United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R03-89/067
March 1989
Superfund
Record of Decision
M.W. Manufacturing, PA
-------
5Ci7>101
JfffiEPOKT DOCUMENTATION
A PAGE
1. REPOftTNO,
EPA/ROD/R03-89/067
SUPERFUND RECORD OF DECISION
M.w. Manufacturing, PA
First Remedial Action
3/31/89
7. A«*Mf<»>
10. Pia|KVTM*/Waift UnN M*.
11. ConmcKO or GrwmO) Mo.
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U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IX Type <* Report 4 Pwtod CoMrad
800/000
14.
15.
1C
(UMfc 200
The M.W. Manufacturing site is a former copper recovery facility located in Montour
County, Pennsylvania, two miles north of Danville. The Pennsylvania Department of
Transportation (PennDOT) maintains a storage area immediately north of the site, and
farmlands and wooded lots are adjacent to the site on the west and south. Mauses
Creek flows in a southerly direction past the site. Several private residences,
notels, gas stations, restaurants, and a Head Start school are located Just north of
the PennDOT storage area and rely on private ground water wells for drinking water.
M.w. Manufacturing was engaged in secondary copper recovery from scrap wire, using
both mechanical and chemical processes. Granular carbon wastes generated by the
chemical process was dumped onsite, and spent solvents and acids were allegedly
disposed of onsite. In 1972, M.w. Manufacturing filed for bankruptcy and the
Philadelphia National Bank acquired the property. Warehouse 81 Inc. acquired the site
in' 1976, and subsequently formed a limited partnership with Domino Salvage, Inc. to
recover wire at the site using mechanical recovery only. The initial remedial
investigation revealed several areas posing potential threats to public health: the
carbon waste pile, four wire-fluff waste piles, a surface impoundment, buried lagoon
and contaminated soils, drums and storage tanks. This remedial action addresses the
(See Attached Sheet)
17. Ooct
Record of Decision - M.W. Manufacturing, ?A
First Remedial Action
Contaminated Media: soil
Key Contaminants: VOCs (PCE, TCE), Organics (PCBs), metals (lead)
e. COSAT1 FW«Grat*
1
ill SMivtty OM« (TM* ftoperi)
None
20. Sccwtty On* <1N« !>•«•)
None
21. Na.o«P*g««
22. Prie*
(SMAMS4-Z3«.tt)
SM lamclon* an A»M«M
OPTIONAL FORM 272 (4-77)
(Formriy NT1S-05)
Ocpwmnt of Cannmre*
-------
DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
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A o?0 19830-381-5:6(8393) OPTIONAL FORM 272 BACK (4-77)
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c>A7ROD/R03-8 9/067
M.W. Manufacturing, PA
First Remedial Action
16. Abstract (continued)
concerns for direct contact with and migration to ground water of contaminants from
the carbon waste pile. The remaining areas are the subject of a long-term remedial
investigation and feasibility study. The primary contaminants of concern affecting
the soil are VOCs including PCE and TCE; organics including PCBs; and metals including
lead.
The selected remedial action for this site includes excavating the carbon waste pile
(approximately 875 yd3 of contaminated waste and contaminated underlying soils) and
transporting the waste offsite to an incinerator facility and disposing of the ash in
an offsite RCRA hazardous waste landfill. The estimated capital cost for this
remedial action is $2,061,000. Since onsite remediation activities are anticipated to
require less than one year, there are no 0 & M costs.
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RECORD OF DECISION
DECLARATION
Site Name and Location
M.W. Manufacturing Superfund Site
Danville, Pennsylvania
Statement of Bg-sis and Purpose
This decision document presents the selected remedial action for
the M.W. Manufacturing Site in Danville, Pennsylvania, developed in
accordance with the Comprehensive Environmental Response, Compensation
and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA) and is consistent, to the extent
practicable, with the National Oil and Hazardous Substances Contingency
Plan (NCP), 40 CFR Part 300.
Tnis decision is based upon the contents of the administrative
record for the M.W. Manufacturing Site. (Index attached)
The Commonwealth of Pennsylvania concurs with the selected remedy.
A copy of their letter of concurrence is attached.
Description of the Remedy
This initial operable unit addresses the source of the contamination
by remediation of the "carbon waste" pile. The function of this operable
unit is to remove the carbon waste pile as a threat to human health and
as a source of continued ground water contamination.
The major components of the selected remedy include:
- Excavation of approximately 875 cubic yards of contaminated
waste and contaminated underlying soils. Incineration of the
wastes and soils in an off-site RCRA permitted incinerator.
- Disposal of incinerator ash in a RCRA permitted hazardous
waste landfill.
Uie en going remedial investigation and feasibility study will
identify the risks associated with the remaining portions of the site
(lagoons, tanks, soils, other waste piles, groundwater) and will evaluate
appropriate remedial alternatives for each.
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The selected remedy is protective of human health and the
environment, attains Federal and state requirements that are applicable
or relevant and appropriate to the remedial action, and is cost-effective.
Tnis remedy satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility or volume as a principal
element and utilizes permanent solutions and alternative treatment
(or resource recovery) technologies to the maximum extent practicable.
Stanley LrLaskowski
Acting Regional Administrator
Date
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DBCISICN SUM^RY
I. Site Location
The 15-acre M.W. Manufacturing Site is located in Montour County,
Pennsylvania 2 miles north of Danville, 700 feet west of state Route 54,
and about 1/2 mile south of Interstate 80 (see Figure 1 for the site
location map). The site is located on the Riverside USGS quadrangle map.
The Pennsylvania Department of Transportation {PennDOT) maintains a storage
area immediately north of the site. Farmlands and wooded lots are ad-
jacent to the site on the west and south. Mauses Creek flows in a
southerly direction past the site on the east side of Route 54.
Mausdale, a residential area with approximately 24 homes, is located
approximately 1/4 mile southeast of the site, and Danvi'le (estimated
population 5,200) is located 2 miles south. At the intersection of Routes
54 and 1-80, there are a number of private residences, three motels, three
gas stations, and several restaurants. These properties, as well as a
Head Start school located just north of the PennDOT storage area,
rely upon private ground water wells for drinking water supplies.
A September 6, 1984, the EPA evaluation of this site determined a
Hazardous Ranking System (HRS) score of 46.44 (overall) based on a 79.59 ,
ground water score and a 10.91 surface water score. The site was placed -
on the National Priorities List (NPL) on October 1, 1984.
II Site History
The site is at present relatively inactive, in part due to legal
actions of the Pennsylvania Department of Environmental Resources (PADER).
PADER records indicate that Mr. Allan Levin of Doylestown, Pennsylvania,
proprietor of M.W. Manufacturing Corporation, owned the property from about
1966 to 1972. M.W. Manufacturing was engaged in secondary copper recovery
from scrap wire, using both mechanical and chemical processes until it
ceased operations. In 1972, M.W. Manufacturing filed for protection under
Chapter 11 of Bankruptcy Laws, and the Philadelphia National Bank acquired
the property.
Warehouse 81 Inc. acquired the site in 1976. Subsequently, Warehouse
81, Inc. and Domino Salvage, Inc. formed a limited partnership to recover
wire at the site. Records indicate that the only activities conducted by
the Warehouse 81/Domino Salvage partnership were mechanical recovery
operations. While the mechanical process generated the largest waste
piles (the fluff material), the chemical process generated the largest
potentiaT for environmental impact (the carbon waste material, the lagoons,
and the contaminated soil). The chemical process used by M.W. Manufacturing
Corporation, as described in the EPA Field Investigation Team (FIT) Report
(June 1985), the Dunn Geoscience Report (March 1983), and the PADER Solid
Waste Water Quality and Air Quality files, is summarized below.
M.W. Manufacturing Corporation used a hot oil .bath to melt the plastic
insulation away from the metal in the scrap wire. The oil bath was hot
enough to decompose the PVC plastic insulation into carbon (which separated
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QUAOIUNGU lOCAflO*
0 2OOO
- SCALE IN FEET _ ^ ,- , — j*~<*. r w -w^^w.
BASE MAP IS A PORTION OF THE U.S.G.S. RIVERSIDE, PA QUADRANGLE (7.9 MMUTE SERIES, 1969. PMQTOREVISED 1979) ANO
THE DANVILLE, PA QUADRANGLE (7.9 MINUTE SERIES, 1969, PHOTOREVISED1977). CONTOUR INTERVAL 20 FEET.
FIGURE I
LOCATION MAP
MW MANUFACTURING SITE. MONTOUR CO.. PA
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as a granular black material) and hydrogen and chlorine which were released
as hydrochloric acid (HC1) vapor. The high temperature also enhanced
the dissolution of lead, zinc, and copper (lead-zinc solder coating on
copper wire) from the metal wire. These metals were concentrated either
in the oil or in the carbon waste. Chlorinated solvents trichloroethene
(TCE) or tetrachloroethene (PCE) were then used to remove the residual
oil from the separated copper. These inorganic and organic contaminants
have been identified in the carbon waste pile. (Refer to Figure 2 for
Site layout)
The granular carbon waste material was dumped onsite in a pile about
200 feet west of the main plant. This pile appears as a black, stained
area on historical aerial photographs. Spent solvents (degreasers) with
associated oil were also allegedly dumped on site. The HC1 generated
was apparently condensed and recovered as a by-product and may have been
dumped onsite or stored in a 10,000-gallon hydrochloric acid storage
tank onsite.
III. Community Relations History
Most of the residents who were interviewed in the Danville and Valley
Township areas said that they first became aware of the problem at the
Manufacturing Site in March 1986. At that time, ETA discovered lead
tamination in a well serving a Head Start school near the site. EH\ noted
the discovery in a news release which was carried in the local papers. In
addition, EPA hosted a public meeting on March. 11, 1986, to discuss the
water situation with officials and parents. Approximately 50 people
attended the meeting. EPA supplied the school with bottled water until
later samples revealed safe levels of lead in the well water. The original
levels have never been observed since then and EPA believes that any lead in
the original sample may have been from lead solder in the plumbing. All
later samples, taken after the water had been run for a few minutes to flush
the lines, have not shown any lead. Interest in the site is limited to
local officials and a few residents living on, or in proximity to it. Of
greater importance to most residents and officials is a long-standing
sewage problem that sometimes affects local wells. The sewage problem
and lack of a municipal sewage treatment system caused many of the rest-
aurants and motels near the site to install elaborate water purification
systems and to regularly test their water supply for a wide variety of
undesirable substances The existence of these safeguards prior to the
discovery that M.V. Wkufacturing had contaminated the local ground water
contribotod to reducing fear and concern about the site on the part of
local hotfll and restaurant owners and employees who comprise a large
segment at tba^local business community.
" The proposed plan was placed in the designated information
repository (the Thomas Beaver Library, Danville, Pa.) on February 24,1989.
concurrently, a public comment period was announced in a newspaper
advertisement which ran until March 27,1989. A public meeting was held
on February 28, 1989, to present the proposed plan and preferred alternative
for remediating the carbon waste pile. Approximately twenty citizens
attended as well as local township and county officials and the media.
Response to community concerns is addressed in the Responsiveness Summary
which is included as part of this Record of Decision (BCD).
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i v©
:> V
nut w* FMMMC•> Luootit (ricMrnri iu« cunoi* MIIIMK. IM< >fti
f iGuHt .'
GENERAL ARRANGEMENT
SITE. VALLEY TOWNSHIP,
IMUB
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IV. Scope and Role of Response Action Within the Site Strategy
The initial remedial field investigations revealed wide-spread
contamination of the M.W. Manufacturing Site that will require a long-
term Ranedial Investigation (RI) and Feasibility Study (FS). In
addition to the carbon waste the Site poses potential threats to human
health and the environment from the following areas: four wire-fluff
waste piles, a surface impoundment, a buried lagoon, contaminated
soils, drums and storage tanJcs.
However, the carbon waste pile was shown to be a relatively
well-defined contaminant source, unique from other source areas in
size, composition, and contaminant concentrations. These character-
istics make it both possible and desirable to undertake interim
remedial actions to address this waste pile, prior to implementing
other remedial actions for the remainder of the site. This response
action is consistent with Section 300.68 (c) of the National Contingency
Plan (NCP). This initial operable unit is being implemented to protect
public health and the environment by preventing direct contact with
contaminated waste and reducing further migration of contaminants
into the groundwater. The operable unit addresses only the carbon
waste pile. The USEPA and FADER feel that direct contact with the
contaminated waste and migration of contaminants into the ground water - ,:
are the major concerns posed by this site. This operable unit was
initiated to deal with these concerns. It is fully consistent with
all future site work.
V. Nature and Extent of Contamination
Eleven samples, including one duplicate, were collected from the
carbon waste pile during the field • investigation. These samples were
analyzed for the full Target Compound List (TCL) as specified in the
EPA Contract Lab Program Statement of Work. Table 1 is a summary of
the validated analytical results.
The table presents a list of all the organic contaminants detected
and includes both, carcinogenic and noncarcinogenic compounds. In addition
to the organics, the levels of lead and copper are greatly elevated in
these samples, and were therefore included in this table. The range of
concentrations at which each compound was detected, the number of samples
in which it was detected, and the average concentrations are presented.
An ariti»Bfeic average was used to generate typical contaminant
concentrations in the carbon waste pile. Many of the contaminants were
found in every sample, so the use of an arithmetic average was felt to be
representative. As the table shows, tetrachloroethene, trichloroethene,
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TA3LE
SUMMARY OF CHEMICAL ANALYTICAL DATA
CAR30N WASTE PILE
MW MANUFACTURING SITE, MONTOUR COUNTY, PENNSYLVANIA
Contaminant
acetone
ethylbenzene
toluene
total xylenes
tetrachloroethene
trichloroethene
1, 2-dichloroethene
1,1,2,2-tetrachloroethane
1, 1, 2-trichloroethane
methylene chloride
chloroform
carbon tetrachloride
bis(2-ethylhexyl)phth«late
di-n-butyl phthalate
benzoic acid
total PC as
copper
lead
Range of Positive
Detections
(mg/kg)
4.6 • 43
1.7
6.3 - 86
3.2 - 8.0
110 - 14,000
4.3 - 130
19
1.7 - 170
7.3 - 510
1.7 - 33
1.2
36
320 - 70,000
27 - 1,700
19
1.04-54.16
6,390 - 69,100
9,450 - 29,600
Mo. of
Positive
Detections/
Mo. of
Samples
4/11
1/11
5/11
3/11
11/11
9/11
1/11
3/11
11/11
11/11
1/11
1/11
11/11
9/11
1/11
11/11
11/11
11/11
Average
Concentration*
(mg/kg)
10.73
0.15
11.0
1.44
5,500 .
27.05
1.73 . .
24.7
215.75
20.49
0.109
3.27
9,354
315
1.72
7.60
32,660
17,100
• Averages arc arithmetic averages calculated using nondetections as zero.
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methylene chloride, and 1,1,2,2-tetrachloroethane are the most prevalent
volatile organic contaminants detected in the carbon -waste. The total
concentration of all volatile organics was as high as 14,697.2 mg/xg
(1.47 percent) in one sample. It is believed that the presence of these
compounds in the carbon waste is due to the use of a solvent bath in the hot-
oil stripping process.
Sampling of onsite monitoring wells revealed the presence of
significant levels of all of the above compounds in the ground water,
though the methylene chloride is questionable because of blank contamin-
ation.
Bis(2-et±iylhexyl)phthalate (DEHP), a common plasticizer, was detected in
all samples at concentrations between 320 and 70,000 mgAg. The average
concentration was slightly less than 1 percent. DEHP and di-n-butyl
phthalate were the only base/neutral extractables found in the carbon
waste, except for one detection of benzoic acid. However, because the
laboratories that analyzed the samples did not conform to accepted quality
control standards, the positive detections in this sample package were
identified as being estimated, and the rest of the package was rejected.
For lack of any other analyses, the estimated results are used in the
analysis of alternatives.
PCBs were detected in every sample collected from the carbon waste pile. t«
PCBs were present in the carbon waste samples at an average concentration*
of 7.60 mgAg. These possibly carcinogenic compounds were likely present
in the hot oil bath.
The eleven waste samples were also analyzed for dioxins which may have
been created when the PCB-laden waste oils were subjected to high temp-
eratures. Based on the validated analytical results, dioxin (2,3,7,8-TCDD
equivalent) was not found in any of the 11 samples.
Finally, lead and copper were found in all samples at very high
concentrations. For example, copper concentrations ranged from 6,390
mg/kg to 69,100 mgAg, with an average concentration of 32,660 mgAg
(3.27 percent). Lead was found at concentrations between 9,450 and
29,600 mgAg, with an average concentration of 17,100 mgAg (1.71
percent). Average concentrations for copper and lead in soils throughout
the eastern U.S. are 22 mgAg, and 17 mgAg, respectively.
upon current site conditions, the potential exposure pathways
associated with contamination from the carbon waste pile are l) direct
contact with the contaminated waste, 2) inhalation of contaminated dusts;
3) inhalation of the volatilized organics from the waste pile and 4)
ingostion of contaminated dusts.
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VI. ^gnnftry of Site RisJcs
Utilizing data generated during the on going RI , a Risk Assessment
was conducted to evaluate the potential impact to human health which may
result from the highly contaminated carbon waste pile.
In order to assess public health risks, three major aspects of
chemical contamination and environmental rate and transport must be
considered: (1) contaminants with toxic characteristics must be present,
and must be released by either natural processes or human action; (2) an
actual or potential exposure pathway must be present; and (3) human receptors
must be present. Risk is a function of both toxicity and exposure; without
any one of the above factors, there will be no risk. This risk assessment
estimates the potential for human health risks at the site by combining
information on the toxicity of the chemicals found onsite with site-specific
estimates of exposures.
Table 1 summarized the chemical analytical results for the samples
collected from the carbon waste pile. Of the organics detected, only*
benzoic acid has no health-based standards or criteria. Other
contaminants that were not included as indicator chemicals for the risk ,
assessment were acetone, ethylbenzene, xylenes, 1,2-dichloroethene, "
chloroform, and carbon tetrachloride, primarily because of their less
frequent occurrence and lower concentrations.
Of the inorganics detected at the site, lead and copper have been
retained as indicator chemicals. Although chromium and antimony appear
to be elevated at this site, lead and copper will drive the risk and the
remediation because of their overwhelmingly greater concentrations in the
carbon waste.
Toxic effects considered include noncarcinogenic (toxic) and
carcinogenic health effects and environmental effects. Toxicological
endpoints, routes of exposure, and doses in humans and/or animal studies
are discussed for noncarcinogenic compounds.
The available toxicological information indicates that several of
the indicator chemicals have both noncarcinogenic and carcinogenic health
effects in htnans and/or in experimental animals. Although the indicator
chemicals may cause adverse health and environmental impacts, dose-
response-relationships and the potential for exposure must be evaluated
before the risks to receptors can be determined. Dose-response
relationships correlate the magnitude of the dose with the probability for
toxic effects, as discussed in the following section.
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An important component of the risk assessment process is -Jie
relationship between the dose of a compound (amount to which an
individual or population is exposed) and the potential for adverse health
effects resulting from exposure to that dose. Dose-response relation-
ships provide a means by which potential public health impacts may be
evaluated. The published information on doses and responses is used in
conjunction with information on the nature and magnitude of human exposure
in order to develop an estimate of health risks. Standard reference
doses (RFDs) and/or carcinogenic potency factors (CPFs) have been developed
for many of the chemicals on the target compound list.
Values of available regulatory standards, reference doses, and
CPFs are presented in Table 2. Table 2 presents values both for
chemicals that are known or suspected human carcinogens and for chemicals
having noncarcinogenic effects. All available toxicity information is
included in this table. Most of the data are from IRIS, EPA's computerized
toxicological data base. However, if a parameter s not currently available
in IRIS, previously published values from other EPA sources are used.
The IRIS file indicates that it is inappropriate to develop an RFD
for lead and that the CPF for tetrachloroethene has been suspended.
However, in order not to leave a significant gap in the risk assessment, *
older published values for these parameters are used. Expected doaps of »
the indicator chemicals are presented later in this section. f
Three actual exposure routes have been identified for contact with
the contaminants in the carbon waste pile. The first is the routine
contact with the waste materials by the onsite residents, which consists
of dermal contact with the waste, accidental ingestion of contaminated
dusts, and inhalation of indoor and outdoor dust. The second is inhala-
tion of volatilized contaminants from the waste material for the site
residents and employees. The third is the accidental contact with the
waste materials by site employees or trespassers which consists of dermal
contact and accidental ingestion.
Carcinogenic risks can be estimated by combining information in the
dose-response assessment (carcinogenic potency factors) with an estimate
of the individual intakes (doses) of a contaminant by a receptor. These
risks are expressed as numbers of excess cancer deaths expected to occur
in an exposed, population. EPA policy requires that Superfund sites be
cleaned so that this excess risk falls between 1 per 10,000 and 1 per
10,000,0flfr (nonnally stated as lxlO~4 and IxlO"7) depending onsite
conditions, feasibility of cleanup, costs, expected future use and other
factors? ^Bjinring any mitigation from_any of these factors, EFA's normal
cleanup goat is 1 per 1,000,000 (lxLO~6) excess cancer risk.
-------
TAUUE
REGULATORY REQUIREMENTS AND DOSfc-RESPONSE PARAMETERS KOR 1NUICATUH ClltMICALS
CARBON WASTE PILE
MM MANUFACTURING SITE. MOMTOUR COUNTY. PENNSYLVANIA
Chaaical
acctomt
• IhyltMiaacna
taltuioe
total nylanck
1,1.2.2-
(•liacfcloioathanti
l.l.i-
t< icbloioath«n*
tatfachloiaathCM
t f ichlotoathana
•*(• M lakia*
H»t«i Act
uiiaxs)
MCL
1««/1)
-
0.00*
HCLC
(•«/il
• .*•
2
0.«4
0
0
Hefeieace Date
(•9/fc9-««y> <2»««>
O(«l
0.1
O.I
0. JO
2.0
0.20
0.02
Inhalation
3.0
i.i
0.44
Aabieat Itotei
Quality Cfitaii*
(M9/» (11
AJjuktcd
far
Of ink 109
W«t*r
only
2.400
1^.000
iO-6
Hick
0.17
0.*
o.so
2.«
Health Advikoiy (2)|«|
(•V/il
1 -day/child: 32
10-day/child: J.2
Utnq-tnf B/chilii: 1
Uta9-t«(«/adult : J.4
Lif«tiac/«dult : 0.6S
1 -day/child: IS
IQ day/child: 6
Li(«tiac/«dult : 10. •
1-day/child: 12
I0-d*y/child: ».•
Long- ta«B/chi Id: J.i
long- (•(•/adult: 21.3
LitatiM/adult: 2.2
1 -day/chi Id; 2.0
10 day /child: 2.0
Lonq-tcra/chi Id: 1.4
Lonq- taia/adul t : 1.0
C^icinogenlc fuiiiccy
ractor (» (4|
(•4/kq/ddyl •»
Oial
0.2
4.1 • 10-2
*.l a 10 2
1 . l«10~2
Inhalal ion
0.2
i. 1 • 10 2
1.) • 10-)
1. 1.10 2
KVA
W«i«ht
at
(2H4|
O
c
c
112
tti
-------
TABLE 2
REGULATORY REQUIREMENTS AND DOSE-RESPONSE PARAMETERS FOR INDICATOR CHEMICALS
CARBON WASTE PILE
MM MANUFACTURING SITE. MONTOUR COUNT*. PENNSYLVANIA
PAGE TWO
CheaiCdl
1.2-
dichloi o«th*n*
cblocofora
•alhyl«o«
cMof id*
t«tf«chloc ide
bit(2-etbylb«Myl)
di-a-butyl
pl)th*l«t«
PC* (all i*oM(*>
£•(• Delating
«*•(•( Act <»
MCL
(•i/H
0.10*
0.004
MCtC
0.07
0
0
Hcierencu Ooae
1 Aa/litt"dAy i • 1 1 ^ )
OCA!
0.01
0.06
0.02
0.01
Inluildi iou
duality Criteii*
(M9/M
-------
TABLE 2
REGULATORY REQUIREMENTS AND DOSE-RESPONSE PARAMETERS FOR INDICATOR CHEMICALS
CARBON HASTE PILE
MM MANUFACTURING SITE. MONTOUH COUNT*. PENNSYLVANIA
PAGE THREE
— ,„,
COpfMf
...d
•*(•( Act
(11(3)1*1
MCL
1*9/11
l.J
O.OOS
MCLC
1.1
0
Mttteience Dote
Oral
0.017
1.4110-1
Inh*l«lioo
0.01
A»bi«i>l Wdtur
Quality C(it«ri«
ooly
1.000
SO
10 0
• ikk
Uaallh Adwikoty (2)|4)
(•4/U
Luni|-ti)i«/cli i Id ;
Lifel iM/«dul t :
C*ic iitu^enic 1'olcocy
r«clO( I 2) (4)
( "wj/ktt/*l * ¥ 1
Oi 4 1
lull* Id I tun
of
|2>(4)
References:
(I) EPA. November 13. 19U5.
121 EPA, November Ib. 19«7.
Ml EPA. October 19B6.
l«t EPA Integrated Risk Information System (IK1S)
(i» EPA. Augu&t IB. 1908.
• Interim MCL for total tr i rial owe Humes
A Known human carcinogen
U1/B2 Probable human carcinogen
C Possible human carcinogen
O Not classifiable
-------
Table 3 presents a suntnary of the potential carcinogenic risks
resulting fron the exposure routes. This total potential risk is the
mathematical summation of the individual risks posed by the chemicals
identified in Table 2. The risk is primarily due to the accidental
ingesticn of and dermal contact with tetrachloroethene, 1,1,2,2-
tetrachloroethane, 1,1,2-trichloroethane, bis(2-ethylhexyl)- phthalate,
and PCBs. PCBs are present at low concentrations, but their high CPF
results in high risks. The other major contributors to risk via these
exposure routes are trichloroethene and methylene chloride.
The risks associated with regular, daily inhalation of contaminants
volatilizing from the carbon waste pile are several orders of magnitude
lower than those estimated for physical contact with the materials.
However, the risks for both site employees and residents exceed lxio~6,
using the average waste concentrations and exposure durations of 8 and 24
hours/day, respectively. The primary contributors to this risk are 1,1,2-
trichloroethane and tetrachloroethene, which were the volatile organics
found at the highest concentrations, and methylene chloride. Other
carcinogens contributing to the total risk are trichloroethene and 1,1,2-
trichloroethane. The total potential carcinogenic risks resulting from
accidental dermal contact or ingestion by site employees or trespassers ,
are lower than those resulting from the other exposure routes. For • • ;
example, the potential risk from dermal contact with the carbon waste by :
employees is 5.3xlO~6 at the average contaminant concentrations, and
accidental ingestion results in a potential risk of 2.1xlO~5.
Potential health risks resulting from exposure to noncarcinogenic
compounds are estimated by comparing an annual daily dose to an
acceptable level such as a Reference Dose (RFD). If the sum of these
ratios, known as the Hazard Index, exceeds unity, there is a potential
for noncarcinogenic health risks (EPA, September 24, 1986). The Hazard
Index is not a mathematical prediction of the severity of toxic effects ;
it is simply a numerical indicator of the transition from acceptable to
unacceptable levels. Table 4 is a summary of the total Hazard Indices
resulting from exposures to the carbon waste pile.
Accidental ingestion, inhalation and dermal contact with the waste
materials on a routine basis by an adult will result in a potential total
Hazard Index of 138 using average contaminant concentrations. Lead is
the most significant hazard under this exposure scenario, followed by
copper, tBtrachloroethene, and bis(2-ethylhexyl)phthalate. Accidental
ingestion: try both trespassers and site employees can also result in a
significant Hazard Index (approaching or exceeding unity). The other
exposure routes examined for the site do not present a significant
noncarcinogenic health risk. The carcinogenic risks resulting from
physical contact with the contaminants in the carbon waste pile greatly
exceed the range generally considered to be acceptable, that is, between
-------
TA3L2 3
POTENTIAL CARCINOGENIC RISKS
CARBON WASTE PILE
•MW MANUFACTURING SITE
MONTOUR COUNTY, PENNSYLVANIA
Exposure Route/Receptor
Volatile Emissions
- employees
- residents
Routine Contact
- residents (adults)
Dermal Contact
- employees
- trespassers
Accidental Ingestion
- employees
- trespassers
Total Potential Carcinogenic Risk
Average Waste
Concentrations
3.4x10-5
6.0x10-*
Approaches 1.0
5.3x10-6
5.7x10-7
2.1x10-5
2.2x10-6
Maximum Waste
Concentrations
1.0x10-4
1.8x10-3
Approaches 1.0
1.6x10-5
1.8x10-6
7.0x10-5
7.6x10-6
This is the mathematical summation of the individual risks posed by
all of the chemicals identified in Table 2.
-------
TABLE 4
TOTAL POTENTIAL HAZARD INDICES
CARBON WASTE PILE
MW MANUFACTURING SITE
MONTOUR COUNTY, PENNSYLVANIA
Exposure
Route/Receptor
Volatile Emissions
- employees
- residents
Routine Contact
- residents
(adults)
Dermal Contact
- employees
- trespassers
Accidental Ingestion
- employees
- trespassers
Total Potential Hazard Index
Average Waste
Concentrations
1.4x10-5
1.5x10-4
138
3.0x10-2
1.6x10-2
1.3x10-2
7.7x10-1
Maximum Waste
Concentrations
1.1x10-4
1.1x10-3
273
1.4x10-1
7.7x10-2
3.8x10-2
1.53
This is the mathematical sum of the annual daily dose/the reference dose
for a,ll of the chemicals identified in Table 2.
-------
1x10 4 and 1x10 7. The carcinogenic risks associated with the regular
inhalation of contaminants volatilizing from the carbon waste pile fall
into the upper end of the "acceptable" range. These results indicate the
need for remedial action of the carbon waste pile.
Based on the results of this risk assessment, it is evident that it
is necessary to propose remedial actions for the carbon waste pile in
order to reduce the incremental cancer risk level and to avoid the
occurrence of noncarcinogenic health effects. The waste presents a
high carcinogenic and noncarcinogenic risk to site residents and
enployees under several of the proposed exposure scenarios.
The potential risks resulting from the routine dermal contact,
inhalation, and ingestion exposures were the highest of all exposure
routes examined. Therefore, this exposure route was selected for
the determination of action levels. If the residual risk is acceptable
via this exposure route, it will also be acceptable via all others.
Two sets of action levels were developed. One total carcinogenic
risk goal was set at IxlO"4 and the second was set at IxlO"6. Action-
levels for noncarcinogens were set to meet a total Hazard Index of unity,
and, therefore, only one action level is needed for each noncarcinogenic .
indicator compound. • ;
Table 5 presents the concentrations of carcinogens required to
meet the total 10~4 and 10"6 risk goals. The table shows that to meet
a IxlO"6 risk goal, the concentrations of all the indicator compounds
will be significantly below detection limits. The action levels for
individual carcinogens under the IxlO"4 risk goal are less than 2 ugAg.
These action levels apply to only the waste material itself — action
levels for the subsurface soils that do not contain any visible traces of
the carbon waste will be addressed in the Feasibility Study for the
rest of the site.
VII. ALTERNATIVE ANALYSIS
Each of the following alternatives, with the exception of Alternative 1,
consist of excavating the approximately 636 cubic yard carbon waste pile
plus an additional 239 cubic yards of soil which contains carbon waste in
visible quantities.
- No Action
This altMMtive is considered in the detailed analysis to provide
a basellne^to which the other remedial alternatives can be compared.
This, alternative involves taking no action at the M.w. Manufacturing
Site" to remove , remediate , or contain the contaminated carbon waste
pile. Institutional controls, such as deed restrictions, are not
applicable to the purpose of this analysis and will be addressed in the
ongoing RI/FS for the rest of the site.
-------
Index to Atainistrative Record
1. Site Inspection of Domino Salvage
NUS Corporation June 14, 1985
2. Revised Final Community Relations Plan
EBASCO Services Inc. November 11, 1988
3. Final Feasibility Study, M W Manufacturing Site
NUS Corporation February, 1989
4. Proposed Plan, M W Manufacturing,
Montour County, Pennsylvania
-------
Deputy Secretary for
Environmental Protection
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Post Office Box 2063
Harrisburg. Pennsylvania 17120
March 30, 1989
(717) 787-5028
Mr. Stephen R. Wassersug, Director
Hazardous Waste Management Division
EPA Region III
841 Chestnut Building
Philadelphia, PA 19107
Re: Letter of Concurrence
M. W. Manufacturing Superfund Site, Record of Decision (ROD)
Dear Mr. Wassersug:
The Record of Decision for the initial operable unit which addresses
the main source of the contamination by remediation of the carbon waste pile at
the M. W. Manufacturing site has been reviewed by the Department.
The major components of the selected source control remedy include:
* Excavation of approximately 875 cubic yards of contaminated waste
and contaminated underlying soils and incineration in an off-site
RCRA approved incinerator.
* Disposal of incinerator ash in a RCRA permitted hazardous waste
landfill.
conditions:
I hereby concur with the EPA's proposed remedy with the following
The Department will be given the opportunity to concur with
decisions related to the overall Remedial Investigation and
Feasibility Study to identify the extent of, and future potential
for, groundwater contamination and remaining sources of that
-contamination, and evaluate appropriate remedial alternatives to
assure compliance with DER cleanup ARARs and design specific
ARARs.
EPA will assure that the Department is provided an opportunity to
fully participate in any negotiations with responsible parties.
The Department will reserve our right and responsibility to take
independent enforcement actions pursuant to state law.
-------
Mr. Stephen R. Wassersug
-2-
March 30, 1989
* This concurrence with the selected remedial action is not
intended to provide any assurances pursuant to SARA
Section 104(c)(3).
Thank you for the opportunity to concur with this EPA Record of Decision,
If you have questions regarding this matter, please do not hesitate to contact me.
Sincerely,
Mark M. McClellan
Deputy Secretary
Environmental Protection
-------
Garment; One written comment was received during the corment period.
The Board of Supervisors of Valley Township recommended that EPA
continue to monitor wells that are within the area of the site on a
regular basis. Further, the Board of Supervisors stated their belief
that funds should be made available to provide a public source of
water to the area near and surrounding the site to eliminate the
threat of drinking contaminated ground water.
Response; EFA is conducting further investigation of the ground water
at the site. This study will include at least one more round of well
sampling to define the extent of contamination and to insure that no
public wells have been contaminated. ETA sees no reason to install a
public water supply system at this time, as no contamination has been
observed off-site. Future remedial activities may include some sort of
ground water clean up which may make such a public water supply unnecessary.
Monitoring on a routine basis will be done by the Commonwealth of
Pennsylvania as part of scheduled operation and maintenance activities
which win take place after all remedial activities have been completed.
-------
EPA Response: This approach could be taken,' but the EPA
prefers other engineering methods to address and remediate
contamination other than the excavation of soil. This
contamination will be addressed with the remainder of the
site other than the carbon waste pile. At such time, the
public will have another opportunity to comment on the
additional remedial alternatives that will be proposed.
Comment:
solvents
solvents
One resident
at the site,
are present.
asked the EPA to identify the
and to state whether chlorinated
EPA
Response:
site
other
include
solvents
Solvents at the
trichloroethylene, tetrachloroethylene, and
such as benzene and vinyl chloride.
F. Off-Site Monitoring and Contamination
Comment: An individual commented that he believed the
sampling of off-site air would reveal the presence of
asbestos stemming from the site, and that this would
conflict with School District requirements for
asbestos-free air.
EPA Response: No comment.
A resident asked whether the Remedial
Investigation would move off-site if heavy metals were
found at great depths.
EPA Response; This is not the focus of the current study.
If heavy metals were found, EPA would conduct additional
studies of contamination.
Comment : Several participants asked about the monitoring
of groundwater taking place and the off-site migration of
contamination via groundwater.
EPA Response: The EPA established thirteen wells on-site
and one well off-site, and also analyzed numerous existing
residential wells. Groundwater under the site is
contaminated. However, evidence does not indicate that the
plume of contamination has migrated off-site thus far.
One participant
the presence of
He surmised that
force the plume
Comment;
due to
center.
rain to
Another
center would continue to be monitored.
disagreed with this assessment
lead in wells at the day-care
there had not yet been adequate
to the schools in the area.
individual asked whether the wells at the day-care
-------
EPA Response: The EPA has not been able to duplicate this
result and considers it anomalous. The wells at the
day-care center were tested as recently as August 1988.
EPA intends to conduct one more round of private well
samples (including the day-care center) as part of the
design of the remedial action. This will assure that
contamination has not moved off-site in the period since
the previous sampling. Any long term monitoring will be
conducted by Pennsylvania Department of Environmental
Resources (PADER) as part of the operation and maintenance
program after completion of the site remediation.
Comment; A member of the community expressed concern
regarding the impact of contamination on wells at some
distance from the site.
EPA Response; If the next round of sampling shows that
contamination has moved off-site, the EPA may need to test
additional off-site wells; however, it is not clear at this
time whether sampling of this type is necessary.
Comment: Participants at the meeting inquired about t-he
locations of the off-site sampling of wells, and about
sampling activities at several restaurants. '
EPA Response: Off-site sampling concentrated on
residential wells where the safety of children could be
jeopardized. The majority of the residences where sampling
took place are located south of the site in Mausdale, in
addition to residences along State Route 54 and the
day-care center. Sampling did not take place at the
restaurants in proximity to the site.
Comment: A member of the audience indicated that the wells
at McDonald's Restaurant have been monitored by its owners
every six months. Tests did not show the presence of
hazardous chemicals. The water is treated there, but it is
not treated for the presence of chemicals.
EPA Response; No comment.
Comment: An individual asked the direction of flow of the
groundwater plume.
EPA Response; Most of the groundwater is flowing to the
east. A portion may be flowing to the northeast.
Comment; One person wanted to know if background wells
could be tested for chlorides to help indicate the presence
of contaminants.
EPA Response; Such tests could be performed. However, the
results of these tests may be misleading because there are
naturally occurring chlorides in the area.
-------
rR?s associated with the MW Manufacturing Site have
declined to participate. However, their lack of
participation does not stop the cleanup process. The EPA's
enforcement branch pursues the PRPs to recover the cost of
EPA's work at the site.
CojnrogJUt: An individual inquired as to whether the current
owners are considered PRPs even if they did not dump
wastes, and therefore, did not contribute to the wastes on
the site.
EPA Response: The enforcement branch of the EPA determines
who constitutes a PRP. The PRP can include the current
owner.
C. Remedial Alternatives
Comment; An individual asked if the same amount of soil
will be removed in each alternative.
EPA Response: The same amount of soil is excavated in each
proposed alternative.
Comment: An individual wanted to know if the EPA returns
and monitors the soil one year following remediation. This
citizen expressed concern that not all contaminants will be
removed and that some may migrate to greater depths or
off-site.
EPA Response: In the preferred Alternative 7, the EPA
would nob return to monitor soil for carbon wastes. The
subsequent phases of this RI/FS would address the cleanup
. of the soil. It is possible that some contamination would
be missed, however, all Superfund sites remain eligible for
additional cleanup.
Comment: A resident of Valley Township inquired as to the
nearest locations of landfills and incinerators authorized
to accept hazardous wastes.
EPA Response: Incinerators are located in New Jersey, Ohio
and Alabama. Landfills are located in North Carolina and
Ohio. There are no appropriate locations in Pennsylvania.
D. Carbon Waste Pile
Comment t An individual asked if this proposed remedial
action pertains to all materials on the site.
EPA' Response; This remedial action pertains only to the
carbon waste pile. Remedial alternatives for other waste
on the site have not yet been developed.
-------
Corient: More than one resident inquired as to the reason
for addressing only the carbon waste pile. The concerns
pertained to whether the area would be recontaminated with
the fluff waste pile after removing only the carbon waste
pile.
EPA Response: The EPA is addressing only the carbon waste
pile at the present time due to its hazardousness and the
associated threats to public health. The EPA considers
contaminants in the carbon waste pile to be at levels
10,000 times greater than any other wastes associated with
the site.
Comment: An individual asked about the time frame for the
removal of the carbon waste pile.
EPA__Re_sp_Q..ns_e.: The EPA anticipates completing the removal
within six months.
Comment: A follow-up question pertained to whether
solvents are continuing to leach from the carbon waste pile.
EPA Response: The EPA believes that leaching 0,1
contaminants continues to occur. Therefore, the EPA
prefers to prevent this leaching of contaminants as soon' as
possible, either through covering the waste with an
impermeable membrane or by removing it from the site
completely. Both techniques would prevent the transport of
additional contaminants into the soil and groundwater.
E. Fluff Waste Pile and Other On-Site Waste
Comment: Several individuals asked about whether the EPA
considers the fluff pile hazardous, specifically whether it
had been analyzed for asbestos particles, and whether
airborne contaminants pose a fire hazard.
EPA Response: The results of the investigation of the
fluff pile and its fire hazards have not yet been
completely analyzed. The investigation did not look
specifically for asbestos. The fluff pile contains paper
and plastics, which may pose a fire hazard.. The fluff pile
also contains solvents and copper wire. EPA tozicologists
are willing to work with the community to address hazards
to the local population resulting from any potential fluff
pile fire.
Comment: An individual asked if the EPA is prepared to
excavate soil to the level of the water table to address
completely any contamination of wells.
-------
This section documents the issues and concerns the local
community expressed during the public comment period and the
EPA's responses to those concerns. These views and opinions
have been considered by the EPA in the final decision-making
process regarding the selected remedial alternative.
Approximately 30 people participated in the public meeting,
including Montour County and Valley Township officials,
interested citizens, and members of the media. Questions and
comments lasted approximately 45 minutes following presentations
by EPA officials. These comments fall into the following
categories of concern:
A. Superfund process
B. Potentially responsible parties (PRPs)
C. Remedial alternatives
D. Carbon waste pile
E. Fluff waste pile and other on-site waste
F. Off-site monitoring and contamination
A. Superfund Process
Comment: A county official commented on the lengthiness of
the Superfund investigation .process. Montour County and
Valley Township are eager to have the Superfund process for
the site completed so that the property can be returned to
the tax rolls and utilized for industrial purposes. The
official inquired as to the reason tor the current availa-
bility of funds authorizing cleanup.
EPA Response: The Superfund investigation process was
delayed because the Superfund program ran out of funds.
When Congress reauthorized the Superfund program, through
the 1986 Superfund Amendments and Reauthorization Act
(SARA), the program had the authority and funds to move
forward with cleanup.
Comment; A county official asked whether Superfund could
run out of funds in the middle of the cleanup process.
-------
=L?A Hespgn^g: All funds requested thus far for the MW
Manufacturing Site have been approved. EPA expects the
Superfund program to proceed for a number of years. The
environmental concerns of the American public and the
associated political pressure should continue to make this
program operative and keep these funds available.
Comment: An individual inquired as to the time frame for
the entire investigation and cleanup.
EPA Response: The following information is based on EPA's
experience at other Superfund sites. After the public
meeting, a 30-day period is set aside for public comments.
EPA prepares a Record of Decision (ROD) (a document
outlining EPA's preferred remedial alternative) on the
carbon waste pile, which constitutes the first component of
the investigation at the MW Manufacturing site. The ROD
incorporates public comments on the proposed alternatives.
Then the EPA proceeds to the remedial design phase, which
takes place over a three to four month period. Following
the remedial design, contractors bid on the work. There-
fore, removal should take place by the end of the summer.
The schedule can be delayed by 60 days if the parties
responsible for contamination (PRPs) negotiate with the EPA
in good faith for their role in the cost of cleanup. "
The second phase of the work addresses contamination other
than the carbon pile at the MW Manufacturing site, includ-
ing the fluff pile, groundwater and soil contamination.
The following schedule with regard to the second phase of
activities is tentative. If the Feasibility Study (FS) for
other parts of the site is completed during the summer of
1989, remedial alternatives should be proposed by late
summer/early fall of 1989. A ROD could be signed by
September 1989. The remedial design for the site would
take approximately one year to complete, and would be
overseen by the US Army Corps of Engineers. If the design
is completed by the autumn of 1990, construction could
begin by the spring of 1991.
B. Potentially Responsible Parties (PRPs)
Comment: An individual inquired about the EPA's efforts to
identify the parties responsible for contamination, and to
secure their cooperation with the remedial program or their
reimbursement of costs.
EPA Response: The EPA Enforcement Division investigates
the* PRPs associated with a Superfund site. The Enforcement
Division gives them an opportunity to participate in the
remedial investigation and cleanup. At this point, the
-------
Utilization of Permanent Solutions and Alternative
Treatment Technologies to the Maximum Extent Practicable
The U.S. EFA believes that the selected alternative is the most approp-
riate solution for remediating the carbon waste pile at the M.W. Manufact-
uring Site. As the contaminated waste will be excavated and removed
from the site, this represents the maximum extent to which permanent
solutions can be utilized. The waste will be treated (incinerated) at
an offsite facility which also represents a permanent solution.
Preference for Treatment as a Principal Element
The statutory preference for permanent treatment is satisfied as the
selected remedy calls for removal and offsite treatment of the carbon
waste.
-------
Alternative 2 would not provide a permanent remedial solution to the
waste pile. With respect to the M.w. Manufacturing Site, Alternatives 3,
4, 6, and 7, offer permanent overall protection to the community oy
ultimately removing the carbon waste material from the site. The perm-
anence of protection provided by Alternative 5 is dependent on the long-
term reliability of the solidified waste which is unknown and must be
evaluated through treatability studies.
Community Acceptance
A public meeting was held for the Site on February 28, 1989. DJO adverse
conments were received at the meeting or during the following 30-day
comment period. In general, the community is happy to see remediation
starting at the site.
State Acceptance
The Commonwealth of Pennsylvania, through its Department of Environmental
Resources (DER), concurs with the selected remedy.
IX. Selected Alternative
After careful consideration of the proposed remedial alternatives with ;
regard to the criteria specified above, EPA's selected alternative for
addressing the carbon waste pile is Alternative 7: Excavation,Offsite
Incineration, and Disposal of Incinerator Ash in an Offsite RCRA Landfill.
This alternative would permanently reduce the on site mobility, toxicity
and volume of the carbon waste so as to eliminate the threat to public
health from direct contact with waste. Off site, the toxicity and volume
of the waste would be reduced by incineration and the mobility of the
residual toxic components in the ash would be limited by their deposition
in a secure RCRA permitted landfill.
By removal of the waste from the site, the potential for further ground
water contamination from the waste would be eliminated.
X. Statutory Determinations
The selected remedy is protective of human health and the environment,
attains all applicable, or relevant and appropriate requirements for this
operable unit, is cost-effective, win utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to
the maximum extent practicable, and satisfies the preference for treat.nent
as a principal element.
-------
Attainment of the Applicable or Relevant or Appropriate Requirements
The selected alternative will be consistent with those ARARs identified
for this site:
- RCRA Subtitle C, Hazardous Waste Management Requirements, 40 CFR 264,
which govern the transportation, treatment, storage and disposal of
hazardous wastes.(applicable) The treatment win be conducted in a
RCRA permitted facility in compliance with all applicable regulations.
- RCRA Subtitle C, Land Disposal Restrictions, 40 CFR 268, which regulate
the land disposal of hazardous waste.(applicable) For this FOOl spent
solvent waste, the treatment method (incineration) win achieve the
treatment standards specified in Subpart 268.41.
- OSHA Requirements (29 CFR 1910, 1926 and 1904) which provide occupational
safety & health requirements applicable to workers engaged in onsite
field activities.(applicable) All remedial contractors employed during
this action will be required to certify that they comply with all OSHA
requirements.
- Clean Air Act, 40 CFR 50, National Ambient Air Quality Standards (NAAQS).
(applicable) This action will cause no violation of the NAAQS due to'
fugitive dust generated during construction activities.
- Clean Air Act, 40 CFR 52, State Implementation Plans for National Ambient
Air Quality Standards.(applicable) Fugitive dust emmissions generated
during construction activities will comply with fugitive dust regulations
in the Federally approved State Implementation Plan for the Commonwealth
of Pennsylvania. Also, the incinerator will comply with the State
Implementation Plan for the State in which it is located.
- Pennsylvania Solid Waste Disposal Regulation, PA Code Title 25, Chapter
75, Subchapter D, which govern the transportation, treatment, storage
and disposal of hazardous waste, (applicable) Transportation and
storage of wastes during this action will comply with these regulations.
Cost-Effectiveness
This alternative affords a high degree of overall effectiveness in not
only protecting the onsite residents as well as any future site visitor
from direct contact with the carbon waste pile, but also in reducing
future contamination migrating to the ground water. The U.S. EPA believes
that the costs of the selected remedy are proportionate to the overall
effectiveness it affords such that it represents a reasonable value for
the money.
-------
.'A3LE 7
SUMMARY OF COSTS
ALTERNATIVES 1 THROUGH 7
MW MANUFACTURING SITE, MONTOUR COUNTY, PENNSYLVANIA
Alternate No.
1
2
3
4 Baseline
4
Low Range
4
High Range
5 Baseline
5
Low Range
5
High Range
6
7
Capital Cost*
(S)
78,000
372,000
1,397,000
831,000
2,299,000
1,659,000
1,093,000
2,556,000
4,757,000
2,061,000
* There are no O&M costs associated with these
alternatives since all periods of remediation are
anticipated to require significantly less than 1
year of onsite activities. Other long term O&M
costs including monitoring will be addressed in the
forthcoming overall site RI/FS. As a result,
present worth costs are equivalent to capital
costs.
-------
Reduction of Toxicity, Mobility, or Volume
Alternative 2, Interim Capping, would not reduce the toxicity of volume
of the carbon waste but would provide some reduction in the mobility of
contaminants in the carbon pile by minimizing migration of water through
the waste.
with respect to the M.W. Manufacturing Site, Alternative 3, 4, 6, and 7
would reduce the overall toxicity and volume of contamination at the site
by completely removing the carbon waste pile from the site. Alternatives
4 and 5 would reduce the toxicity by removing a percentage of the organic
contaminants from the waste. Alternative 5 would reduce the mobility of
inorganic contaminants in the waste through onsite solidification, whereas
Alternatives 3, 4, 6, and 7 would reduce the mobility of contaminants, or
residual contaminants remaining after treatment, by placing the waste or
waste residuals in an offsite RCRA hazardous waste landfill. Alternatives
6 and 7, which include incineration, offer the greatest reduction in
toxicity and volume, because all of the organic contaminants would be
permanently destroyed along with approximately 80 percent of the carbon
waste.
Implementabili ty
The technologies proposed for all alternatives are, in general, demon-
strated and commercially available. With Alternatives 4 and 5, however,
treatability studies would be needed to determine the overall implement-
ability and operating conditions of the solvent extraction process.
With respect to ease of implementability, Alternatives 2, 3, and 7 would
be the most readily implementable because these alternative do not
involve the mobilization, operation, and.demobilization of onsite treat-
ment systems.
Cost
The total estimated costs of the remedial alternatives are summarized in
Table 7. Since onsite remediation activities are anticipated to require
less than one year, there are no O&M costs. Other long-term O&M consider-
ations, including monitoring, will be included in the overall site RI/TS.
Compliance witn ARARs
Alternative 1 (no action) has no ARARs. Alternatives 2, and 4 through 7
would comply with all ARARs. Alternative 3 would not comply with the
RCRA Land Disposal treatment standards for spent solvent waste.
Overall Protection of Human Health and the Environment
With the exception of Alternative l, No Action, all alternatives would
achieve the remedial, action objective of protecting the public health
from exposure risks (ingestion, inhalation, and dermal contact) associated
with the carbon waste pile and would decrease the current migration of
contaminants into the environment.
-------
TABLE 6
SUMMARY MATRIX FOH DETAILED EVALUATION Of ALTERNATIVES
MM MANUFACTURING SITE. MONTOUH COUNT*. PENNSYLVANIA
1 •
•a. 1
•a Action
•a. 2
Intel i* C«0p'*4
•a J
BBC«V«| lon/Ot 1 • 1 l«
IU««idau» M*>t*
Ludttll
Remedial Alternatives
•o. «
Kic*v«t tun/On* Ke
Solvent Kelt *ct ion/
Olltite Oik|K>»«l la
Ma. 4
K>i>v4l luu/Un* i It
Solvent Kit itcl ion/
Onsit* iial idil ic*«t tun/
Onutlii Oi*uak«l la
•o. b
I:MC«V«I kou/Oit* 1 1«
1 04: 1 iia i A 1 k on/Ot t ^ 1 1 tt
Ui*uob*l ot Akh In
U«x«l.dautt Mafclc
Landt il 1
Ha. 1
Int Him «l laa/Oi till*
lltfitffduut M«»l«
COMPLIANCE WITH MUUItt (CONTINUED)
•CCA
aa* M4
(ac
((••la*nt. •tai«9«.
•nd dt*aa*«l
laciltttas.
OHO«I*
a(
taclliiicc.
HCBA ic^ul^liuut «ml
ttaadaid* la< aunei »
•ad a|M<«la<* a(
fct«a«l4fda lai UWIIKCS
and apn(«iaik at
feiaoilAidft (a( awnci
aod a|w(«ta<« at
«SC> Aii
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TABLE 6
SUMMAHV MATRIX FOH DKTAIl.tO EVALUATION UK ALTKHNATIVKS
HW MAMUKACTUHINC SITE. MOMTOUH COUNTV. PENNSYLVANIA
Remedial Alternatives
•a. I
•u Action
Ma. I
Into im Capping
Ho. i
•acavat iou/oi ( k i t B
Biapoaal 10
Maiaidou* Macla
Landfill
Hu. «
Kiic4v«t ion/Oiiki In
OitMilv Dik|M>aial io
Maiaidou* Makta
Landfill
•u. &
C«c«vat iaa/Oa>itc
Salvaat Canadian/
Oak He Sol idit lotion/
Oak i In Oikpok*! la
•aaltai«idauk Landfill
Ho t>
KMC«V*I lull/On* 1 la
1 iiClilvl «l luu/OI 1 k 1 1«
Uiapo^Al ut Aftft In
U«<«iUuuk M«ktc
Ltfiidt II 1
•a. 1
K«t:«v4t loa/Otf •! t«
lut IIICIAI >aa/O(f >li«
Uikpukal at *•!> !•
U^^««luu« W««t«
Landfill
COMPLIANCE WITH AKAH3
Hot
•ugitiva •ajiaaioaa
• Claaa Al« Act
•ollutioa
•agulallon*
MBfkai piotactiou
• OSMA dout aaata
ganaialai aa4
tiantpof tai
lagulatian*.
HOT 1 (ank|M»i lat ion
ft anhpui tat tan ot
• ItCMA haxardou* **»(•
gttM.atoc aod
••9uiat ion*.
t rau*(M»i t«r
f «<|ui*t Aon*.
HOT If *u»|M>t tat toil
(•9,ulat ion*
fu^l I t we ••!*« tunk
• Clvdiii Air Act
r *
MUI a\M( UIUlCCI IUU
llul lll«| ICMCilldll IUI1
• OiU* (29 CCM fat Ik
i9iO, 1926. *H«J I9U4|
• MCMA naiaidou* M*»CC
gca«i atoi and
l ian*|»o< t«*r
t ««|ulal Ion* .
• fenitty 1 v«iiii *
ijcitei alur aaU
1 C<|ultf t 1011k .
UUY 1 1 4itk|>ui l«i mil
i c«ju lat t oiik
dui i n^ i CaMdiai ion
• Clean Air Act
• t*eniiky Ivauta Al i
Wo* *«il ui utec t l uu
dui IULJ icMdiai tuu
• O^Ma |29 Cm *»-»• i*
I91O. I92o. and tttu«)
*|*)n«i atui and
i a^ulat loo* .
•jcaci atoi and
l« *iia>u4if tcr
i ctjulai tun* .
DOT 1 t ..IIBpUl l«l IUII
i e«jul atl ion*
-------
TABLE 6
SUMMARY MATRIX fOH DETAILED EVALUATION OK ALTEHNATIVES
MM MANUfACTUHINC SITE. MONTOUH COUNTY. PENNSYLVANIA
Henedidl Alternatives
•a. 1
•a Acliaa
Ha. 2
Inianai Caftptaa,
Ma J
ftaca,vat tau/Ut 1 aila
Ha. «
8aca»«t lan/Onk i (•
Solvent Katiactlaa/
OttkilD Oi tpctal in
Haiaiduut Meat*
Lawllill
Ma. S
Kacavat ian/Onk He
Salvonl Kalian ion/
Ooklt«i Sal idit ica( lan/
Oaalte Ol*pat«l In
Huobaaaidaut Landtlll
Ma. b
K>i;avat Ban/Unk 1 1 a
Inclueiatlali/OI tklla
Uii>|jakal at Aall la
tt«**(dauk Mdkla
Laiidf ill
Ha. 1
•u"',uirii!«/o!«.u.
Uit|>akal at Aau In
Uaiaidaua Waate
•--ndtill
COMPL.IAMCB WITH ARARa (CONTINUED)
HCHA laod dikoakal
a Oa«k not caatfily
apeol aalwaata.
Ootite (uiface vatei
• Clean M*tef Act Hfl>t^>
• renaaylvaaia HPOKS
HCHA land illklMifeal
• May coeiply vith HI1AT
Ontitu •«*!!•€• wattfc
• Clean Uatef Ace HPUts
• reanaylvania HPUiS
..,ul.tia,i*
HCHA land diauakal
• May caouly with BUAT
a HtKjuKei tiealvd
Makta Ca be delikted
fenatylwaaia aalid
Maate dikfMikal
le^ulat lout
af lbl» AAAU
G«k,l. ku.Uc. -at«.
a Cleen Matci Act HPUKS
a faiiUkflvanla MVUktt
.e4ulat.u..k
HCHA laaU dl^tnikal
a Caaplick «llli MUAT
HtHA la,Hl d..|.U..l
a Cu«it>llek with MUAT
o, »»,«»! kol.ant.
-------
Ccnpliance with ARARs
This alternative would comply with all ARARs. See Table 6 for a summary
of significant ARARs.
Overall Protection of Human Health and the Environment
This alternative would achieve the remedial action objective of protecting
the public health from exposure risks (ingestion, inhalation, and dermal
contact) associated with the carbon waste pile and would provide a perma-
nent remedial solution to the waste pile with respect to the M.W. Manufact-
uring Site. Since the organics are destroyed and the ash taken offsite,
this material would no longer continue to contaminate the groundwater.
VIII. COMPARISON AMZM3 ALTERNATIVES
The remedial alternatives analyzed in detail in Section VII are compared
against each other in this section. The nine evaluation criteria used
in Section VII will be used for the comparison.
Short-term Effectiveness
With the exception of Alternative 1, No Action, all remedial alternatives
would provide protection of public health from exposure to the carbon
waste pile in the short-term. Alternative 2, Interim Capping, could be
implemented in the shortest time period, approximately one to two weeks
after the start of onsite remediation activities. .Alternatives 4 and 5
would require the longest periods of time to implement due to the need
for treatability studies. Once onsite action begins, all alternatives
could be implemented in a short amount of time (less than six months) due
to the relatively small quantity of carbon waste material.
Long-term Effectiveness
With respect to long-term reliability, Alternatives 2 and 5 present the
greatest uncertainty.. The resistance of the temporary cap to physical
and chemical degradation is not expected to exceed more than two years.
The long-term reliability of the solidification of this hazardous waste
has not been proven and must be evaluated through treatability studies.
Alternatives 6 and 7, which include incineration, provide the maximum
long term effectiveness because all of the organic contaminants would be
permanently destroyed along with approximately 80 percent of the carbon
waste. Alternatives 3 and 4, which would ultimately remove the carbon
waste material from the M.W. Manufacturing site and place the waste in a
RCRA hazardous waste landfill, would also be effective in the long term
but not as effective as Alternatives 6 and 7 due to the volume reduction
and destruction of the organics achieved by the incineration process.
-------
a RCRA hazardous waste landfill. This alternative would protect tl-.e
public health frcm exposure to the carbon waste by destroying the ::urbon
waste and contaminants and then removing the residual .ash frcm the .site.
Short-term Effectiveness
This alternative would remove all risks posed by the organic compounds
because they would be destroyed by incineration. Metals would remain in
the residual ash. which would be hauled offsite for disposal. This action
would protect the public health from exposure to the metals in the ash.
Long-term Effectiveness
There would be no remaining long-term risks associated with this alterna-
tive and no long-term management, operation, or maintenance requirements,
because the carbon waste pile would be incinerated in a short time period
and the ash completely removed from the site.
Reduction of Toxicity, Mobility, or Volume
with respect to the M.W. Manufacturing site, incineration of the carbon,waste
followed by complete removal of the ash from the site is a permanent remedial
action which reduces the overall toxicity and volume of contamination 'at
the site. All of the organic contaminants in the carbon waste would be
destroyed to the risk-based remedial action levels and the carbon waste
volume would be reduced by approximately 80 percent.
Residuals remaining after implementation of this alternative include the
incinerator ash, (approximately 130 tons), decontamination fluids, and the
waste water frcm air pollution controls. The ash would be hauled offsite
for disposal in a RCRA hazardous waste landfill and the waste waters would
be taken offsite for treatment.
Implementability
The technologies proposed for excavation, incineration, and offsite land-
filling are demonstrated and conroercially available. A clean area, large
enough, to fit two to three tractor trailers, is required to set up the
incinerator and material handling equipment. The incinerator will
require an auxiliary fuel source, potable water, and possibly electricity.
Cost
The estimated cost of this potential remedial alternative totals $4,757,000.
Since onsite remediation activities are anticipated to require less than
one year, there are no O&M costs.
Compliance with ARARs
This alternative will comply with all ARARs. See Table 6 for a summary
of significant ARARs.
-------
Overall Protection of Human Health and the Environment
This alternative would achieve the remedial action objective of protecting
the public health fron exposure risks (ingestion, inhalation, and dermal
contact) associated with the carbon waste pile and would provide a perm-
anent remedial solution to the waste pile with respect to the M.W.
Manufacturing Site. Since the organics are destroyed and the ash taken
off site, the materials would no longer continue to contaminate the
groundwater.
Alternative 7 - Excavation. Off site Incineration f
an f fSJte DiSPOSal Of Ah Tn E-te Tarrng Wa<;t:e
This alternative involves excavating the carbon waste pile, transporting
the waste off site to an incinerator facility, and then disposing the ash
in an off site RCRA hazardous waste landfill. This alternative would
protect the public health from exposure to the carbon waste by removing
the waste from the site and then destroying a significant percentage of
the carbon waste and contaminants by incineration.
Short-term Effectiveness
Protection of public health from exposure to the carbon waste pile would
be achieved upon removal of the entire carbon waste pile.
Long-term Effectiveness
There would be no remaining long-term risks associated with this alterna-
tive and no long-term management, operation, or maintenance requirements,
because the carbon waste pile would be completely removed from the site.
Reduction of Toxicity, Mobility, or Volume
Removal of the carbon waste from the site followed by incineration of the
waste is a permanent remedial action which reduces the overall toxic ity
and volume of contamination at the site. All of the organic contaminants
in the carbon waste would be destroyed to the risk-based remedial action
and the carbon waste volume would be reduced by approximately 80
Implementability
The technologies proposed for excavation, incineration, and off site land
filling are demonstrated and commercially available.
Cost
The estimated cost for this potential remedial alternative totals
$2,061,000. Since onsite remediation activities are anticipated to
require less than one year, there are no O&M costs.
-------
Overall Protection of Human Health and Environment
This alternative would achieve the remedial action objective of protect-
ing the public health from exposure risks (ingestion, inhalation, and
dermal contact) associated with the carbon waste pile and would provide
a permanent remedial solution to the waste pile with respect to the M.w.
Manufacturing Site. Since the wastes have been removed from the site
they would no longer continue to contaminate the groundwater.
Alternative 5 - Excavation.Onsite Solvent Extraction.
Qnsite solidification, and Onsite Disposal In Nonhazardous
fill
This alternative involves: excavating the carbon waste pile; treating
the waste onsite using a solvent extraction technology to remove organic
contaminants; stabilizing/solidifying the solvent extracted waste using
a cement/pozzoIan-based technology to immobilize heavy metal contaminants;
and then disposing the solidified waste onsite in a nonhazafdous landfill.
This alternative would protect the public health from exposure to the
carbon waste by treating/solidifying the waste to remove and imrobilize-
contaminants so that the waste could be delisted as a RCRA hazardous
waste and then placing the treated waste in an underground, nonhazardous
type landfill.
Short-term effectiveness
Protection of public health from exposure to the carbon waste pile would
be achieved upon onsite disposal of the treated/solidified carbon waste
material.
Long-term Effectiveness
The long-term reliability of solidification technology is unknown.
Environmental forces such as precipitation (which is slightly acidic)
infiltration, freezing/thawing, and wetting/drying due to ground water
contact may cause the solidified material to lose its structural integrity
over time, allowing contaminants to become more mobile. Leaching tests
and compressive strength tests will be conducted during the treatability
study to determine the integrity of the solid end product. Because wastes
are being left onsite, the mandatory 5-year review would be triggered.
Operation and maintenance activities would be necessary to ensure the future
integrity of the landfill cover.
Reduction of Itixicity, Mobility, or Volume
»
Solvent extraction would not reduce the overall volume of the carbon
waste, and although the process would reduce the toxicity of waste by
removing a percentage of organic contaminants, the waste would remain
highly toxic due primarily to the presence of high levels of lead.
-------
Solidification of the waste 'would increase the volume of the waste by as
nuch as 100 percent, tut would significantly reduce the rrobility of the
heavy metal contaminants in the waste.
Implementability
The technologies proposed for excavation, material handling, and onsite
landfilling are demonstrated and commercially available. The solvent
extraction and solidification processes have been demonstrated for
contaminated soils and sludges. Therefore, treatability studies
would be needed to determine the overall implementability and operating
conditions of the extraction and solidification processes used on the
carbon waste.
Cost
The cost variability of this alternative is mainly dependent on the type
of solvent extraction process used and the mobilization/demobilization
costs for the process. The corresponding low range, baseline, and high
range total cost estimates for this alternative (including solvent
extraction, solidification, and disposal are shown below:
Low Range $1,093,000 - •
Baseline $1,659,000
High Range $2,556,000
Compliance with ARARs
It is anticipated that the combination of solvent extraction and solidi-
fication will allow the treated waste to be delisted as a RCRA hazardous
waste.
There are no location specific ARARs associated with this remedial
alternative. See Table 6 for a summary of significant ARARs.
Overall Protection of Human Health and the Qrvironment
This alternative would achieve the remedial action objective of protect-
ing the public health from exposure risks (ingest ion, inhalation, and
dermal contact) associated with the carbon waste pile. The permanence
of this alternative is dependent on the long-term reliability of the
solidified waste which is unknown at this tune.
»
Alternative 6 ~ Excavation. Qnsite Incineration.
and Of fsite Disosal Of Ash In
This alternative involves excavating the carbon waste pile, incinerating
the waste onsite, and then transporting the ash for of fsite disposal at
-------
il
Alternative 3 - Excavation and Offsite
rcto115* Waste
This alternative involves excavating the carbon waste pile (approximately
636 cubic yards of carbon and 239 cubic yards of underlying soil) and
transporting it off site for disposal in a RCRA hazardous waste landfill.
This alternative was analyzed in the Focused Feasibility Study.
This waste has been determined to be an F001 spent-solvent waste, subject
to the RCRA Land Disposal Regulations and, as such, cannot be diposed of
in a hazardous waste landfill without prior treatment. This alternative,
therefore, does not comply with ARARs and no waiver is justifiable. Mb
further discussion of it will take place.
Alternative 4 - Excavation. Qnsite Solvent Extraction.
and Offsite Disposal In HaTLardQiiq Maqft=» r^Tvi-^i i \
This alternative involves excavating the carbon waste pile, treating
the waste onsite using a solvent extraction technology, and then
transporting it Offsite for disposal in a RCRA hazardous waste landfill.
This alternative would protect the public health from exposure to the -
carbon waste by treating the waste and then removing the waste pile
from the site. " ' -
Short-term Effectiveness -,
Protection of public health from exposure to the carbon waste pile would
be achieved upon removal of the entire carbon waste pile from the M.W.
Manufacturing site.
Long-term Effectiveness
There would be no remaining long-term risks associated with this alterna-
tive and no long-term management, operation, or maintenance requirements,
because the carbon waste pile would be treated in a short time period and
then completely removed from the site.
Reduction of Tbxicity, Mobility, or Volume
With respect to the M.W. Manufacturing Site, solvent extraction treatment
followed ty complete removal of the carbon waste pile from the site is
a permaoint remedial action which reduces the overall toxicity and volume
of contamination at the site.
Solvent extraction would not reduce the overall volume of the carbon
wast£ and although the process would reduce the toxicity of the waste
-------
by removing a percentage of organic contaminants, the waste would
remain highly toxic due primarily to the presence of high levels of
lead. Disposal of the waste in an offsite, RCRA hazardous waste landfill
'would significantly reduce the mobility of contaminants in the waste by
placing the waste in a double-lined, multi-layer, capped landfill with a
leachate detection and collection/treatment system.
Implementabi 1 i ty
The technologies proposed for excavation, material handling, and offsite
landfilling are demonstrated and commercially available although the
number of RCRA permitted landfills is limited. Solvent extraction processes
have been demonstrated for many contaminated soils and sludges. Therefore,
treatability studies would be needed to determine the overall implementability
and operating conditions of the extraction process used on the carbon
waste.
Cost
The costs of this alternative are mainly dependent on the type of solvent
extraction process used and the mobilization/demobilization costs for
this process.
The corresponding low range, baseline, and high range cost estimates for
this alternative, based on three different commercially available solvent
extraction processes, are shown below:
Low Range $831,000
Baseline $1,397,000
High Range $2,299,000
Compliance with ARARs
It is expected that the onsite solvent extraction treatment process would
treat the carbon waste to the Best Demonstrated Available Technology
(BCftT) treatment standards for spent solvents, which would allow the
waste to comply with the RCRA land disposal regulations (40 CFR Part
268).
There are no location-specific ARARs associated with this remedial alter-
native. See Table 6 for a summary of significant ARARs.
-------
Short-term Effectiveness
This alternative provides no short-term protection of public iieaith
fron exposure to the carbon waste pile.
Long-term Effectiveness
This alternative does not provide any reduction in the magnitude of
existing or future health. ris)cs associated with the carbon waste
pile.
Reduction of Toxic ity, Mobility, or Volume
This alternative does not reduce the toxicity, mobility, or volume
of contaminants in the carbon waste pile.
Implementabi 1 i ty
There are no implementability considerations associated with this
alternative. .
Cost " J
- • i
There are no capital or operating costs associated with this alternative^
Compliance with ARARs
There are no ARARs directly associated with No Action.
Overall Protection of Human Health and the Environment.
This alternative would not achieve the remedial action objective
of protecting the public health from exposure risJcs (ingestion,
inhalation, and dermal contact) associated with the carbon waste
pile. Additionally, contaminants would likely continue migrating
into the groundwater.
Ar"P3.t ive 2 ~ Intarun
This alternative involves the installation of a low permeability,
synthetic inanbrane cap over the carbon waste pile to provide an
interim •oacure of protection until the total site remediation is
evaluatflft-in the corplete RI/TS and subsequently implemented. A
3-inch layer of soil would be placed between the membrane and the
waste to prevent degradation of the membrane by the solvents.
Short term Effectiveness
Protection of public health from exposure to the carbon waste pile
would ijimediately be achieved upon installation of the synthetic
cap. In addition, the cap would reduce contaminant migration from
the carbon waste pile into underlying soil and groundwater.
-------
Long-term Effectiveness
Tills alternative is not considered effective in the long term since
the membrane win degrade and the system integrity win be affected
by erosion, weathering, and general degradation. The cap would not be
designed for long-term effectiveness as the objective is immediate
protection.
Reduction of Toxicity, Mobility, or Volume
This alternative would not reduce the toxicity or volume of contami-
nants in the carbon waste pile or the volume of carbon material itself and
does not provide permanent, irreversible treatment of the carbon waste
pile. This alternative would provide some reduction in the mobility
of contaminants in the carbon pile by minimizing migration of water
through the waste. The soil layer between the synthetic cap and the
waste would increase the quantity of contaminated material to be
remediated by approximately 13 percent.
Implementabi li ty
»
The technologies proposed for capping are all demonstrated and ;
ccmnercially available. *
Cost
The estimated cost for this potential remedial alternative totals $78,000.
Since onsite remediation activities are anticipated to require significantly
less than one year, there are no 0 & M costs.
Compliance with ARARs
RCRA closure requirements (40 CFR Parts 264.228, 264.258, and 264.310)
are applicable and Pennsylvania closure requirements (PA Code, Title 25,
Chapter 75, Subchapters c and D) are relevant and appropriate. However,
because the cap is designed as an interim remedy, these ARARs win not be
met at this time. They will be complied with at the close of remedial
activities at the site.
There are no location-specific ARARs associated with this remedial
See Table 6 for a summary of significant ARARs.
Overall Protection of Human Health and the Environment
%
r' •
This alternative would achieve the remedial action objective of
protecting the public health from exposure risks (ingest ion,
inhalation, and dermal contact) associated with the carbon waste
pile but would not provide a permanent remedial solution to the
waste pile. This alternative would provide an additional benefit
of controlling the continuing ground water degradation resulting
from this material.
-------
TA3LE 5
RISK-BASED ACTION LEVELS
CARSON WASTE PILE
MW MANUFACTURING SITS
MONTOUR COUNTY, PENNSYLVANIA
Contaminant
toluene
tetrachloroethene
trichloroethene
1,1,2,2-tetrachloroethane
1, 1, 2-trichloroethane
methylene chloride
bis( 2-ethylhexyl)phthalate
di-n-butyl phthalate
copper
Concentration
for 10-6 Risk
(mg/kg)
*
lxlO-«
1x10-5
1x10-6
1x10-6
1x10-5
1x10-4
200**
800**
Concentration
for 10"* Risk
(mg/kg)
*
5x10-4
IxlO-3
lxlO-«
5x10-4
1x10-3
2x10-3'
200**
800**
* No action level required for this contaminant based on
maximum concentrations detected on site.
** Action level for this noncarcinogen based on total Hazard
Index £ 1.0.
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