculation*. *lnc* Inhalation rtpra**nt* th* prloary rout* of
tuposur* at tkl* alt*.
PAN* nor* ovaluatod In t*na» of bonio(a)pyron* oojulvatont*.
HA • Hot Applicable
-------
IM1I 5
C(MAQ»QMS fftlMf MOtfCf
CMIMHNM1
ItnioUIAntfcracana
•wuotblfluoranthana •
•aniott II luoranlhana
•antoUIPyrana
lndana(1.2.9-cd)Fyrana
Difcant(a»Antlirac*na
ttryltliai
• ••••••••••••••••••••••••••I
951 Utt
(••/to)
0.40
0.40
0.41
0.40
0.19
0.19
1.97
CMCIMMMIC
im«a
lMO/kt/4^)
.4X-07
.4«f-or
.911-07
.Mf-07
.241-07
.2U-07
4.12C-06
MHCMCIN08MIC
IMI«tt
(••/kt/*y)
.971-06
.971-06
.991-06
.941-06
.921-06
.921-06
*
9.611-06
CMCIWMfMIC
•IK
7.46C-07
6.MI-07
2.771-07
5.071-06
1.401-06
5.571-06
9.461-05
MONCMCINOCtHIC IWtAI
(WUMtt OUOIIfHI)
HA
N*
MA
HA
HA
HA
1. 921-09
CUNUUIIVCt 4.09f-05 1.92f-05
lit* C*nc«r Colmey factor* and IIP* UMd l« ctlcuUtt carclneomlc riakt antf noocwclnot«nlc thr««u can ba fount In l*bl« S.
Mm avallabla, InHalatlon tonlclty crllarla Mara
aipoaura at tMa alia.
to rlak calculatlona. alnca Inkatatlan raprattnU tha pri«ary route ol
PAHt Mara avaluatatf In tara« of banio(a)pyrana aojilvaianla.
HA • Hat AppllcaMa
-------
1MU 6
COIf HUM. CARCINOGENIC RISKS MB NMCMCIMOGEN 1C THREATS TO LONG-TERN UORKERS
CORAOPOUS MIOGC PROJECT
••••••••••••••••••••••••••1
COMIANINANT
•ontoUIAnthracana
•anioiblf luoronthana
•ento(k Hluoranthana
•anio(a)Pyrana
lndano( 1 .2. S-coWyrana
Oibcni(a,h)Anthracana
••rylllua
9SXUCL
0.40
0.40
0.41
0.40
0.39
0.39
1.97
CARCINOGENIC
INTAKE
7.0SC-07
7.0K-07
7.12E-07
6.94E-07
6.59E-07
6.ME-07
3.44E-06
NONCARCINOGENIC
INTAKE
(oi/kf/day)
.97E-06
.98E-06
.99E-06
.94E-06
.93E-06
.93E-06
9.64E-06
CARCINOGENIC
RISK
0.24E-07
S.SOE-07
2.31E-07
4.24E-06
1.17E-M
4.ooE-.Oo
2.89E-OS
NONCARCINOGENIC THREAT
(HA1ARD OUOTIENTI
NA
NA
NA
NA
NA
HA
1.91E-OJ
OMUIATIVE: 4.04E-OS 1.93E-01
Iht C«w«r Pettney factor* and If0» u*«d to calculate carcinogenic rlaka and noncarclnefonlc threat* can ba found In Tabu J.
Mian awallabla. Irtialatlon tonlclty crltarla Mara appllad to rlak calculation*, alnca inhalation rapraaanta tha prlawy rout* of
aipoaura at thla alta.
MNa Mara avaluatad In tanai of banio(a)pyrana aojulvatanta.
NA • Not ApiMlcabta
-------
IAM.E 7
POIfHIIAl CAM1N06ENIC IICKS AND MONCARCIMOGEN1C fMEAIS 10 SHOBI-IERN UtMKfftS
COtAOPOLIS MIOtI MNMICI
••••••••••••••••••••••••••
CONIANIHAN!
fttniof>yren*
Oibeni(a,b)Anthracene
•erylllua
••••••••••••••••I
95XUCL
(•o/ko)
0.40
0.40
0.41
0.40
0.39
0.39
1.97
•••••••••••••••••••a
CMCIM06EMIC
IMIAKE
4.84E-09
4.0SE-09
4.MC-09
4.76E-09
4.73C-09
4.721-09
2.36E-OB
•••••••••••••••••a*
NONCAICINOCCMIC
INTAKE
(•f/kf/day)
.06E-06
.07E-06
.OOE-06
.011-06
.OIE-06
2.01E-06
I.OU-OS
I«BBBBBBBBB«B»BB
CAICIMOGCNIC
•ISK
4.26E-09
3.63E-09
1.S9E-09
2.90E-OB
8.041-09
3.19E-OB
1.90E-07
•••••••••••••••••••••••••••••I
NONCMCINOGENIC ?««*!
(MA2JUK) QUOtlEHt)
MA
MA
MA
MA
MA
MA
2.0U-OJ
CUNUIATIVE: 2.77E-07 2.011-OJ
lh« Canctr Poltncy factors and ItOs u$«d to olcuUlt carcinogtnlc rltki «nd noncarclnoemlc thr«*tt cm bt found In Tiblt I.
Mien awailablt, inhaUtion to*Icily criteria utrt applied to rUk calculations, tinea Inhalation rtprasmta tha prlavry rout* of
tupoture at this aft*.
PAHs nara evaluated In laraa ol beruo(a)pyrene equivalents.
MA • Mot Applicable
------- |