United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-93/165
January 1993
&EPA Superfund
Record of Decision:
Saegertown Industrial
Area, PA
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R03-93/165
3. Recipient*» Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Saegertown Industrial Area, PA
First Remedial Action - Final
5. Report Oat*
01/29/93
6.
7. Authors)
8. Performing Organization Rapt. No.
9. Performing Organization Name and Address
10 Project Task/Work Unit No.
11. Contract(C) or Grant(6) No.
(Q
(6)
1Z Sponsoring Organization Nam* and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report 4 Period Covered
800/800
14.
15. Supplementary Nat**
PB94-963917
16. Abstract (Umtt: 200 words)
The 100-acre Saegertown Industrial Area is .an industrial park located in Saegertovm
Borough, Crawford County, Pennsylvania. Land use in the area is mixed rural,
residential, and agricultural. Woodcock Creek borders the site to the south, and French
Creek runs from north to south on the western side of the Borough of Saegertown.
Portions of the industrial park lie within the 100-year floodplain of French Creek or
Woodcock Creek. The estimated 1,050 people who reside in the Borough of Saegertown use
ground water from 4 wells, 3 of which are located within a one-mile radius of the site
to obtain their sole source of drinking water. The industrial park consists of four
main areas:, the Lord Corporation (Lord) property; the Saegertown Manufacturing
Corporation (SMC) property; the Spectrum Controls Incorporated (SCI) property; and the
properties that formerly were owned by the General American Transportation Corporation
(GATX). From approximately 1951 until 1967, GATX operated a facility for the cleaning,
painting, and repairing of railroad tank cars on 55'acres of the site property. GATX
operated a wastewater treatment plant onsite, and disposed of wash water and solvents
used to clean the railroad cars in a sludge bed, a lagoon, and a pond. Wastes that
were contained in the cars also were disposed of onsite and consisted of fuel oils,
sludge, phenols, caustic soda, unknown solvents and degreasers, paint and tar residues,
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Saegertown Industrial Area, PA
First Remedial Action - Final
Contaminated Media: soil, debris, sludge, gw
Key Contaminants: VOCs (PCE, ICE, xylenes), other organics (PAHs, PCBs, phenols)
b. IdantHiers/Open-ended Terms
e. COSATI FMd/Gmip
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Pigs)
None
21. No. of Pages
114
22. Pries
(SeeANSI-239.18)
See Instructions an ffever**
OPTIONAL FORM 272 (4-77)
(Formerly KTIS-35)
Department of Commerce
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EPA/ROD/R03-93/165
Saegertown Industrial Area, PA
First Remedial Action- Final
Abstract (Continued)
anhydrous ammonia, benzene, chlorphene, and scrap iron barrels of old paint. Since 1962,
Lord produced adhesives, urethane coatings, and rubber chemicals on approximately 30 acres
of the site. Lord currently uses solvents, including TCE, TCA, xylenes, and methyl
isobutyl ketone (MIBK), in its manufacturing process. From 1968 until approximately 1987,
Lord discharged non-contact cooling water to a shallow impoundment on its property. Since
1987, Lord has been discharging non-contact cooling water via a pipeline to French Creek
.under a NPDES permit. In 1965, SMC began cold metal forming and metal cutting/machining
operations on approximately 15 acres of the site. SMC currently uses a variety of oils
and solvents for degreasing. Cutting oil mixed with metal chips is collected and stored
onsite in a pit prior to offsite disposal; the metal chips are separated from the oil and
recycled onsite. Prior to 1974, a milkplant operated on the current SCI property. In
1974, SCI began manufacturing ceramic capacitors and electroplating silver, nickel, and
tin on approximately 6 acres of the site. Since 1981, SCI has had a NPDES permit for the
pretreatment and discharge of waste and cooling water. SCI wastes include liquid and
solid acid and caustic waste associated with the electroplating operations, and waste
containing MIBK and acetone produced in the manufacturing of capacitors. In 1989, plating
operations were discontinued, and, in 1990, SCI began gasket forming operations on the
property. A 1979 release of waste oil on the SMC property resulted in the removal of 778
yd3 of waste/soil from the site. In 1980, routine sampling of the Borough of Saegertown's
municipal wells revealed elevated levels of TCE, and one of the wells (#2) subsequently
was removed from service. Test pits dug in the vicinity of the pond, on the former GATX
property, revealed deteriorating barrels containing TCE-contaminated sludge. In 1984, EPA
investigated the site and confirmed the presence of TCE and TCA in onsite ground water.
Soil and sludge samples taken from the GATX pond area revealed the presence of TCE, PCE,
PAHs, and 1,4-dichlorobenzene. EPA has determined that remedial action is required at the
former GATX and Lord properties due to improper waste disposal practices. Remedial action
will not be taken at the SMC or SCI properties; however, ground water in the vicinity of
the whole site will be subject to long-term monitoring. This ROD addresses a final remedy
for the contaminated soil and sludge on the former GATX property and the contaminated
ground water in the vicinity of the Lord property. The primary contaminants of concern
affecting the soil, debris, sludge, and ground water are VOCs, including PCE, TCE, and
xylenes; and other organics, including PAHs, PCBs, and phenols.
The selected remedial action for the GATX property includes excavating all contaminated
sludge and soil that contains total carcinogenic PAH concentrations in excess of 1 mg/kg
in benzo(a)pyrene equivalents; processing the excavated sludge and soil by drying, mixing,
or shredding to provide a uniform feedstock for the incinerator, followed by incineration
of the soil and sludge; decontaminating and treating any debris in the excavated material
to render it non-hazardous for offsite disposal, or incinerating it onsite; testing the
incinerator ash by TCLP to determine the concentration of metals in the ash, and, if
necessary, treating it using fixation prior to placing it in the excavated area onsite or
removing it for offsite disposal; restoring or replacing the pond and wetland areas; and
monitoring ground water. The selected remedial action for the Lord property includes
installing air sparging injection wells in the source area to strip contaminants present
in the soil; installing vapor extraction wells in the unsaturated zone to capture
contaminants that are stripped by the air injected into the sparging wells, and capturing
vapor phase contaminants using a carbon absorption unit; delineating the ground water
plume; extracting and treating the ground water onsite using filtration to remove
suspended solids, followed by a packed column air stripping unit with vapor extraction and
carbon adsorption to capture effluent air contaminants, or a UV oxidation system, with
onsite discharge of treated effluent to French Creek via the storm water outfall pipe that
drains the site surface water, or reuse by Lord for its non-contact cooling water needs;
and monitoring ground water for contaminants found in the -sludge. Should contaminant
concentrations in the ground water exceed background concentrations at any time during the
monitoring period, the pump and treat system will be restarted until background
concentrations are achieved for 12 consecutive quarters. The estimated present worth cost
for these remedial actions is $15,100,000, which includes an estimated annual O&M cost of
$275,000 for 10 years.
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EPA/ROD/R03-93/165
Saegertown Industrial Area, PA
First Remedial Action- Final
Abstract (Continued)
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil and sludge cleanup goals on the former GATX property are based on
the carcinogenic risk-based concentration of PAHs that, if left in soil, would not affect
ground water. The total concentration of carcinogenic PAH compounds in the soil following
excavation shall not exceed 1 mg/kg in B(a)P equivalents. Chemical-specific ground water
cleanup goals in the vicinity of the Lord property are based on the more stringent of
background levels or SDWA MCLs, and include 1,2-DCA 5 ug/1; 1,1-DCE 7 ug/1; 1,2-DCE (cis)
70 ug/1; 1,2-DCE (trans) 100 ug/1; PCE 5 ug/1; 1,1,1-TCA 200 ug/1; TCE 5 ug/1; vinyl
chloride 2 ug/1;.'and xylenes 10,000 ug/1.
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RECORD OF DECISION
SAEGERTOWN INDUSTRIAL AREA SITE
DECLARATION
SITE NAME AND LOCATION
Saegertown Industrial Area Site
Saegertown Borough, Crawford County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Saegertown Industrial Area Site (the "Site"), Saegertown
Borough, Crawford County, Pennsylvania, which was chosen in
accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
("CERCLA"), as amended by the Superfund Amendments and
Reauthorization Act of 1986 ("SARA"), and, to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan ("NCP"), 40 C.F.R. Part 300. This decision
document explains the factual and legal basis for selecting the
remedial action for this Site. The information supporting this
decision is contained in the Administrative Record for this Site.
The Commonwealth of Pennsylvania concurs with the selected
remedy. •
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine,
pursuant to Section 106 of CERCLA, 42 U.S.C. § 9606, that actual
or threatened releases of hazardous substances from this Site, if
not addressed by implementing the response action selected in
this Record of Decision ("ROD"), may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE REMEDY
The Saegertown Industrial Area Site is an industrial park
approximately 100 acres in size. The remedial action selected
for the Site is a final remedy which will address soil and ground
water contamination on portions of the Site. The soil
contamination represents the principal threat. Therefore,
excavation and treatment of the contaminated soil will be
required. The ground water contamination represents a
significant threat. Therefore, remediation of the contaminated
ground water will be required.
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The selected remedial action includes the following components:
• Excavation and onsite incineration of contaminated soil
and sludge from the lagoon, sludge bed, and pond areas
on the former General American Transportation Corporation
("GATX") property which is a part of the Site;
• Restoration or replacement of the pond and wetland area
on the former GATX property;
• Long-term ground water monitoring on the former GATX
property;
• Delineation of the ground water plume in the vicinity of
the Lord Corporation property, which is also a part of the
Site;
• Extraction and treatment of contaminated ground
water in the vicinity of the Lord Corporation property,
combined with air sparging and vapor extraction in the
source area of contamination; and
• Long-term ground water monitoring in the vicinity of the
Lord Corporation property.
STATUTORY DETERMINATIONS
The selected remedial action is protective of human health and
the environment, complies with Federal and State requirements
that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedial action
utilizes permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent
practicable, and satisfies the statutory preference for remedies
that employ treatment that reduces toxicity, mobility, or volume
as a principal element.
Because this remedial action will result in hazardous substances
remaining at the Site, a review by EPA will be conducted within
five years after the initiation of the remedial action, and every
five years thereafter, as required by Section 121(c) of CERCLA,
42 U.S.C.- § 9621(c), to ensure that the remedial action continues
to provide adequate protection of human health and the
environment.
Stanley Ix"" Laskowski Date
Acting Regional Administrator
Region III
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RECORD OF DECISION
8AEGBRTOWN INDUSTRIAL AREA SUPBRFUND SITE
DECISION SUMMARY
TABLE OF CONTENTS
Page
Z. SITE NAME, LOCATION AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 6
A. History of the Properties that Comprise the Site. . 6
B. Enforcement Activities 7
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 9
IV. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY. 10
7. SUMMARY OF SITS CHARACTERISTICS .10
A. Land Use, Soils, Geology, Hydrogeology, Hydrology. 10
Soils 10
Geology 11
Hydrogeology 11
Hydrology 12
B. Nature and Extent of Contamination 13
Former GATX Facility 13
Pond Area 15
Lagoon and Sludge Bed Area 21
Soil Gas 22
Rail Siding Area 22
Lord Facility 22
Ground Water 22
Soils 25
Sediments 26
SMC Facility 26
SCI Facility 27
French Creek 27
Drinking Water Analysis 28
C. Contaminant Fate and Transport 28
Former GATX Facility 29
Pond Area. 29
Lagoon and Sludge Bed Area. . 30
Rail Siding Area 31
Ground Water. 31
Lord Facility 32
Ground Water 32
Soil and Sediment 33
SMC Facility 34
SCI Facility 34
D. Principal Conclusions 35
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Page
VI. SUMMARY OF SITE RISKS 37
A. Human Health Risks 37
Identification of Contaminants of Concern. . . 37
Exposure Assessment Summary. ......... 41
Potentially Exposed Human Populations. ... 41
Chemical Exposure Pathways. .' 41
Exposure Point concentrations 42
Routes of Exposure . 42
Toxicity Assessment Summary 48
Risk Characterization Summary 49
Noncarcinogenic Risk 49
carcinogenic Risk 57
B. Environmental Risks 57
C. Significant Sources of Uncertainty 65
D. Risk Assessment Conclusions 65
VII. DESCRIPTION OF REMEDIAL ALTERNATIVES 65
A. Remedial Alternatives for GATX Soil/Sludge. ... 67
B. Remedial Alternatives for Lord Ground Water. ... 76
VIII. SUMMARY OF TEE COMPARATIVE ANALYSIS OF ALTERNATIVES. . 84
A. Comparative Analysis of Alternatives
for GATX Soil/Sludge 85
B. Comparative Analysis of Alternatives
for Lord Ground Water. ., 89
IZ. TEE SELECTED REMEDIES AMD PERFORMANCE STANDARDS. ... 92
A. Selected Remedy for the Contaminated Soil
on the Former GATX Property 93
B. Selected Remedy for the Ground Water
in the Vicinity of the Lord Property 96
C. Selected Alternative for the SMC Property 100
D. Selected Alternative for the SCI Property 101
Z. STATUTORY DETERMINATIONS 101
A. Protection of Human Health and the Environment. . 101
B. Compliance with ARARs 101
C. Cost-Effectiveness 106
D. Utilization of Permanent Solutions and
Alternative Treatment Technologies
to the Maximum Extent Practicable 106
B. Preference for Treatment as a Principal Element. 107
ZI. BXPLAMATIOM Of SIGNIFICANT CHANGES 107
FIGURES AMD TABLES
Figure 1: Site Location and Regional Topographic Map. 2
Figure 2: Water Supply well Location Map 3
ii
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AMD TABLES, Continued
Page
Figure 3: Saegertovn Industrial Area Site Map. ... 4
Figure 4: Sample Location Map 14
Figure 5: Aerial Extent of Sludge
on the Former GATX Property 16
Figure 6: Vertical Extent of Sludge
on the Former GATX Property 17
Figure 7: Aerial Extent of Groundvater Plume
on the Lord Property. 23
Figure 8: Vertical Extent of Groundvater Plume
on the Lord Property. . . • 24
Table 1: Summary of Soil and Groundvater
Calculations 18
Table 2: Exposure Point Concentrations 38-40
Table 3: Summary of Exposure Pathways and
Routes to be Quantitatively Assessed. . .43-44
Table 4: Summary of Exposure Factors
for Risk Estimation 45-47
Table 5: Chemical Toxicity Values and Absorption
Estimates Used for Risk Quantification. 50-53
Table 6: Summary of Risk Estimates by Type of
Land Use, Area, Potentially Exposed
Population and Medium 55-56
Table 7: Maximum Values of Chemicals Detected
in Media of Ecological Concern 59-61
Table 8: Potential Ecological Exposure Pathways. . 62
Table 9: Risk Estimates to Small Mammals'
from Site Contaminants 63-64
Table 10:
Table 11:
Carcinogenic PAB/Relative Potency Factor. 94
Contaminants of Concern in Ground Water
in the vicinity of the Lord Property. .
98
iii
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DECISION SUMMARY
I. SITE NAME, LOCATION, AND DESCRIPTION
The Saegertown Industrial Area Site (the "Site") is an industrial
park in the Borough of Saegertown, Crawford County, Pennsylvania.
(Si<2 figure 1, p. 2) . Saegertown is located approximately 25
miles south of the City of Erie, Pennsylvania, and 5 miles north
of the City of Meadville, Pennsylvania.
The Site is approximately 10O acres in size and is located in,a
broad valley formed by the stream terrace of the French Creek.
It is bordered to the west by the elevated railroad track bed of
the Erie-Lackawanna Railroad. Beyond the railroad tracks to the
west lies the heavily populated area of Saegertown and the French
Creek. Woodcock Creek borders the Site to the south. Rural
residential and agricultural lands border the Site to the north
and east, respectively. Beyond the Borough of Saegertown, the
area is predominantly rural.
Ground water is the sole source of potable water in western
Crawford County. The 1050 residents of the Borough of Saegertown
are supplied with potable water by four wells. Three of the
wells are within a one-mile radius of the Site. The fourth well
is approximately t-;o miles northwest of the Site. (See figure 2,
p. 3). In addition, homes outside the municipal water supply
area in the Site vicinity utilize private wells for potable water
supply.
The industrial park consists of four main areas: the Lord
Corporation ("Lord") property; the Saegertown Manufacturing
Corporation ("SMC") property; the Spectrum Controls Incorporated
("SCI") property; and the properties that were formerly owned by
the General American Transportation Corporation ("GATX"). (See
figure 3, p. 4).
On the properties formerly owned by GATX, approximately 9,000
cubic yards of sludge and' soil contaminated with volatile organic
compounds ("VOCs") and polyaromatic hydrocarbons ("PAHs") are
present in a lagoon, a sludge bed and a pond area.
On the Lord property, an estimated 7,500 pounds of chlorinated
ethanes- have leaked from a sump area into the ground water. As a
result, approximately 9.3 million gallons of ground water have
been contaminated with tetrachloroethene, 1,2 dichloroethene,
vinyl chloride and trichloroethene.
After assessing the risk of the above contaminants to human
health and the environment, EPA has determined that remedial
action is required at the former GATX and Lord properties.
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Figure 1
SITE LOCATION
and REGIONAL TOPOGRAPHIC MAP
SAEGERTOWN INDUSTRIAL AREA SITE
SAEGERTOWN INDUSTRIAL AREA
SUPERFUND SITE
0 2000
SCALE IN FEET
Source: Meadville, PA, 7.5 Minute USGS Topographic Quadrangle Map
1968, Pbotorevised 1973.
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Figure 2
SAEGERTOWN INDUSTRIAL AREA SITE
WATER SUPPLY WELL LOCATION MAP
SITE LOCATION
LEGEND
BPW1
PRIVATE WATER SUPPLY WELL
LOCATION AND NUMBER (APPROXIMATE)
HW3 BOROUGH WATER SUPPLY WELL
LOCATION A, D NUMBER (APPROXIMATE)
NOTES
1. SITE LOCATION MAP DEVELOPED FROM THE
MEADV1LLE. PENNSYLVANIA 7.5 MINUTE
USGS TOPOGRAPHIC QUADRANGLE MAP DATED
1968. PHOTOREVISED 1973.
north
2000
SCALE IN FEET
4000
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Figure 3
SAEGERTOWN INDUSTRIAL AREA SITE MAP
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The SMC property contains 15-60 cubic yards of polychlorinated
biphenyl ("PCB")-contaminated sediment. However, the
concentration of PCBs in the sediment, .260 parts per million
("ppm"), is well below the 10-25 ppm action level for industrial
areas or the 1 ppm action level for residential areas which EPA
has established. (See Guidance on Remedial Action for Superfund
Sites with PCB Contamination, U.S. EPA, 3SWER Directive No.
9355.4-01, August 1990). Therefore, remedial action will not be
taken at the SMC property.
Similarly, the 31 property contains 40-240 bic :rds of soil
contaminated wita low levels of VOCs and PAHs These
concentrations of PAH compounds were detected _n the subsurface
soils. The low levels of PAHs are comparable to concentrations
found in background surface soil samples. The concentration of
the VOCs (ethylbenzene, xylene and toluene) in the majority of
the soil samples taken are below the required detection limits.
No VOCs or PAHs were detected in the SCI area ground water. No
adverse health effects are presented by the current use of the
SCI property. The health effects of exposure to the SCI soil
contamination under a future Site use scenario as a residential
property were assessed quantitatively in the Risk Assessment
performed in the Remedial Investigation. The contaminated soil
was found not to present an unacceptable risk to human health or
the environment under the future residential Site use scenario.
Therefore, remedial action will not be taken at the SCI property.
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II. SITE HISTORY AND ENFORCEMENT ACTIVITIES.
A. History of the Properties that Comprise the Site
The Former General American Transportation Corporation Property
From approximately 1951 until 1967, GATX operated a facility for
the cleaning, painting and repairing of railroad tank cars on 55
acres of the Site property. During its active use, approximately
two-thirds of the GATX property was covered with rail sidings.
GATX operated a wastewater treatment plant onsite, and wash water
and solvents used to clean the railroad cars were disposed of
onsite in a sludge bed, a lagoon, and a pond. Wastes contained
in the cars which were also disposed of onsite consisted of fuel
oils, sludges, phenols, caustic soda, unknown solvents and
degreasers, paint and tar residues, anhydrous ammonia, benzene,
chlorphene and scrap iron barrels of old paint. In 1967 all of
the rail sidings were removed and the GATX facility was closed.
In 1970 GATX sold the property to the Meadville Area Industrial
Commission. The former GATX property is currently owned by David
J. and Judith S. Froess, the Borough of Saegertown, Haemer Tool
and Die, Inc., Tru - Weld Corporation, C.J. Ferry, and Multi-
Plastics, Inc.
The Lord Corporation Property
Since 1962, the Lord Corporation has produced adhesives, urethane
coatings and rubber chemicals on approximately 30 acres of
property on the Site. Lord uses solvents including
trichloroethylene ("TCE"), trichloroethane ("TCA"), xylene and
methyl isobutyl ketone ("MIBK") in its manufacturing processes.
From 1968 until approximately 1987, Lord discharged non-contact
cooling water to a shallow impoundment on its property. From
1987 until the present, Lord has been discharging non-contact
cooling water via a pipeline to French Creek under National
Pollutant Discharge Elimination System ("NPDES") permit No.
PA0101800.
The Saegertown Manufacturing Corporation Property
In 1965, the Saegertown-Manufacturing Corporation started cold
metal forming and metal cutting/machining operations on
approximately 15 acres of property on the Site. SMC uses a
variety of oils for cooling, cutting and lubricating metal. It
also uses solvents for degreasing. Cutting oil mixed with metal
chips is collected and stored in a pit onsite prior to offsite
disposal. Metal chips are separated from the oil and recycled.
In 1985, SMC produced approximately 7 tons per year of cold
forming and metal cutting sludge, which contained between 3% and
5% Varsol solvent. SMC continues to operate its business onsite.
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The spectrum Control Incorporated Property
Prior to 1974, a milk plant operated on the current Spectrum
Control Incorporated property. In 1974, SCI began manufacturing
ceramic capacitors and electroplating silver, nickel and tin on
approximately 6 acres of property on the Site. SCJ generated a
silver cyanide electroplating bat'' waste in their ^ctroplatir.g
operations which rhey sent to a r: "cling facility or recover
of the silver. Since 1981 SCI has ad an NPDES pernit for the
pretreatment and discharge of waste and cooling water. In 1981
over 17,000 gallons per day of this wastewater was discharged to
a storm sewer which empties into the French Creek upstream of its
confluence with Woodcock Creek. SCI wastes included liquid and
solid acid and caustic waste associated with the s sctroplating
operations, and waste containing MIBK and acetone _ .-oduced in the
manufacturing of capacitors. SCI used TCE before 1978, and TCA
after 1978, to clean the capacitors. SCI utilized acetone, MIBK,
toluene, acids, and caustics from 1974 until 1989. Plating
operations were discontinued in 1989. In April 1990 SCI began
gasket forming operations on the property.
B. Enforcement Activities
In February 1979 a waste oil collection pit on the SMC property
was flooded with surface water runoff from a heavy rain. The
rainwater displaced the oil, resulting in a reported release of
approximately 500 gallons of waste oil. The waste oil stained an
area 150 feet by 20 feet along the SMC property line, and
partially on the adjacent SCI property. In June 1979, Kebert
Construction Company, on behalf of SMC, reportedly excavated an
area of soil affected by the spill that was approximately 175
feet long by 25 feet wide by 13 feet deep. The Pennsylvania
Department of Environmental Resources ("PADER") observed the
removal of the oil-stained soil. Approximately 778 cubic yards
of waste/soil was excavated from this area and taken offsite for
disposal.
In April 1980, during routine sampling of the Borough of
Saegertown's municipal wells, PADER discovered that Borough Well
Number 2 ("BW2"), which is located approximately 400 feet west of
the Saegertown Industrial Area Site, was contaminated with TCE at
a level of 310 parts per billion ("ppb"). The Borough removed
BW2 from service, but continued to pump the well in an attempt to
flush the contaminants from the ground water. The Borough also
hired Moody and Associates ("MAI"), environmental consultants, to
investigate the potential sources of the contamination. Test
pits dug in the vicinity of the pond on the former GATX property
revealed deteriorating barrels containing sludge. Analysis of a
sample from one of the deteriorating barrels showed that the
sludge contained 100 ppb TCE. MAI concluded that sludge in the
pond and in the former treatment area on the GATX property were
the sources of the contaminants impacting BW2.
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In 1980 PADER sampled Lord Corporation's non-contact cooling
water, which was being discharged to an onsite impoundment.
Analysis of the samples revealed that they contained trace to low
levels of several volatile organic compounds, including TCE,
tetrachloroethylene ("PCE"), benzene and xylene. Lord contended
that the source of these contaminants was the water supplied by
the Borough.
In 1980, PADER detected TCE and TCA in a monitoring well on the
SMC property.
In 1981, analysis of samples obtained by PADER from cutting oil
tanks on the SMC property revealed the presence of trace amounts
of TCA. SMC asserted that the source of the TCA was the
Borough's water supply. SMC denied that it used TCA in its
manufacturing processes, except in very small quantities which
were totally consumed in the process, so that no waste was
created.
In 1981 samples were taken on the SCI property from a well used
by the milk plant that formerly operated there. Analysis of the
ground water samples revealed the presence of TCE and TCA.
On June 11, 1982, the Borough of Saegertown filed a legal action
against SMC and SCI, alleging that these companies were
responsible for polluting BW2. The Borough later voluntarily
discontinued its action against SMC and SCI.
In July 1984, EPA began a Site Inspection of the Saegertown
Industrial Area Site. Sampling confirmed the presence of TCE and
TCA in ground water onsite. Soil and sludge samples from the
GATX pond area revealed the presence of TCE, PCE, polyaromatic
hydrocarbons ("PAHs") and 1,4-dichlorobenzene.
On November 20, 1985, EPA calculated a Hazard Ranking System
score of 33.62 for the Saegertown Industrial Area Site.
This score was based primarily on the presence of hazardous
substances in the ground water in the vicinity of the Site.
On June 24, 1988, the Saegertown Industrial Area Site was
proposed for listing on the National Priority List ("NPL") of
Superfund- Sites.
In late 1989, GATX, SMC, SCI and Lord signed an Administrative
Order on Consent ("Consent Order") with EPA (Docket No. 111-90-
08-DC). Under the terms of the Consent Order, the Companies
agreed to conduct a Remedial Investigation/Feasibility Study
("RI/FS") for the Site. (The RI/FS Reports for the Site have
recently been completed and accepted by EPA.)
On February 21, 1990, the Saegertown Industrial Area Site was
listed on the NPL.
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III. HIGHLIGHTS OP COMMUNITY PARTICIPATION
A public meeting was held on November 27, 1990 to discuss the
start of the Remedial Investigation and Feasibility Study for the
Saegertown Industrial Area Site.
The RI/FS Report and the Proposed Plan for the Saeger~own
Industrial Area Site were released to the public on October 21,
1992. These documents were made available to the public in both
the Administrative Record located at the EPA Docket Room in
Region III, and the information repository at the Saegertown Area
Library in Saegertown, Pennsylvania. In accordance with Sections
113(k)(2) and 117 of CERCLA, 42 U.S.C. §§ 9613(k)(2) and 9617, on
October 21, 1992, EPA placed a 1/4 page advertisement in the
Meadville Tribune and the Erie Times newspapers announcing the
30-day comment period on the Proposed Plan for the remedial
action at the Saegertown Industrial Area Site.
The public comment period began October 21, 1992 and ended
November 20, 1992. A request for an extension to the public
comment period was made. On November 27, 1992, EPA placed an
advertisement in the Meadville Tribune and the Erie Times
announcing that an additional 30 days had been added to the
comment period, and that the comment period would end on December
20, 1992.
A public meeting was held on November 5, 1992. At this meeting
representatives from EPA summarized the rasults of trie RI/FS,
explained the incineration process proposed for the contaminated
soil on the former GATX property, and discussed the risk to human
health and the environment posed by the Site. EPA also answered
questions from citizens at the meeting about the proposed
remedial alternatives for the Site. A response to the comments
received during the public comment period is included in t ?.
Responsiveness Summary, which is part of this Record of Decision.
This Record of Decision ("ROD") presents the selected remedial
action for the Saegertown Industrial Area Site, in the Borough of
Saegertown, Crawford County, Pennsylvania, chosen in accordance
with CERCLA, as amended by SARA, and, to the extent practicable,
the National Contingency Plan.
-------
IV. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
This final remedy for the Site addresses contaminated soil and
sludge on the former GATX property and contaminated ground water
located on, and emanating from, the Lord Corporation property.
On the former GATX property, potential ingestion or inhalation of
the carcinogenic PAHs in the sludge and soil poses the principal
risk to human health or the environment. Excavation and
incineration of the sludge/soil will eliminate the risk. EPA has
determined that there are no contaminants in the ground water
requiring remediation at this time. However, the ROD specifies
continued monitoring of the ground water during the
implementation of the selected remedy to ensure the effectiveness
of the remedial action.
On the Lord Corporation property, potential ingestion, inhalation
or dermal contact with the concentrations of organic contaminants
in the ground water poses a significant risk to human health or
the environment. Pumping and treating the ground water and air
sparging the source area of contamination will reduce the
concentration of organic contaminants in the ground water to
background levels and eliminate the risk.
On the SMC and SCI properties, potential ingestion, inhalation or
dermal contact with contaminants in the soil would not pose an
unacceptable risk to human health or the environment. Ground
water under these properties is not affected by the contaminants
present in the soil. Therefore, this ROD selects the No Action
Alternatives for the SMC and SCI properties.
V. SUMMARY OF SITE CHARACTERISTICS
A. Land Use. Soils. Geology. Hvdrogeoloay. Hydrology
The Site consists of industrial buildings, paved and gravel
parking lots, grassy fields/lawns, woods, a public park,
agricultural fields and old field vegetation. A small pond and
wetland area are located on the former GATX property. A wetland
area also exists south of the Site near the confluence of the
Woodcock and French Creeks.
1. Soils
Surficial soils have been disturbed over much of the Site due to
the construction and dismantling of structures on the former GATX
property, as well as to the construction of other industries. As
a result, the upper soil profile has been altered over portions
of the Site.
Based on RI field investigation results, the surficial soils
mainly consist of well drained organic silts and fine sand.
10
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Varying amounts of clay and gravel exist near the surface at many
locations.
2. Geology
The Site is located on a broad stream terrace (formed during
glacial times) cf French Creek within the glaciated section of
the Appalachian Plateau Physiographic Province.
The Site is underlain by glacial material consisting of either
outwash or till. The glacial deposits are generally 45 to 50
feet thick and consist mainly of sand and gravel. However, based
on data collected during the RI, these deposits also contain
varying percentages of clay and silt.
The heterogeneous nature of the Site's unconsolidated soil
suggest that scattered discontinuous winding belts of sand and
gravel exist within the valley fill material. Based on the
boring logs and cross-sections, there appear to be no distinctive
individual stratigraphic units within the unconsolidated
deposits.
Bedrock is generally encountered between 45 and 50 feet below the
ground surface. Bedrock near Saegertown is mapped as consisting
of the Devonian age Conewango Group. The Riceville shale is the
upper shale unit in the Group and consists mostly of interbedded
light greenish gray to light bluish gray shale and siltstone.
The Conewango Group is approximately 385 feet thick near the
Site. The rock units dip to the south at approximately 10 to 20
feet per mile and strike generally east-west; as a result, rock
thickness is generally dependent on topography.
3. Hydrogeology
Ground water is the sole source of potable water in the vicinity
of the Site in Western Crawford County. Ground water flow is
generally from the upland areas, through the weathered shale
toward the valleys containing glacial outwash. Ground water in
the outwash discharges, to streams. Highly productive outwash
aquifers are found in major valleys, including French and
Woodcock Creeks. A northwest-southeast trending ribbon of
outwash is reported to be present beneath the former GATX
facility (Schiner & Gallaher, 1979). This outwash ribbon is
flanked to the northeast and southwest by finer grained till.
Recharge to the outwash aquifer occurs through direct
infiltration and precipitation.
The Saegertown Borough water supply wells tap these granular
outwash deposits. The well screen for Borough Well 1 is between
50 and 60 feet below the surface, the screen on Borough Well 2 is
between 32 and 49 feet, and the screen on Borough Well 3 is
between 45 and 60 feet below the surface.
11
-------
The deeper shale formation yields only small quantities of water
and is considered a poor aquifer. However, some private water
supply wells in the area draw water from the shale.
Ground water occurs under unconfined conditions in the
unconsolidated sand and gravel aquifer. No aquitards or
aquicludes were discovered during the RI.
Ground water flow beneath the Site is primarily horizontal,
generally from east to west and southwest beneath the Site. Well
nests located in close proximity to French Creek had an upward
vertical gradient, suggesting that French Creek is likely a local
ground water discharge zone. The ground water flow direction in
the deeper portion of the outwash aquifer is similar to the flow
direction in the water table.
4. Hydrology
French Creek runs from north to south on the western side of the
Borough of Saegertown. In the Saegertown area, French Creek is
approximately 200 feet wide and varies in depth from 6 inches to
3 feet during the period of late summer low water. French Creek
is classified as a warm water fishery by the Pennsylvania Fish
Commission. Mussel species, including the northern riffleshell
and clubshell, which were formally proposed for listing as
endangered species under the Endangered Species Act of 1973, may
inhabit French Creek. French Creek has well defined banks
without distinct ripple or pool areas or much streamside wetland.
The banks are approximately 2 to 10 feet high on both sides of
the creek.
The French Creek stream bottom sediment in most areas appears to
be a gray clay. The clay material of the stream bed provides
poor habitat and poor substrate for organism colonization.
Submerged grasses near the banks of the Creek are not in
evidence, although some of the trees may have been wetland
species. Rocks or cobbles in the stream bed are not visible.
A storm sewer outfall, the discharge point established in SCI's
NPDES permit, is located on the eastern bank of French Creek,
approximately 50 feet south of the South Street bridge. The
stream here has a hard bottom in the stream channel, but has
silty-gravelly deposits with much organic detritus in the side
area that forms the mouth of the drainage culvert.
French Creek is joined by the westerly-flowing Woodcock Creek
approximately 1800 feet south of the southwest corner of the
Site.
South of the Site, Woodcock Creek is a meandering stream
approximately 30 to 40 feet wide, and 1 to 2 feet deep. The
creek is classified by the Pennsylvania Fish Commission as a cold
12
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water stream. It contains typical coldwater fish species, such
as trout species and white suckers. Near the confluence of
Woodcock Creek and French Creek, the stream is slow moving,
perhaps 3 feet or more deep, approximately 20 feet wide. Further
upstream the Woodcock Creek narrows to approximately 6 to 8 feet
in width, and approximately 1 foot in depth, with a silty sand
bottom.
An intermittent stream is located adjacent to the eastern Site
boundary. This intermittent stream feeds into Woodcock Creek at
a point southeast of the Site and east of the Saegertown waste
water treatment plant.
There is little topographic relief over the Site area. Ground
surface slopes away from the northeastern topographic high gently
to the south and to the west at a grade of 0 to 3 percent.
Several small drainage ditches and low spots where surface water
runoff collects are present on the Site. The pond on the former
GATX property and a small catchment basin on the SMC property are
two areas where surface water collects following precipitation
events.
Portions of the Site are located within the "100-year floodplain"
of French Creek or Woodcock Creek as defined by the Federal
Emergency Management Agency (FEMA).
B. Nature and Extent of Contamination
The investigation into the nature and xtent of contamination at
the Saegertown Industrial Area Site occurred in two phases.
Phase I RI field activities occurred from September 1990 through
February 1991. Phase II RI field activities occurred from August
to October 1991. Onsite sample locations are shown on Figure 4
(p. 14) . A summary of the results from the RI sampling program
by property are shown below.-
Former GATX Facility
Three distinct areas on the former GATX facility property were
assessed during the RI. These areas and the locations sampled
are as follows:
' Pond Area
' Former Lagoon and Sludge Bed Area
' Former Rail Siding Area
13
-------
Figure 4
SAEGERTOWN INDUSTRIAL AREA SITE SAMPLE LOCATION MAP
-------
GATX Pond Area
Sampling in this area revealed buried sludge materials containing
VOCs and semi-volatile compounds ("SVOCs"), including high
concentrations of polyaromatic hydrocarbons. Tr.s cor.~amination
in the sludge may be from residues of a coal tar derivative
coating which was, in the past, applied to the exterior of
railcars. Coal tars and sludges are comprised primarily of
hundreds of different PAHs and minor amounts of phenolics and
aromatic hydrocarbons. The VOCs could have originated from
solvent systems used in the railcar coatings, or from equipment
and railcar cleaning activities.
Figure 5 (p. 16) depicts the aerial extent of the sludge in the
pond area. Figure 6 (p. 17) depicts a cross section of the
sludge in this area, showing the vertical extent. The thickness
of the sludge layer ranges from 0.5 to 6 feet. Sludge is visible
at the surface in some areas, while a soil cover approximately
one foot thick is present over the majority of the area south of
the pond. The sludge layer is thickest south of the pond.
Samples of the sludge taken from this area contained high
concentrations of organics and inorganics when compared to
samples of the surrounding soil. Table 1 (p. 18) summarizes the
contaminants and the volume of the contaminated media found in
the pond area.
VOCs detected in these sludge samples include the chlorinated
hydrocarbons tetrachloroethene, trichloroethene, and 1,1,1-
trichloroethane at concentrations up to 39,000 micrograms per
kilogram ("ug/kg"). Aromatic volatiles detected include benzene,
toluene, ethylbenzene, styrene, xylenes and chlorobenzene at
concentrations up to 230,000 ug/kg. SVOCs detected in sludge
samples included phenols, chlorinated benzenes and PAHs, at
concentrations-up to 45,000,000 ug/kg.
Non-aqueous samples collected from the GATX pond area include
shallow soil boring, shallow auger probe, test pit and sediment
samples. Depending on the season and the weather, the pond size
varies considerably, from extending throughout the entire fenced
area to completely drying up. Locations sampled as sediments in
January were dry and vegetated in September. Samples collected
from shallow soil borings, shallow auger probes and test pits
were considered sub-surface samples.
15
-------
Figure 5
AERIAL EXTENT OF SLUDGE ON THE FORMER GATX PROPERTY
o\
LLGQNP
-------
Figure 6
VERTICAL EXTENT OF SLUDGE ON THE FORMER GATX PROPERTY
NORTH
ELEVATION
1120 r
1115
1110
1105
1100
NORTH
ELEVATION
1115
1110
1105
POND AREA
B
FORMER LAQOON/8LUDQE BED AREA
h FORMER J l_
UGOON n r
FORMER SLUDGE
BED
H
EAST
ELEVATION
-i 1120
1115
1 HO
1105
1100
SOUTH
ELEVATION
A' -, 1115
1110
-> 1105
ESTIMATED ZONE OF SLUDGE CONTAMINATION
ASSUMED ZONE OF RESIDUA!. SOIL
CONTAMINATION FROM SLUDGE
ESTIMA1EO ZONE OF PCB CONTAMINATION
NOTES
I. REFER TO FIGURE 4-10 FOR CROSS SECTION LOCATIONS.
2. ESTIMATED ZONES OF SLUDGE AND PCBs ARE FOR DESIGN
PURPOSES IN THE FEASIBILITY STUDY.
CROSS SECTION SCALE
6 n
0 60 100
SCALE IN FEET
VFRTICAI EXAGGERATION: TEN TIMES
-------
TABLE 1
SUMMARY OF SOIL AND GROUNDWATER CALCULATIONS
SAEGERTOWN INDUSTRIAL AREA SITE
Area
SCI
SMC
GATX
Imparted
Medium
Ground waier
SoU
Sediment
Sofl(B7)
Sediments (SD6)
Sludge (pond)
Volume1"
9300,000 gallons
40-240 cu. yds."
15-60 cu. yds.
285 cu. yds.
260 en. yds.
6JOOcu. yds.
Sludge (lagoon)
2^00 en. yds.
Chemical
Group'
tetrachloroethene
trichloroethene
l,2dichloroethene
1.1,1 trichloroethane
vinyl chloride
PAHs
PCBs
PCBs
PCBs
PAHs
BETX
Chlorinated Ethenes
Chlorinated Benzenes
Phenols
Miscellaneous
Metals
PAHs
BETX
Chlorinated Ethenes
Chlorinated Benzenes
Miscellaneous
Metals
18*
0260'
BOO-
SO*
120,000"
17,000-
24»
380"
1,900"
3.500"
1,900"
27.000°
1.6°
580"
440"
36"
Max Cone'
9.80-
1.125*
0.1504
0.770s
OJ260'
800*
50*
190,000"
28JXX)11
39"
950"
Z900"
5,800"
3.100"
46W
3300°
IS"
980°
750"
39U
Notes
T. Chemical groups are broken oat as shown in Tables 4-t thru 4-4.
Z Concentrations listed are for the indicated target compound or the sum of all of the target compounds within a chemical group.
3. A flow-weighted average concentration, determined using pumping rates for the aggressive pomp and treat system modeled in
Appendix B, was considered to be representative for mis target compound. The determination of the flow-weighted average
concentration for each target minimum I is shown in the Attachment.
4. Maximum of temporary weUpoint samples WP1 to WP6, WP12 to WP1S, WP17, WP2S. E-2, E-4, E-10, and monitoring wells
W-3 and W-7 was considered to be representative of the maximum concentration for this target TMtirwnd
5. Data from groundwater monitoring well sample GWW11S-02 was considered to be representative of the maximum
6. Data from subsurface soil sample B2^ was considered to be representative of the maximum and average concentration^) for
target compound^) in this chemical group.
7. Data from sediment sample SD9 was considered to be representative of the maximum and average concentration^) for target
compound^) in this chemical group.
8. Data from subsurface soil sample B7-02 was considered to be representative of the «"«v""fii and average concentration(s) for
target compounds) in mis chemical group.
9. Data from sediment sample SD6 was considered to be representative of the maximum and average concentration(s) for target
10. The volume weighted avenge of test pit samples TP1 and TP2, where TPl represents sludge and TP2 represents lower
concentration smoge and contaminated soil present below and at the perimeter of the sludge was considered to be representative
of the average coDceninaon(s) for target compounds) in this chemical group.
11. Data from test pit sample TPl was considered to be representative of the maximum concentration(s) for target compounds) in
12. The volume weighted average of subsurface soil samples AP83 and B4-6. where AP83 represents sludge and B4-6 represents
lower concentration sludge and contaminated soil present below and at the perimeter of the sludge was considered to be
representative of the average concentration^) for target compound(s) in this chemical group.
13. Data from subsurface sou sample AP83 was considered to be representative of the maximum concentrauon(s) for target
compoundXs) m this chenucal giuuu.
14. Soil and sludge volumes represent excavated volumes, assuming 30 percent bulking upon excavation.
15. See Section 4J.Z3, Description for assumptions used to establish the volume of potentially contaminated SCI soil
18
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Soil samples were collected from shallow auger probe locations
around the perimeter of the sludge in the pond area. These
samples were collected to evaluate the quality of the soils
surrounding the sludge. VOCs were not detected in samples
collected from these locations. SVOCs, with the exception of
naphthalene (35 ug/kg), were also not detected in the shallow
auger probe sa.. pies.
The PCB compound Aroclor 1260 was detected in a soil sample at
830,000 ug/kg. Fill material is present at 0 to 1.5 feet at this
boring location and the Aroclor 1260 may be related to the fill.
No other pesticides or PCBs were found in either of the shallow
soil borings.
Of the metals detected in the soil samples collected around the
pond, aluminum, antimony, arsenic, barium, cadmium, chromium,
cobalt, copper, iron, lead, magnesium, manganese, mercury,
nickel, potassium, selenium, sodium, thallium, vanadium, zinc and
cyanide were found at concentrations above background values.
Elevated metals concentrations in surficial soils or sediments
may be due to fugitive losses of metal dusts and particulates
from former GATX operations, including metal blasting and
maintenance activities.
.Two sediment samples were taken at the GATX Pond. One sample on
the northwestern side of the pond contained no detectable VOCs,
while the sample on the eastern edge of the pond (within the
sludge area) contained tetrachloroethene and trichlorcethene at
1,500,000 and 610,000 ug/kg, respectively, and 1,1,2,2-
tetrachloroethane and 1,1,2-trichloroethane at estimated
concentrations of 27,000 and 43,000 ug/kg, respectively. In
addition, this sample contained benzene, ethylbenzene, toluene,
and xylene ("BETX") compounds at concentrations up to 95,000
ug/kg. Styrene and chlorobenzene were detected at 22,000 and
170,000 ug/kg.
SVOC analysis indicated that the sediment sample on the eastern
edge of the pond was highly contaminated with a variety of
substituted phenols and PAHs totaling 14% of >.ie sample dry
weight. The sediment sample on the northwest side of the pond
contained similar SVOC compounds, but at substantially lower
concentrations of 190-3900 ug/kg. Both Pond area sediment
samples contained the PCB Aroclor 1260 at concentrations of
33,000 ug/kg and 340 ug/kg, respectively.
Barium, chromium, lead, mercury and zinc were present above soil
background levels for both sediment samples. In addition, the
northwest sediment sample contained aluminum, potassium and
vanadium above soil background values, while the eastern sediment
sample contained elevated levels of arsenic, cadmium, calcium,
copper, iron, nickel, selenium, silver, thallium and cyanide.
19
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Surface water samples were collected from the pond in January
1991. Trichloroethene and tetrachloroethene were both detected
at low concentrations (1 to 3 micrograms per liter ("ug/1")). No
SVOC, pesticide or PCB compounds were detected in the pond
surface waters.
Metals results in the surface water samples from the pond were
compared directly to metals results in a sample collected
upstream of the Site in French Creek. The concentrations of
metals were similar, with the exception of zinc, which was
detected at the pond at 20 to 28 ug/1, aluminum, which was
detected at 70 to 85 ug/1, and iron, which was detected at 93 to
106 ug/1. Zinc, aluminum, and iron were not detected above the
reported detection limit ("RDL") in the upstream surface water
sample.
Ground water samples were collected from temporary well points
installed on the former GATX property in close proximity to the
pond. Trichloroethene and 1,2-dichloroethene were detected, with
TCE concentrations ranging from 35 to 41 ug/1 in two temporary
wellpoint samples (WP20, WP22). A permanent monitoring well
(Wioi) was installed adjacent to the temporary well point WP22.
Ground water monitoring wells were located downgradient of the
sludge and pond areas. (See Figure 2, p. 3). Tetrachloroethene
(1-3 ug/1) was detected in Wells W4S and W9S during both phases
of sampling. Trichloroethene was detected in Well W9S (l ug/1)
in the second phase of sampling. Benzene was detected in W5S (5
ug/1) in the second phase of sampling only. Other wells showed
no detected VOCs in either of the sampling phases.
SVOC and pesticide/PCB organic compounds were not detected in
ground water samples, with the exception of 1,4-Dichlorobenzene
at 3 ug/1 and diethylphthalate at 1 ug/1, which were found in one
well during the second sampling phase.
Metals analysis of these filtered samples indicated that most
metals are below ground water background values, with the
following exceptions. One well contained antimony .at 5.3 ug/1 in
Phase 1 and cyanide at 12 and 5 ug/1 in Phases 1 and 2,
respectively. Another well contained zinc (17 ug/1 in phase 2),
iron (3330 and 3250 ug/1 in Phases 1 and 2)/ and manganese (3230
and 4120 ug/1 in Phases l and 2) at levels above ground water
background* values. Antimony and total cyanides were detected in
excess of background levels downgradient from the former
lagoon/sludge bed area, while iron, manganese, and zinc were
detected in excess of background levels downgradient from the
pond area.
Total cyanide was the only inorganic compound which has a primary
Safe Drinking Water Act ("SDWA") Maximum Contaminant Level
("MCL") and which was detected above background levels. The
20
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measured concentrations of 12 and 5 ug/1 are well below its
proposed MCL of 200 ug/1. The source of the total cyanides is
believed to be wastewater discharges which occurred during the
operation of the railcar cleaning and repair facility.
The potential for contamination from air emissions related to the
pond was evaluated by estimating contaminant emissions from the
pond and then assessii••: downwind contaminant concentrations using
dispersion modeling. The results of this modeling are discussed
in the Summary of Site Risks section of this ROD.
GATX Lagoon and Sludge Bed Area
The lagoon and sludge bed area on the former GATX property also
contains buried sludge. Figure 5 (p. 16) depicts the aerial
extent of the sludge in this area. Figure 6 (p. 17) depicts a
cross section of the sludge, showing the vertical extent.
Samples of sludge from this area contained high concentrations of
organics and inorganics when compared to samples of the
surrounding soil. Table 1 (p. 18) summarizes the contaminants
and the volume of contaminated media" found in this area.
VOCs detected in shallow soil boring and shallow auger probe
samples include tetrachlcroethene, trichloroethene, 1,2-
dichloroethene, 1,2-dich-aropropane, 2-butanone (methyl ethyl
ketone or MEK), and 4-methyl-2-pentanone (methyl isobutyl ketone
or MIBK). Concentrations ranged up to 1500 ug/kg. Aromatic VOCs
detected include xylenes, styrene, ethylbenzene, toluene, benzene
and chlorobenzene. Concentrations ranged up to 44,000 ug/kg.
The highest concentrations were found in the former sludge bed
area. SVOCs detected in samples included dichlorobenzenes and
other chlorinated benzenes, and a wide range of PAHs at
concentrations up to 770,000 ug/kg\
Soil samples were collected from shallow auger probe locations
around the perimeter of the area containing slue-re in order to
evaluate the quality of the soil surrounding the sludge. VOCs
were not detected in samples collected, from these locations.
SVOCs, naphthalene (up to 580 ug/kg) and 2-methylnaphthalene (39
ug/kg) were detected in soil samples. The PCB Aroclor 1260 was
detected in soil boring 3 at a depth of six feet at 1100 ug/kg.
Of the metals detected in these samples, arsenic, calcium,
chromium, copper, lead, magnesium, manganese, mercury, nickel,
sodium, zinc and cyanide were detected at concentrations greater
than soil background concentrations.
In addition to the shallow soil boring and shallow auger probe
samples collected in the sludge bed/lagoon area, two surface soil
samples were also collected. No volatiles were detected in these
samples. PAHs similar to those found at depth were detected at
concentrations ranging up to 4400 ug/kg. Pesticide and PCB
compounds were not detected in the surface soils. Barium,
21
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calcium, chromium, lead, magnesium, mercury and zinc were found
at concentrations greater than background concentrations.
GATX Soil Gas Sampling
Soil gas samples were collected from two grid areas on the former
GATX property: one near the lagoon, and one near the sludge bed.
Figure 4 (p. 14) shows the location of the soil gas grids. In
addition, soil gas samples were obtained from the area south of
the two grids and from the pond area. VOCs were not detected in
any of the soil gas samples from these areas.
GATX Rail Siding Area
Two surface soil samples taken from the former GATX rail siding
area both contained toluene (28 to 46 ug/kg) . One of the samples
also contained benzoic acid (76 ug/kg). No other VOCs, SVOCs,
pesticide or PCB compounds were detected. The presence of
toluene in shallow soil boring samples collected from this area
could be sample contamination resulting from the use of
electrical tape to seal the sample bottles. Of the metals
detected, only lead was present in excess of two times background
values. Aluminum, barium, chromium, lead, vanadium and zinc were
found above soil background concentrations.
Subsurface soil samples also contained toluene (1.0 to 49 ug/kg)
but no other VOCs. As indicated above, the presence of toluene
in subsurface soil samples could be sample contamination
resulting from the use of electrical tape to seal the sample
bottles. Several PAHs were detected at levels below their
reported detection limits. No pesticide/PCB compounds were
detected. Of the metals detected in the sub-surface soil samples
from this area, aluminum, arsenic, barium, calcium, chromium,
copper, lead and vanadium concentrations were all above soil
background concentrations .
Lord Facility
Samples of soil, sediments, and ground water were collected from
the Lord Corporation property during the RI. Figure 4 (p. 14)
shows the sample locations.
Ground Water
Ground water contamination was discovered on the Lord Corporation
property during the RI. Figure 7 (p. 23) depicts the aerial
extent of the contamination. Figure 8 (p. 24) depicts a cross
section of the ground water contamination, showing the vertical
extent. The ground water plume was not fully delineated during
the RI. Table 1 (p. 18) summarizes the contaminants and the
volume of contaminated media found on the Lord property.
22
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Figure 7
AERIAL EXTENT OF GROUNDWATER PLUME ON THE LORD PROPERTY
Total Ethane contours in PPB
to
u
• LORD ,
I PARKING LOT
LORD
BUILDING
0 60 WO
ITU-LI 1
SCALE IN FEET
\
V
\
ERIE LACKAHANNA RAILROAD
v
-------
Figure 8
VERTICAL EXTENT OF GROUNDWATER PLUME ON THE LORD PROPERTY
• APPROXIMATE GROUND SURFACE
A WP2«
ELE.'ATION
1110
1100
1090
1080
1070
1060
TR&S
UNCONSOUOATCO
DEPOSITS
ROBERT E. KNU1H
! p-nuu
'-- \v---
-ROUTE 6/19
A'
ELEVATION
1110
1EOENJ2
—100-
NO
TOTAL CTHENE CONTOUR (ug/L)
TEMPORARY WELL POINT SAMPLING
DEPTH AND TOTAL ETHENE
CONCENTRATION (ug/L)
WATER TABLE
NO ETHENES DETECTED
SHALE
NQIE8
t. SAMPLING WAS CONDUCTED BY WARZYN DURING THE
PERIOD AUGUST 26 THROUGH AUGUST 30. 1801.
AND BY REMCOR(E2. E4. WJ. AND W7) DURING THE
PERIOD OF OCTOBER 3 THROUGH OCTOBER 6, 1991.
SAMPLES WERE ANALYZED IN THE FIELD USING A
GAS CHROUATOGRAPH.
2. TOTAL ETHENES IS THE SUM OF THE CONCENTRATION
OF TETRACHLOROETHENE. TRICHLOROETHENE. AND
TOTAL 1.2-DICHLOROETHENE.
3. LOCATION OF PROFILE SHOWN ON DRAWING 60882-F15.
4. THE CONTAMINANT PROflLE ALONG THE WESTERN PROPERTY
LINE IS ILLUSTRATED ON FIGURE 9. FIGURE 9 SHOWS
THAT CONTAMINANTS WERE NOT DETECTED AT DEPTH
AT WELL W70.
•> FRENCH
\ CREEK
\ 1080.22
I 100
1090
1080
1070
1060
CROSS SECTION SCALE
10
0 100 200
SCALE IN FEET
VERTICAL EXAGGERATION:
TEN TIMES
-------
Two phases of samples were collected from most of the wells on
the Lord property, voc analysis of samples during the first
phase detected chlorinated alkenes (tetrachloroethene,
trichloroethene and 1,2-dichloroethene) at individual
concentrations ranging from 220 to 860 ug/1. In the second phase
of sampling the same contaminants were detected, but at lower
concentrations.
An additional well was installed after the first phase cf ground
water sampling. Analysis of a ground water sample from this well
detected 1,1-dichloroethene and vinyl chloride (2 ug/1 and 770
ug/1, respectively), and 1,1,1-trichloroethane and 1,1-
dichloroethane (7 ug/1 and 3 ug/1, respectively), in addition to
the chlorinated alkenes detected in prior sampling of the ground
water.
No SVOCs were detected in ground water samples from the Lord
facility, with the exception of phenol (1 to 3 ug/1) and
diethylphthalate, di-n-butylphthalate, bis(2-ethylhexyl)phthalate
(1 to 6 ug/1). Phenol was also found in a background ground
water well at 2 ug/1.
Pesticide and PCB compounds were not detected in the ground water
samples from the Lord monitoring wells, with the exception of
heptachlor epoxide at 0.006 ug/1 in a second phase sample from
one well.
Aluminum, antimony, barium, cobalt, lead, manganese, mercury and
potassium were detected in the filtered ground water samples at
levels above ground water Background values.
Ground water sample, were also collected from temporary well
points installed on -he Lord property. Tetrachloroethene,
trichloroethene, 1,2-dichloroethene, 1,1,1-trichloroethane and
ethylbenzene were detected. Total ethene concentrations were
detected at concentrations ranging from 16 to 1,406 ug/1.
Sampling of temporary well points was also conducted by a
consultant to Lord in a study outside the scope of the RI. VOCs
were detected during this investigation in the vicinity of the
Lord RG-l Sump. This study has been included as an appendix to
the RI.
Lord Soils
One shallow soil boring sample was collected from the Lord
facility property. VOCs were not detected, with the exception of
toluene at 3 ug/kg. As discussed earlier, this could be due to
sample contamination resulting from the use of electrical tape to
seal the sample bottles. SVOCs were not detected.
Dichlorodiphenyldichloroethylene ("DDE") and dichlorodiphenyl-
trichloroethane ("DDT") were both detected in the sample at 69
and 70 ug/kg, respectively, possibly as a result of past
25
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pesticide use or the accumulation of surface water runoff.
Copper and lead were detected at concentrations greater than
background concentrations in the shallow soil boring. All other
metals detected were below background concentrations.
Lord Sediments
Two sediment samples were taken from the Lord property. VOCs
were not detected. The SVOC benzoic acid was detected in both
samples (8,700 to 46,000 ug/kg), as were small amounts of
fluoranthene (59 ug/kg in one sample).
Bis(2ethylhexyl)phthalate, a common laboratory contaminant, was
detected at 59 to 110 ug/kg. Aroclor 1254, at 340 ug/kg, was
found in the field duplicate of a sample taken from the former
impoundment area, but not in the primary sample. One sediment
sample taken from the Lord property also contained DDE at 80
ug/kg.
Metals analysis of the sediments from the Lord property area
detected aluminum, barium, chromium, copper, lead, mercury,
vanadium and zinc at concentrations greater than soil background
concentrations. Several metals levels exceeded two times the
soil background levels. Soil background concentrations we're used
for comparison at these locations since they were considered more
representative of the sediment matrix from this location than
were the background sediments of French Creek. Potential sources
of metals in the sediments include an accumulation of metal-laden
sediments in surface water runoff, or deposits of metal grit from
plant water pipes that may have been present in the past
discharge of non-contact cooling water to that area.
SMC Facility
The SMC property was used as the location for one of the
background shallow soil samples (B17) and one of the background
ground water monitoring wells (W1S, WlD), since it is
topographically upgradient from most of the Site.
Soil gas sampling and shallow soil borings were also collected
from the SMC property to investigate possible contamination
there. Figure 4 (p. 14) shows the sample locations.
Toluene was the only Target compound List ("TCL") VOC detected in
the soil boring.samples collected in the SMC area. The presence
of toluene is believed to be the result of sealing sampling jars
with electrical tape. SVOC and pesticide/PCB compounds were not
detected in the soils. Concentrations of metals were less than
the background concentrations.
One sediment sample, collected from a drainage ditch near the
northern boundary of the SMC facility, was found to contain
26
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benzole acid at 130 ug/kg, bis(2-ethylhexyl)phthalate at 65 ug/lcg
and Aroclor 1254 at 260 ug/kg. The concentration of each metal
detected in sediment samples was less than its respective
background soil concentration, with the exception of vanadium,
which was found in one sample at 15.4 mg/kg but was not found in
the background samples. Concentrations of metals in sediments
were compared to background soil concentrations, instead of
background sediment concentrations in French Creek, because the
matrix characteristics of the SMC property sediments more closely
resemble the soil boring samples at the Site than the sediment
matrix of French Creek.
SCI Facility
Soil gas samples were collected from the area located west of the
SCI building and analyzed for VOCs. Figure 4 (p. 14) shows the
sample locations on the SCI property. VOCs were not detected in
any of these samples.
Samples of shallow soil borings were collected from two locations
to the west of the SCI facility. Location B2 yielded one
detection of ethylbenzene at 1 ug/kg, and two detections of
xylene at 2 and 7 ug/kg. These concentrations are below or
slightly above the sample's reported detection limit (RDL) of 5.5
ug/kg. Shallow soil boring samples from B2 at two depths also
contained PAHs at concentrations ranging from 47 to 3500 ug/kg.
No other SVOCs were detected. Concentrations appeared highest at
the shallow 6-foot depth. Fewer compounds at lower
concentrations were present at 18 feet.
Toluene was detected in the B2 and B16 borings at concentrations
from 3 to 25 ug/kg. It is believed that the toluene
contamination resulted from the electrical tape used to seal the
sample jars. No SVOCs were detected in soil boring B16.
No pesticides/PCBs were detected in any :.l samples from the :ci
area. Metals were not detected above background concentrations
in these soil samples.
Ground water samples were collected from a deep and a shallow
well 'on the western border of the SCI facility. VOC, SVOC, and
pesticide/PCB TCL compounds were not detected in these samples.
Metals were not detected above the background concentrations in
the filtered ground water samples.
French Creek
Surface water and sediment samples were collected at four
locations in French Creek: one upstream, two midstream, and one
downstream location. The upstream sample location was considered
a background sample.
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Analysis of the surface water samples detected no VOC, SVOC, or
pesticide/PCB target compounds. Metals concentrations were
generally similar for surface waters collected both downstream
and upstream of the Site. Antimony, chromium and silver were the
exceptions, appearing downstream at concentrations slightly
greater than two times surface water background concentrations.
VOCs were not detected in the sediment samples from French Creek,
with the exception of chloroform at 80 ug/1 in one midstream
sample location. Chloroform at lower concentrations was present
in other sediment samples as a laboratory contaminant from the
sample dilution water.
Low concentrations of PAHs (51-107 ug/kg) were found in sediments
both upstream and downstream of the Site and are therefore not
likely to be related to contaminant migration from the Site.
Pesticide/PCB compounds were not detected in the sediments from
the Creek.
Concentrations of nickel, thallium, arsenic and lead in samples
taken adjacent to or downstream from the Site were greater than
two times their concentrations in samples taken upstream.
Calcium levels were also elevated downstream of the Site compared
to levels at the upstream location. Downstream concentrations of
aluminum, copper, iron, magnesium and zinc were greater than
upstream concentrations, but less than two times greater.
Drinking Water Analysis
Water samples were collected from Borough of Saegertown wells
BWl, BW2, and BW3, the Saegertown Beverage Company well (well
PW6) and private well PW18. Figure 2 (p. 3) shows the location
of the drinking water wells in relation to the Site.
1,l,l,trichloroethane was detected in well BWl at 1 ug/1 in Phase
1 only. Well BW3 contained 1,1,1-trichloroethane at 2 to 3 ug/1
in both phases of sampling. These concentrations are below the
SDWA MCL of 200 ug/1 for this compound. No contaminants were
detected in the Saegertown Beverage Company well or the other
private wells.
C. Cojntaminant Fate and Transport
The following discussions of contaminant fate and transport
mechanisms are organized' by potential source areas for each
property.
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Former GATX Facility
GATX Fond Area
The presence of the contaminants in the GATX pond area can be
correlated to the visual observation of a black oil or tar-like
sludge. This relationship is evident in a comparison of
analytical results for sediment samples collected from an area
where the black sludge was observed to be present, where high
levels of VOCs and SVOCs were detected, with a sample collected
from an area with no black sludge present, w.iicr. had no
detectable VOCs and very low levels of SVOCs.
It appears that the organic contaminants exist in a non-aqueous
oil phase (i.e., the coal tar residuals were deposited or
released in sufficient volumes to remain as a non-aqueous phase
in the soil environment). Case studies where coal tar migrates
as a separate, insoluble fluid phase in soil and ground water
have been observed at a number of former gas plant sites. Coal
tar has a density greater than water and has the potential to
form a dense non-aqueous phase liquid below the water table.
However, in this case, black sludge was not observed below the
depth of the water table (approximately 5 feet) in the pond area
based on the Phase 2 RI shallow auger probe sampling. The black
sludge did extend to the approximate depth of the water table in
shallow auger probe locations south of the pond. Figure 6 (p.
17) depicts a cross section of the depth of sludge observed
during the RI. Photoionization detector (PID) readings exceeded
background levels in some of the soil samples collected at depths
corresponding to the approximate surface of the water table.
Coal tar's high viscosity, hydrophobic nature, and strong
adsorption to soils, should severely limit its rate and extent of
downward migration.
Numerous constituents of coal tar exist in the solid state at
subsurface temperatures. Visual observations of the test pit
excavations show a significant portion of the black sludge to be
in a solidified state. Contaminants which are bound up in the
solidified materials would not be subject to downward migration.
The strongly hydrophobic nature of coal tar materials would be
expected to minimize the contact of organics in the sludge zone
intervals with infiltrating precipitation and ground water.
VOCs, such as benzene and the chlorinated solvents, would be
expected to be present in the ground water if a soil/water
equilibrium partitioning relationship existed in the subsurface.
These VOCs are relatively soluble in water. Their absence in
downgradient ground water samples from wells in close proximity
to the sludge during Phase 1, and the low level (5 ug/1) presence
of benzene in Phase 2 sampling, suggests that the VOCs have
remained preferentially dissolved in the non-aqueous oil phase or
are bound up in the solidified state.
29
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The VOCs and SVOCs would be expected to persist over a long
period of time since they are slow to biodegrade under natural
soil conditions. The two and three-ring PAHs are more prone to
biodegradation than the larger PAH compounds. The concentrated
nature of the sludge zones would not be expected to be conducive
to natural biodegradation.
PCBs detected in the pond area are strongly adsorbed to soils and
have a very low water solubility. PCBs would not be expected to
migrate to further depths or into ground water, but would be
expected to persist in the environment over a long period of time
since they do not biodegrade under natural soil conditions.
Several metals were detected at concentrations above background
levels in soil and sludge samples. Metals levels did not
significantly exceed background concentrations in the
downgradient ground water samples.
GATX Lagoon and Sludge Bed Area
VOCs and SVOCs were detected in sludge samples taken from both
the former lagoon and the sludge bed areas. The total
concentrations detected in the former sludge bed area were at
least one order of magnitude lower than the concentrations in the
pond area, while total concentrations detected in the former
lagoon area were several orders of magnitude lower. Contaminants
were detected only in the 4 to 6-foot deep sample interval in the
former lagoon area; they extended from the 4 to 6-foot deep
interval down to the water table in the former sludge bed area.
As was the case in the pond area, there was a direct correlation
between the presence of VOCs and SVOCs and the presence of a
black oil or tar-like sludge. Figures 5 and 6 (pp. 16-17) show
the extent of the black sludge, as determined by shallow auger
probe sampling and visual observations during the RI.
The source of the VOCs and the SVOCs is believed to be coal tar
derivative coating residuals generated during onsite painting
operations. These residuals were part of the wastewater effluent
which was discharged to the lagoon, area. Since coal tar has a
density greater than water, it settled to the bottom of the
lagoon. It is believed that the sludge was then dredged from the
bottom of the lagoon and placed in. the sludge bed area.
It also appears that the organic contaminants exist in a non-
aqueous oil phase or solidified state in the former lagoon/sludge
bed areas. The black sludge was not observed, to. extend to the
depth of the water table (approximately 8 feet) in the former
lagoon/sludge bed area, based on the shallow auger sampling. .
Boring B4 in the sludge bed area, however, did extend into the
water table and black fine to coarse sand and gravel was
intermixed and/or coated with black sludge.
30
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It is believed that there is a direct correlation between
observed black sludge or sand and gravel coated and/or intermixed
with black sludge and the detected VOC/SVOC contamination. VOCs
and SVOCs were detected in the samples of these coated sands and
gravels. VOCs and SVOCs were not detected in downgradient ground
water samples.
The high bacterial plate ;ount ani high Tentatively Identified
Compound ("TIC") concentrations in sludge from this area may a.lso
be indicative of biological activity and the degradation products
attributable to this activity. The occurrence of enhanced
biological activity in the sludge zones is consistent with the
past use of the lagoon for treatment of wastewaters. Naturally-
occurring bacteria could have become acclimated to the sludge
during the period of wastewater (i.e., moisture) presence and
continuous aeration. The lower concentrations of VOCs and SVOCs,
as well as the proximity of the sludge layer to the water table,
would also provide more suitable conditions for enhanced
biological activity in the former lagoon/sludge bed area than in
the pond area. The larger PAH compounds (greater than three
benzene rings) would not be expected to biodegrade under natural
soil conditions.
GATX Rail Siding Area
The PAHs and lead which were detected in the former GATX rail
siding area are strongly adsorbed to soils and have low water
solubilities. Consequently, the presence of these substances
should not represent a contamination threat to drinking water
wells.
GATX Ground Water
Figure 4 (p. 14) shows the location of the monitoring wells on
the former GATX property in relation to the sludge bed, lagoon
and pond areas.
Despite the presence of approximately 3 million pounds of
contaminants in the soil, and the close proximity of the
monitoring wells to the areas of contamination, only three VOCs
were detected in ground water samples. All three were present in
concentrations at or below their respective SDWA MCLs of 5 ug/1.
Tetrachloroethene (1-3 ug/1) was detected in Wells W4S and W9S
during both phases of sampling. Trichloroethene was detected in
Well W9S (1 ug/1) in the second phase of sampling. Well W5S is
located less than 100 feet from the pond area sludge. No organic
compounds were detected in the first phase sampling of this well.
Benzene was detected in W5S (5 ug/1) only in the second phase.
Well WlOI is located less than 50 feet from the pond area sludge.
No organic compounds were detected in samples taken from this
well.
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No ground water plume that could affect the Borough or private
wells was identified as being present on the former GATX
property. Furthermore, no VOCs were present in the contaminated
soil surrounding the sludge areas. Since the GATX facility
operated from approximately 1951 until 1967, some of the
contaminants on the property may have been present for more than
thirty years. VOCs may never have been present in the soil
surrounding the sludge matrix, or they may already have leached
from the soil.
Lord Facility
Lord Ground Water
The chlorinated solvents tetrachloroethene, trichloroethene, 1,1-
dichloroethene, 1,2-dichloroethene, 1,1,1-trichloroethane and
vinyl chloride were detected in excess of the SDWA MCLs for each
of these substances in both ground water monitoring well samples
and temporary well point samples collected during the RI from the
Lord property. 1,l-Dichloroethene, 1,2-dichloroethene and vinyl
chloride are believed to be the degradation products of the
parent compounds tetrachloroethene and trichloroethene, resulting
from reductive dehalogenation mechanisms under anaerobic
conditions in ground water. These degradation products are
present at higher concentrations towards the more distant
downgradient locations. This is indicative of ongoing anaerobic
degradation as the contaminant plume ages and moves downgradient.
The aerial and vertical extent of the chlorinated solvent-
containing ground water plume is shown on Figures 7 and 8 (pp.
23-24). Additional investigation necessary to determine both the
downgradient extent of the plume to the west of the Lord
Corporation property and the vertical extent of the ground water
contamination will be conducted during the remedial design.
All of the chlorinated solvents in the ground water are
considered to be relatively mobile to mobile, except for
tetrachloroethene, which is considered to be relatively immobile.
Estimated contaminant velocities are very low, ranging from 0.54
to 2.52 feet per year, because of the low ground water velocity,
which was calculated from measurements of hydraulic gradient and
permeability.
The plume pattern indicates that the contamination originates
from the main manufacturing buildings on the Lord property and
has migrated downgradient to the west and southwest. On April
26, 1991, Lord'Corporation discovered that the walls of a
plastic/fiberglass RG-l sump tank had softened. The sump tank,
located east of the main manufacturing buildings, had a capacity
of approximately 300 gallons and was used to collect and store
hazardous wastes. The RG-l sump tank and visibly contaminated
soil were removed by Lord on May 21, 1991.
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The plume pattern suggests that the RG-l sump area is a potential
source of the ground water contamination. However, based on the
low groundwater velocities that were estimated, it appears that
the furthest downgradient chlorinated solvent concentrations
cannot be attributed to this recent sump tank release. Other
possible sources could be past releases in the vicinity of the
Lord building, tank farm and unloading areas, or past releases
from the identified sump area that has been in use for over ten
years.
The vertical extent of the chlorinated solvents detected in
ground water beneath the RG-l sump area has not been defined.
Sampling was not performed below a 20-foot depth in the vicinity
of the RG-l sump area, the suspected ground water contamination
source. The volume of chlorinated solvents which were released
from the RG-l sump is also unknown.
Several metals were present above background levels in the ground
water in the vicinity of the Lord property. The increase in
metals concentrations in ground water may be a result of the
chlorinated solvent plume. A reduced chemical state would exist
within the chlorinated plume which could cause metals that occur
naturally in soil to be more soluble in the ground water.
Lord Soil and sediment
DOE and DDT were both detected in the Lord soil sample.
This is believed to have resulted from either the use of
pesticides during past land uses, or the accumulation of surface
water runoff. DDE and DDT are strongly adsorbed to soils and do
not pose a contamination threat to nearby drinking water wells.
Analysis of the sediments from the Lord facility area for metals
revealed aluminum, barium, chromium, copper, lead, mercury,
vanadium and zinc at concentrations greater than soil background
concentrations. Several metals levels exceeded two times the
soil background levels. Metals incorporated in steel or metal
alloy particulates with relatively large particle diameters are
typically not subject to leaching due to precipitation
infiltration. Metals also tend to be immobilized by fixation
into the soil matrix or adsorption onto the surface of the soil
matrix.
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SMC Facility
One sediment sample from a drainage ditch on the SMC facility
property contained Aroclor 1254 at 260 ug/kg or .260 ppm. The
source of the PCB is not known. The drainage ditch could act as
a collection point where the surface runoff of soils with
adsorbed PCBs could accumulate. PCBs are strongly adsorbed to
soils and have very low water solubilities; thus, they would not
be expected to migrate from the drainage ditch sediments. The
PCB concentration which was detected is below U.S. EPA action
levels of 1 ppm for expected residential areas and over an order
of magnitude below the 10 to 25 ppm PCB action levels for
expected non-residential areas. (See Guidance on Remedial Action •
for Superfund Sites with PCB Contamination. U.S. EPA, OSWER
Directive No. 9355.4-01, August 1990).
SCI Facility
VOCs and PAHs were detected in both the 4 to 6 foot deep soil
sample and the 16 to 18 foot deep soil sample from boring B2 on
the SCI property. The VOCs were detected at low levels in both
the shallow and deeper samples. The concentrations of PAH
compounds were generally an order of magnitude higher in the
shallow sample than in the deeper sample. Some of the PAHs
detected in the shallow sample were not detected in the deeper
sample. The presence of PAHs at the lower depth could have
resulted from their adsorption to the aquifer soil matrix
originating from either fluctuating water table conditions or
unsaturated zone infiltration.
The Summers Model was run in order to estimate ground water
concentrations which could result from the leaching of PAHs
detected in the soil on the SCI property. The Summers Model
predicted that ground water concentrations for several individual
PAHs would exceed Contract Lab Program ("CLP") low-level
analytical detection limits, based on the most conservative input
parameters. The Summers Model also estimated that total PAH
concentrations would exceed the proposed MCL of 0.2 ug/1 for
PAHs, based on the most conservative input parameters.
Ground water monitoring wells W2S and W2D are located less than
100 feet from the B2 boring where the soil contamination was
detected on the SCI property. Figure 4 (p. 14) shows the
relative locations of wells W2S and W2D to boring B2. No VOCs or
PAHs were detected in ground water samples collected from wells
W2S and W2D in Phase 1 and Phase 2 of the RI. Additional ground
water samples were obtained from these wells in July 1992 and
analyzed for carcinogenic PAHs using detection limits of one half
the ground water MCLs for these compounds. No PAHs were detected
in the ground water samples obtained in July 1992.
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D. Principal Conclusions
Former GATX Facility
The estimated volume of sludge and contaminated soil on the
former GATX property is 9,000 cubic yards. The delineation of
the horizontal extent of si ige and soil inc.'.udec in the volume
calculations is based on th.^ visual observations -f the sludge
made during the RI (Figures 5 and 6, pp. 16-17). Sludge was
defined in the RI/FS to be the presence of total PAHs in excess
of 1% by weight. Soil on the periphery of the observed sludge
with detectable PAH concentrations in excess of 1 ppm are also
included in the delineation of horizontal extent of the sludge.
The vertical extent (i.e., depth) used in the volume calculations
includes an additional two feet of soil below the lowest depth of
observed sludge presence in each area.
Limited areas of superficial sludge were also observed north of
the pond. It was estimated that the sludge and residual soil
thickness is one foot in this area, yielding an additional 150
cubic yards of volume.
The total mass of VOCs and SVOCs in the lagoon/sludge bed and
pond areas is estimated to be three million pounds. This is
based on a weighted average total VOC and SVOC concentration of
11% (i.e., 110,000 ppm) for the pond and former lagoon/sludge bed
areas.
Surface soil above the observed sludge was not included in the
sludge and soil volume calculations. VOCs were not detected in
surface soil samples collected from the former lagoon/sludge bed
area. SVOCs were either not detected or present in the low parts
per billion for most of the samples taken from these areas. It
is believed that the surface soil is fill material placed in the
pond and former lagoon/sludge bed areas when use of these areas
ceased.
The total estimated volume of PCB-contaminated soil and sediment
is 550 cubic yards. The volume of PCB-contaminated soil and
sediment: was estimated separately because PCBs were detected in
only one soil sample and one sediment sample in the pond area,
and one subsoil sample from the lagoon/sludge bed area. SVOCs
were also detected in these samples. A soil sample collected at
a depth of 0 to 2 feet immediately northwest of the pond, where
surficial staining was observed, had the highest level of PCBs
detected onsite (830 ppm). A sediment sample collected from the
southern half of the pond, where a 6-inch sludge layer was
observed, had a. PCB level of 33 ppm. PCBs were detected in one
subsoil sample (l.l ppm) taken at a depth of 6 feet, from a
location in the former lagoon area.
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The horizontal extent of PCB-contaminated soil northwest of the
pond has been estimated, based on visual observations of
surficial staining and assuming a conservative radius centered
around the sample location where it was detected in the pond
area. A vertical depth of 4 feet was used since no PCB was
detected in the 2 to 4 foot deep sample from this boring
location. The horizontal extent of PCB-contaminated sediment in
the pond itself is assumed to include only the southern half,
since PCBs were not detected in sediment sample SD05 taken from
the northern half of the pond. A 1 foot vertical depth was used
to estimate the volume of PCB-contaminated sediment in the pond.
This depth includes an additional six inches below the observed
depth of the sludge thickness.
Lord Facility
Sampling conducted during the RI confirmed the presence of ground
water contamination beneath the Lord corporation property. VOCs
including vinyl chloride, TCE, TCEA, PCE and 1,2 dichloroethene
("chlorinated ethenes") were found in the ground water. The RI
estimates that 9.3 million gallons of ground water onsite has
been impacted by the plume. This estimate does not include the
volume of ground water outside the Lord property boundaries
because the full extent of the plume is not known. The
chlorinated ethenes in the ground water are estimated to be
moving at 0.54 to 2.52 feet per year. The total onsite
chlorinated ethene mass on the Lord property is estimated to be
7,500 pounds, with 800 pounds being present in the dissolved
phase. This is based on a flow-weighted average total
chlorinated ethene concentration of 10 mg/1, and appropriate
equilibrium partitioning relationships for soil and ground water.
The RG-l sump is believed to be the source of ground water
contamination on the Lord property. Depth to ground water is
approximately five to ten feet in the vicinity of the sump. When
the sump was removed, Lord excavated soil down to the water
table.
The horizontal and vertical extent of the chlorinated ethene
ground water plume which encompasses concentrations in excess of
analytical detection limits, is depicted in Figures 7 and 8 (pp.
23-24). It is assumed that the vertical extent of the
chlorinated ethene plume includes most of the depth of the upper
aquifer in the area of the RG-l sump, an average of approximately
35 feet. Field geoprobe well point sampling during the RI
detected chlorinated ethenes up to 15 feet into the aquifer. A
separate investigation conducted by Lord in 1991 ("Remcor Study")
detected chlorinated ethenes 10 feet into the aquifer. The
Remcor Study- information was included in the RI Report. The
vertical extent of the chlorinated ethene plume in the RG-l sump
area will be. more clearly defined during the design phase. The
36
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investigation of the potential presence of an identifiable non-
aqueous phase will also be included in the additional subsurface
investigation conducted during the remedial design.
The extent of the ground water plume to the west of the Lord
property was not fully delineated during the RI due to the
inability to gain access to these properties. However, EPA
believes that sufficient information regarding ground water
movement and contamination was collected during the RI to prepare
the ROD for the Site at this time. The full extent of the ground
water plume will be determined during remedy design.
VI. SUMMARY OF SITE RISKS
The baseline risk assessment provides the basis for taking action
and indicates the exposure pathways that need -.:> be addressed by
the remedial action. It serves as the baseline indicating what
risks would exist if no action were taken at the Site. This
section of the ROD reports the results of the baseline risk
assessment conducted for the Site.
A. Human Health Risks
Identification of Contaminants of concern
The SMC, SCI, Lord and the former GATX properties were each
evaluated during the Baseline Risk Assessment ("BRA") and
chemical contaminants of concern were identified by media for
each property. Table 2 lists the contaminants of concern. The
BRA provides the rationale for the selection of the contaminants
of concern for each area of the Site.
The PCB Aroclor 1254, found in soil, is the only contaminant of
concern identified on the SMC property.
PAH compounds are the contaminants of concern identified in SCI
property soils. No other media are impacted on the SCI property.
VOCs, including PCE, TCE, 1,2 dichloroethene and vinyl chloride,
are the contaminants of concern identified in the ground water in
the vicinity of the Lord property. Lord property sediment
contains several metals in concentrations that exceed two times
their background concentrations.
PAH and PCB compounds and metals are the contaminants of concern
identified in the former GATX property soils. Contaminants of
concern in the sludge include VOCs, PAHs, PCBs and metals.
Ground water in the former GATX property area contains benzene,
TCE and PCE at levels below SDWA MCL.
37
-------
TABLE 2
EXPOSURE POINT CONCENTRATIONS
Saegertown Industrial Area Site Rl
Saegertown, Pennnsylvanla
to
09
GATX
GU
LORD
GU
'
GATX
SLUDGE AREA
SURF. SOILS
GATX
SLUDGE AREA
ALL SOILS
GATX
RAIL SIDING
SURF. SOILS
GATX
RAIL SIDING
ALL SOILS
GATX
POND
SURF. SOILS
GATX
POND
ALL SOILS
LORD
SURF. SED
LORD
ALL SOILS
SCI
ALL SOILS
GATX
AMBIENT A
Parameter
(rog/L)
Vinyl chloride
1,1-Dlchloroethene
1,1-Olchloroethane
1,2-Olchloroethene (trans)
Chloroform
2-Butanone
1,1.1-Trlchlproethane
1,2-DIchIoropropane
Trichloroethene
1,1,2-Trlchloroethene
Benzene
4-Methyl-2-pentonone
TetrachIoroethene
1,1,2,2-TetrachIoroethane
Toluene • .
Chlorqbenzene
Ethyloenzene
Styren'e
Xylenes (mixed)
1.0e-03
5.0e-03
3.0e-03
Phenol
1,3•0IchIorobenzene
1,4-Dlchtorobenzene
1,2-Olchlorobeniene
2-Methylphenol
4-Methylphenol
2,4-Dlmethylphenol
Benzole Acid
1,2,4-Trlchlorobenzene
Naphthalene
HexachIorobut adIene
Z-HethyI naphthalene
Acenephthylene
Acenaphthene
Olbenzofuran
2.4-Dlnltrotoluene
DiXBlylphthalate
Fltjfjene
H«och I orobenzene
PhWdn threne
Arttfljacene
(mg/L)
7.7e-01
2.5e-03
3.0e-03
9.8e-01
2.2e-01
1.1e400
1.0e-03
3.0e-03
3.0e-03
1.0c-03
(mg/kg)
1.4e-01
7.8e-02
2.0e-01
9.8e-02
3.5e-01
1.6e-01
2.0o«00
4.60-01
(mg/kg) (mg/kg) (mg/kg) (mg/kg)
3.9e-02
9.Be-03
7.2e-03
8.7e-01
2.6e-01
2.0e-03
1.Set00
1.26400
2.4e»01
4.4e»01
2.3e-01
2.36400
2.3e+02
2.4e»02
2.4e«03
1.8e»02
8.0e402
1.4e«02
4.9e«02
5.7e«02
9.7e»02
(.26401
1.86403
3.06403
A.6e-02
4.9e-02
7.6e-02
7.6e-02
(mg/kg) (mg/kg)
4.5e-02
6.16402
4.36401
4.06401
1.56403.
2.76401
4.46401
1.76402
2.7e401
2.26401
9.5e401
1.Se402
1.2e403
5.26402
7.06401
1.86402
1.56402
1.56403
5.96403
3.1e402
4.06403
4.46402
2.8e«03
3.4e403
1.06402
5.56403
2.06402
2.66404
7.06404
1.7e-01
LOe-OS
6.16402
4.36401
2.16402
1.56403
2.76401
2.36402
1.76402
2.76401
2.26401
2.16402
9.7e402
2.16-01
1.26403
5. 86401
3.86402
1.16403
4.36402
6.36402
1.56403
1.7e404
3.66401
6.96403
1.6&403
4.3e«03
5.2&403
1.16401
7.36403
2.46401
2.66404
7.0e*04
(mg/kg)
3.0C-03
(mg/kg)
1.6e-01
5.7e-02
5.2e-01
3.0e-01
«.7c-OI
3.5c«00
7.3C-01
(mg/m3)
A.Oc-06
1.7e-0fl
2.5e-02
I.Oe-03
7.0o-03
5.8e-03
1.8e-04
2.86-03
3.9e-03
1.7e-05
8.2e-(K
2.5e-04
2.2e-05
1.3e-OS
2.5e-(K
5.5e-OC
1.6e-04
6.7e-0(
1.1e-05
1.5e-0i
2.9e-0t
7.2e-OJ
4.7e-05
4.7c-0?
7.2e-0<
4.1c-0!
4.5e-0/
6.4c-0;
9.Be Ot
5.9e-0
-------
TABLE 2
EXPOSURE POINT CONCENTRATIONS
Saegertoun Industrial Area Site Rl
Seegertotm, Pennnsylvanla
Parameter
GATX
CU
(mg/L)
LORD
GW
(mg/L)
Ol-n-butylphthalate
Fluoranthene
Pyrene
Butylbenzylphthalate
8enzo(a)anthracene (c)
Chryaene (c) •
bls(2-ethythexyl)phthalate
Dl-n-octyi Phthalate
Benzo(b)fluoranthene (c)
Benzo(k)fluoranthene (c)
Benzo(a)pyrene (c)
lndeno(1,2,3-cd)pyrene (c)
Oibenz(a,h)anthracene (c)
Benzo(g.h,l)perylene (c)
Carbazole
Total; Carcinogenic PAHs
Heptachlor epoxlde
4,4'-DDE
4,«'-DOT
Total PCBs
Aluminum
Antimony
Arsenic
Barium
Cadmium (food/soil)
Calcium
Chromium VI
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
'Mercury
Nickel
Potassium
Selenium
fliver
Sodium
5.3e-03
4.1e+00
6.0e-06
5.1e-03
2.7e-01
1.0e-02
3.5e-03
2.4e+00
2.9e-04
GATX GATX GATX GATX GATX GATX
SLUDGE AREA SLUDGE AREA RAIL SIDING RAIL SIDING POND POND
SURF. SOILS ALL SOILS SURF. SOILS ALL SOILS SURF. SOILS ALL SOILS
(mg/kg) (mg/kg) (mg/kg) (mg/kg)
4.4e+00
3-Oe+OO
1.2c-0l
2.3e>00
I.Be+00
8e+00
Be+00
Oe+00
t.Oe+00
3.86-01
1.Oe+00
I.Be-01
1.6e+01
9.1c+01
1.6e«01
1.5e«02
2.60-01
6.4e+02
S.le+02
1.2e-01
1.7e+02
2.1*«02
2.7e+00
1.3e+02
1.36+02
2.16+02
4.6e+01
3.1e-01
7.1e»01
1.36+03
9.7e+02
1.1e+00
1.7e+01
9.1e+01
1.0e+02
3.6e+01
1.5e+02
1.26+03
1.5e+00
2.0e+01
1.1e+02
1.6e+01
2.5e+6l
(mg/kg) (mg/kg)
LORD
SURF. SED
(mg/kg)
LORD
ALL SOILS
(mg/kg)
1.6e-01
1.1e-01
S.Se-02
6.8e-02
1.2e-01
1.2e-01
3.6e-01
1 .9e*02
4.9e»03
4.1e+03
2.2e+03
3.3e»03
I.Be+02
1.0e+02
I.Se+03
7.3e»02
1.1e+03
4.0e+02
1 .Ae+02
3.6e+02
9.76+03
2.3e+01
8.2e»03
8.2e«03
3.1e»03
1.3e»04
S.3e»01
1.1e«01
4.0e+03
4.0e»03
1 .9e»03
7.7e+02
J.Oe+02
7.Be>02
1.3e+04
2.8e+04
8.0e-02
3.3e+01
B.3e+02
B.Oe-02
7.0e-02
1.6e+01
9.2eO1
1.46+01
2.7e+01
3.6e+01
8.3e+02
6.9e+02
2.5e+01
5.86+02
3.1e»00
3.2e»02
3.4e+03
3.16+02
1.56+02
Z.5e+01
4.06*00
1.2e«01
1.5e+02
3.3e+02
9.2e+00
1.5e+02
1.7e+01
3.1e+02
3.4e+03
8.86+02
3.1e+02
5.0e+01
1.'8c«00
1.2e+02
2.2e+01
7.0e+01
3.3e»01 •
2.26-01
1.2e+02
2.2e+01
7.0e«01
3.3e+01
2.2e-01
SCI
ALL SOUS
(mg/kg)
GAIX
AMBIENT A
(mg/m3)
3.3e+00
3.0e«QO
1.1e+00
1.0e+00
1.3c«00
4.36-01
1.1e+00
S.le-01
5.46-02
5.0e-01
6.0c«00
1.86-11
3.4e-09
1.7e-09
5.3e-12
6.4e-12
2.8e-11
5.7e-12
1.5e-10
1.56-10
7.96-13
5.46-15
2.16-15
5.7e-15
B.8e-07
5.7e-09
3.1c-0?
-------
TABLE 2
EXPOSURE POINT CONCENTRATIONS
Saegertown Industrial Area Site Rl
Saegertown, Pennnsylvania
Parameter
Thallium
Vanadium
Zinc
Cyanide
GATX LORD
GU GW
(mg/l) (mg/L)
1.78-02
1.2e-02
GATX
SLUDGE AREA
SURF. SOILS
(mg/kg)
2.5e»02
GATX
SLUDGE AREA
ALL SOILS
(mg/kg)
6.2e*02
1.5e»01
GATX GATX
RAIL SIDING RAIL SIDING
SURF. SOILS ALL SOILS
(mg/kg)
1.8e«01
8.6e«01
Note:
This table presents a summary of exposure point concentrations for chemicals of potential
for an explanation of the selection and calculation process used to derive these values.
GU
BW
Surf. Soils
Surf. Sed.
All-SolU
(Saegertown.
JAH/jah/MUK
1/2/W
« Groundwater
• Bor rough Well
• Surface Soils
. = Surficlal Sediments
• A combination of surface soils,
20201 EPC1.w20
sediments, soil
borings, auger probes and
(mg/kg)
1.5e»01
7.7e+01
GATX
POND
SURF. SOILS
(mg/kg)
5.9e*00
2.9e»01
6.3e»OJ
5.8e»00
GATX LORD LORD SCI GATX
POND SURF. SEO ALL SOILS ALL SOILS AHBIEHI AIR
ALL SOILS
(mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/m3)
9.0e*00
1.7e»01 2.1e»01 2.1e»01
6.3e»OJ 2.5e»02 2.5e»02
1.2e«01
concern for each operable unit and medium. See Appendix u
test pits
-------
Exposure Assessment Summary
The exposure assessment identifies actual or potential pathways
for human exposure to the contaminants of concern present in the
different impacted media at the Site. Exposure pathways are
assessed based on two scenarios: current land use and future land
use. The majority of the property comprising the Site is
currently zoned industrial. Permitted land use under this zoning
includes light manufacturing, research laboratories, offices,
warehousing, truck terminals, public buildings, agriculture and
open land recreation. The northeastern corner of the Site is
zoned for single family homes, although this area is currently
used as a park and open space. In addition, current zoning
permits the owner of a facility in the industrial zoned portion
of the Site to dwell in a single family residence adjacent to
his/her facility.
1. Potentially Exposed Human Populations
Based on the current and potential future land use of the Site,
the following reasonable maximally exposed ("RME") subpopulations
were identified:
Current Land Use - onsite workers
- offsite residents
- older children trespassing onsite
Future Land Use - onsite residents
2. Chemical Exposure Pathways
In order for one of the subpopulations identified above to be
exposed to the chemicals of concern at the Site a chemical
exposure pathway must be present. A pathway is the route taken
by a chemical from its source in the environment until it
contacts a receptor. Each exposure pathway must include the
following elements:
• a source and mechanism of chemical release to the
environment;
• an environmental transport medium (e.g., air, ground
water) for the released chemical;
• a point of potential human contact with the contaminated
medium (referred to as the exposure point); and
• receptor contact (e.g., ingestion of contaminated ground
water).
41
-------
Exposure may occur when contaminants migrate from the Site to an
exposure point (i.e., a location where receptors can come into
contact with contaminants) or when a receptor comes into direct
contact with waste or contaminated media at the Site. An
exposure pathway is complete (i.e., exposure occurs) if there is
a way for the receptor to take in contaminants through ingestion,
inhalation, or dermal absorption of contaminated media. Table 3
(pp. 43-44) is a summary of the exposure pathways considered to
be complete by the BRA, and the routes of exposure that were
quantitatively assessed.
3. Exposure Point Concentrations
The concentration of contaminants in a given medium (e.g., soil,
surface water, etc.) used to represent the exposure point
concentration were derived by calculating the 95% upper
confidence limit (95% UCLM) on the mean of sample concentrations.
If this value exceeded the maximum value identified, the maximum
measured value was used as the exposure point concentration.
Exposure point concentrations calculated for each area are
summarized in Table 2 (pp. 38-40).
4. Routes of Exposure
The following routes of exposure were assessed in the BRA: ground
water/surface water contact; sediment/soil contact; and air
exposure. Table 4 (pp. 45-47) presents a summary of exposure
factors assumed or calculated for risk estimation. Exposure to
contaminants through the use of contaminated ground water as a
water supply source was assumed to occur through, ingestion,
dermal absorption, and inhalation. Exposure to contaminants in
soils and sediments was assumed to occur through dermal
absorption and incidental ingestion. Based on current and future
land-use conditions, and the fact that there is a vegetative
cover onsite, it was assumed that fugitive dust emissions due to
wind erosion would probably not result in a substantial pathway
of human exposure. However, VOC Air Modeling results indicate
that contaminants are being released to ambient air from the pond
area through volatilization.
42
-------
TABLE 3
Summary of Exposure Pathways and Routes
- -> be Quantitatively Assessed
Sa ertown Industrial Area Site RI
Pane 1 of 2
Area
Exposure Routes
Source Exposure
Receptor Area Pathway Inhalation Digestion
—Current Land Use Conditions
Dermal
GATX Trespasser Former Surface
Sludge Area Soils
GATX Trespasser Former Rail Surface
Siding Area Soils
GATX
GATX
GATX
GATX
GATX
Trespasser
Trespasser
Trespasser
On-Site
Workers
Off-Site
Residents
Pond
Pond
Pond
Pond
Pond
Surface
Sediment
Surface
Water
Air
Air
Air
—
X
X
X
Lord Trespasser Former Surface
Impoundment Sediments
SCI
On-Site
Resident
Future Land Use Conditions-
Residential Use
General^ Soils(1)
43
-------
Page 2 or" 2
TABLE 3
Exposure Routes
Source
Area Recepior Area Pathway Inhalation Ingestion Dermal
GATX On-Site Sludge Area Soils(1) — X
Resident
GATX On-Site Former Rail Soils*1) — X
Resident Siding Area
GATX On-Site Pond Soils*1 > — X
Resident
GATX On-Site Pond Air X —
Resident
GATX On-Site Pond Groundwater XXX
Resident
Lord On-Site Former Soil*1) — X
Resident Impoundment
Lord On-Site Sump Groundwater XXX
Resident
FOOTNOTES:
1. Both surface soil/sediment and subsurface soil data are used in combination to represent
potential levels of contaminant exposure.
44
-------
TABLE 4
U1
Receptor Characteristic*
Age Bracket (years)
Body Weight (kg)
Exposure Duration (yean)
Averaging Time (days)
Noncancer Type Effects
Cancer Type Effect*
Chemical Characteristics
Dermal Permeability Factor (cm/hr)
Dermal Absorption Estimates (unilleis)
Inhalation Absorption Estimates
(unilless)
Oral Absorption Estimates (unilless)
Medium Specific Characteristics
Air Source Area(s)
Air Inhalation Rale
.Exposure Time (hrs/day)
Exposure Frequency (days/year)
Soil/Sediment
Source Area(s)
Skin surface area available for
contact (cm2)
Soil/Sediment Ingeslion Rale
(mg/day)
Soil/Sediment to Skin A
Adherance Factor (ing/cm*)
Fraction Ingested from
Contaminated source (unilless)
Exposure Frequency (days/year)
Summary of Exposure Factors for Risk Estimation
Saegertowu Industrial Area Site Rl
Trespasser
On-Sitc Worker
Off-Site Resident
On-Sile Resident
7 to 16
40(a)
I0(b)
3.650
25.550
Chem, specific
see Table 7-8
Chem. specific
see Table 7-8
100%
Chem. specific
see Table 7-8
OATX
I.2m3/hr(e)
4(b)
52(h)
OATX.
LORD. SMC
l,490(g)
100(0
145(1)
70(0
25(0
9.125
25.550
Chem. specific
see Table 7-8
Chem. specific
see Table 7-8
100%
Chem. specific
see Table 7-8
QATX
20m3/day(0
250(0
...
...
birth to 30
59(c)
30(d)
10.950
25.550
Chem. specific
see Table 7-8
100%
Chem. specific
see Table 7-8
GATX
20m3/day (0
24(b)
350(0
...
...
birth to 30
' 59(c)
30(d)
10,950
25,550
Chem. specific
see Table 7-8
100%
Chem. specific
see Table 7-8
GATX
• . 20m3/d«y(0
24(b)
350(0
SCI, GATX.
LORD. SMC
7,900 cm2 (p)
I20(q)
1.45(1)
52 (h)
350(0
-------
TABLE 4
On-Sile Worker
Off-Silt Resident
On-iile Reiidenl
Groundwater^"1)
Source Area(i)
Ingestion Rale (IVdty)
Skin surface tret tvtilable for
oonUct (cm')
Exposure Time (i.e.. while
bithing) (hours/day)
Exposure Frequency (days/yen)
GATX,
' Lord
KO
...
250(0
GATX.
Lord
2(0
18,1 S
-------
TABLE 4
I. 50th pcrcenlilc surface area (or children* handj, legs and feel (U.S. EPA 1989); lime weighted value for ages 7 lo 16 years old.
m. InhtUtion of volatile contaminant! while fhowering with contaminated groundwaiet was assessed utilizing a predictive model. Refer to Appendix W fnr the specific
exposure assumptions used for estimating the intake of chemicals while showering.
n. SOih percenlile total surface area for persons (U.S. EPA, 1989) time weighted from birth to 30 years old.
o. 9fth percentile value for length of shower (U.S. EPA. 1989).
p. 50th percentile surface area for hands, arms, feel and legs (U.S. EPA, 1989); lime weighted value for persons from birth lo 30 years old.
q. Time weighted soil ingestion rale for person from birth lo 30 years old (U.S. EPA, 1991).
r. Average adult inhalation rate for light activity level (e.g., most domestic work, and conducting minor indoor repairs); (U.S. EPA, 1989).
s. Assumed that work day would be 9 hours long (8 hours work 4-1 hour lunch).
l. Soil to skin adherance factor for polling soil to hands (U.S. EPA, 1989).
-------
Toxicity Assessment Summary
The risk assessment addresses two general types of toxicities
which may result from chemical exposure: carcinogenic and
noncarcinogenic effects.
Noncarcinogenic effects of chemicals are assumed to display a
threshold phenomenon; i.e., effects are not observed below a
given chemical concentration (threshold dose). Therefore, a
health risk is thought to exist only if established threshold
doses are exceeded. Noncarcinogenic health effects include a
variety of toxic effects on body systems, such as renal toxicity
(toxicity to the kidneys), teratogenicity (damage to the
developing fetus), and central nervous system disorders.
Reference doses ("RfDs") have been developed by EPA for
indicating the potential for adverse health effects from exposure
to contaminant(s) of concern exhibiting noncarcinogenic effects.
RfDs, which are expressed in units of mg/kg-day, are estimates of
lifetime daily exposure levels for humans, including sensitive
individuals. Estimates of intakes of contaminant(s) from
environmental media (e.g., the amount of a contaminant(s) of
concern ingested from contaminated drinking water, etc.) can be
compared to the RfD. RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors have been
applied (e.g., to account for the use of animal data to predict
effects on humans).
Carcinogenic effects are considered' to have a dose-response
relationship with no threshold. Thus, the BRA considers that any
exposure to a carcinogen is associated with some degree of risk.
The U.S. EPA has- developed a scheme for the review of information
and the classification of chemicals as to their likelihood of
causing cancer. This classification scheme distinguishes between
chemicals which are known human carcinogens (Group A) and
chemicals which- are: probable human carcinogens (Group B), based
on their cancer-causing' properties in animal studies. The dose-
response relationship- for an established or potential carcinogen
is incorporated1 into the slope factor ("SF"), a value expressed
in (mg/kg-day)"1, which is directly proportional to the cancer
potency of the chemical.
Slope factors have been developed by EPA's Carcinogenic
Assessment-Group as a means of estimating excess lifetime cancer
risks associated: with exposure to potentially carcinogenic
contaminant(s) of concern. SFs are multiplied by the estimated
intake of a potential carcinogen-, in mg/kg-day, to provide an
upper-bound estimate of the excess lifetime cancer risk
associated with exposure at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated
from the SF. Use of this approach makes underestimation of the
actual cancer risk- highly unlikely. Slope factors are derived
48
-------
from the results of human epidemiological studies or chronic
animal bioassays to which animal-to-human extrapolation and
uncertainty factors have been applied (e.g., to account for the
use of animal data to predict effects on humans).
The critical toxicity values (RfDs ->.nd Sfs) used in the present
risk assessment are shown in Table (pp. 50-53). For each
chemical, with the exception of PAL:, a chemical toxicity valu~
(either noncancer or cancer) was derived based on toxicity data
specific to the chemical. The carcinogenicity of benzo(a)pyrene
("B(a)P") was used to represent the PAHs.
Risk Characterization Summary
The National Contingency Plan ("NCP") establishes acceptable
levels of carcinogenic risk for Superfund sites at between one in
10,000 and one in l million additional cancer cases if no cleanup
actions are taken at a site. Expressed in scientific notation.
this translates to an acceptable risk range of between 1 x 10'**
and 1 x 10"6 over a defined period of exposure to contaminants at
a site. This means that one additional person in ten thousand or
one additional person in a million, respectively, could develop
cancer over a defined period of exposure to contaminants at the
Site.
The baseline Risk Assessment calculates risk to humans of
contracting other, non-carcinogenic health effects from exposure
to substances associated with the Site by dividing the reasonable
maximum exposure associated with the Site by doses that are
determined by EPA to be without deleterious health effects. The
ratios are added to represent exposure to multiple contaminants.
Any result of this calculation (known as the Hazard Index) which
is greater than one (1.0) is considered to present an
unacceptable risk.
When reviewing the quantitative information presented in this
section, values greater than 1 x 10~4 to 1 x 10~6 for
carcinogenic risk, and chronic Hazard Index values greater than
1.0 for noncarcinogenic risk, indicate the potential for adverse
health impacts.
1. Noncarcinoaenic Risk
The Hazard Index ("HI") Method is used for assessing the overall
potential for noncarcinogenic effects posed by the indicator
compounds. Potential concern for noncarcinogenic effects of a
single contaminant in a single medium is expressed as the hazard
quotient ("HQ") (or the ratio of the estimated intake derived
from the contaminant concentration in a given medi" :. to -he
contaminant's reference dose). By adding the HQs i^r all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the HI can be generated.
49
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TABLE 5
CHEMICAL TOXICIIT VALUES AND ABSORPTION ESTIMATES USED FOR RISK QUANTIFICATION
Saegertown industrial Area Site Rl
Chemical
Vinyl chloride
1,1-Olchloroethene
1.1-Dlehloroethane
1,2-Olchloroethene (trans)
. Chloroform
2-Butanone
1.1.1-Trlehloroethane
1,2-Dlehloroprepane
Trlchloroethene
1,1,2-Trlchloroethane
Ui Semene
O 4-Hethyl-2-pentanone
Tetrachloroethene
1,1,2.2-Tetrachloroethane
Toluene.
Chlorobeniene
Ethylbenzene
Styrene
Xylenea (mixed)
SEMIVOIATILES
Phenol
1,3-Olchlorobenzene
1,4-Dlchlorobenzene
1,2-Olchlorobeniena
2-Methytphenot
4-Hethylphenol
2,4-Dlmethylphenol
Benzole Acid
1,2,4-Trlchlorobenxene
Naphthalene
NexachIorobutadIene
2-Hethylnaphthalene
Acenaphthylene
Acenaphtnene
Olbenzofuran
2,4-Dlnltrotoluene
Dlethylphthalate
Chronic Reference Dose (mg/kg-d)
Slope Factor (mg/kg-d)
-1
Chemical Absorption
Estimate (unlt(ess)
Inhalation
Oral Dermal
Inhalation
Oral .
Dermal
Oral
Dermal
NO
NO
1.0e-01
NO
NO
9.08-02
3. Oo-01
HO
NO
NO
NO
2.0e-02
NO
NO
2.0e«00
5.0e-03
2.9e-01
NO
8.6e-02
ND
NO
2.0e-OI
4.0e-02
HO
ND
ND
ND
3.0e-03
ND
ND
ND
NO
ND
NO
ND
NO
2
H
2
H2
N2
D
2
H2
HZ
H2
1
H2
D
H2
H
H
D
D
01
ND
9.0e-03
1.08-01
2.06-02
1.0»-02
5.0*-02
9.0e-02
ND
NO
4.0e-03
ND
S.Of-02
1.0e-02
HO
2.0«-01
2.08-02
1.0e-01
2.0«-01
2.0e»00
6.0«-01
NO
NO
9.00-02
5. le-02
ND
2.0e-02
4.0e«00
1.3e-03
4.0e-03
2.0e-03
ND
ND
6.06-02
ND
NO
B.Oe-01
|
H
H
1
HI
12
*
1
2
Ht
1
2
1
1
1
12
1
1
1
1
11
1
1
HI
H2
|
1
1
1
ND
9.08-03
I.Oe-01
1.9e-02
I.Oe-02
2.5e-02
9.0e-02
ND
ND
2.0.-03
ND
2.58-02
1.08-02
NO
2.06-01
6.08-03
5.08-02
1.88-01
1.08*00
5.4e-01
NO
ND
4.58-02
4.18-02
4.0e-02
1.0e-02
3.0e»00
6.6e-04
3.4e-03
1.0e-03
ND
NO
3.0e-02
NO
ND
4.08-01
3.06-01
1.2e*00
ND
NO
B.le-02
NO
NO
NO
1.7«-02
5.7e-02
2.96-02
NO
3.38-03
2.08-01
ND
ND
NO
2.0e-03
ND
NO
NO
NO
NO
ND
NO
ND
ND
ND
ND
7.86-02
ND
ND
NO
NO
ND
ND
6
H
H
H
H
HI
6
H
H
*
1
1 .96*00
6.08-01
ND
ND
6.18-03
ND
ND
6.8e-02
1.1e-02
5.7e-02
2.98-02
ND
5. le-02
2.08-01
NO
ND
NO
3.08-02
ND
ND
NO
2.4e*02
NO
ND
ND
NO
ND
ND
ND
7.86-02
ND
ND
ND
NO
6.8e*01
NO
H
1
1
H
H
1
1
H
1
H
H
1
HI
1 .9e>00
6.08-01
ND
NO
6.16-03
NO
ND
1.4e-01
1. le-02
1.10-01
5.86-02
ND
5. le-02
2.1e-01
ND
ND
NO
3.38-02
ND
ND
ND
2.48-02
NO
ND
ND
ND
NO
ND
ND
1.6e-01
ND
ND
ND
NO
1.48400
NO
0.91
1.00
1.00
1.00
1.00
0.50
1.00
0.50
1.00
0.50
0.90
0.50
1.00
1.00
0.99
0.13
0.92
0.90
0.92
0.98
O.SO
1.00
O.SO
0.80
0.80
0.50
0.95
0.50
0.84
0.50
O.SO
0.50
O.SO
O.SO
O.SO
0.50
19
12
19
19
19
12
IB
19
IB
16*
12
19
19
20
19
19
19
13
13
17
18
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
Dermal
Permeability
Constant
(cm/hr)
7.0e-03
9.9e-03
8.9e-03
t.Oe-02
9.0e-03
5.0e-03
l.ee-02
I.Oe-02
1.5e-02
1.7e-02-
l.lo-OI
2.06-03
1.3e-02
9.06-03
1 .Oe*00
4.0e-02
1.4e*00
6.7e-01
8.0e-02
8.2e-03
6.0e-02
6.0e-02
6.0e-02
1.6e-02
1.8e-02
7!fle-03
1.7e-01
7.0e-02
1.2o-0t
7.0e-02
9.5e-02
1.5e-01
5.4e-02
3.9e-03
1.1e-05
6
E
E
6
E
C
E
E
E
E
C
E
E
E
C
6
C
C
6
C
E
6
6
C
C
E
E
C
-------
TABLE 5
CHEMICAL TOXICITY VALUES AND ABSORPTION ESTIMATES USED FOR RISK QUANTIFICATION
Saegertown Industrial Area Site Rl
Chemical
Chronic Reference Dose (mg/kg-d)
Slope Factor (mg/kg-d)
-1
Chemical Absorption
Estimate (unitless)
Fluorene
Hexachlorobenzene
Phenanthrene
Anthracene
Of-n-butylphthalate
Fluoranthene
Pyrene
Butylbeniylphthalate
Bento(a)anthracene
Chrysene
bls(2-ethylhexyl)phthalete
Ol-n-octyl Phthalate
Bento(b)fluoranthene
Benzo(k)fluoranthene
8enio(e)pyrene
lndeno(1,2,3-cd)pyrene
Dlbens(a.h)anthracene
Benio(g,h,l)perylene
Carbaiole
Total Carcinogenic PAHs
PESTICIDE/PCB
Heptechtor epoxlde
4.4'-DDE
4,4'-DDT
PCS
METALS
Aluminum
Antimony
Arsenic
Barium
Cadmium (water)
Cadmium (food/soil)
Calcium
Chromium III
Chromium VI
Cobalt
Copper
Inhalation
NO
ND
NO D
NO
ND 1
HD
ND
HD
ND
ND D
ND
ND
ND
ND
NO
ND
NO
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
1.0e-04 H
NO 2
ND 2
ND
2.0e-06 H
2.0e-06 HZ
ND
ND
Oral
4.0e-02
8.0e-04
ND
J.Oe-01
1.0«-01
4.06-02
3.06-02
2.0e-01
ND
ND
2.0e-02 1
Z.Oe-02 H
NO
ND
NO
ND
NO
ND
ND
ND
1.3e-05 1
NO
S.Oe-04 1
NO
NO
4.06-04
3.06-04
7.0e-02
S.Oe-04
1. Oe-03
ND
1.0e+00 H
5. Oe-03 1
NO
ND
Dermal
2.0e-02
4.0e-04
NO 1
1.5e-01
».0e-02
2.0e-02
l.Se-02
1.8e-01
NO
ND
S. Oe-03
1.0e-02
ND
NO.
NO*
NO
ND
ND
ND
ND
6.Se-06
ND
2.5e-04
ND
ND
Z.Oe-05
9.56.04
3.Se-03
I.Se-OS
7.0e-05
HD
S.Oe-01
2.5e-OJ
NO
ND
Inhalation
ND
1.6e»00 H
ND
NO
ND
ND
ND
NO
ND
• NO
NO
ND
NO
ND
ND 116
ND
ND
ND
ND
6.1e«00 3
9.1e+00 H
NO
3.4e-01 H
NO
ND
NO
S.OetOI H
ND
6.1e*00 Hi
6.1e*00 HI
ND
ND
4.1e»01 HI
NO
NO
Oral
ND
1.6e»00 1
ND
NO
ND
ND
NO
NO
ND
NO
1.46-02 1
ND
NO
ND
ND H6
ND
ND
NO
2.0e-02
1.2e*OI 3
9.1e*00 1
3.4e-OI 1
3.4e-01 1
7.7e«00 H
NO
ND
1.8e«00 6
ND
NO
NO
ND
ND
ND
NO
ND
Dermal
ND
3.2e«00
ND
ND
NO
ND
ND
NO
ND
ND
5.66-02
ND
NO
NO
ND
ND
ND
NO
NO
2.3e+01
1.8e»01
3.06-01
6.8e-01
2.6e»01
NO
NO
1.9e*00
ND
HD
ND
ND
NO
ND
ND
ND
Oral
O.SO
0.50
O.SO
O.JO
0.90
O.SO
O.SO
0.90
O.SO
O.SO
0.2S
O.SO
O.SO
O.SO
O.SO
O.SO
O.SO
O.SO
O.SO
O.SO
0.70
0.90
O.SO
0.30
o.os
0.01
1.00
o.os
0.07
0.07
O.OS
0.04
O.tl
0.97
0.97
14
21
19
19*
19
12
6
6
19
19
19
19
19
19
Dermal
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.30
0.08
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
22
Dermal
Permeability
Constant
(cm/hr)
3.6e-01
1.69-04
2. Jo- 01
2.3e-01
2.3e-06
4.0e-01
3.3e-01
2.1e-02
7.3e-OI
7.5e-OI
5.7e-06
2.4e-02
1.1e«00
1.1e*00
1 . 1e*00
1.6e«00
2.6e«00
1.76400
4.0e-02
1.1e*00
1.5e-03
l.fle-01
3.0e-01
5.3e-01
.Oe-03
.Oe-03
.Oe-03
.Oe-03
.Oe-03
.Oe-03
.Oe-03
2.1e-03
2.le-03
«.0e-04
1. Oe-03
E
C
E
E
C
6
E
E
E
E
C
E
E
E
E
E
E
E
E
E
6
6
6
6
7
7
6
Page 2 of
-------
TABLE 5
CHEMICAL TOXICITY VALUES AND ABSORPTION ESTIMATES USED FOR RISK QUANTIFICATION
Saegertown Industrial Area Site Rl
Ui
fo
Chemical
Iron
Lead
Magnesium
Manganese
Hereury
Nickel
Potassium
Selenlun
Silver
Sodlun
Thalllun
Vanadlun
Zinc
Cyanide
Chronic Reference Dose (mg/kg-d)
Slope Factor (mg/kg-d)
•1
Chemical Absorption
Estimate (unities*)
1
ft
*
Inhalation
NO
ND
NO
.1e-04 I
.6e-05 H2
ND 2
ND
ND
ND
ND
ND
ND
ND
NO
Oral
ND
ND
ND
1.0e-01
8.6e-05
2.0a-02
ND
S. Oe-03
ND
HO
7.0t-05
r.Oe-03
2.0«-01
2.0e-02
1
1
H2
1
1
n
H
H2
H2
1
Dermal
4
4
2
3
3
3
6
1
ND
ND
ND
.Oe-03
.5e-05
.Oe-03
ND
ND
.Oe-04
ND
.Se-06
.$e-0*
.Oe-02
.4e-02
Inhalation
ND
ND
ND
NO
HD
S.4e-01 4
NO
ND
ND
ND
ND
ND
NO
ND
Oral
ND
ND
ND
ND
ND
ND
ND
ND
HD
ND
ND
ND
ND
NO
Dermal
NO
ND
ND
NO
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
Oral
0.10
0.50
0.30
0.03
0.15
0.10
O.OS
0.97
0.10
O.OS
1.00
0.01
0.30
0.17
12
11
14
19
12
19
23
24
20
19
12
Dermal
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
Dermal
Permeability
Constant
(cm/hr)
1.Oe-03
4.Oe-06
.Oe-03 .
.Oe-03
.Oe-03
.Oe-03
.Oe-03
.Oe-03
!Oe-03
.Oe-03
.Oe-03
.Oe-03
.Oe-03
Notes:
Toxlclty values were obtained from the U.S. EPA's Integrated Rlak Information System (IRIS), U.S. EPA's "Heal h Effects Assessment
Suimary Tables'1 (NEAST, Annual FT-1991), and Information provided by U.S.EPA Environmental Criteria Assessment Office (ECAO).
Toxlclty values for the TIC groupings are valuea for the repreaentatlve compounds.
Chemical specific oral and dermal absorption were provided by ECAO; specific references ere given below. In the
absence of chemical specific values, It was assumed that the oral absorption efficiency for organ e compounds end metals
waa 50 X and 5 X, respectively. The dermal absorption estimates were assumed to be SOX for organic compounds end 1.0 X
for metals. The oral and dermal absorption estimates are presented as unit lets values where 1.0 represents 100 X (complete)
absorption. Chemical-specific dermal permeability constants were obtained from the U.S. EPA "Superfund Exposure
Assessment Manual" (SEAM) 1988, or thiECAO. As required by the U.S.EPA, when chemical-specific Information Is not available.
default values were estimated (E) using the following equations
Log OPC • -2.72 * 0.71 log Kou - 0.0061 HW
Where DPC • Dermal Permeability Constant
Kou • Octanol/Uater Partition Coefficient
MU • Molecular Uleght
Reference Doses and Slope Factors designated for the dermal route of exposure are not provided In »h« "•«• »» Information sources,
but were calculated from corresponding values for the oral route of exposure, these values are used to "leulate risks
associated with chemical dose esTlmatee based on an absorbed (In contreat to en adn nlstered) eve of chem eel. All chemical
dose estimates for the dermal route of exposure are based on absorbed chemical levels, fhe, following relationships Mere
used to derive dermal toxlclty values!
Oral Reference Dose (administered) x Oral Absorption Estimate • Dermal Reference Dose (absorbed)
Oral Slope Factor (administered) / Oral Absorption Estimate • Dermal Slope Factor (absorbed)
Page 3 o/. <\
-------
TABLE 5
Ui
ui
CHEMICAL TOXICITY VALUES AND ABSORPTION ESTIHATES USED FOR RISK QUANTIFICATION
Saegertown Industrial Area Site Rl
FOOTNOTES - (lUted to the right of the value)
I
H
0
NO
C
E
S
1
2
3
4
5
6
7
8
11
12
13
14
15
19
17
10
19
20
21
22
23
24
Verified In IRIS 5/15/91
Values from HEAST FY-1991
"Data Inadequate for quantitative risk atte
-------
The HI provides a useful reference point for gauging the
potential significance of multiple contaminant exposures within a
single medium or across media.
Table 6 (pp. 55-56) presents the calculated Hazard Indices for
the potentially exposed populations identified. The table
summarizes the risk estimates by type of land use, area,
environmental media and routes of exposure. Risk in Table 6 is
reported in a different kind of scientific notation. For example,
le-04 is a different way of expressing 1 x 10"4 or 1 in 10,000.
Exposures to multiple sources of contamination through several
routes of exposure may occur. Therefore, the sum of all hazard
indices for each exposed population is given.
An HI of 21 was calculated for the ingestion of GATX pond soil by
an onsite resident under the future site use scenario. An HI of
2.2 was calculated for the ingestion of GATX sludge bed and
lagoon soil by an onsite resident under the future site use
scenario. An HI of 1.9 was calculated for the ingestion,
inhalation and dermal contact with the GATX area ground water by
an onsite resident under the future site use scenario. Antimony
and manganese represent the majority of the HI risk. These
naturally-occurring metals were not found at excessive
concentrations in the sludge/soil on the GATX property.
An HI of 6.7 was calculated for the ingestion, inhalation and
dermal contact with the Lord ground water by an onsite resident
under the future site use scenario.
Under current Site use conditions the SCI property does not pose
a health concern. PAH compounds detected in subsurface soils
were comparable to concentrations found in background samples.
The SCI property is vegetated by a lawn of grass. The health
effects of exposure to the SCI soil contamination under a future
Site use scenario as a residential property was assessed
quantitatively in the Risk Assessment performed in the RI. Table
6 (pp. 55-56) presents the results of the RA. The HI was several
orders of magnitude less than 1 (3e-07 or .000003).
Health risks associated with the SMC property were qualitatively
assessed based on the RI analytical results and Site conditions.
One sediment sample from a vegetated area that collected surface
water from offsite areas contained PCS at a concentration of 260
ppb. Because of the low concentration of the contaminant
detected, and the low potential for exposure to the sediment, it
was determined that this medium does not pose a health concern.
The level of PCB in the sediment is below the 10 to 25 ppm action
level for industrial areas and the 1 ppm action level for
residential areas specified in EPA's "Guidance on Remedial Action
for Superfund Sites with PCB Contamination," OSWER Directive No.
9355.4-01, August, 1990.
54
-------
TABLE 6
Summary of Risk Estimates by Type of Land Use, Area, Potentially
Exposed Population and Medium
Sacgertown Industrial Area Site RI
Current Land Use Conditions
Table Index Medium
Dermal
Expoied Population: On-iileTreipaiier (children) -O ATX
Y-l Slud|« Are* Surface Soil
Y-2 R«ll Am Suihce Soil
Y-3 Pond Surface Sediment
Y-4 Pond Surf«ce Water
Y-3 Pond Air
Total Riik
Exooied Population.! On-tlle Worker - OATX
U1
Y-6 Pond Air
Total Riik
Exnoied Population; Off-ille Reildenti -OATX
Y-7 Pond Air
Total Rlik
Bxpoied Population; On-iite Treipaner (children) - Lord
Y-8 Impoundment Surface Sed.
Total Rlik
B»poied Population; On-lite Reiidenti - SCI
y-9 Property Soils
Total Riik
Hazard Index by Route Cancer Rlik by Route
Oral Inhalation Total Dermal Oral Inhalation
7e-05 •- 7e45 •- 2e47
7e-OS — 7e-OS
9e-OJ -. 9t41 •- 5e-OJ
4e-OS — 4e-05 — 3e-09
le«3 le-03 — — 5e-07
9c-02
le-02 leO2 — — leOJ
le^>2
2e-02 2e-02 — — 3c-05
2e«2
le4M — le-04 — 4e-U
lt-04
Future Land Use Conditions
3e-07 — 3e-07
3e-07
Total
2e«7
5eW*
3e-09
Je-07
5e-OJ
le -05*
U05
3e-05*
3e^)5
4e-ll
4e \\
...
Paqe 1 ~f 2
-------
TABLE 6
Table Index
Medium
Ilizurd Index fay Route
Cnnccr Ritk by Route
Dermal
Oral
Inhalation Total
Dermal
Oral
Inhalation
Total
Y-IO
Y-1J
Y-12
Y-13
Y-U
Y-15
Y-16
Eipoied Population; On-lite ReiidenU • OATX
Sludge Area Soili — 2e+00
Rtll Siding Souj — le-OI
pond Soil* — 2e+OI
Pond Air — — 2e-02
Pond Oroundwiter Be-02 2e+00 3e-05
Total Rlik
Expoied PopuUlloni; On-ille ReiidenU - Lord
Impoundment Soili — 3e-02
Sump Oroundwater 7e-02 7e+00 2e-03
Total Rlik
2e+00
le-OI
2e40l*
2e-02*
2eiOO*
2e«OI
3e4»
7«+00
7e+00
le-07
4e-03
3e-05
3e-OI
Se-06
4e-0>
4e-03
U-06
3eOI
3e05
6e-06*
le-03
2e-02
Ul
* B denote* that cxpoture to Ihlt medium mty be t health concern for the expoied population.
NA • not applicable becauie no carcinofeni were iclected M chcmlctli of potential concern In medium.
NO • not determined becauie Inhalation reference dotet wen not available.
— B not conildered ippticable for ipeciTtc pathway.
Risk in Table 6 is reported, for example, as le-04 which is a
different way of expressing ix 10~4 or 1 in 10,000.
Hazard Indexes and Cancer Risk reported in Table 6 is rounded up
one number for numbers .5 and higher and rounded down for numbers
.4 and lower. Actual risk numbers calculated and used in the
text of the ROD are in Appendix Y in the Remedial Investigation
Report.
Paqe 7. of
-------
2. Carcinogenic Risk
For potential carcinogens, risks are estimated as probabilities.
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency slope and expressing the
result in scientific notation. An excess, lifetime cancer risk of
1 x 10~6 indicates that, as a plausible upper bound, an
individual has a one in one million chance of developing cancer
as a result of site-related exposure to a carcinogen over a 70-
year lifetime under the specific exposure conditions at a site.
Table 6 (pp. 55-56) presents the calculated potential
carcinogenic risk to the potentially exposed populations for each
area of the Site.
An excess cancer risk of 2.8 x 10"1 was calculated for the
ingestion of GATX pond soil by an onsite resident under the
future site use scenario. An excess cancer risk of 3.8 x 10"3
was calculated for the ingestion of GATX sludge bed and lagoon
soil by an onsite resident under the future site use scenario.
An excess cancer risk of 2.7 x 10~5 was calculated for the
ingestion of GATX rail siding area soil by an onsite resident
under the future site use scenario. An excess cancer risk of 6.4
x 10~6 was calculated for the ingestion, inhalation and dermal
contact with the GATX area ground water by an onsite resident
under the future site use scenario.
An excess cancer risk of 2.3 x 1C~2 was calculated for the
ingestion, inhalation and dermal contact with the Lord ground
water by an onsite resident under the future site use scenario.
Carcinogenic risk associated with exposure to contaminants
present in the SCI soil was quantitatively assessed. The SCI
soil was determined not to present a carcinogenic risk.
Carcinogenic risk associated with the SMC property was
qualitatively assessed based on the RI analytical results and
Site conditions. The SMC property was determined not to present
an unacceptable risk.
B. Environmental Risks
An Ecological Assessment was performed for the Site. Most of the
Site is occupied by buildings, paved areas, and lawns.
Undeveloped Site areas are limited to coarse lawns north of SMC
and south of the Lord southern fence line, old field areas mostly
on the former GATX property, and a pond on the GATX property.
The area surrounding the Site includes the Borough of Saegertown
and less developed land. The heavily populated
commercial/residential section of the Borough is located to the
west of the Site. Some rural residences, farmland, and woods lie
to the north, east, and south of the Site. Aquatic resources in
57
-------
the area include French Creek, with a warm water fishery, and
Woodcock Creek, with a cold water fishery. Mussel species were
observed in French Creek downstream from the Site. The northern
riffleshell and clubshell mussels, which were recently proposed
for listing as endangered species under the Endangered Species
Act of 1973, may inhabit French Creek. Macroinvertebrate
populations were sampled at several locations on French and
Woodcock Creeks. Similar numbers of macroinvertebrate families
were identified in both Creeks.
The only Site wetland exists around the GATX pond. The GATX pond
and wetland contains contamination at levels that could pose a
threat to migratory birds.
Table 7 (pp. 59-61) lists the maximum values of chemicals present
in the media of ecological concern at the Site. Site
contaminants of concern were limited to the GATX pond
soil/sediment, the GATX lagoon/sludge bed soil, and the soil
south of the Lord property. Contaminants in these areas include
VOCs, PAHs and other SVOCs, PCBs/pesticides and metals.
Contaminants of concern did not occur at concentrations above
twice the background concentrations at the SMC or SCI properties,
in outlying GATX property areas, or in French Creek.
Table 8 (p. 62) lists the potential ecological exposure pathways
at the Site for many kinds of exposed populations. Exposure
concentrations for chemicals of concern were developed for
burrowing mammals, based on their incidental consumption of
maximum concentrations of contaminants in Site soils through
eating plant material, burrowing and grooming, and drinking water
from the GATX pond. The exposure concentrations were compared
with toxicological doses producing initial effects likely to
affect the health of small mammals. This exposure concentration
is referred to as the lowest-observed-adverse-effect level
("LOAEL"). Table 9 (pp. 63-64) presents the risk estimates, in
terms of the Hazard Quotient and LOAEL, to small mammals from
Site contaminants. The resulting hazard quotients indicate
little potential for concern from the Lord soils. One SVOC
compound (naphthalene) at the former GATX pond and two SVOC
compounds (hexachlorobutadiene, hexachlorobenzene) at the former
lagoon/sludge bed area had hazard quotients that suggested
potential problems for a small mammal population.
Several other chemicals of concern, including lead, PCBs and
several PAHs, were available at potentially high dosages, but
could not be properly assessed because appropriate LOAEL values
are not available. Without toxicological information from
literature sources, these chemicals cannot be assessed
quantitatively. However, locations of elevated concentrations of
these chemicals are the same as those of maximum concentrations
of chemicals for which quantitative assessments were possible,
namely the GATX pond and lagoon/sludge bed areas.
58
-------
TABLE 7
Muimnm Values of Chemical Delected in Media of Ecological Concern
Saegertown Industrial Area Site Rl
Ul
(1)
(2)
(3)
(4)
(5)
(6)
(7) (8)
(9)
(10)
French Cr.
Background
METALS
Aluminum
Antimony
Arsenic
Barium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
VOLATILES
1,2-
dichloroelhene
chloroform
l.l.l-ui-
chloioethane
1.2-
dichloropropane
trichWoethene
1.1,2-
trichloc IK thane
benzene
tetrachloroelhene
Surface
Water
83
ND
ND
25
ND
24.900
ND
ND
ND
229
ND
4.660
34
ND
ND
1.120
ND
ND
5.220
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
French Cr.
Surface
Water
ND
101
ND
31
ND
27.000
II
ND
ND
828
ND
4,940
40
ND
ND
1.160
ND
14
5,860
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
GATX Pond
Surface
Water
ND
ND
ND
14
ND
14,000
ND
ND
ND
ND
ND
2.840
ND
ND
ND
1,120
ND
ND
4.540
ND
ND
28
ND
ND
ND
ND
ND
3
ND
ND
2
French Cr.
Background
Sediment
5.570.000
ND
. 5.900
42.100
ND
1,960,000
7.800
ND
9.600
11.900.000
10.500
1.480.000
577.000
ND
ND
892.000
ND
ND
ND
ND
ND
40.300
ND
ND
ND
ND
ND
ND
ND
ND
ND
French Cr.
Sediment
6.040,000
ND
17,400
33,300
ND
14,600,000
6,600
ND
12,300
16.800.000
50.900
2,990.000
325.000
ND
8.700
538.000
ND
.ND
ND
830
ND
52.600
ND
ND
80
ND
ND
ND
ND
ND
ND
GATX Pond
Sediment
21,900.000
ND
830.000
690.000
24.900
10.900,000
576,000
3.100
324,000
49.700.000
3.410.000
2.830.000
294.000
305.000
152,000
1.640,000
24,600
4.000
ND
5.900
29.400
6.340.000
5.800
ND
ND
ND
ND
610.000
43.000
40.000
1.500.000
Shallow SMC
Site Soil Shallow
Background Soils
11.000.000 8.760.000
ND ND
13.500 10.100
82.800 55.900
ND ND
2.470.000 1,160,000
11,100 9.000
9.200 3,800
16.900 16.000
21.700.000 1 7.800.000
34.300 16.400
2.510.000 2.390.000
871.000 884.000
80 ND
17.100 13.100
792,000 523,000
ND ND
ND ND
ND ND
970 650
14.000 15.400
78.100 43.200
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
SCI
Shallow
Soils
6,850,000
ND
8,800
45.000
ND
661.000
5.900
3,500 ,
12,000
17,300,000
14.100
1.910.000
625.000
ND
14,200
639.000
ND
ND
ND
ND
ND
42.100
ND
ND
ND
ND
ND
ND
ND
ND
ND
GATX Pond
Area Shallow
Soils
12.400.000
15.100
134,000
248.000
8,300
18.900.000
174.000
19.500
168.000
220,000.000
2.910.000
4.770.000
1.200,000
5.900
42,300
1.220.000
5.300
ND
4.770.000
25,300
14.100
1.620,000
25,000
ND
2.000
1
ND
39,000
ND
210.000
30.000
(ID
GATX Pond
Lagoon
Sludge
Bed Soils
9,240,000
ND
21.000
90.800
ND
38,000.000
72,800
5,600
29.500
20,600,000
149.000
9,530.000
651,000
420
15.800
1. 010.000
ND
ND
ND
840
11.100
254,000
16.000
160
ND
ND
II
870
ND
420
1,500
(12)
Other GATX
Area
Shallow
Soils
15,200,000
ND
22.400
110.000
ND
4,600.000
16.200
8,900
33.600
27,100,000
52.200
2,670,000
969,000
ND
18.700
1,210.000
ND
ND
ND
1,400
18,000
86.200
ND
ND
ND
ND
ND
ND
ND
ND
ND
(13)
Lord
Cmp.
Shallow
Soils
14,500.000
ND
8.900
124.000
ND
3.950.000
22.300
6.800
69.900
27,100,000
33.400
2.500,000
497,000
220
16.700
1,3.10.000
570
ND
ND
ND
20,700
248.000
ND
ND
ND
ND
ND
ND
ND
ND
ND
1 of i
-------
TABLE 7
(I) (2) (3) (4) (5) (6) (7) (8)
French Cr.
Background French Cr GATX Pond French Cr. Shlllow SMC
Sutfice Surfice Suffice Background French Cr. OATX Pond Site Soil Shlllow
Witer Witer Witer Sediment Sediment Sediment Bickground Soili
(9)
(10)
SCI OATX Pond
Shlllow Are* Shlllow
Soils Soils
(ID
GATX Pond
Lagoon
Sludge
Bed Soils
(12)
Other GATX
AIM
Shallow
Soils
(13)
Lord
Cotp.
Shallow
Soili
1.1.2.2-
lelrachloroelhane ND
toluene ND
chlorobenzene ND
cthyibcnienc ND
styrene ND
xylenei ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
27.000
44,000
170.000
27.000
22.000
95.000
ND
17
ND
3
ND
3
ND
5
ND
ND
ND
ND
ND
5
ND
ND
ND
ND
ND
230.000
14.000
21.000
2.700
210.000
ND
1.200
24.000
44.000
230
2.300
NO
49
NI)
ND
ND
NI)
ND
3
NI)
NI)
ND
ND
PESTICIDES/TCBi
Dieldrin ND
4,4'-DDE ND
4,4' DDT ND
alpha chlordane ND
gamma chlocdane ND
Arochlorl260 ND
Arochlor 1254 ND
SEMI VOLATILES
°> Phenol ND
1.4-
dichloiobcounc ND
1.2-
dichlorobenune ND
2-rneihylphenol ND
4melhylphenol ND
2.4-
dimelhylphenol ND
bentoic acid ND
1.2.4-
trichlcfobetteoe ND
naphthalene ND
heuchtoro-
butadiene ND
2-methyl-
naphlhalene ND
icenaphdiylene ND
acenaphlhene ND
dibeiuofuran ND
2.4-diniuo-
toluene ND
duoiene ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
130
ND
S3
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
33.000
ND
150.000
1.200.00
520.000
70.000
180,000
150.000
ND
1.500.000
5.900,000
310,000
4.000.000
440.000
2.800.000
3,400.000
100.000
3.500.000
1.4
4.3
ND
0.44
0.39
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
330
ND
140
73
85
120
ND
180
ND
ND
ND
ND
ND
ND
260
ND
ND
ND
ND
ND
ND
130
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
830.000
ND
970.000
250
ND
380.000
1,100,000
430.000
630.000
ND
17.000.000
ND
6.900.000
1.600.000
4.300.000
5.200.000
ND
7.30O.OOO
ND
ND
ND
ND
ND
ND
ND
ND
230,000
440.000
ND
ND
ND
NA
240.000
2,400.000
180.000
800.000
140.000
490.000
570.000
ND
970.000
ND
ND
NI)
ND
NI)
NI)
ND
NI)
NI)
NI)
ND
ND
ND
76
ND
ND
ND
ND
ND
NI)
NI)
NI)
NI)
. NI)
80
70
NI)
NI)
NI)
NO
65
NI)
NI)
ND
ND
ND
25.000
NI)
ND
NI)
NI)
NI)
NI)
NI)
NI)
NI)
I'aoo
-------
TABLE 7
(1)
French Cr.
(2)
Background French Cr.
Surface
W.itr
heiochloro-
benzene ND
phemnlhrene ND
anthracene ND
di-n-
butylphihalale ND
fiuoranihene ND
pyrene ND
bulylbenzyl-
phlhalate ND
beoz0(a)-
anthracene ND
chrysene ND
bis(2-eihylhe»yl)
phihalate ND
di-o-
oclylphihalale ND
• benzo(b)
fluoianthent ND
benzoQc)
• flounnlheoe ND
btnto(a)pyrene ND
ideno(l,2.3-cd)-
pyrene ND
dibenz(a.h)-
anthracene ND
benzo(g,h.i)-
perylcne ND
Notes:
(1) fromSWOI-OI
(2) (torn SW02-OI. SW03-OI
(3) fromSWOS-OI.SWOfrOI
(4) (romSD-OI-OI
(5) fromSD02-OI.SD03-OI.
(6) fromSD05-OI.SD06-OI
Surface
Water
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
HO
ND
ND
ND
ND
ND
. SW04-01
SD04-OI
(3)
G ATX Pond
Surface
Water
ND
ND
ND
ND
ND
NO
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
(4)
French Cr.
Background
Sediment .
ND
IS
ND
62
99
90
ND
54
ND
82
ND
73
73
ND
ND
ND
ND
(7) from SSBI 1 04. SSB12-04, SSBI7-04. SU03-02
(5)
French Cr.
Sediment
ND
75
61
ND
170
110
ND
91
92
65
ND
tio
ND
71
ND
ND
ND
(8)
(9)
(10)
(II)
(12)
(13)
(6) (7)
Shallow
GATX Pond Site Soil
Sediment Background
200.000 57
26.000.000 700
70.000.000 630
190.000 ND
4.900.000 800
4,100.000 740
ND 51
1.100.000 460
3.300.000 430
180.000 ND
100.000 ND
1.500,000 1.000
730.000 1.000
1.100.000 320
400.000 260
140.000 ND
360.000 280
fromSD09-01.SSBOI-04.
from SSB 16-04
fromSSAP82-03. SSAP88
TP03-02.TP04-02
(8)
SMC
Shallow
Soili
ND
ND
ND
ND
ND
ND
ND
ND
NO
65
ND
ND
ND
ND
ND
ND
ND
SSDOI-06
(9)
SCI
Shallow
Soils
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
(10)
GATX Pond
Area Shallow
Soil!
610
16.000.000
45.000.000
ND
8.200.000
8.200.000
ND
3.100.000
13.000.000
3.400
ND
4.000.000
4.000.000
1.900.000
770.000
300.000
780.000
•03. SSAP89-04. SSAP90-04. SSD07 02.
from SUOI-02. SU02-02. SSAP83 04.
from SSB05-04. SSD06-02. SSB06-04
from SSD 10-02. SD07-OI.
SD080I
(II)
GATX Pond
Lagoon
Sludge
Bed Soils
50.000
1.800.000
3,000.000
ND
640,000
510.000
120
170.000
210.000
ND
ND
130.000
130.000
210.000
71.000
380
71.000
(12)
Older GATX
Area
Shallow
Soils
ND
45
ND
ND
160
110
ND
55
68
ND
ND
120
120
ND
ND
ND
NO
SSB07 04. i>MU>8 04, S.SII09
(13)
Lord
Corp.
Shallow
Soils
ND
ND
ND
ND
59
ND
ND
ND
ND
no
ND
NO
^
Nl)
Ntl
Nl)
NO
ND
01. TPOI 01.
SSAP84-03. SSAP8S 03. SSAP86 04. SSAP87 01
.SSB 13-04.
SSBI4-02.SSBI5-04
All values are in ug/L or ug/kg.
.1 of
-------
TABLE 8
Potential Ecological Exposure Pathways
Saegertown Industrial Area Site RI
Polcnliil Source
(Environmental Medium)
Surface water
cn
Sediment
Diou
Surface wain
Sediment
Biota
Soil
Exposure
Point
French Creek
•
French Creek
French Creek
GATX Pond
GATX Pond
Route of
Contaminant Uptake
Direct contact
Ingeslion
Diiecl contact
Biomagnification
Diiect contact
Ingetlion
Direct coolacl
Eipoted
Population
Fish, algae,
macrophytes,
aquatic birds,
macroin vertebrate!,
reptiles
Fith.
aquatic birds, macro-
Invenebraies.
reptiles
M>ciophyiu,
tnactoinvcitebtates
Fish, imall mammals,
reptiles, aquatic
birds
maciophytes. algae, .
macroin vertebrates,
aquatic birds,
reptiles
Fith. aquatic birds.
macroin vertebrates
Macrophytes.
macroinvertebratei,
amphibians
GATX Pond
Terrestrial llabilali
Biomagnificalion
Direct contact
Ingcition
fliomagnifkalion
Small mammals, birds
Small mammals.
reptiles, toil
inv< rtebrales
Small mammals,
reptiles
Small mammals, birdi,
reptiles
Eiposure
Potential
Low, contaminants do not
appear site related.
Low, conlaminanu do not
appear site related.
Low. contiuninnnU «lo mrt
appeal to be site related.
Low, conlaminanu arc not
present in luge
concenualions.
Low, little contamination
Is present in pond water.
Low, linle contamination
is present in pond water.
High, some oiganics and
metals bioaccumulale and
biomagnify.
High, some organics and
metals bioaccumulale
and biomagnify.
High in some areai. tome
organics and mcuils
bioacciimultle and biomigniCy.
High in some nieu. sonic
oigania and metals
bioacciimiilaie and binuingnily.
High in inme area.<. some
organic* and melals
-------
TABLE 9
Risk Estimates to Small Mammals from Site Contaminants
Saegertown Industrial Area Site RI
OATX Poad Ait»
OATX Forma Uiooa/SMn Btd
LOB! Corn.
M«uU
AnUmoajr
Arienk
Bvium
Cidmiuin
Chromium
Macuy
Nickel
Seledum
Thtllium
UK
CfMide
VoUUlM
CNaroform
I.M-kkMoroclhine
l.l-Dio|MiK
TrkMoraefeM
I.I.I TricWaroeih.ne
TttndilwuclheM
I.U,2-Tt*»d>k>fo
-------
TABLE 9
OATX Pond Area
OATX Forma I^ioon/Sludgc Bed
Metalt
ftnkidej/TCBi
4.4'DOB
4.4-• DOT
ArocMorl260
Scmivolalilej
Eipmure Value ToiucilY Fndpoinl
CUI from LOAEL from
Table 15 Table 1-6
Lord Corp.
NO
ND
2961
NA
0.05
NA
Btpoiura Value
CDIfrom
llauid Tabkl-5
Quotient (u«A*/d»y)
NO
NO
ND
To»kityE«dpoial
LOAEL from
Table I 6
NA
0.05
NA
lluvd
Quotient
EipotuR Ekdpoi
CDIrrom
Tatfe I-S
(into/day)
0.24
0.11
ND
Toiicily EnJpoint
LOAEL from
Table ••« Haunl
Quotien>
NA
0.0)
NA
0.004
Phnol
1 ,4-dichlorobcoiene
U-dUMotofeMene
I-melhyl|Aenal
4 meihylflieaol
2.4 dimcthylphcool
DeaioktcU
1,2.4 Trichlorobenune
N*|4iihaleM
tleiachlototiuladwne
2 Mtthylaaphthaltoe
'
Accnifhdttoe
Dibtiiofuian
Fluorne
HettcMorobeaKne
flitaaolhtcae
Anthncxoe
Ruoianlheae
BurlbtatYlphlhaltlc
bcBto(a)aiiihiaccne
Orfitnt
Bti(2-cdtyDieiyl)phdukle
De»o(b)t1uoraDiheae
Baiu>(li)flcjutaa(heae
Dciio(a)pyTtne
lde«o(l.l.3 cdjpyrcne
DibcDi(a^i)anlhrac«oe
Be»o(|.h.i)|>eryleae
4071
0.7]
ND
159)
4617
110)
2644
ND
71.149
ND
2I.9S9
671)
11.047
21.124
10.611
2.6
67.112
IM.86J
14.41)
14.41)
NU
11.011
54.561
14.1
16.711
16.711
7974
1212
1259
1274
60
NA
19
50
50
50
NA
20
1J.7
0.1
NA
NA
175
NA
12)
O.OS
NA
1000
12)
7)
1)9
NA
NA
19
NA
NA
NA
NA
NA
NA
0.07
..
0
0.01
0.09
0.04
-
0
2.0
0
..
..
0.1
_
0.2
0.01
0.2
0.1
0.5
0
..
..
0.0001
..
-
..
--
..
ND
690
1120
ND
ND
ND
ND
1007
10.071
75)
1151
511
1056
2192
4071
210
755)
12.591
2616
2140
1.1
71)
Ml
ND
546
546
III
291
1.6
291
60
NA
19
50
50
50
NA
20
15.7
0.2
NA
NA
175
NA
125
0.01
NA
1000
12)
7)
159
NA
NA
19
NA
NA
NA
NA
NA
NA
0.01
0
0
0
0.0)
0.)
4
0.01
0.01
1
0.01
0.02
0.0)
lc-05
0.27
ND
ND
ND
ND
ND
105
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.2
ND
ND
ND
ND
as
ND
ND
ND
ND
ND
ND
60
NA
19
50
50
50
NA
20
15.7
0.2
NA
NA
175
NA
125
0.01
NA
1000
12)
75
159
NA
NA
19
NA
NA
NA
NA
NA
NA
4e06
0
0
0
0
0
0
0'
0
0
0
2t06
0
0
0.00001
NO1ES:
llauid Quotient = Ciponire Value/Toiicil)r Endpoinl/IO1 uj/mj
NU • Not delected in area lamrilei
NA • Value not available
• m llauid quotient cannot be calculated.
nf
-------
C. significant sources of Uncertainty
The BRA makes certain assumptions in calculating risk for the
Site and reflects some omissions. For example, the BRA assumes
that the Site is fully characterized and that critical toxicity
values derived primarily from animal studies accurately assess
risk. Reference doses incorporate conservative uncertainty
factors, and cancer slope factors estimate upper bound 95th
percentile values. No consideration was given to the likelihood
of the actual occurrence of the current and future Site use
scenarios. No allowance was made for antagonistic or synergistic
chemical interactions in calculating toxicity of chemicals. The
toxicity of the tentatively identified compounds was not
considered since little is known about these chemicals. Some
uncertainty is introduced into the risk assessment process as a
result of these assumptions and omissions.
D. Risk Assessment Conclusions
An unacceptable level of risk is presented by the former GATX
pond, sludge bed and lagoon areas in a future land use scenario
involving an onsite resident's accidental ingestion of soil
contaminants. Actual or threatened releases of hazardous
substances from this portion of the Site, if not addressed by
implementing the response action selected in this ROD, may
present a substantial endangerment to public health, welfare, or
the environment.
An unacceptable level of risk is presented by the groundwater in
the vicinity of the Lord property in a future land use scenario
involving an onsite resident's ingestion, inhalation and dermal
contact; with the ground water contaminants. Actual or threatened
releases of hazardous substances from this portion of the Site,
if not addressed by implementing the response action selected in
this ROD, may present a substantial endangerment to public
health, welfare, or the environment.
VII. DESCRIPTION OF REMEDIAL ALTERNATIVES
In accordance with Section 300.430 of the National Oil and
Hazardous Substances Pollution Contingency Plan ("NCP"), 4O
C.F.R. § 3OO.43O, a list of remedial response actions and
representative technologies were identified and screened to
determine whether they would meet the remedial action objectives
at the Site. Those that would meet the remedial action
objectives are discussed below as Remedial Alternatives.
Section 121(d) of CERCLA requires that remedial actions at CERCLA
Sites at least attain legally applicable or relevant and
appropriate federal and State standards, requirements, criteria
and limitations which are collectively referred to as "ARARs,"
65
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unless such ARARs are waived under CERCLA Section 121(d)(4).
Applicable requirements are those substantive environmental
protection requirements, criteria, or limitations promulgated
under federal or State law that specifically address hazardous
substances found at the Site, the remedial action to be
implemented at the Site, the location of the Site or other
circumstances present at the Site. Relevant and appropriate
requirements are those substantive environmental protection
requirements, criteria or limitations promulgated under federal
or State law which, while not applicable to the hazardous
materials found at the Site, the remedial action itself, the Site
location or other circumstances at the Site, nevertheless address
problems or situation sufficiently similar to those encountered
at the Site that their use is well-suited to the Site. ARARs may
relate to the substances addressed by the remedial action
(chemical-specific), to the location of the Site (location-
specific) , or to the manner in which the .remedial action is
implemented (action-specific).
It should be noted that all costs, time frames and
waste/treatment volumes indicated below are estimates based on
the RI/FS and the Administrative Record for this Site. This
information will be further refined for the selected remedial
alternatives during the remedial design.
SUMMARY OF REMEDIAL ALTERNATIVES
FOR THE SAEGERTOWN INDUSTRIAL AREA SITE
GATX Alternative l -
GATX Alternative 2 -
GATX Alternative 3A -
GATX Alternative 3B -
GATX Alternative 3C -
GATX Alternative 4A -
GATX Alternative 4B -
GATX Alternative 5 -
GATX Alternative 6 -
GATX Alternative 7A -
GATX Alternative 7B -
GATX Alternative 8 -
No Action
Containment Onsite (Capping)
Offsite Landfilling
Offsite Incineration
Offsite Disposal as a Hazardous Waste Fuel
Onsite Landfarming
Onsite Slurry Phased Bioreactor
Solvent Extraction
Onsite Incineration
Combination Alternative with Landfarming
Combination Alternative with Slurry Phased
Bioreactor
Combination Alternative with Solvent
Extraction
Lord
Lord
Lord
Lord
Lord
Lord
Alternative
Alternative
Alternative
Alternative
Alternative 5
Alternative 6
No Action
Ground Water Containment and Source Control
Ground Water Pumping and Treatment
In-situ Air Sparging
In-situ Biological Treatment
Combination with Air Sparging, Steam
Stripping or Biological Treatment
Lord Alternative 7 - Combination with In-situ Vapor Extraction
66
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A. Remedial Alternatives for QATX Soil/Sludge
GATX ALTERNATIVE 1 - NO ACTION
Major Components of the Remedial Action
The NCP requires that EPA consider a "No Action" Alternative for
every site to establish a baseline for comparison to Alternatives
that do require action. Under this Alternative, no action would
be taken at the former GATX property to monitor, remove,
remediate, contain, or otherwise address soil/sludge
contamination. No treatment or containment would be performed
under this Alternative.
Estimated Capital Costs: $0
Estimated Annual O&M Costs: $0
Estimated Present-Worth Costs: $0
Estimated Implementation Time: N/A
Compliance with ARARs
There are no ARARs associated with a No Action Alternative.
GATX ALTERNATIVE 2 - CONTAINMENT ONSITE (Capping)
Major Components of the Remedial Action
This Alternative would involve capping all the areas of surface
and subsurface sludge and. contaminated soil on the former GATX
property. A cap would be utilized to minimize precipitation
infiltration, reduce the potential for erosion and transport of
contaminated surface soil, minimize the potential for the
volatilization of VOCs into ths asbient air, eliainate the
generation of particulate airborne contaminants and prevent
exposure as a result of dermal contact and ingest ion. Some
surface regrading would be necessary to redirect surface water
that currently collects in the GATX pond and other low areas.
The cap would consist of a vegetative (topsoil) layer, a drainage
(sand) layer and a low permeability (synthetic and soil) layer.
Deed restrictions, fencing and continued ground water monitoring
would be needed to reduce the potential for future human
exposure. Caps require long-term maintenance and have an
uncertain design life. Caps need to be inspected for settlement,
intrusion by burrowing animals, ponding of liquids, erosion and
invasion by naturally occurring deep-rooted vegetation. In
addition, ground water monitoring wells need to be maintained and
periodically sampled. No treatment would be performed under this
Alternative.
67
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Estimated Capital Costs: $1,010,000
Estimated Annual O&M Costs: $82,500
Estimated Present-Worth Costs: $1,700,000
Estimated Implementation Time: One Year
Compliance with ARARs
Capping of the pond would impact wetlands area. This Alternative
would have to comply with the provisions for protection of
wetlands and flood plain management in 40 C.F.R. Parts 6 and 230
and 25 PA Code §§ 105.17-105.20(a).
Fugitive dust emissions generated during remedial activities will
be controlled in order to comply with fugitive dust regulations
in the federally-approved State Implementation Plan for the
Commonwealth of Pennsylvania, 25 PA Code §§ 123.1 - 123.2, and
will not violate the National Ambient Air Quality Standards for
particulate matter, 40 C.F.R. § 50.6 and 25 PA Code §§ 131.2 and
131.3.
GATX ALTERNATIVE 3A - OFFSITE LANDFILLING
Major Components of the Remedial Action
The RI has estimated that 9,000 cubic yards of sludge/soil are
contaminated on the former GATX property, tinder Alternative 3A
this material would be excavated and removed for offsite
disposal. Sludge and contaminated soil would initially be
excavated based on visual observations. Verification samples
would then be collected to demonstrate that residual PAH
concentrations in soil are below the established cleanup criteria
for the Site. Areas of contaminated soil exceeding established
cleanup criteria for the Site would subsequently be excavated for
treatment or disposal. Excavation and sampling activities would
continue until the residual contaminant concentrations in both
the pond and former lagoon/sludge bed areas meet the established
cleanup criteria- for the Site. The former GATX pond would have
to be drained prior to excavation, then regraded with clean soil
to its former contours. Other excavated areas would have to be
backfilled and graded.
Offsite landfill ing may require above-ground pretreatment of
sludge and soil to remove vocs. Pretreatment by vapor extraction
would be used to render the sludge and contaminated soil non-
hazardous in order to meet the RCRA Land Disposal Restriction.
The sludges/soils would then be transported offsite for disposal
at a solid waste landfill.
During and after implementation of this Alternative, monitoring
would be performed to assess the impact and effectiveness of the
68
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removal of the source contaminants in the pond, lagoon and sludge
bed areas ("source removal") on ground water, and the need for
ground water remediation.
Estimated Capital Costs: $10,000,000
Estimated Annual O&M Costs: $25,000
Estimated Present-Worth Costs: $10,100,000
Estimated Implementation Time: One Year
Compliance with ARARs
This Alternative would comply with the applicable portions of the
PADER Ground Water Quality Protection Strategy, which prohibits
continued ground water quality degradation, since the entire
waste volume will be removed from the Site.
This Alternative would comply with PADER regulations for the
generation and transportation of hazardous wastes (25 PA Code
Chapter 262, Subchapters A and C, and Chapter 263).
Offsite and onsite treatment, storage and disposal would comply
with RCRA regulations and standards for owners and operators of
hazardous waste treatment, storage and disposal facilities, in
accordance with 25 PA Code Chapter 264, Subchapters A-E,
Subchapter I (containers) and Subchapter J (tanks).
Any treatment of the soil to remove VOCs under this Alternative
would comply with the requirement for treatment before disposal
to meet Land Disposal Regulations (40 C.F.R. Part 268).
ARARs for Excavation, Removal of Contamination and Soil Handling
(Applicable to GATX Alternatives 3A, 3B, 3C, 4A, 4B, 5, 6, 7A, 7B
and 8):
Determinations about the effectiveness of any soil remediation at
the Site would be based on EPA document no. 230/02-89-042,
Methods for Evaluating Cleanup Standards. Vol. I: Soils and
Solid Media.
Any generation, treatment, storage and offsite disposal of PCB-
impacted soil and debris would comply with 40 C.F.R. Part 761 and
specifically, Subpaft G. Determinations about the effectiveness
of soil remediation of PCB waste at the site would be based on
EPA document no. 560/05-85-026, Verification of PCB Soill Cleanup
by Sampli.no? and Analysis.
In the event that any Alternative did not comply with State
regulations for the closure of hazardous waste sites (25 PA Code
Chapter 264, Subchapter G), the closure regulations would be
waived if an Equivalent Standard of Performance were achieved by
the removal of the contaminated soils.
69
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Excavation for offsite disposal would impact the pond and wetland
area. This Alternative would have to comply with the provisions
for protection of wetlands and flood plain management in 40
C.F.R. Parts 6 and 230 and 25 PA Code §§ 105.17-105.20(a).
Fugitive dust emissions generated during remedial activities will
be controlled in order to comply with fugitive dust regulations
in the federally-approved State Implementation Plan for the
Commonwealth of Pennsylvania, 25 PA Code §5 123.1 - 123.2, and
will not violate the National Ambient Air Quality Standards for
particulate matter, 40 C.F.R. § 50.6 and 25 PA Code §§ 131.2 and
131.3.
GATX ALTERNATIVE 3B - OFFSITB INCINERATION
Major Components of the Remedial Action
This Alternative incorporates all of the actions outlined in
Alternative 3A except that instead of offsite disposal at a
landfill, the sludge/soil would be transported to an offsite
permitted commercial incinerator. During and after
implementation of this Alternative, monitoring would be performed
to assess the impact and effectiveness of the source removal on
ground water and the need for ground water remediation.
Estimated Capital Costs: $33,690,000
Estimated Annual O&M Costs: $25,000
Estimated Present-Worth Costs: $33,800,000
Estimated Implementation Time: One Year
Compliance with ARARs
This Alternative would comply with the ARARS for excavation,
removal of contamination and soil handling specified under GATX
Alternative 3A.
The offsite incineration would be performed at a RCRA permitted
facility.
If the sludge contains concentrations of PCBs greater than 50
ppm, the operation of the offsite incinerator would be required
to meet applicable storage and treatment regulations as specified
in 40 C.F.R. Part 761.
GATX ALTERNATIVE 3C - OFFSITE DISPOSAL AS A HAZARDOUS WASTE FUEL
Major Components of the Remedial Action
This Alternative incorporates all of the actions outlined in
Alternative 3A except for the final offsite disposal location.
Instead of offsite disposal at a landfill or incinerator, the
70
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sludge/soil would be transported to a cement kiln approved for
the burning of hazardous waste-derived fuels. During and after
implementation of this Alternative, a ground water monitoring
program would be performed to assess the impact and effectiveness
of the source removal on ground water and the need for ground
water remediatior.
Estimated Capital Costs: $11,710,000
Estimated Annual O&M Costs: $25,000
Estimated Present-Worth Costs: $11,800,000
Estimated Implementation Time: One Year
Compliance with ARARs
This Alternative would comply with the ARARS for excavation,
removal of contamination and soil handling specified under GATX
Alternative 3A.
Burning tne contaminated sludge and soil as a fuel in a cement
kiln in the Commonwealth of Pennsylvania would comply with 25 PA
Code Chapter 127.
40 C.F.R. Part 266, Subpart H is also an ARAR for the burning of
contaminated sludge and soil' as a fuel.
GATX ALTERNATIVE 4A - ONSITE LANDFARMING
Major components of tbe Remedial Action
This Alternative would involve the excavation and contained
storage ("staging") onsite of contaminated soils and sludge for
biological treatment in an engineered cell. Landfarming is a
process by which microorganisms degrade waste. Biodegradation of
waste by microorganisms can be optimized when conditions
including Ph, oxygen, nutrient availability and moisture are
controlled. Sludge from the Site would require mixing with clean
soil prior to placement in a landfarm treatment cell since it is
too contaminated in its present condition. Sludge would
periodically be added to the cell as biodegradation of the waste
occurred until all of the contaminated material is treated.
Estimated Capital Costs: $4,300,000
Estimated Annual O&M Costs: $513,000
Estimated Present-Worth Costs: $7,500,000
Estimated Implementation Time: Eight Years
Compliance with ARARs
This Alternative would comply with the ARARS for excavation,
removal of contamination and soil handling specified under GATX
Alternative 3A.
ARARs for residual contaminants which remain onsite would include
71
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40 C.F.R. Part 264, Subparts F and G, pertaining to releases from
Solid Waste Management Units (SWMUs) and the closure and
post-closure regulations for RCRA landfills.
The operation of the biological treatment system would have to
meet the RCRA .hazardous waste and TSCA PCS regulations. The
construction and operation of the landfarm treatment cells would
have to comply with 25 PA Code Chapter 264, Subchapter L,
governing hazardous waste piles.
Since landfarming would be performed in engineered treatment
cells designed to meet RCRA ARARs for waste piles, the RCRA Land
Disposal Restriction ("LDRs") should not apply to the placement
of soil into the treatment cells. The operation of the landfarm
would have to comply with 40 C.F.R. Part 264, Subpart M, and 25
PA Code Chapter 264, Subchapter M, pertaining to land treatment
of hazardous waste.
If VOC emissions from the landfarm exceed PADER reguirements, an
off-gas capture and treatment system would have to be
incorporated into the ventilation system for the landfarm
enclosure. Landfarm VOC emissions would be collected and treated
by carbon absorption or thermal treatment.
GATX ALTERNATIVE 4B - ONSITE SLURRY PHASED BIOREACTOR
Major Components of the Remedial Action
This Alternative would involve the excavation and staging onsite
of contaminated soils and sludge for biological treatment in a
slurry phased biological reactor. Slurry phased bioreactors
offer greater control over biological treatment processes than
landfarming. Increased contact time between the microorganism
and the contaminants, use of engineered microorganisms, decreased
acclimation time and greater control over process parameters, can
all be achieved in the bioreactor. A slurry, made by mixing 15%
sludge or soil (by weight) with water, would be processed through
the bioreactor. A residual amount of contaminants would remain
in the soil/sludge after treatment.
Estimated Capital Costs: $9,200,000
Estimated Annual O&M Costs: $958,000
Estimated Present-Worth Costs: $12,200,000
Estimated Implementation Time: Three Years
Compliance with ARARs
This Alternative would comply with the ARARS for excavation,
removal of contamination and soil handling specified under GATX
Alternative 3A.
ARARS for GATX Alternative 4A are also applicable to this
Alternative.
72
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The offsite disposal of generated biological treatment sludge
from the slurry phase bioreactors would have to comply either
with 25 PA Code Chapter 264, Subchapters A-E, I and J, or 25 PA
Code Chapters 287-289 (Residual Waste Regulations).
A treatability variance from the applicable LDRs under 40 C.F.R.
§ 2*3.44 would be required to allow the biologically treated
slu_ge and -il to be redeposited on-Site.
6ATZ ALTERNATIVE 5 - SOLVENT EXTRACTION
Major components of the Remedial Action
This Alternative involves the excavation and staging of
contaminated sludge and soil fcr onsite solvent extraction.
Solver- extractic- transfers the contaminants from the solid
phase -a the _iqu..i phase. A solvent is used to wash the
contaminants out of the soil/sludge. As many as eight separate
washings may be needed to reduce the levels of contaminants in
the soil/sludge to acceptable levels. The extracted contaminants
would then be transported offsite for incineration or secondary
fuel blending.
Estimated Capital Costs: $8,770,000
Estimated Annual O&M Costs: $2,180,000
Estimated Present-Worth. Costs: $13,300,000
Estimated Implementation Time: Two Years
Compliance with ARARs
This Alternative would comply with the ARARS for excavation,
removal of contamination and soil handling specified under GATX
Alternative 3A.
The ARARs specified in GATX Alternatives 4A and 4B pertaining to
hazardous waste classification and treatment, air emissions, and
obtaining a treatability variance from the RCRA LDRs, also apply
to solvent extraction treatment.
GATZ ALTERNATIVE 6 - EXCAVATION AND ONSITE INCINERATION
Major Components of the Remedial Action
This Alternative would involve the excavation, pretreatment and
staging of contaminated soil/sludge for onsite incineration.
Pretreatment of the soil/sludge, including mixing and screening,
would be required to provide a uniform feedstock for the
incinerator. The removal efficiencies, that are attainable for
incineration would reduce the risk to human health and the
environment to acceptable levels for both the current and future
Site use scenarios. Incineration of the soil/sludge would reduce
or eliminate the toxicity and volume of organic contaminants by
converting them to non-toxic combustion gases. Ash remaining
73
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after the incineration could be redeposited onsite or removed for
offsite disposal, either with or without fixation to immobilize
any metals in the ash. If the ash passed the Toxicity
Characteristic Leachate Procedure ("TCLP") test (i.e., were
determined to be non-hazardous), it would not require fixation
prior to onsite or offsite disposal.
Estimated Capital Costs: $11,670,000
Estimated Annual O&M Costs: $25,000
Estimated Present-Worth Costs: $11,700,000
Estimated Implementation Period: Six Months to One Year
Compliance with ARARs
This Alternative would comply with the ARARS for excavation,
removal of contamination and soil handling specified under GATX
Alternative 3A.
The operation of the onsite incinerator will comply with 25 PA
Code Chapter 264, Subchapter O.
Air emissions from onsite incineration will comply with PADER Air
Quality Regulations 25 PA Code Chapters 121-143, specifically
§§ 121.7, 123.1, 123.2 and 127.1.
Air emissions will also comply with 40 C.F.R. § 266.106 (for
metals) and 40 C.F.R. Part 50 (for releases of carbon monoxide,
lead, nitrogen dioxide, particulate matter (PM10) , ozone and
sulfur oxides) . Increased carcinogenic and non-carcinogenic risJc
from emissions during the implementation of the remedy will not
exceed 1 x 10~6, or an HI greater than 1, for a modeled maximally
exposed -individual.
Additional ARARs for this Alternative are discussed in Section X,
"Statutory Determinations."
GATX ALTERNATIVE 7A - COMBINATION ALTERNATIVE WITH LANDFARMING
Major Components of the Remedial Action
This Alternative would combine either onsite incineration or
offsite disposal of the pond area sludge and soil with
landfarming to remediate the lagoon and sludge bed area sludge
and soil. Approximately 4,000 cubic yards of soil/sludge would
either be incinerated onsite or removed for offsite disposal (in
accordance with GATX Alternatives 6, 3A, 3B or 3C) and
approximately 5,000 cubic yards of contaminated soil/sludge would
be biologically treated in a landfarm onsite (in accordance with
GATX Alternative 4A). Biologically treated soil and any ash from
any onsite incineration would be used for backfilling
excavations. Concentrations of organic contaminants in the
lagoon/sludge bed area sludges are an order of magnitude lower
than the concentrations of organic contaminants in the pond area
sludges. This initial lower concentration would result in a
74
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lower residual concentration after biological treatment has been
completed.
Estimated Capital Costs: $8,890,000
Estimated Annual O&M Costs: $419,000
Estimated Present-Vforth Costs: $11,100,000
Estimated Implementation Time: Four Years
Compliance with ARARs
This combination Alternative would have to comply with the ARARs
for GATX Alternatives 3Af 3B, 3C (offsite disposal) or 6 (Onsite
Incineration) and GATX Alternative 4A (Onsite Landfarming). See
the descriptions of these Alternatives for a discussion of the
ARARs.
GATX ALTERNATIVE 7B - COMBINATION ALTERNATIVE WITH SLURRY PHASED
BIOREACTOR
Major Components of the Remedial Action
This Alternative would combine either onsite incineration or
off site disposal of the pond area sludge and soil (in accordance
with GATX Alternatives 6, 3A, 3B or 3C) with slurry phased
bioreactor treatment (in accordance with GATX Alternative 4B) to
remediate the lagoon and sludge bed area sludge and soil. This
Alternative is the same as GATX Alternative 7A except that a
bioreactor rather than landfarming would be utilized for the less
contaminated soil/sludge.
Estimated Capital Costs: $11,900,000
Estimated Annual O&M Costs: $823,000
Estimated Present-Worth Costs: $13,700,000
Estimated Implementation Time: Three Years
Compliance with ARARs
This combination Alternative would have to comply with the ARARs
for GATX Alternatives 3A, 3B, 3C (offsite disposal) or 6 (Onsite
Incineration) and GATX Alternative 4B (Onsite. Slurry Phased
Bioreactor). See the descriptions of these Alternatives for a
discussion of the ARARs.
GATX ALTERNATIVE 8 - COMBINATION ALTERNATIVE WITH SOLVENT
EXTRACTION
Major Components of the Remedial Action
This Alternative would combine either onsite incineration or
off site disposal of the pond area sludge ar.d soil (in accordance
with GATX Alternatives 6, 3A, 3B or 3C) with solvent extraction
treatment (in accordance with GATX Alternative 5) to remediate^
the lagoon and sludge bed area sludge and soil. This Alternative
75
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is the same as GATX Alternative 7A (Combination Alternative with
Landfarming) except that solvent extraction rather than
landfarming would be utilized for the less contaminated
soil/sludge.
Estimated Capital Costs: $11,340,000
Estimated Annual O&M Costs: $1,503,000
Estimated Present-Worth Costs: $14,600,000
Estimated Implementation Time: Two Years
Compliance with ARARs
This combination Alternative would have to comply with the ARARs
for GATX Alternatives 3A, 3B, 3C (offsite disposal) or 6 (Onsite
Incineration) and GATX Alternative 5 (Onsite Solvent Extraction).
See the descriptions of these Alternatives for a discussion of
the ARARs.
B. Remedial Alternatives for Lord Ground Water
LORD ALTERNATIVE 1 - NO ACTION
Major Components of the Remedial Action
The NCP requires that EPA consider a "No Action" Alternative for
every site to establish a baseline for comparison to Alternatives
that do require action. Under this Alternative, no action would
be taken at the Saegertown Industrial Area Site to remove,
remediate, contain, or otherwise address ground water
contamination emanating from the Lord property.
Estimated Capital Costs: $0
Estimated Annual O&M Costs: $0
Estimated Present-Worth Costs: $0
Estimated Implementation Time: N/A
Compliance with ARARs
There are no ARARs for a no action Alternative.
LORD ALTERNATIVE 2 - GROUND WATER CONTAINMENT AND SOURCE CONTROL
Major Components of the Remedial Action
This Alternative would contain ground water by using a hydraulic
barrier to prevent further offsite movement of contaminants. Air
sparging and extraction wells, an interceptor trench designed for
biological treatment, or ground water extraction wells with
above-ground treatment of effluent are three examples of
containment remedies considered in this Alternative. Unsaturated
zone source treatment (vapor extraction) could be implemented in
the vicinity of the RG-l sump as part of this Alternative. For
76
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the purposes of estimating the cost of this Alternative, an
assumption was made that ground water pumping and treatment would
be used. Ground water would be recovered at 40 gallons per minute
and an estimated maximum of 1.5 pounds of contaminants per day
would be removed from the treated ground water. A further
assumption was made that the ground water would be treated
through UV/oxidation, which does not result in VOC air emissions.
Estimated Capital Costs: $950,000
Estimated Annual O&M Costs:' $120,000
Estimated Present-Worth Costs: $2,800,000
Estimated Implementation Time: Thirty Years
Compliance with ARARs
It is uncertain whether this containment Alternative would
achieve the ARARs associated with restoring ground water to
background conditions.
Contamination in the ground water is required to be reduced to
background levels by 25 PA Code §§ 264.90 - 264.100, specifically
25 PA Code §§ 264.90(i) and (j) and 264.100(a)(9). PADER's
February, 1992, policy document, "Ground water Quality Protection
Strategy," would be considered in the implementation of this
remedy. This policy document defines the framework for ground
water remediation programs. In it, PADER states that its goal is
"nondegradation of ground water quality" (p.l), which means that
the ultimate goal of all remediation projects is to restore
levels to background quality. However, PADER recognizes that
"there are technical and economic limitations to immediately
achieving the goal of nondegradation for all ground waters" (pp.
1-2), and that levels above background may not present
unacceptable risk to human health and the environment. If EPA
and PADER determine that it is not technically practicable to
achieve the background concentration for any contaminant
throughout the entire area of the ground water contamination,
both onsite and offsite, then the SDWA MCL for that contaminant
will become the chemical-specific ARAR with which this
Alternative must comply.
Action-specific ARARs would apply to the discharge of treated
ground water. Depending on the method- of effluent discharge from
the ground water treatment system, applicable NPDES or Publicly
Owned Treatment Works ("POTW") pretreatment regulations would
apply. Ground water from the Lord property would be pretreated
for metals, removal, if necessary, in an above-ground remediation
system to comply with NPDES or POTW discharge requirements. Any
surface water discharge would comply with the substantive
requirements of the Clean Water Act NPDES discharge regulations
(40 C.?.R. §§ 122.41 - 122.50 and 40 C.F.R. § 131), the
Pennsylvania NPDES Regulations (25 PA Code SS 91 and 92.31), the
Pennsylvania Water Treatment Regulations (25 PA Code §S 95.1 -
95.3 and 97) and the Pennsylvania Water Quality Standards (25 PA
Code §§ 93.1 - 93.9).
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If ground water is discharged to French Creek, this Alternative
would comply with 25 PA Code Chapter 105, Subchapter G
(requirements relating to outfalls and headwalls). If ground
water is discharged to a POTW, this Alternative would comply with
40 C.F.R. Part 403.
Action-specific ARARs would also apply to the VOC emissions from
any air stripping tower. VOC emissions from an air stripping
tower would be governed by the PADER air pollution regulations.
Air Emissions would also comply with 40 C.F.R. Part 264, Subpart
AA, and 25 PA Code Chapter 264, Subchapter AA (Standards for
Process Vents), and with 40 C.F.R. Part 264, Subpart BB, and 25
PA Code Chapter 264, Subchapter BB (Air Emissions Standards for
Equipment Leaks). Air emissions of Vinyl Chloride would comply
with 40 C.F.R. Part 61, National Emission Standards for Hazardous
A ir.Po1lutants (NESHAPS).
Air permitting and emissions ARARs are outlined in 25 PA Code
Chapters 123, 127, 131, 135 and 139. 25 PA Code § 127.12
requires all new air emission sources to achieve minimum
attainable emissions using the best available control technology
(BAT). In addition, the PADER air permitting guidelines for
remediation projects require all air stripping and vapor
extraction units to include emission control equipment. However,
the permitting regulations allow for exemptions if a source is
considered to be of "minor significance," or if emission controls
are not economically or technically feasible. OSWER Directive
9355.0—28 — Control of Air Emissions from Superfund Air Strippers
at Superfund Ground water Sites would be an action-specific ARAR
for any air stripper used in this remedy.
Fugitive dust emissions generated during remedial activities
would be controlled in order to comply with fugitive dust
regulations in the federally-approved State Implementation Plan
for the Commonwealth of Pennsylvania, 40 C.F.R. Part 52, Subpart
NN, §§ 52.2020 - 52.2023, and 25 PA Code § 123.2, and the
National Ambient Air Quality Standards for particulate matter in
40 C.F.R. § 50.6 and 25 PA Code §S 131.2 and 131.3.
This Alternative would comply with the ground water monitoring
requirements in 25 PA Code Chapter 264, Subchapter F.
The removal of suspended solids in ground water in a settling
tank will result in the generation of small quantities of
residual solids requiring disposal. The exact quantity will vary
with treatment flow rates. These residual solids shall be tested
to determine if they are a RCRA hazardous waste. Similarly, if
carbon absorption is utilized with an air stripping tower or
vapor extraction vent, a RCRA hazardous waste could result. If a
RCRA hazardous waste is determined to be present, this remedy
will comply with the regulations for the generation and
transportation of hazardous wastes, 25 PA Code Chapter 262,
Subchapters A and C, and Chapter 263. It shall also comply with
the RCRA regulations and standards for owners and operators of
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hazardous waste treatment, storage and disposal facilities, 25 PA
Code Chapter 264. In addition, the Department of Transportation
Rules-for Hazardous Materials Transport (49 C.F.R. Parts 107 and
171-179) shall be met.
This Alternative would comply with CERCLA § 121(d)(3) and with
EPA OSWER Directive #9834.11, bo~h of which prohibit the disposal
of Superfund site waste at a facility which is nor: in compliance
with §§ 3004 and 3005 of RCRA and all applicable Jrate
requirements.
LORD ALTERNATIVE 3 - GROUND WATER PUMPING AND TREATMENT
Major Components of the Remedial Action
The ground water pumping and treatment Alternative is designed to
prevent further migration of the contaminant plume and to
aggressively flush contaminants from the saturated zone. Ground
water would be extracted at a rate of approximately 100 gallons
per minute and treated above ground by UV/oxidation or air
stripping and discharged either on or offsite. Unsaturated zone
source treatment would be implemented in the vicinity of the RG-1
sump as part of this Alternative. An estimated maximum of 4
pounds per day of contaminants would be removed from the ground
water. The pounds per day of contaminants removed would reduce
with time but possibly could rebound after pumping stopped.
Chlorinated ethenes in the saturated zone would be significantly
reduced through the flushing action of the ground water pumping.
The effectiveness of this Alternative could be limited by
desorption of the contaminants from the saturated zone soil,
diffusion of the contaminants in the ground water, and
contaminants not disr^iv&d in the ground water which continue to
act as a contamination source.
Air stripping would Ł3 used to treat the ground water. If the
VOC emissions from tha air stripper did not qualify as a minor
source under the federally-approved Commonwealth of Pennsylvania
State Implementation Plan, they would be treated in a carbon
adsorption bed or through a UV/Oxidation system. The treatment
cost estimate is bas.ed on UV/Oxidation which eliminates VOC
emissions.
Estimated Capital Costs: $1,300,000
Estimated Annual O&M Costs: $145,000
Estimated Present-Worth Costs: $3,500,000
Estimated Implementation Time: Thirty Years
Compliance with ARARs
The ARARs discussed under Lord Alternative 2 would also apply to
Lord Alternative 3.
It is not certain that the ground water pumping and treating
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Alternative would achieve the EPA or PADER ground water ARARs.
Desorption and diffusion limitations in the saturated zone, as
well as the potential presence of contaminants in a non-aqueous
phase, have been found to hinder the effectiveness of pump and
treat systems in achieving ARARs.
LORD ALTERNATIVE 4 - IN-SITU AIR SPARGING
Major Components of the Remedial Action
The in-situ air sparging Alternative is designed to volatilize
contaminants present in the saturated zone and collect them for
discharge to the atmosphere or above-ground treatment. Air
sparging involves the injection of air under pressure via a
network of horizontal trenches or vertical wells into the
saturated zone of the aquifer. This Alternative would include
elements of Lord Alternative 2 for containment of further offsite
movement of contaminants. This Alternative could also include
unsaturated zone source treatment by vapor, extraction in the
vicinity of the RG-1 sump.
The air sparging Alternative would establish a grid on 50 foot
centers in an area approximately 400 feet by 400 feet area within
the contaminant plume. Two sparging wells screened at shallow
and deep intervals would be installed at each grid location to
force air into the subsurface. A vapor extraction well, screened
in the unsaturated zone, would be located at 100 foot intervals
to collect the injected air and contaminants. The entire system
would consist of 98 air sparging wells introducing 600 cubic feet
per minute ("CFM") of air and 25 extraction wells collecting 1200
CFM. It is estimated that air sparging would remove
approximately 4.1 pounds per day of chlorinated ethenes from the
ground water and saturated zone. These contaminants, collected
in the vapor phase by the extraction wells, would be captured in
an above-ground carbon adsorption treatment system.
Estimated Capital Costs: $3,110,000
Estimated Annual O&M Costs: $330,000
Estimated Present-Worth Costs: $4,500,000
Estimated Implementation Time: Five Years
Compliance with ARARs
The ARARs discussed under Lord Alternative 2 would also apply to
Lord Alternative 4.
Although it is not certain that the In-Situ Air Sparging
Alternative would be capable of achieving ground water ARARs,
the limited history which exists for this technology suggests
that it is feasible to achieve ground water ARARs in fairly
homogeneous, permeable soils like those in the area of the
Saegertown Site.
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LORD ALTERNATIVE 5 - IN-SITD BIOLOGICAL TREATMENT
Major Components of the Remedial Action
The In-situ Biological Treatment Alternative is designed to
degrade saturated zone contaminants in place. Ground water would
be pumped and chlorinated ethenes would be treated by
uv/oxidation or air stripping. The treated ground water would
then have supplemental oxygen/gases, nutrients and other
additives mixed with it in an above-ground reactor prior to being
reinjected into the aquifer. This Alternative could also
include unsaturated zone source treatment by vapor extraction in
the vicinity of the RG-1 sump. The effectiveness of the In-situ
Biological Treatment Alternative in degrading contaminants
depends on the ability of the injected treated ground water to
intimately contact the chlorinated ethenes in the aquifer.
Estimated Capital Costs: $1,490,000
Estimated Annual O&M Costs: $217,000
Estimated Present-Worth Costs: $2,400,000
Estimated Implementation Time: Five Years
Compliance with ARARs
It is not known if the In-Situ Biological Treatment Alternative
would be capable of achieving ground water ARARs. To date,
in-situ biological degradation of chlorinated ethenes has not '
been demonstrated for full-scale applications.
FADER has expressed concern that the injection of additives into
the aquifer would violate its ARARs for "nondegradation of ground
waters." The injection of additives into the aquifer should not
violate this ground water ARAR, since the remediation goal of
background levels applies to the completion of a remediation
project. Injected nutrients, etc. would be contained within the
ground water extraction/injection systems. At the end of the
remediation process, all of the injected additives would be
consumed and a return to background conditions would occur. The
end result of in-situ biological treatment would thus be in
compliance with the FADER ground water ARARs.
The ARARs discussed under Lord Alternative 2 would also apply to
Lord Alternative 5.
LORD ALTERNATIVE 6 - COMBINATION OF PUMPING AND TREATMENT WITH
AIR SPARGING, STEAM STRIPPING OR BIOLOGICAL TREATMENT
Major Components of the Remedial Action
This Alternative combines the use of in-situ technology for the
more highly contaminated area of the plume with ground water
pumping and treatment of the downgradient portion of the plume.
The pump and treat system would be more cost effective than the
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in-situ technology in remediating the portion of the plume with
the lower concentrations of chlorinated ethenes. Conversely, the
in-situ treatments would be more effective than the pump and
treatment technology in treating the more highly contaminated
portion of the plume beneath the Lord manufacturing building.
The in-situ treatments proposed in this Alternative would be
either air sparging, biological treatment or steam stripping.
Alternatives 4 and 5 discuss air sparging and biological
treatment, respectively. Steam stripping is analogous in design
to air sparging except that steam, rather than air, is injected
into the saturated zone. The steam stripping wells would be
installed in a grid pattern over a portion of the plume
approximately 150 feet by 150 feet which would include the RG-l
sump area and an area beneath the manufacturing building. The
ground water pump and treat system in this Alternative would
extract 85 gallons per minute of ground water from five wells.
This combination Alternative would be more effective at removing
adsorbed and non-aqueous phase contaminants than the pump and
treat Alternative alone. An estimated average of 800 pounds per
year of chlorinated ethenes could be removed from the ground
water if air sparging were used in this combination Alternative,
while the pump and treat system would remove an additional 1100
pounds per year.
Estimated Capital Costs: $1,840,000
Estimated Annual O&M Costs: $250,000
Estimated Present-Worth Costs: $3,400,000
Estimated Implementation Time: Ten Years
Compliance with ARARs
The ARARs discussed under Lord Alternative 2 would also apply to
Lord Alternative 6. '
This Alternative should achieve ground water ARARs and reduce the
risk to below acceptable levels.
Additional ARARs for this Alternative are discussed in Section X,
"Statutory Determinations."
LORD ALTERNATIVE 7 - COMBINATION OF PUMPINO AND TREATMENT WITH
IN-SITU VAPOR EXTRACTION
Major Components of the Remedial Action
This Alternative is similar to Alternative 6 in that ground water
pumping and treatment would be used to treat the area of the
plume with the lower concentration of contaminants. However,
this Alternative would utilize in-situ vapor extraction instead
of air sparging, steam stripping or biological treatment for the
area of the plume with the higher concentration of contaminants.
The pumping and treatment should remediate the plume and also
prevent its further migration.
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In-situ vapor extraction is only capable of removing contaminants
in the unsaturated zone. Therefore, ground water beneath the
manufacturing building and in the vicinity of the RG-1 sump would
have to be pumped in order to lower the water table and create a
deeper unsaturated zone. Six ground water recovery wells pumping
a total of 155 gallons of water per minute would be required for
this Alternative. Two recovery wells, one to the northeast and
one to the west of the manufacturing buildinr. would be used to
dewater the highly contaminates portion of t...; plume. The other
four recovery wells would be operated for thn pumping ind
treatment of the downgradient portion of the Around water plume.
The vapor extraction system would be installs- in a grid fashion
and spaced at intervals in an area 150 feet by 150 feet which
would include the RG-1 sump and the manufacturing building.
within this area four vapor axtraction wells would be located
which would extract a combined total of 200 cubic feet per minute
of vapor. VOCs captured in the vapor extraction system would be
treated by carbon adsorption. Vapor extraction would take an
estimated 4 years to complete. After this time the dewatering
wells would be shut down but the four remaining pump and treat
wells would continue to operate.
The vapor extraction system would remove an estimated average of
1,300 pounds of chlorinated ethanes per year. The pump and treat
system would remove an estimated maximum of 1100 pounds per year.
Estimated Capital Costs: $1,890,000
Estimatc-d Annual O&M Costs: $275,000
Estiimarai Present-Worth Costs: $3,800,000
Estimated Implementation Time: Fourteen Years
Compliance with ARARs
This combination Alternative would have to comply with the ARARs
for Lord Alternative 3 which are discussed under Alternative 2.
This Alternative may achieve ARARs and reduce risk in the future
Site use scenario to below acceptable levels.
SDWA MCLs would be relevant and appropriate chemical-specific
ARARs for ground water. The amount of residual chlorinated
ethenes remaining after treatment would depend on the ability of
the extracted air to intimately contact all of the chlorinated
ethene mass. Therefore, the effectiveness of the dewatering
system, the design of the extraction system, the subsurface
contaminant distribution, and the presence of subsurface geologic
heterogeneities, are all factors that can impact the overall
effectiveness of the vapor extraction treatment.
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VIII. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial action Alternatives described above for each area of
the Site were evaluated under the nine evaluation criteria set
forth in the NCP at 40 C.F.R. § 300.430(e)(9). These nine
criteria are organized according to the following categories
listed in 40 C.F.R. § 300.430(f)(1):
Threshold Criteria
• Overall protection of human health and the environment
• Compliance with applicable or relevant and appropriate
requirements (ARARs)
Primary Balancing Criteria
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Modifying Criteria
• Community acceptance
• State acceptance
Threshold criteria must be satisfied in order for an Alternative
to be eligible for selection. Primary balancing criteria are
used to weigh the strengths and weaknesses of the Alternatives
and to identify the Alternative which provides the best balance
of the criteria. State and community acceptance are modifying
criteria which are taken into account after public comment is
received on the Proposed Plan. Descriptions of the individual
criteria follow:
Overall Protection of Human Health and th« Environment. Overall
protection of human health and the environment addresses whether
each alternative provides adequate protection of human health and
environment and describes how risks posed through each exposure
pathway are eliminated, reduced, or controlled, though treatment,
engineering controls and/or institutional controls.
compliance vitb Applicable or Relevant and Appropriate
Requirements. Compliance with ARARs addresses whether a remedy
will meet all of the applicable or relevant and appropriate
requirements of other federal and state environmental statutes or
whether it provides a basis for invoking a waiver.
Long-Term Effectiveness and Permanence. Long-term effectiveness
and permanence refers to expected residual risk and the ability
of a remedy to maintain its effectiveness over time. It includes
the consideration of residual risk and the adequacy and
reliability of controls.
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Reduction of Toxicity, Mobility/ and Volume. Reduction of
toxicity, mobility, or volume through treatment refers to the
anticipated performance of the treatment technologies a remedy
may employ.
Short-Term Effectiveness. Short-term effectiveness refers to the
period of time needed to complete the amedy and any idverse
impacts on human health and the envirc aent that may :e posed
during the construction and implementation of the remedy until
cleanup levels are achieved.
Implementabilitv. Implementability refers to the technical and
administrative feasibility of a remedy including the
availability of ma.arials and services needed to implement that
remedy.
Cost. Cost includes estimated capital, operation and
maintenance, and net present worth costs.
Community Acceptance. Community acceptance addresses whether or
not the public agrees with the Preferred Remedial Alternative.
This is assessed in the Record of Decision following a review of
the public ccr.r.ents received on the Administrative Record and the
Propc.'.'d Plan
State Acceptance. State acceptance addresses whether the state
concurs with, opposes, or has no comment on the Preferred
Remedial Alternative.
A. Comparative Analysis of Alternatives for SATZ Soil/Sludge
Overall Pretactie® of Human Health and the Environment
Since GATX Alternative 1 (Mo Action) would neither eliminate nor
reduce to acceptable levels the threats to human health or the
environment presented by contamination at the Site, it will not
be discussed in the remainder of this analysis.
GATX Alternative 2 (Capping) would not reduce the mass of
contaminants or their toxicity but would reduce the level of risk
associated with the current Site use by preventing contact and
accidental ingestion of the contaminated sludge and soil by
limiting the air exposure route. Alternative 2 would still pose
an unacceptable risk under the future Site use scenario.
GATX Alternatives 3A, 3B, 3C (offsite disposal) and 6 (Onsite
Incineration) would reduce the level of risk associated with the
current and future Site use scenarios. Alternatives 3B, 3C and 6
are capable of destroying over 99.99% of the organic contaminants
(vocs, PAHs and PCBs) with a corresponding reduction in toxicity.
Incinerator air pollution control devices are expected to be able
to achieve air ARARS. GATX Alternative 3A, Offsite Landfilling,
would not reduce the toxicity or volume of contaminants in the
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soil or sludge, unless combined with some treatment.
GATX Alternatives 4A, 4B, 5, 7A, 7B and 8 (biological treatment
and solvent extraction) are capable of significantly reducing the
level of VOCs and PAHs in the soil and sludge. However, residual
contamination would remain following the implementation of these
Alternatives. The amount of residual contamination would be less
for the combination Alternatives 7A, 7B and 8 since the more
highly contaminated sludge and soil would be removed for offsite
disposal and only the less contaminated sludge and soil would be
treated onsite. It is not known whether the removal efficiencies
of Alternatives 4A, 4B, 5, 7A, 7B and 8 would reduce the
concentration of residual contaminants to a level where they
would pose an acceptable risk in current or future Site use
scenarios.
Compliance with ARARs.
All Alternatives would attain their respective federal and State
ARARs. However, GATX Alternatives 4A, 4B, 5, 7A, 7B and 8 may
require a treatability variance in order to comply with RCRA Land
Disposal Restrictions.
Long-Term Effectiveness and Permanence.
As stated above, GATX Alternatives 3A, 3B, 3C and 6 would either
effectively destroy the organic contaminants or remove them from
the Site. These Alternatives would all permanently reduce the
level of risk associated with the current Site use and any
possible future Site use.
Alternatives 4A, 4B, 5, 7A, 7B and 8 would achieve a significant
reduction in contaminant volume. However, it is unclear whether
the residual remaining after biological treatment would be low
enough to prevent risk in the future Site use scenario.
Alternative 2 would not achieve a permanent reduction in
contaminant mass. Long-term effectiveness would depend on
maintaining the cap's integrity and on institutional controls,
such as deed restrictions.
Reduction of Toxicity, Mobility, or Volume through Treatment.
GATX Alternatives 3B, 3C and 6 would achieve the highest
reduction in contaminant toxicity, mobility and volume. Thermal
treatment of organics (VOCs and PAHs) can destroy over 99.99% of
these contaminants. However, thermal treatment processes do not
destroy metals. In GATX Alternative 6, incinerators equipped
with particulate scrubbers would be capable of removing metals at
the concentrations found in the GATX sludge. The captured metals
and those remaining in the ash following thermal treatment could
be immobilized, by chemical fixation or incorporation in a
matrix, prior to onsite or offsite disposal.
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Alternatives 7A, 7B and 8 would involve thermal treatment of
approximately 4,000 cubic yards of the more heavily contaminated
soil and sludge from the pond area. The thermal treatment
portion of these Alternatives would achieve at least a 99.99%
destruction of the organic contaminants. However, the remaining
approximately 5,000 cubic yards of the soil and sludge would be
treated by a biological treatment or solvent extraction and the
actual percentage of reduction of organic contaminants that can
be achieved by these Alternatives is not clear.
Alternative 5 (and the relevant portion of Alternative 8) would
utilize solvent extraction to leach contaminants from the soil
and sludge, and would then collect the contaminants and treat
them. Because of the high concentration of contaminants in the
sludge at the Site, solvent extraction would only reduce the
material requiring offsite disposal by approximately 50%. Some
residual contaminants would remain in the soil and sludge after
treatment. Since solvent extraction has not yet been
demonstrated on a full scale, removal efficiencies and levels of
residuals are hard to predict. Metals can be removed from the
soil in a second soil washing process after the solvent has
extracted the VOCs and PAHs.
Alternatives 4A and 4B (Biological Treatment) would achieve some:
reduction in toxicity and volume. However, little data is
available to predict the removal efficiency attainable and the
volume of residual contamination that would remain. Some of the
sludge contains as much as 27% organic contaminants. Under these
Alternatives, dilution with clean soil weald ba required in order
to reduce the contaminants to a level that would not be toxic to
bacteria used in the biological treatment. Research has shown
that the larger PAH compounds are more difficult and take longer
to biologically degrade. Some of these same PAH compounds are
considered carcinogenic and would have the most stringent risk-
based cleanup levels. Metals are not subject to biological
degradation processes and would remain in the soil and sludge.
VOCs present in the sludge and soil are likely to volatilize
during the biological treatment processes.
Alternatives 2 and 3A (Capping and Offsite Landfilling,
respectively) do not reduce the toxicity, mobility or volume of
the contaminants, unless some treatment is done to the soil and
sludge prior to offsite landfilling.
short-Tern Effectiveness.
GATX Alternatives 2 through 8 would all reduce the risk
associated with the current Site use scenario. However, nearby
residents and onsite remedial construction workers could be
exposed to airborne particulates and contaminants that might
volatilize from the sludge and soil during excavation and
material-handling activities.
Alternative 6 would take the least time to complete: an estimated
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6 months to one year. Alternatives 2, 3A, 3B, and 3C would take
an estimated one year to complete. Alternatives 5 and 8 and
Alternatives 4B and 7B would take an estimated two years and
three years, respectively, to complete. Alternatives 7A and 4A
would take the longest to complete: an estimated four years and
eight years, respectively.
Implementability.
There are no implementability issues associated with Alternatives
1, 2 (Capping) or 3A (Offsite Landfilling).
Thermal treatment, which is associated with GATX Alternatives 3B,
3C, 6 and portions of Alternatives 7A, 7B and 8, is a proven
technology. Mobile incinerators are available to perform the
onsite thermal treatment as outlined in Alternative 6. There is
no known commercial incinerator in Pennsylvania to which the soil
and sludge can be sent for offsite disposal.
Biological treatment associated with Alternatives 4A and 4B and
portions of Alternatives 7A and 7B has been specified in numerous
CERCLA RODs with similar waste. The sludge and soil volumes may
be too small to justify the mobilization and capital expense of
the slurry phased biological treatment system called for in
Alternatives 4B and 7B. A very large area would be required in
order to construct the landfarm treatment cell called for in
Alternatives 4A and 7A. This is due to the need to dilute the
sludge and soil with clean soil, which would increase the volume
of waste to be treated.
Solvent extraction associated with Alternative 5 and a portion of
Alternative 8 has yet to be demonstrated in a full scale soil
cleanup. Contaminants have varying solubility in solvents and
the most appropriate solvent or solvents to use would have to be
determined in treatability studies prior to implementing this
remedy. Solvent residuals can remain in the soil after treatment
and may require further treatment of the soil prior to its being
redeposited onsite. Wastewater is produced in the solvent
extraction process and would have to be treated and discharged.
The cost estimate for solvent extraction assumes that the
wastewater would be disposed of at the Saegertown POTW. The
capital costs for this Alternative would increase significantly
if a discharge permit to the Saegertown POTW were denied.
costs.
Capital costs include the primary equipment needs for an
Alternative. Operation and Maintenance (O&M) costs include the
costs for utilities and general maintenance of the equipment.
Net present worth is the total cost of the equipment and its
operation and maintenance cost for a 10-year period. Of the
Alternatives containing remedial action, GATX Alternative 2
(Containment Onsite) would have the lowest capital and net
present worth cost. Alternative 3B (Offsite Incineration) would
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have the highest capital and net present worth cost. GATX
Alternative 6, the selected remedy for the former GATX property,
has the third highest capital cost and is the seventh highest
Alternative in net present worth costs.
Community Acceptance.
The October 20, 1992 Proposed Plan and the November 5, 1992
public meeting produced a number of comments from the general
public and from potentially responsible parties (PRPs) for the
Site. Responses to these comments appear in the Responsiveness
Summary section of this ROD. There were no objections to EPA's
proposed selection of GATX Alternative 6 as the remedy for this
portion of the Saegertown Industrial Area Site.
State Acceptance.
The Commonwealth of Pennsylvania concurs with the selection of
GATX Alternative 6 as the remedy for this portion of the Site.
B. Comparative Analysis of Alternatives for Lord Ground Water
Overall Protection.
Lord Alternative 1 (No Action) would neither eliminate nor reduce
to acceptable levels the threats to human health or the
environment presented by contamination at the Site. Therefore,
it will not be discussed further in this analysis.
y
Lord Alternative 2 (Containment) would not reduce contaminant
volume enough to lower future risk to acceptable levels.
Therefore, it will not be discussed further in this analysis.
All of the remaining Lord Alternatives (Alternatives 3 through 7)
have the potential to reduce the amount of contaminant mass in
the ground water aquifer, with varying dagreea of efficiency.
All could be expected to produce a protective remedy.
Compliance with ARARs.
Lord Alternatives 3 through 7 can all meet the requirements of
ARARs.
Long Term Effectiveness and Permanence.
Lord Alternatives 3 through 7 would likely reduce risk to
acceptable levels under the future Site use scenario. Lord
Alternative 3 (Pumping and Treatment), although not as effective
as the in-situ treatment Alternatives 4,5,6 and 7, is a proven
technology.
Alternative 6 combines a proven technology in pumping and
treatment with source removal of contaminants by air sparging,
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steam stripping or biological degradation for the area of the
plume with the highest contaminants.
Alternative 4 (Air Sparging) has not been specified in any CERCLA
RODs to date but has been demonstrated to be effective at a small
number of sites involving chlorinated VOCs and gasoline
contaminants.
Alternative 5 (In-situ Biological Treatment of chlorinated
ethenes) has yet to be demonstrated for a full scale remediation
project. If incomplete degradation were to occur, breakdown
products could be formed that are more toxic than the parent
compounds.
Alternative 7 combines pumping and treatment with source removal
by vapor extraction. Vapor extraction is designed to remove
contaminants from the unsaturated zone and would not be as
effective at removing contaminants from the saturated zone.
Reduction of Toxicity, Mobility, or Volume through Treatment.
Lord Alternatives 3 through 7 would significantly reduce the
chlorinated ethene mass in the saturated zone and ground water at
the Site.
Alternatives 4 (Air Sparging) and 6 (Combination Pumping and
Treatment with Air Sparging, Steam Stripping or Biological
Treatment) should be more effective at removing contaminants in
any adsorbed or non-aqueous phase.
If a successful biological, treatment scheme could be developed
and implemented, Alternative 5 (In-situ Biological Treatment)
would reduce the toxicity and mass of contaminants.
Alternative 7 (Combination Pumping and Treatment with In-situ
Vapor Extraction), while the most proven in-situ treatment, has
implementation problems associated with the need to lower the
water table in the contaminated area. Contaminants would remain
on soil particles after the water table was lowered. However,
once the water table was lowered, the soil would no longer be
subject to the ground water flushing action of the pumping and
treatment portion of- this Alternative. In addition, vapor
extraction normally is used to treat the most highly contaminated
source area. It is not practical to install a vapor extraction
system to treat the entire area where the water table would be
lowered.
Short-Tern Effectiveness.
The risk associated with the current Site use scenario was not
calculated during the FS since there is no current use of the
contaminated ground water. No drinking water wells in the area
appear to be affected by the ground water contamination on the
Lord property. Remedial construction workers would be exposed to
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contaminated soil during any well and pipe installation
activities associated with Lord Alternatives 3 through 7.
Alternative 3 would take approximately 30 years to complete the
remediation. Alternatives 4 and 5 would taJce approximately 5
years, and Alternatives 6 and 7 would take 10 and 14 years,
respectively, to complete remediation.
Imp1ementabi1ity.
Lord Alternatives 3 and 7 zre proven technologies that have been
specified in numerous CERCLA RODs. However, there are several
implementability issues associated with the use of Alternative 7
(Combination with In-situ Vapor Extraction) at the Saegertown
Site. The information collected during the RI indicates that the
mass of the contaminants in the Lord area ground water
contamination is present in the saturated zone, and vapor
extraction is not capable of removing contaminants from the
saturated zone. The water table in the vicinity of the RG-1 sump
would have to be lowered in order to implement vapor extraction.
The contaminants adsorbed onto the soil in the dewatered area
outside the vapor extraction area would not be subject to the
ground water flushing action of the pumping and treatment portion
of this Alternative.
Air sparging, as discussed in Alternatives 4 and 6, is a fairly
recent technology, but it has been shown to be effective at
removing chlorinated VOCs at a small number of sites. If
improperly designed, air sparging could cause migration of
contaminants.
The biological degradation technology used to remediate ground
water under Lord Alternative 5 (and the relevant portion of
Alternative 6) has not yet been fully developed to effectively
degrade TCE and PCE, the primary Site contaminants. Further
research would be needed before this remedy could be implemented
in a full scale project. Incomplete degradation of chlorinated
ethenes could result in the production of vinyl chloride and
other degradation products that are as toxic or more toxic than
the parent compounds, currently present in the aquifer.
Both the air sparging and steam stripping portions of Lord
Alternative 6 would be effective in removing the chlorinated
ethenes present in the saturated zone. Both technologies utilize
the same principle for operation: introducing a gas to volatilize
dissolved contaminants from the aquifer by direct contact or by
creating turbulence. The effectiveness of both technologies is
dependent on the installation of injection and extraction wells
in direct contact with the contaminants. Air sparging and steam
stripping both utilize a vapor extraction system to remove the
injected air or steam containing the contaminants from the
unsaturated zone.
Steam stripping, if used in Lord Alternative 6, would require the
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construction and operation of a steam source. There are many
maintenance and operational problems associated with the
production and delivery of steam over long distances.
The presumed source area, the RG-1 sump, is in close proximity to
the manufacturing areas on the Lord property. The Alternatives
involving source remediation (Alternatives 4, 5, 6 and 7) all
involve placement of wells and piping in and around these
production areas. However, Lord, has already successfully
collected soil, gas samples from borings inside its main building
onsite.
Costs.
Lord Alternative 5, In-situ Biological Treatment, has the lowest
estimated present-worth cost. Lord Alternative 6 (Combination
of Pumping and Treatment with Air Sparging, Steam Stripping or
Biological Treatment), the preferred Alternative, has the third
highest capital cost for an action Alternative, and is the fourth
highest in net present-worth cost.
Community Acceptance.
The October 20, 1992 Proposed Plan and the November 5, 1992
public meeting produced a number of comments from the general
public and from PRPs for the Site. Responses to these comment
appear in the Responsiveness Summary section of this ROD. There
were no objections to EPA's proposed selection of Lord
Alternative 6 as the remedy for this portion of the Saegertown
Site. '
state Acceptance.
The Commonwealth of Pennsylvania concurs with, the selection of
Lord Alternative 6 as the remedy for this portion of the
Saegertown Site.
IX. THE SELECTED REMEDIES AND PERFORMANCE STANDARDS
A» Selectad Remedy for the Contaminated Soil
on the Former GATX Property
Following review and consideration of the information in the
Administrative Record file, the requirements of CERCLA and the
NCP, and public comment, EPA has selected GATX Alternative 6,
(Excavation and Onsite Incineration), for the treatment of the
contaminated sludge and soil on the former GATX property. GATX
Alternative 6 meets the threshold criteria of overall protection
of human health and the environment and compliance with ARARs,
and provides the best balance of long term effectiveness and
permanence, reduction of toxicity, mobility or volume of
contaminants through treatment, short term effectiveness,
implementability and cost.
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The selected remedy for the former GATX property consists of the
following components:
• excavation of contaminated sludge and soil;
• onsite incineration with air pollution controls;
• restoration or replacement of the pond and wetland; and
• long-term ground water monitoring.
l. Excavation of GATX Contaminated Sludge and Soil
The sludge on the former GATX property shall be excavated.
Sludge may be defined visually as being a black, viscous, tar-
like material. (The results of sludge sampling from the RI
suggest that there is a direct correlation between the visual
(qualitative) definition of sludge and the quantitative
definition of elevated levels of VOCs and PAHs.) All sludge and
soil, both contiguous and noncontiguous with the sludge, that
contains total carcinogenic PAH concentrations in excess of 1.0
ppm in benzo(a)pyrene ("B(a)P") equivalents, as explained below,
shall also be excavated. (Table 10 (p. 94) lists the
carcinogenic PAHs whose total shall not exceed 1 ppm in B(a)P
equivalents ("l ppm B(a)P") in the soil following excavation).
The GATX sludge contains a mixture of VOCs, SVOCs (including
PAHs) and metals, while the GATX contaminated soil contains
primarily SVOCs. The RI indic;-es that the VOCs are bound in the
sludge and not subject to leaching. EPA has established a
cleanup level based on the concentration of PAHs, since they are
present in both the sludge and the soil. The VOCs, SVOCs and
metals in the sludge are commingled with the PAHs and will be
removed along with them in the cleanup of the PAHs.
EPA has established relative potency factors ("RPFs") for PAH
compounds in Comparative Potency Approach for Estimating the
Cancer Risk Associated with Exposure to Mixtures of Polycvclic
Aromatic Hydrocarbons (1988). The compound B(a)P is assigned a
RPF of one (1.000)., 'The carcinogenic potency of all other PAH
compounds are compared to B(a)P and assigned an RPF which
represents the carcinogenicity of those compounds in proportion
to the carcinogenicity of B(a)P. Table 10 below lists the PAH
compounds which are present in the soil and shows their RPF or
B(a)P equivalents.
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Table 10
CARCINOGENIC PAH
benzo(a) pyrene
benzo (a) anthracene
benzo(b) f luoranthene
benzo (k) f luoranthene
chrysene
dibenzo ( a , h) anthracene
indeno (1,2, 3-cd) pyrene
RELATIVE POTENCY FACTOR
(B(a)P EQUIVALENT)
1.000
0.145
0.140
0.066
0.004
1.110
0.232
The total carcinogenicity of all of the PAH compounds in the
sludge or soil is calculated in two steps. First, the
concentration of each PAH compound listed in Table 10 which is
identified in soil and sludge is multiplied by its RPF to derive
its B(a)P equivalent concentration. The individual
concentrations, in B(a)P equivalents, of all PAH compounds are
then added together to obtain the total concentration of PAH
compounds in B(a)P equivalents.
2. Performance Standard for GATZ Sludge and Soil
EPA has developed a Performance Standard ("cleanup level") for
the contaminated sludge and soil based on a concentration of
carcinogenic PAHs that, if left in the soil, would not affect
ground water and would not present an unacceptable risk to human
health or the environment through ingestion. The Performance
Standard is expressed in terms of a carcinogenic risk-based
concentration. The total concentration of carcinogenic PAH
compounds in the soil following excavation shall not exceed 1.0
ppm in B(a)P equivalents (the Performance Standard).
The excavation of contaminated sludge and soil shall continue
until such time as the Performance Standard for PAH contaminants
in onsite soil has been achieved, as determined by EPA.
3. GATX Onsite Incineration with Air Pollution Controls
An incinerator and support structures shall be mobilized onsite.
The incinerator shall be equipped with air pollution controls
capable of reducing metal emissions in order to achieve the NCP
and RCRA-required risk criteria. The air pollution controls
proposed to be used in the onsite incinerator shall be subject to
EPA approval prior to the implementation of the remedy.
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Excavated sludge and soil shall be processed to provide a uniform
feedstock for the incinerator. Processing may include, but shall
not be limited to, drying, mixing and shredding, as approved by
EPA. Sampling for PCBs in the waste to be incinerated shall be
conducted according to the US EPA document entitled Verification
of PCS Spill Cleanup By Sampling and Analysis. August 1985.
If debris is :.~countere.-. in the excavated material, it shall
either be decc.-.taminated and/or treated to render it non-
hazardous for offsite disposal, or processed through the onsite
incinerator. Debris shall be determined to be non-hazardous if
it passes the TCLP test ani is not a RCRA characteristic waste.
The onsite incinerator ash shall be tested to determine the
concentration of ratals in the ash. If the ash does not pass the
TCLP test and is datenair.od to be-hazardous, it shall either be
treated prior to placement in the excavated area onsite or
removed for offsite disposal. Ash remaining onsite shall comply
with the PADER residual waste regulations.
Following treatme.it of the sludge and soil on the former GATX
property, the onsite incinerator shall be demobilized and removed
from the Site.
4. Performance Standards for the GATX Onsite Incinerator
The onsite incinerator shall be operated to achieve a Destruction
and Removal Efficiency ("ORE") of 99.99% for all organic
chemicals in the waste, with the exception of polychlorinated
biphenyls ("PCBs"). The onsite incinerator shall achieve a ORE
of 99.9999% for any waste containing PCBs. The total
concentration of carcinogenic PAH compounds in the resulting
incinerator ash shall not e^caed 1.0 ppm in B(a)P equivalents.
All incinerator emissions shall comply with the regulations in 40
C.F.SU Part 50 for releases «f carbon monoxide, lead, nitrogen
dioxide, particulate matter i.?M10), ozone and sulfur oxides.
Noncarcinogenic emission rates shall not exceed the Reference Air
Concentrations set forth in 40 C.F.R. Part 266, Appendix IV.
Increased carcinogenic and non-carcinogenic risk presented by the
incinerator emissions shall not exceed 1 x 10~6, or an HI greater
than 1, for a modeled maximally exposed individual.
5. Restoration or Replacement of the GATX Pond and Wetland
Once excavation is complete, the excavated areas shall be
regraded to pre-existing contours. The pond and wetland area
onsite shall be restored, or an equal area shall be created, to
replace any habitat destroyed in the implementation of the
remedy. The restoration or replacement of the pond and wetland
habitat shall be subject to EPA approval.
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6. Long-Term Monitoring of the GATX Ground Water
The ground water beneath the former GATX property shall be
monitored for contaminants found in the sludge throughout the
implementation of the remedy and for at least five years
following the completion of remedial construction.
EPA shall determine the number of monitoring wells necessary to
verify the performance of the remedial action. The installation
of additional monitoring wells may be required. The wells shall
be sampled quarterly during the implementation of the remedy and
for the first two years following the completion of the
sludge/soil removal. Thereafter, the wells shall be sampled
semi-annually until background concentrations of contaminants
have been achieved. Once background levels have been reached,
the wells shall be sampled for twelve consecutive quarters. If
contaminants remain at the background level for twelve
consecutive quarters, monitoring can be discontinued.
If EPA determines at any time that action to address ground water
contamination beneath the former GATX property is necessary to
protect public health or the environment, such action may be
addressed in an amendment to this ROD or an Explanation of
Significant Differences.
7. Five Year Review
Five Year Reviews will be conducted after the remedy is
implemented to ensure that the remedy continues to protect human
health and the environment.
B. Selected Remedy for the Groundwater
in the Vicinity of the Lord Property
Following review and consideration of the information in the
Administrative Record file, the requirements of CERCLA and the
NCP, and public comment, EPA has selected Lord Alternative 6
(Combination Pumping and Treatment with Air Sparging) for the
treatment of the ground water contamination in the vicinity of
the Lord property. Lord Alternative 6 meets the threshold
criteria of overall protection of human health and the
environment and compliance with ARARs, and provides the best
balance of long term effectiveness and permanence, reduction of
toxicity, mobility and volume of contaminants through treatment,
short term effectiveness, implementability and cost.
The selected remedy consist of the following components:
• Delineation of the ground water plume;
• ground water extraction and treatment through air stripping or
UV/oxidation;
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• air sparging injection wells;
• vapor extraction and treatment through carbon adsorption; and
• long-term ground water monitoring.
l. Delineation of the Ground Water Plume
in the Vicinity of the Lord Corporation
Prior to installation of the extraction wells, additional
monitoring wells shall be installed on the Lord property and to
the west of the Lord property in order to determine the extent of
the contaminant plume. Monitoring wells shall also be installed
to delineate the vertical extent of the ground water plume. The
number and location of these wells shall be approved by EPA.
The contaminant plume shall be defined as the presence of any of
the hazardous substances listed in Table 11 (p. 98) in the
groundwater at concentrations above background concentrations.
2. Ground Water Extraction and Treatment
Ground water si-all be extracted using multiple extraction wells,
the exact loca.ion and number of which will be determined by EFA
during the design of the ground water recovery system. The
system shall be designed to capture and treat the contaminant
plume, as defined above.
Recovered ground water shall be treated using an onsite treatment
system. Suspended solids shall be removed using a settl .ng ti/.-jc
or clarifier followed by an on-line filtration unit. The ground
water shall then be treated using a packed column airstripping
unit or a UV/oxidation system. Final flow rates and air stripper
or UV/oxidation system specifications shall be determined by EPA,
in consultation with PADER, during the remedial design.
The treated effluent shall be discharged to French Creek via a
storm water outfall pipe that drains the Site surface water. As
an alternative, the effluent may be utilized by Lord Corporation
for its non-contact cooling water needs. Lord's current NPDES
permit for non-contact cooling water discharge would have to be
amended, with PADER approval, if ground water effluent were to be
added to this flow.
If an air stripping unit is utilized, contaminants in the
effluent air shall be captured by a carbon adsorption unit, the
dimensions of which shall be determined by EPA, in consultation
with PADER, during the remedial design. The air stripping tower
shall reduce emissions to the minimum attainable level through
the use of the Best Available Technology ("BAT"), in accordance
with 25 PA Code § 127.12(a)(5).
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3. Performance standard for Ground Water
in the Vicinity of the Lord Property
Groundwater extraction, treatment and discharge shall be required
until such time as EPA determines, in consultation with PAOER,
that the Performance Standard for each contaminant of concern has
been achieved to the extent technically practicable throughout
the entire area of groundwater contamination, both onsite and
offsite.
The Performance Standard for each contaminant of concern in the
ground water (see Table 11) shall be the lower of either the
background concentration or the SDWA MCL for that contaminant.
The background concentration for each contaminant of concern
shall be established in accordance with the procedures for ground
water monitoring set forth in 25 PA Code § 264.97 before ground
water treatment begins. In the event that a contaminant of
concern is not detected in samples taken for the establishment of
background concentrations, the detection limit for the method of
analysis utilized with respect to that contaminant shall
constitute the "background" concentration of the contaminant.
The MCLs for all of the contaminants of concern are set forth at
40 C.F.R. § 141.61. The MCLs, the detection limits and the
appropriate analytical- methods for testing for the contaminants
of concern are listed in table 11 below:
Table 11
Contaminants of Concern in around Water
in the Vicinity of the Lord Property
Contaminant
vinyl chloride
1, l-dichloroethene
l, 2-dichloroethene
(cis)
l, 2-dichloroethene -
(trans)
1 , 2-dichloroethane
t r i ch loroethene
1,1, i-trichloroethane
tetrachloroethene
xylene
MCL (ug/1)
2
7
70
100
5
5
200
5
10,000
Detection
Limit (ug/1)
.18
.13
.12
.06
.03
.12
.13
.03
.05-. 13
Method
601
601
524.2
524.2
601
601
601
601
524.2
Method 601 is found in 40 C.F.R. Part 136
Method 524.2 is found in 40 clF.R. Part 141
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4. Air Sparging and vapor Extraction veils
Air sparging injection wells shall be installed in the source
area of the ground water contamination on the Lord Corporation
property. The exact location and number of injection wells will
be determined by EP:-. luring the design of the air sparging
system. A sufficie- quantity of air shall be injected into the
ground water aquifer :eneath the Lord Corporation property to
strip contaminants present in the aquifer.
Vapor extraction wells shall be installed in the unsaturated zone
in the vicinity of the source area. The exact location and
number of vapor extraction wells will be determined by EPA during
the design of the air sparging system. A sufficient quantity of
soil gas shall be extracted from the unsaturated zone to capture
contaminants stripped from the ground water by the air injected
in the sparging wells. The vapor phase contaminants recovered by
the extraction wells will be captured by a carbon adsorption
unit, the dimensions of which will be determined by EPA, in
consultation with PADER, during the remedial design. . The carbon
adsorption unit must reduce emissions to the minimum attainable
level through the use of the Best Available Technology ("BAT"),
in accordance with 25 PA Code § 127.12(a)(5).
5. Long-Term Monitoring of the Ground Water
in the vicinity of the Lord Property
The ground water in the vicinity of the Lord property shall be
monitored for the hazardous substances listed in Table 11 (p. 98)
throughout the implementation of the remedy and for at least five
years following- the completion of remedial construction.
EPA will determine the number of monitoring wells necessary to
verify the performance of the remedial action. The installation
of additional monitoring wells may be required. The wells shall
be sampled quarterly during the implementation of the remedy and
for the first two years following the completion of the
construction. Thereafter, the wells shall be sampled semi-
annually until background concentrations of contaminants have
been achieved. Once background levels have been reached, the
wells shall be sampled for twelve consecutive quarters. If
contaminants remain "at background levels for twelve consecutive
quarters, monitoring can be discontinued.
During the ground water monitoring period, if the concentrations
in the ground water of any of the contaminants listed in Table 11
exceeds their background concentrations, the pump and treat
system shall be restarted and operated until the background
concentration has once more been attained for twelve consecutive
quarters.
6. Five Year Review
Five Year Reviews will be conducted after the remedy is
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implemented to ensure that the remedy continues to protect human
health and the environment.
7. Lord Corporation Ground Water Remedy Implementation
An operation and maintenance plan for the ground water extraction
and treatment system shall be required. The performance of the
ground water extraction and treatment system shall be carefully
monitored on a regular basis and the system may be modified, as
warranted by the performance data collected during the operation.
These modifications may include, for example, alternate pumping
of the extraction wells or the addition or elimination of certain
extraction well(s).
It may become apparent during the implementation or operation of
the ground water extraction system and its modifications, that
contaminant levels have ceased to decline and are remaining
constant at levels higher than the Performance Standards over
some portion of the contaminated plume. If EPA determines, in
consultation with PADER, that implementation of the selected
remedy demonstrates that it will be technically impractical to .
achieve and maintain the Performance Standards throughout the
entire area of the ground water contamination, EPA may require
that any and all. of the following measures be taken, for an
indefinite period of time, as further modification(s) of the
existing system:
1) long-term gradient control may be provided by low level
pumping, as a containment measure;
2) chemical-specific ARARs may be waived for those portions of
the aquifer for which EPA determines, in consultation with PADER,
that it is technically impracticable to achieve further
contaminant reduction;
3) institutional controls may be provided/maintained to restrict
access to those portions of the aquifer where contaminants remain
above Performance Standards; and
4) remedial technologies for ground water restoration may be re-
evaluated.
The decision to invoice any or all of these measures may be made
during the 5-year reviews of the remedial action. If such a
decision is made, EPA may amend the ROD or issue an Explanation
of Significant Differences.
C. Selected Alternative for the SMC Property
EPA has selected the No Action Alternative for the SMC property
since it will be protective of human health and the environment.
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D. Selected Alternative for the SCI Property
EPA has selected the No Action Alternative for the SCI property
since it will be protective of human health and the environment.
X. STATUTORY DETERMINATIONS
Section 121 of CERCLA requires that a selected remedy:
. be protective of human health and the environment;
. comply with ARARs;
. be cost-effective;
. utilize permanent solutions and Alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable; and
. address whether the preference for treatment as a
principal element is satisfied.
A description of how the selected remedies satisfy each of the
above statutory requirements is provided below.
A. Protection ol
The selected remedies for the Site will be protective of human
health and the environment by reducing the principal threat posed
at the Site, on the former GATX property: sludge and soil
contamination, and by addressing the ground water contamination
in the vicinity of the Lord Corporation property. Potential
health threats posed by the Site through exposure pathways (i.e.
direct contact, ingestior« of sludge, contaminated soils,
sediments and contaminated ground water, and inhalation of
ambient air) will be eliminated by the remedies selected in this
ROD.
Soil and sludge on the former GATX property that poses a
principal threat (i.e., that exceeds 1 ppm B(a)P equivalent) will
be excavated and treated onsite in an incinerator. Contaminants
in the ground water in the vicinity of the Lord property will be
remediated to background levels.
B. Compliance vith ARARs
All applicable or relevant and appropriate requirements (ARARs)
pertaining to the selected remedies for the former GATX property
and the ground water contamination in the vicinity of the Lord
property will be attained. The ARARs are presented below.
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GATX Excavation and Onsite incineration.
The remedy for the former GATX property will comply with the
applicable portions of the PADER Ground Water Quality Protection
Strategy, which prohibits continued ground water quality
degradation, since all contaminated sludge and soil which could
potentially impact the ground water will be excavated for
treatment onsite.
Offsite and onsite treatment, storage and disposal will comply
with RCRA regulations and standards for owners and operators of
hazardous waste treatment, storage and disposal facilities. If
it occurs in the Commonwealth of Pennsylvania, it will comply
with 25 PA Code Chapter 264. If it occurs outside of the
Commonwealth of Pennsylvania, it will comply with 40 C.F.R. Part
264 or other federally-authorized State regulations.
RCRA regulations for the generation and transportation of
hazardous wastes (25 PA Code Chapter 262, Subchapters A and C,
and Chapter 263) and the Department of Transportation Rules for
Hazardous Materials Transport (49 C.F.R. Parts 107 and 171-179)
will be met.
Determinations about the effectiveness of any soil remediation at
the Site will be based on EPA document no. 230/02-89-042, Methods
for Evaluating Cleanup Standards. Vol. I; Soils and Solid Media.
Any generation, treatment, storage and offsite disposal of PCB-
impacted soil and debris; will comply with 40 C.F.R. Part 761 and
specifically, Subparts D and G. Determinations about the
effectiveness of soil remediation of PCB waste at the Site will
be based on EPA Document No. 560/05-85-026, Verification of PCB
Spill Cleanup by Sampling and Analysis.
The location of the onsite incinerator will comply with siting
requirements in 25 PA Code Chapter 269.
The operation of the onsite incinerator will comply with 25 PA
Code Chapter 264, Subchapter O.
Air emissions from onsite incineration will comply with PADER Air
Quality Regulations, 25 PA Code Chapters 121-143, specifically
§§ 121.7r, 123.1, 123'.2 and 127.1.
Air emissions^ will also comply with 40 C.F.R. § 266.106 (for
metals) and 40 C.F.R. Part 50 (for releases of carbon monoxide,
lead, nitrogen dioxide, particulate matter (PM10), ozone and
sulfur oxides). Increased carcinogenic and non-carcinogenic risk
from emissions during the implementation of the remedy will not
exceed l x 10"6, or an HI greater than 1, for a modeled maximally
exposed individual.
If a wet scrubber is used in the air pollution controls for the
onsite incinerator, or the pond requires draining prior to
102.
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excavation, any effluent discharged to surface water will comply
with the substantive requirements of the Clean Water Act NPDES
discharge regulations (40 C.F.R. §§ 122.41 - 122.50 and 40 C.F.R.
Part 131), the Pennsylvania NPDES Regulations (25 PA Code §§ 91
and 92.31), the Pennsylvania Water Treatment Regulations (25 PA
Code §§ 95.1 - 95.3 and 97) the Pennsylvania Water Quality
Standards (25 PA Code §§ 93.1 - 93. ,, and l~ ?A Code § 105
(requirements relating to outfalls _nd headw .s).
A variance from the RCRA LDRs may have to be obtained to allow
the thermally treated soil to be redeposited onsite. However, it
is expected that applicable LDRs can be met, since incineration
is the best demonstrated available technology (BOAT) for most of
the organic compounds.
Excavation for onsite treatment will impact the pond and wetland
area. This Alternative will cosply with the provisions for
protection of wetlands and flood plain management in 40 C.F.R.
Parts 6 and 230 and 25 PA Code §S 105.17-105.20(a). It will also
comply with erosion control requirements related to excavation
activities in 25 PA Code Chapter 102.
Incinerator ash redeposited onsite will comply with the residual
waste regulations as set forth in 25 PA Code Chapters 287-289.
In the event that the remedy does not comply with Pennsylvania
regulations for the closure of hazardous waste sites (25 PA Code
Chapter 264, Subchapter G), the closure regulations will be
waived if an Equivalent Standard of Performance is achieved by
the removal of the contaminated soils.
Fugitive dust emissions generated during remedial activities will
be controlled in order to comply with fugitive dust regulations
in the federally-approved State Implementation Plan for the
Commonwealth of Pennsylvania, 25 PA Code §§ 123.1 - 123.2, and
will not violate the National Ambient Air Quality Standards for
particulate matter, 40 C.F.R. §5 50.6 and 25 PA Code §§ 131.2 and
131.3.
This remedy will comply with the ground water monitoring
requirements in 25 PA Code Chapter 264, Subchapter F.
This remedy will comply with CERCLA S 121(d)(3) and with EPA
OSWER Directive #9834.11, both of which prohibit the disposal of
Superfund site waste at a facility which is not in compliance
with §§3004 and 3005 of RCRA and all applicable State
requirements.
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Lord Ground water Pumping and Treatment in Combination with
Air sparging.
Contamination in the ground water in the vicinity of the Lord
property is required to be reduced to background levels by 25 PA
Code §§ 264.90 - 264.100, specifically 25 PA Code §§ 264.90(i)
and (j) and 264.100(a)(9). PADER's February, 1992, policy
document, "Ground water Quality Protection Strategy," will be
followed in the implementation of this remedy. This policy
document: defines the framework for ground water remediation
programs. In the document, PAOER states that its goal is
"nondegradation of ground water quality" (p. l), which means that
the ultimate goal of all remediation projects is to restore
levels to background quality. However, PADER recognizes that
"there are technical and economic limitations to immediately
achieving the goal of nondegradation for all ground waters" (pp.
1-2), and that levels above background may not present
unacceptable risk to human health and the environment. The
background concentration for each contaminant of concern shall be
established in accordance with the procedures for ground water
monitoring in 25 PA Code § 264.97, which shall be an ARAR for
this remedy. The SOWA MCLs listed in Table 11 are also ARARs
with which this remedy will comply.
Action-specific ARARs for the discharge of treated ground water
will be met. Depending on the method of effluent discharge from
the ground water treatment system, applicable NPDES or POTW
pretreatment regulations will apply. Ground water from the Lord
property will be pretreated for metals removal, if necessary, in
an above-ground remediation system, in order to comply with NPDES
or POTW discharge requirements. If the effluent is discharged to
French Creek, this remedy will comply with the substantive
requirements of the Clean Water Act NPDES discharge regulations
(40 C.F.R. §§122.41 - 122.50 and 40 C.F.R. Part 131), the
Pennsylvania NPDES Regulations (25 PA Code §§ 91 and 92.31), the
Pennsylvania Water Treatment Regulations (25 PA Code §§ 95.1 -
95.3 and 97), the Pennsylvania Water Quality Standards (25 PA
Code §§ 93.1 - 93.9), and 25 PA Code Chapter 105 (requirements
relating to outfalls and headvalls). If the effluent is
discharged to a Publicly Owned Treatment Works (POTW), this
remedy will comply with 40 C.F.R. Part 403.
voc emissions from any air stripping tower will be governed by
the PADER air pollution regulations. Air Emissions will also
comply with 40 C.F.R. Part 264, Subpart AA, and 25 PA Code
Chapter 264, Subchapter AA (Standards for Process Vents), and
with 40 C.F.R. Part 264, Subpart BB, and 25 PA Code Chapter 264,
Subchapter BB (Air Emissions Standards for Equipment Leaks). Air
emissions of Vinyl Chloride will comply with 40 C.F.R. Part 61,
Subpart F, National Emission Standards for Hazardous Air
Pollutants (NESHAPS).
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Air permitting and emissions ARARs are outlined in 25 PA Code
Chapters 123, 127, 131, 135, and 139. 25 PA Code § 127.12
requires all new air emission sources to achieve minimum
attainable emissions using the best available technology ("BAT").
In addition, the PADER air permitting guidelines for remediation
projects require all air stripping and vapor extraction units to
include emission control equipment. However, the permitting
regulations allow for exemptions if a source is Considered to be
of "minor significance," or if emission controls are not
economically or technically feasible. During design of the air
stripping unit, PADER shall determine from actual design flow
rates and VOC loading rates whether emission controls need to be
installed.
If required, a vapor phase carbon adsorption or thermal
destruction unit shall be installed to ensure compliance with
§ 112 of the Clean Air Act, 42 U.S.C. § 7412, National Emission
Standards for Hazardous Air Pollutants (NESHAPs). The relevant
and appropriate NESHAP for vinyl chloride is set forth at 40
•C.F.R. Part 61, Subpart F. OSWER Directive 9355.0-28 - Control
of Air Emissions from Suoerfund Air Strippers at Superfund Ground
water Sites will be an action-specific ARAR for any air stripper
used in this remedy.
The removal of suspended solids in ground water in a settling
tank will result in the generation of small quantities of
residual solids requiring disposal. The exact quantity will vary
with treatment flow rates. These residual solids shall be tested
to determine if they are a RCRA hazardous waste. Similarly, if
carbon absorption is utilized with an air stripping tower or
vapor extraction vent, a RCRA hazardous waste could result. If a
RCRA hazardous waste is determined to be present, this remedy
will comply with the regulations for the generation and
transportation of hazardous wastes, 25 PA Code Chapter 262,
Subchapters A and C, and Chapter 263. It shall also comply with
the RCRA regulations and standards for owners and operators of
hazardous waste treatment, storage and disposal facilities, 25 PA
Code Chapter 264. In addition, the Department of Transportation
Rules for Hazardous Materials Transport (49 C.F.R. Parts 107 and
171-179) shall be met.
Fugitive dust emissions generated during remedial activities will
be controlled in order to comply with fugitive dust regulations
in the federally-approved State Implementation Plan for the
Commonwealth of Pennsylvania, 25 PA Code §§ 123.1 - 123.2, and
will not violate the National Ambient Air Quality Standards for
fugitive dust generated during construction activities, 40 C.F.R.
§§ 50.6 and 52.21(j) and 25 PA Code §§ 131.2 and 131.3.
This remedy will comply with the ground water monitoring
requirements in 25 PA Code Chapter 264, Subchapter F.
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This remedy will comply with CERCLA § 121(d) (3) and with EPA
OSWER Directive #9834.11, both of which prohibit the disposal of
Superfund site waste at a facility which is not in compliance
with §§ 3004 and 3005 of RCRA and all applicable State
requirements.
C. Cost— Ef f ectiveness
The estimated present worth cost of the selected, remedy for the
former GATX property (excavation and onsite incineration) is
$11,700,000. The estimated present worth cost for off site
incineration as hazardous waste is $33,800,000, or almost three
times the cost for onsite incineration. The estimated present
worth cost for onsite incineration does not include the cost for
immobilizing metals remaining in the ash. It assumes that no
such treatment will be necessary.
Onsite incineration is a proven technology and the best available
technology for the destruction of organics. Costs for other
Alternatives were comparable but the technology was not as proven
and residuals would remain following treatment.
The estimated present worth cost of the selected remedy for the
ground water contamination in the vicinity of. the Lord property
(ground water pumping and treatment combined with air sparging)
is $3,400,000. Ground water pumping and treatment alone would
have a comparable cost but would not directly treat the area
which is the source of* the contamination and would take an
estimated thirty years to complete. The in- situ biological
Alternative would have a lower present worth cost, $2,400,000,
but the degradation process has not been fully developed or
implemented on ground water contaminated with TCE and PCE. Air
sparging alone as an Alternative would not be as cost effective
at treating areas of lower contaminant concentrations and the
full extent of the ground water plume.
D. Utilization of Permanent Solutions and alternative Treatment
Technologies to the Maxim*™ FK^**"^ Practicable
EPA has determined that the selected remedies represent the
maximum extent to which permanent solutions and treatment
technologies can be utilized while providing the best balance
among the? other evaluation criteria. Of the alternatives
evaluated that are protective of human health and the environment
and meet: ARARs, the selected remedies provide the best balance of
tradeoffs, in terms of long-term and short-term effectiveness and
permanence, cost, implementability, reduction in toxicity,
mobility, or volume through treatment, State and community
acceptance, and preference for treatment as a principal element.
The selected remedy for the contaminated sludge and soil on the
former GATX property, excavation and onsite incineration, will
provide a higher degree of treatment and a lower residual
contamination than the other Alternatives evaluated.
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The selected remedy for the contaminated ground water in the
vicinity of the Lord property, pumping and treatment with air
sparging, combines a proven technology with a promising
innovative technology. This remedy presents fewer implementation
problems, and requires a shorter time frame for completion, than
the other Alternatives evaluated.
E. Preference for Treatment as a Principal Element
Onsite incineration of the contaminated sludge and soil on the
former GATX property fulfills the statutory preference for
remedies that employ treatment as a principal element.
Ground water pumping and treatment combined with air sparging of
the contaminated ground water in tha vicinity of the Lord
property also fulfills the statutory preference for remedies that
employ treatment as a principal element.
XI. EXPLANATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Saegertown Industrial Area Site was
released for public comment on October 21, 1992. The Proposed
Plan identified GATX Alternative 6 (Excavation and Onsite
Incineration) and Lord Alternative 6 (Combination of Pumping and
Treatment with Air Sparging, Steam Stripping or Biological
Treatment) as EPA's preferred Alternatives for soil and ground
water remediation. EPA reviewed all written and verbal comments
submitted during the public comment period. Upon review of these
comments it was determined that no significant changes to the
remedies, as originally identified in the Proposed Plan, were
necessary.
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PENNSYLVANIA
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
1012 Water Street
Meadville, Pennsylvania 16335
A.C. 814/332-6070
January 12, 1993
Mr. Stanley L. Laskowski
Acting Regional Administrator
U.S. EPA, Region III
841 Chestnut Building
Philadelphia, PA 19107
Re: Saegertown Industrial Area Site
Record of Decision (ROD) concurrence
Dear Mr. Laskowski:
The Record of Decision (as received December 31, 1992)
for the Saegertown Industrial Area Site, has been reviewed by the
Department.
The major components of the selected remedy include:
1. Excavation and On-site Incineration for the- treatment
of contaminated sludge and soil on the former GATX
property;
2. Groundwater Pumping and Treatment in combination with
Air Sparging for treatment of groundwater
contamination in and around the Lord property; and
3. No action for SCI area soils and SMC area sediments,
I hereby concur with the EPA's proposed remedy, with the
following, conditions:
* The Department's concurrence is based upon the
understanding that contaminated groundwater beneath the
entire site will be remediated to background quality.
Therefore, not only will the contaminated pluma beneath
and in the vicinity of the Lord property need remediation,
but all groundwater beneath the site, including
contaminated groundwater beneath the GATX portion of the
site, is required to be remediated to background quality.
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Stanley L. Laskowski -2- January 12, 1993
* EPA will assure that the Department is provided an
opportunity to fully participate in any negotiations with
responsible parties.
* The Department will be given the opportunity to concur
with decisions related to the design of the remedial
action, to assure compliance with DER design-specific
ARARS.
* The Department's position is that its design standards are
ARARs pursuant to CERCLA Section 121, and we will reserve
our right to enforce those design-standards.
* The Department will reserve its right and responsibility
to take independent enforcement actions pursuant to State
and Federal law.
* This concurrence with the selected remedial action is not
intended to provide any assurances pursuant to CERCLA
Section 104(c)(3).
Thank you for the opportunity to concur with this SPA
Record of Decision and for the ongoing cooperation of your s~aff in
this effort. If you have any questions regarding this matter please
do not hesitate to contact me.
Sincerely,
Richard H. Zinf.
'Regional Director
Northwest Region
cc: Mr. Kimball (file)
Ms. Dougherty
Mr. Gorman
Mr. Fruehstorfer
Mr. Zinn
Mr. Buchwach
Ms. Brems
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