PB96-963904
EPA/ROD/R03-96/220
July 1996
EPA Superfund
Record of Decision:
Revere Chemical Site (O.U. 2),
Nockamixion Township, PA
6/20/1996
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RECORD OF DECISION
REVERE CHEMICAL SITE
OPERABLE UNIT TWO
DECLARATION
SITE NAME AND LOCATION
Revere Chemical Site
Operable Unit Two
Nockamixion Township
Bucks County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
Operable Unit Two ("OU2") at the Revere Chemical Site ("Site") in
Nockamixon Township, Bucks County, Pennsylvania, developed and
chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980, as amended,
("CERCLA") 42 U.S.C. §§ 9601 to 9675 and to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan ("NCP"), 40 C.F.R. Part 300. This decision is
based on the Administrative Record file for this Site.
The Commonwealth of Pennsylvania Department of Environmental
Protection ("PADEP") has indicated agreement with the selected
remedy, No Further Action With Stream Corridor Monitoring.
However PADEP does not concur with EPA's assessment that Act 2 is
not an ARAR for this Site and asserts that EPA has not complied
with the statutory requirements for the selection of a remedy.
ASSESSMENT OF THE SITE
After consideration of the existing and future risks posed to
human health and the environment, EPA's selected remedy for the
contaminated ground water and stream sediments at this Site is No
Further Action with Stream Corridor Monitoring. The shallow
ground water unit beneath the Site is contaminated with organic
chemicals above Maximum Contaminant Levels ("MCLs") established
under the Federal Safe Drinking Water Act ("SDWA"), 42 U.S.C. §§
300 (f) to 300{j-26). For the selected remedy, MCLs have been
identified as ARARs by EPA but are being waived under Section
121(d)(4k(c) of CERCLA, 42 U.S.C. § 9621 (d)(4)(c) as technically
impracticable from an engineering perspective. Based on the
information collected to date, EPA has determined that no
additional remedial actions, other than those already selected as
part of the Operable Unit One ("OU1") ROD for the Site, are
required to ensure protection of human health and the
environment. All the components of the OU1 remedy should be
completed in the next twenty-four months. The Site will then
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qualify for inclusion in the "sites awaiting deletion"
subcategory of the Construction Completion category of the
National Priorities List.
DESCRIPTION OF THE REMEDY
This Operable Unit is the second and final operable unit ROD for
the Site. This ROD addresses shallow ground water contamination
and mercury-contaminated sediments in the stream corridor. The
selected alternative for OU2 is No Further Action with Stream
Corridor Monitoring. The stream corridor monitoring will be
conducted annually for seven years to ensure that the OU1 remedy
is.mitigating adverse impacts to the onsite tributaries. This
data will be evaluated by EPA in consultation with PADEP to
determine whether additional future monitoring will be required.
The ground water will be monitored pursuant to the Remedial
Action selected in the OU1 ROD.
STATUTORY DETERMINATIONS
Pursuant to duly delegated authority, I hereby determine,
pursuant to Section 104 of CERCLA, 42 U.S.C. § 9604, that the
selected remedy is protective of human health and the
environment. Although no.further remedial actions will be taken,
ground water and stream corridor quality at and in
the vicinity of the Site will be reviewed within five years in
accordance with Section 121(c) of CERCLA, 42 U.S.C. § 9621(c) to
ensure that human health and the environment continue to be
adequately protected.
Thomas Voltaggrio f s' Date
Hazardous Wasie_/^i^ision Director
Region III
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TABLE OF CONTENTS
I. SITE NAME, LOCATION, AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITY .. . 1
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
IV. SCOPE AND ROLE OF THE RESPONSE ACTION WITHIN SITE
STRATEGY 5
V. SUMMARY OF SITE CHARACTERISTICS AND EXTENT OF
CONTAMINATION 6
VI. SUMMARY OF SITE RISKS 11
VII. DESCRIPTION OF THE SELECTED ALTERNATIVE ....... 14
No Further Action with Monitoring 14
VIII. BASIS FOR ARAR WAIVER 16
IX. EXPLANATION OF SIGNIFICANT CHANGES 17
X. RESPONSIVENESS SUMMARY 17
Appendix A Figures
Appendix B Tables
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RECORD OF DECISION
REVERE CHEMICAL SITE OPERABLE UNIT TWO
DECISION SUMMARY
I. SITE NAME, LOCATION, AND DESCRIPTION
The Revere Chemical Site (the "Site") is located east of U.S.
Route 611 approximately one mile south of Revere in Nockamixon
Township, Bucks County, Pennsylvania. The Site was a former
metal reclamation facility located on an approximate 113-acre
parcel of property (Figure 1, Site Vicinity Map) which includes
two unnamed tributaries of Rapp Creek. Rapp Creek is a tributary
to Tinicum Creek, which flows into the Delaware River,
approximately 4 miles from the Site. Rapp Creek has been
nominated to the Pennsylvania Scenic Rivers System under the
designation of Scenic, First Priority - Group A, Water Quality
Group 1. The area surrounding the Site includes recreational
streams, forests, fields, and Pennsylvania State Game Lands.
Nockamixon State Park, located approximately 4,700 feet southwest
of the Site contains Nockamixon Lake which has a surface area of
1,450 acres. State Game Land is located approximately 4,700 feet
northeast of the Site. The Site is bounded on the south, east,
and west by farm land, and Cotner Trailer, a commercial operation
that manufactures horse trailers, abuts the Site to the north.
II. SITE HISTORY AND ENFORCEMENT ACTIVITY
Facility documents regarding the Revere Chemical Company were
destroyed in a 1984 fire 'on the Site. Documents from EPA, the
Pennsylvania Department of Environmental Protection ("PADEP") and
the Bucks County Department of Health files provided most of the
information regarding the historical layout of the Site and
facility processes.
Beginning in approximately 1963, Echo, Inc. ("Echo") operated a
reclamation facility. Echo's operations included metals
reclamation from printed circuit boards, recycling of spent
chromic acid, recovery of copper from plating solutions and
production of copper chemicals. From 1963 to 1969 the Site was
operated at various times by Echo, the DeRewal Chemical Company
and the Revere Chemical Company. The companies arranged for the
transport.and onsite treatment of hazardous substances, including
waste metal plating and etching solutions.
The area of the Site used for the processing of materials
("Process Area") covered approximately 25 acres. The Process
Area, now enclosed by a fence, contained several buildings and
structures that were used during the metal reclamation
operations. Also included in this area were 19 storage and/or
process lagoons; a waste lagoon; and a fresh water pond. The
East and South Spray fields are located outside the Process Area.
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They were used for liquids disposal during the metal reclamation
operations.
Detailed descriptions of past Site operations are unavailable.
Similarly, no detailed records regarding the types and quantities
of sludge and plating materials stored on the Site during the
years of operation are available. However, samples of materials
in the process basins and lagoons on Site were collected by the
Commonwealth of Pennsylvania, Department of Health ("PADOH"),
PADEP's predecessor, in March 1970. On the basis of this data,
it was concluded that facility processes used chromic acid,
copper sulfate, ammonia, ferric chloride, nickel, and sulfuric
acid solutions.
In 1968, the Bucks County Department of Health determined that
the facility had never submitted the required Pollution Incident
Prevention Plan. Subsequent inspections revealed that waste
material from the.facility was escaping from the processing and
holding lagoons on Site, and was entering the unnamed tributaries
of Rapp Creek. The State and County Health Departments took
enforcement action against the company in an attempt to bring
them into compliance with existing laws. The operators abandoned
the Site in December 1969.
PADOH performed a response action at the Site during 1970 and
1971. An estimated 3.5 million gallons of waste sludges and
liquids were removed.
Pumpable sludges were removed and disposed of off-site. The
remaining sludges were fixed with lime, sodium sulfide and sodium
sulfite, mixed with native soils, and buried onsite in process
lagoons, and storage lagoons. As a result of this remedial
action, the Process Area has been extensively disturbed. No
process or storage lagoons remain. Drums were reported to have
been crushed and buried in former storage lagoon C and former
process lagoon 7 during this action. (Figure 2, Site Features)
Some of the lagoons were closed by the operator during the period
of Site operation and the remainder have been closed during the
remedial action by the PADOH. Present ground cover in the
Process Area consists of rock fragments, soil, and miscellaneous
debris (trash, uprooted brush, and small trees). For the most
part, the ground surface is devoid of vegetation. The remaining
88-acre portion of the Site that was not used for metal
reclamation is mostly vegetated.
EPA performed additional response work at the Site from March 28
through April 17, 1984. This included the removal of 30 drums
containing chromic acid and etching wastes, and 30 cubic yards of
chemical solids from surface soils. Liquid wastes went to
Frontier Chemical in Niagara, New York, and solid wastes went to
Fondessy in Oregon, Ohio.
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The Site was placed on the National Priorities List ("NPL") on
July 22, 1987. The NPL is a list of hazardous waste Sites across
the country in need of remedial evaluation and response. The
Site scored 31.31 under EPA's Hazard Ranking System, which is
above the level of 28.5 needed to be placed on the NPL.
In December 1988, EPA entered in to an Administrative Order on
Consent Order with .the following respondents to conduct a
Remedial Investigation and Feasibility Study ("RI/FS"): AT&T
Technologies, Inc.; Carpenter Technology Corporation;
International Business Machines Corporation; and Yates
Industries, Incorporated. The Respondents are also known as the
Revere Steering Committee (hereinafter referred to as "RSC" or
"Respondents"). Currently the RSC is comprised of AT&T
Corporation, Inc. (currently Lucent Technologies), AT&T Global
Information Solutions, Inc. (currently NCR Corporation),
Carpenter Technology Corporation, General Electric Company, GTE
Operations Support Incorporated (as successor to the interests of
GTE Products Corporation), International Business Machines
Corporation, Square D Company (on behalf of Yates Industries),
and Unisys Corporation.
The first task performed under the RI was installation of an 8-
foot-high security fence around the Process Area during the Phase
I RI in October 1989.
Environmental conditions at the Site were initially characterized
through implementation of the Phase I and Phase IA RIs. The
results of these investigations are detailed in reports dated
March 14, 1990, and July 23, 1990, respectively, prepared by
Dames &'Moore on behalf of the RSC and are included in the
Administrative Record for the Site. The results of these
investigations indicated that further study was necessary.
The Phase II investigation consisted of the additional collection
and analysis of samples to further characterize Site soil, ground
water, surface water, stream sediment, and the contents of the
onsite septic tank and aboveground storage tank. The results
indicate that the soil is contaminated with heavy metal and
organic compounds. Some heavy metals were also detected in the
sediments in the onsite tributaries to Rapp Creek. The ground
water in the shallow ground water unit contains organic
chemicals.. The deep ground water aquifer is not contaminated.
Chrysotile asbestos was detected in samples collected from the
corrugated material covering the process building, the shingle
pile, and the white material covering aboveground storage tank 1
(AST 1). Detailed results of the Phase II investigation are
provided in the Phase II Remedial Investigation Report dated May
19, 1993.
In December 1991, EPA issued a Unilateral Administrative Order
("UAO") for removal response activities to all identified PRPs. •
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The RSC responded and erected temporary soil erosion and
sedimentation control structures, and conducted removal
activities with regard to drums and soil staged onsite during the
Phase II RI. The RSC completed the work in May 1992.
Following the completion of the Phase II RI, EPA released a
Proposed Plan to address all aspects of the Site in July 1993.
That Proposed Plan included shallow ground water extraction as
part of the proposed remedy for the Site. Based upon comments
submitted and the complexity of the issues, EPA divided the Site
into two operable units to facilitate the remedial activities at
the Site. An operable unit is a portion of an overall response
action that, by itself, eliminates or mitigates a release, a
threat of a release, or an exposure pathway; however, it may
reflect the final remediation of a defined portion of a site. At
this Site, Operable Unit One addresses the contaminated soil,
solid wastes, and debris. Operable Unit Two addresses ground
water and stream sediment.
EPA issued the Operable Unit One Record of Decision ("OU1 ROD")
for the Site on December 27, 1993. The major components of the
OU1 ROD remedy are: offsite disposal of solid wastes and debris;
treatment of VOC contaminated soil by insitu vacuum extraction;
source containment by slurry wall; source containment by capping;
fencing to limit access to the Site; Site restoration by
revegetation; deed restrictions and long-term ground water
monitoring.
In the OU1 ROD, EPA deferred the selection of a remedy for
shallow ground water and stream sediments until additional data
could be gathered to evaluate the practicability of actively
pumping ground water to achieve cleanup, and to assess the
natural attenuation rate of aquifer contaminants after source
control measures have been implemented. Additional stream
corridor sediment sampling was conducted to further define
mercury contamination in the stream corridor sediments and to
evaluate if active remedial options for the stream sediment were
necessary.
In December 1994, EPA issued a UAO that required the PRPs to
implement the remedial alternative selected by EPA in the OU1
ROD. The RSC complied with the UAO. Remedial Design/Remedial
Action (RD/RA) work was initiated on January 13, 1995.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan for the Revere Chemical Site was
completed in June 1989. This document lists contacts and
interested parties throughout government and the local community.
It also establishes communication procedures to ensure timely
dissemination of pertinent information. The Comprehensive
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Remedial Investigation Report For Operable Unit 2; the
Feasibility Study for Groundwater (OU2) and the Proposed Plan for
the Site were released to the public as part of the
Administrative Record on April 29, 1996, in accordance with
Sections 113(k)(2)(B), 117(a), and 121(f)(l)(G) of CERCLA, 42
U.S.C. §§• 9613 (k) (2) (B) , 9617 (a) , and 9621 (f) (1) (G) . These and
other related documents form the Administrative Record for the
Site, which is located at the U.S. EPA Region III Office, 841
Chestnut Building, Philadelphia, Pennsylvania, 19107; and at the
Site Repository: Nockamixon Township Building, Center Hill and
Lake Warren Roads, Ferndale, Pennsylvania 18921.
A public meeting was held on May 15, 1996 to discuss the results
of the RI/FS and the preferred alternative as presented in the
Proposed Plan for the Site. Notice of the Proposed Plan and
public meeting was published in two local newspapers of general
circulation: The Morning Call (April 29,1996); and the Bucks
County edition of The Doylestown Daily Intelligencer (April 28,
1996). Additionally, copies of the Proposed Plan were mailed to
residences in the vicinity of the Site and to other interested
parties on the Site mailing list.
In accordance with 40 C.F.R. § 300.430 (f)(3)(F), all significant
comments on the Proposed Plan which were received by EPA prior to
the end of the public comment period, including those expressed
orally at the public meeting, are addressed in the Responsiveness
Summary which is attached to this Record of Decision ("ROD").
A copy of the transcript of the public meeting has been placed in
the Administrative Record File.
IV. SCOPE AND ROLE OF OPERABLE UNITS
As set forth above, EPA had divided the Revere Chemical Site into
two operable units:
OU1 • Contaminated soil areas;
Solid waste and miscellaneous debris.
OU2 • Ground water and
Mercury-contaminated stream sediments.
Offsite disposal of solid wastes and debris, drum excavation of
Lagoon C, and the demolition of the Process Building were
completed in the Spring of 1996. The Remedial Design for the
remaining portions of the OU1 remedy is still underway. EPA
expects the OU1 remedy to be completed in the next twenty-four
months.
This ROD addresses OU2 and is the final ROD for the Site. The
remedy addresses ground water contamination and contamination of
the onsite stream corridor sediments by mercury.
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V. SUMMARY OP SITE CHARACTERISTICS AND EXTENT OP CONTAMINATION
The Site is situated in the portion of the Piedmont Physiographic
province designated as the Piedmont Upland which is characterized
by gently rolling hills and sloping topography. Elevations at
the Revere Chemical Site range from approximately 520 feet above
mean sea level at the north corner of the Site to approximately
390 feet above mean sea level along Rapp Creek and its
tributaries at the southwest property boundary. Two types of
wetlands, Riverine and Palustrine, are found on the Site as well
as the endangered floral species Tomanthra auriculata (false
foxglove).
The Site is primarily drained-by the east and west tributaries to
Rapp Creek that join in the southeast portion of the Site and
discharge to Rapp Creek approximately 300 feet beyond the
property boundary.
The primary source of drinking water for the businesses and homes
surrounding the Site is ground water. Private wells pump ground
water from the Lockatong Formation.
Soil Characteristics
The predominant soil types at the Revere Chemical Site are the
Abbottstown Series, Alluvial Land, Bowmansville Series, Lansdale
Series, and Urban Land.
The Abbottstown Series consists of deep, nearly level to sloping
soils on uplands. They are formed at the base of slopes, on side
slopes, and on broad ridge tops in loamy material weathered from
red and brown shale and sandstone.
Alluvial land appears on the floodplains of small streams.
Moderate stands of moisture tolerant trees grow in some areas of
Alluvial land.
Bowmansville Series consists of deep, poorly drained, nearly
level soils on floodplains. The Bowmansville Series forms along
small meandering streams in loamy alluvium that washed from
upland soils underlain by shale and sandstone.
Lansdale Series consists of deep, well-drained, soils on uplands.
These soils occur on side slopes and ridges, and form loamy
material weathered chiefly from brown and yellow-brown shale and
sandstone.
Most areas .of Urban Land have been graded, and the original soil
material and structure have been disturbed, filled over, or
otherwise destroyed. Urban land appears in highly developed
areas of Bucks County.
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Surface Drainage
Site drainage is characterized by two stream channels (the "East"
and "West" tributaries) that form an onsite confluence and
discharge to Rapp Creek approximately 400 feet southeast of the
Site (see Figure 3). Rapp Creek flows into Tinicum Creek, which
in turn empties into the Delaware River. The Delaware River is
approximately four miles from the Site.
Both tributary streams are bedrock-base streams that flow
intermittently in response to precipitation events.
Geology
The area surrounding the Site is underlain by various members of
the Triassic-age Newark Group. The Lockatong Formation which
underlies the Site is fairly homogeneous. It is composed of
black to dark-gray, thickly-bedded argillites, with local
occurrences of thin-bedded black shales. The Lockatong and
Brunswick Formations are interbedded in the Site vicinity. The
Brunswick Formation ranges in composition from a thick-bedded,
resistant red to dark-gray argillite to a thin-bedded, fissile,
red shale, and siltstones. Fractures within the Lockatong and
Brunswick Formations are found along bedding planes and as joints
cutting across beds. The degree of fracturing is dependent on
the thickness and brittleness of the beds. Bedrock is at ground
surface to a depth of approximately 15 feet below ground surface.
Hydrogeo1ogy
The primary porosity and associated permeabilities of the
Lockatong and Brunswick Formations are very low. However, the
development of fractures in the bedrock can increase permeability
through secondary porosity. Regional and site-specific
information on ground water flow in the Lockatong Formation
indicates restricted ground water movement through small
fractures (or cracks) in bedrock. The Lockatong Formation is
utilized as an aquifer for residential and commercial purposes
throughout Bucks County, including the Site vicinity.
The aquifer system at the Site consists of a shallow ground water
unit and a deep ground water unit which are separated by a semi-
permeable black shale unit (aquitard). Geophysical logs from the
RI (temperature, fluid resistivity, and brine trace logs)
indicated there is little vertical ground water movement between
the shallow zone and the unimpacted deeper aquifer at the Site.
In addition, shallow ground water in the Process Area at the Site
probably discharges (through seeps) to the onsite tributaries.
Sampling results indicate the limits of contamination do not
extend to the tributaries.
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The shallow zone is a low-permeability, fractured-rock ground
water unit with few fracture interconnections. The results of
the RI hydrologic evaluations indicate that the hydraulic
conductivity of the shallow zone is extremely low resulting in
very low ground water flow and very slow migration of impacted
ground water beneath the Process Area. The lack of fracture
interconnection may partially explain why ground water movement
in the shallow ground water unit is minimal and has resulted in
low-yielding wells.
Ground Water Investigation
The hydraulic conductivity of the shallow bedrock ground water
unit at the Site, is primarily controlled by fractures and is
relatively low. Ground water flows from the northwest corner of
the Site, downslope to the unnamed tributaries. Shallow ground
water from the south and east portions of the Site (spray fields)
also- flows toward the onsite tributaries. Shallow ground water
from the northwest corner and the south and east portions of the
Site converges at the tributaries and discharges to the creek.
Sampling results indicate that contamination does not extend to
the tributaries. Deeper ground water may flow beneath the creek.
Shallow and deep ground water flowing beneath the Site are
separated by a series of black unfractured shale beds. These
beds occur at around 60 feet below ground surface and cause the
ground water flow to behave as two systems. Ground water in the
deeper flow system is not affected by the presence of the
tributaries. Flow in the deeper system is to the southeast.
Volatile organic contaminants ("VOCs") were detected in 7 of the
10 shallow ground water unit monitoring wells at the Site. See
Figure 3 for the locations of the ground water monitoring wells.
These wells were all completed at a depth above the unfractured
black shales.
The primary VOC contaminant, trichloroethene ("TCE") was detected
in the shallow zone within a limited area of the Process Area (in
the vicinity where the greatest concentrations of VOCs were
detected in soil). The greatest TCE concentration was detected
at a concentration of 220 parts per billion ("ppb") or micrograms
per liter (ug/1) in monitoring well MW-14. The Maximum
Contaminant Level ("MCL") for TCE is 5 ppb. MCLs are
enforceable, health-based drinking water standards established
under the Safe Drinking Water Act ("SWDA"), 42 U.S.C. §§ 300(f)
to 300(j-26). Table 1 is a summary of detected VOC analytical
data of the onsite monitoring wells from all the sampling events
conducted during the RI.
Other' VOCs detected in shallow ground water include methylene
chloride, carbon disulfide, trichloroethane, tetrachloroethylene,
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and toluene. Each of these contaminants was well below its
respective MCL and, in all cases, was less than 1 ppb.
1,2,4-trichlorobenzene ("TCB") was detected at 90.2 ppb and 1,2-
dichlorobenzene ("DCB") was detected at 2.31 ppb only in MW-4
during the OU2 sampling round. These semi-volatile contaminants
were also detected at similar concentrations in the Phase II RI
sampling rounds in only this well, MW-4, at concentrations
ranging from 41 ug/1 to 150 ug/1 for TCB and at concentrations
ranging from 3 ug/1 to 5 ug/1 for DCB. The MCL for TCB is 70
ug/1. The MCL for DCB is 600 ug/1.
TCE and TCB concentrations in ground water at the Site appear to
be limited to the northwest portion of the Process Area. Neither
TCE nor TCB were detected in any of the four quarterly ground
water samples collected during the Phase II RI from monitoring
wells MW-ll, MW-5 & MW-10. These wells were all completed at a
depth below the black shales in the deep aquifer.
Bis(2-ethylhexyl)phthalate ("BEHP") was detected in the following
wells: MW-2, MW-5, MW-8, MW-10, MW-ll, and MW-12 at concen-
trations ranging from 3 ppb to 42 ppb. The MCL for BEHP is 6
ppb. '
Infrequent detection of the organic compounds acetone, methylene
chloride, and carbon disulfide in the monitoring wells sampled
does not indicate that the Site is a source of these compounds.
The detected organic compounds acetone and methylene chloride are
common laboratory contaminants and were detected in blank samples
(i.e., control samples .used to determine if contaminants are
originating from sampling and analysis procedures).
No pesticides, PCBs, or acid extractable organic compounds
("AEs") were detected in any of the onsite ground water samples.
With the exception of sporadic detections of lead above EPA
Drinking Water Action Level (15 ppb) and one single detection of
arsenic in the filtered sample from MW-9, inorganics have not
been detected in ground water above MCLs during any phase of the
RI.
The site-specific ground water quality data that has been
collected over the course of the entire RI from 1990-1995
indicates that the contaminated ground water has not migrated .
substantially since disposal activities at the Site ceased in
1969. In addition, the low hydraulic conductivity of the shallow
ground water unit indicates that it is not likely that it will
migrate in the future. Ground water in the shallow zone
discharges to the onsite tributaries. Sampling results indicate
the limits of contamination do not extend to the tributaries.
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Off-Site Well Sampling Results
TCE and 1,1,1-trichloroethane ("1,1,1-TCA") were detected in one
offsite residential well south of the Site during round one
ground water sampling at estimated concentrations of 2 ug/1 and 3
ug/1, respectively. These concentrations are below MCLs for TCE
(5 ug/1) and 1,1,1-TCA (200 ug/1). TCE was also detected in
round four ground water samples collected from an offsite
residential well north of the Site at 0.397 ug/1 and at an
offsite residential well west of the Site on the south side of
Route 611 at a concentration of 0.422 ug/1. Each of these
concentrations is less than the MCL for TCE.
With the exception of lead that was detected in the filtered
ground water sample collected from an offsite residential well
north of the Site during round one sampling, none of the metals
or hexavalent chromium concentrations detected exceed MCLs in
either the round one or roun'd four filtered ground water samples
collected from the residential wells.
No VOCs, semi-volatiles, or PCBs were detected in the Cotner
ground water sample collected during round one. Lead was
detected at a concentration that exceeded the MCL in the
unfiltered ground water sample collected from the Cotner well
during round one. No metals were detected above MCLs in the
filtered samples.
Ground water elevation data obtained for residential wells in the
Site vicinity and the results of a ground water elevation study
conducted in the Site vicinity by the United States Geological
Survey ("USGS") indicate that the Site is hydraulically
downgradient of the residential wells that were subject to ground
water sampling and analyses during the Phase II RI. Therefore,
it is concluded that constituent concentrations detected in off-
site well water samples are not attributed to the Site.
Surface Water and Sediment Sampling Results
No VOCs, semi-Volatiles, pesticides, or PCBs were detected in any
of the surface water or stream sediments samples during the RI.
During Phase I and Phase II several Site-related metals detected
in surfafce water and sediment exceeded levels detected in
background samples. Copper, chromium and mercury were detected
in tributary sediment. Copper and manganese were detected in
surface water samples at concentrations that exceed their
corresponding background .level. Mercury was not detected in
background sediment samples.
Table 2 is a comparison of inorganic analytical results of
surface water samples to background surface samples. Table 3 is
a comparison of inorganic analytical results of sediment samples.
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to background sediment samples. Figure 3 shows the location of
the surface water and sediment samples for the Phase I and Phase
II sampling events. Table 4 is a comparison of the analytical
results for surface water samples to Pennsylvania Water Quality
Criteria where the criteria were exceeded.
OU2 Additional Stream Sediment Sampling For Mercury
The objective of the additional OU2 stream corridor sampling was
to further evaluate potential Site-related impacts regarding
mercury concentrations in sediment within the onsite tributaries.
The OU2 sampling consisted of collection and analysis of sediment
samples from upstream (background) locations, onsite locations,
and offsite locations between the southern property boundary and
the confluence of the tributaries with Rapp Creek. The point of
convergence of the tributaries with Rapp Creek occurs at an
offsite location beyond the southern property boundary.
Observations made during the selection of sediment sampling
locations suggested that the majority of sediment that enters the
stream is not deposited on the bedrock base of the tributaries;
rather, the fine-grained deposits are present along the stream
banks and at inter-stream bars where flow velocities decrease.
Sediment samples were collected from (14) fourteen locations
within the onsite tributaries and along the banks of the
tributaries where fine-grained sediment accumulations are
present. Mercury was detected in sediment collected from three
locations: Sediment locations TES003, TES004 and TES005. (See
Figure 3 for locations and analytical results.) Replicate
samples were collected at location TES005. Samples from these
locations contained mercury above the detectable concentrations
of 0.1 mg/kg or parts per million ("ppm"). No other samples
contained mercury concentrations above the detectable
concentrations. The greatest mercury concentration (0.64 mg/kg
or ppm) was detected at the sample location TES003 immediately
adjacent to a large eroded embankment where surface water runoff
has historically discharged from the Site to the east tributary.
Based on the sediment transport and deposition characteristics of
Rapp Creek and the relatively low levels of mercury detected
during additional sampling events, EPA determined that further
delineation of mercury contamination in Rapp Creek and its
tributaries (adjacent and downstream of the Site) was not
necessary.
VI. SUMMARY OF SITE RISKS
An assessment of the potential risks posed to human health and
the environment was completed in accordance with the NCP [40
C.F.R. 300.430(d)]. The results of the baseline risk assessment
are used to determine whether remediation is necessary, to help
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provide justification for performing the remedial action and to
assist in determining what exposure pathways need to be
remediated. The remedy outlined in the OU1 ROD addresses the
current threats posed by the Site related to the areas of the
Site soils contaminated with heavy metals and organics; asbestos
siding on the Process Building; and asbestos insulation on
storage tanks and miscellaneous debris.
In order for contaminants found at a site to pose a risk to human
health, an exposure pathway must be identified. An exposure
pathway is the course that a hazardous agent takes from a source
of contamination to an individual through transport mechanisms
such as breathing, eating, or direct contact.
Ground Water
During the baseline risk assessment performed during GUI, it was
assumed that individuals could be exposed to contaminants in the
shallow ground water unit in the future if a residential drinking
water well was constructed on the Site. However, the OU2
investigation demonstrated that this scenario would be unlikely
to occur and, as a result ground water in the shallow unit does
not pose a risk to human health.
The results of RI hydrologic evaluations indicate that the
hydraulic conductivity of the shallow zone is extremely low.
This results in very low horizontal and vertical ground water
flow and, low yielding wells. The time period from well
installation to the time static water levels were reached in
wells MW-13, MW-14 and MW-16 (MW-15 is dry) was approximately two
months. This period of water level equilibrium is extremely
lengthy and indicates the rate of ground water movement in the
shallow unit is very low. The capacity of the shallow ground
water unit to recharge the wells and produce the amount of water
needed for a ground water extraction and treatment system is
insufficient. Therefore, installation of a ground water
extraction system is impractical at this Site given the
characteristics of the shallow ground water unit.
Additionally, based on the low yield and slow recharge of wells
located in the shallow zone, the shallow ground water unit does
not yield enough water to sustain residential well use. As
discussed further below, EPA believes that exposure to
contaminated shallow ground water is unlikely to occur because
the low yielding aquifer is not useable for a potable water
source, the contamination is not migrating outside the Process
Area, and OU1 deed/use restrictions will preclude Site
development in the area of ground water contamination.
Ground water in the shallow unit eventually discharges to the
onsite tributaries of Rapp Creek. Sampling results indicate the
limits of contamination do not extend to the tributaries.
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Organic contamination has not been detected in the stream
corridor.
Stream Sediments
The stream sediment sampling results were compared to sediment
quality guidelines developed by the National Oceanic and
Atmospheric Administration ("NOAA"). These guidelines, the
Effects Range-Low (ERL) value and the Effects Range-Median
("ERM") value concentration for mercury, are 0.15 ppm and 0.71
ppm.
The two guideline values, ERL and ERM, delineate three
concentratibn ranges for a particular chemical. The
concentrations below the ERL value represent a minimal-effects
range, a range intended to estimate conditions in which effects
would be rarely observed. Concentrations equal to and above the
ERL, but below the ERM, represent a possible-effects range within
which effects would occasionally occur. The concentrations
equivalent to and above the ERM value represent a probable-
effects range within which effects would frequently occur.
The detected concentrations for- mercury adjacent to the Site were
greater than the ERL but below the ERM suggesting that any
potential for impacts to biological receptors would be limited to
those areas onsite. Samples collected downstream of the Site's
southeast property boundary indicate that mercury, if present, is
at concentrations near or below the NOAA ERL, and therefore, does
not represent a significant toxicological threat to potential
downstream ecological receptors.
The OU2 mercury sampling data is consistent with Phase I and
Phase II RI sediment data in that mercury concentrations in
tributary sediment were greatest where surface water runoff from
the Site had discharged to the tributaries and diminished to non-
detect levels at offsite, downstream sampling locations.
Due to the reduction in aquatic community diversity and
population observed in the onsite east and west tributaries of
Rapp Creek, it has been concluded that the benthic
macroinvertebrate community in the onsite tributaries has been
adversely impacted. There is a rebound in the benthic community
as distance from the Process Area increases and the concentration
of Site-related contaminants diminish to natural background
levels.
Interim remedial measures which help to minimize surface water
runoff and erosion of Process Area soil have been in place since
May 1992. The. OU1 remedy includes the installation of a clay cap
over the Process Area, as well as revegetation of areas of the
Site that have eroded, are barren, or are poorly vegetated due to
historic Site activities. The OU1 remedy will further minimize
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or eliminate the discharge of metals-contaminated sediment 'to the
onsite tributaries. Thus EPA expects the benthic
macroinvertebrate community adjacent to the former Process Area
to rebound after cap construction and Site restoration.
VII. DESCRIPTION OP THE SELECTED ALTERNATIVE OF NO FURTHER
ACTION WITH STREAM CORRIDOR MONITORING
In accordance with Section 300.430 of the NCP, 40 CFR 300.430, a
list of remedial response actions and representative technologies
was identified and screened to determine whether they would meet
the remedial action objectives at the Site.
Section 121(d) of CERCLA requires that remedial actions at CERCLA
Sites attain legally applicable or relevant and appropriate federal
and State standards, requirements, criteria and limitations which
are collectively referred to as "ARARs", 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 are not applicable to the hazardous
materials found at the Site, however, the Site problems are
sufficiently similar such 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).
The Feasibility Study Report discusses alternatives that were
considered to address the contaminants identified in the shallow
ground water unit and provides the supporting information leading
to the remedy selection by EPA. The three alternatives considered
were no further action, institutional controls, and ground water
extraction and treatment.
A common component of remedies proposed for many sites with ground
water contamination above MCLs is ground water extraction and
treatment^. Ground water extraction and treatment was screened out
of consideration for a full evaluation in the FS for the reason of
technical impracticability as discussed, in Section VIII, below.
The alternative EPA has selected for OU2 is No-Further Action with
Stream Corridor Monitoring. Under this alternative, EPA requires
no further action to prevent exposure to the contaminated onsite
ground water other than the actions which are part of the OU1
source control remedy which includes, among other things,
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institutional controls regarding ground water use and ground water
monitoring. EPA believes the selected alternative will be
protective of human health and the environment since, as discussed
in Section VIII, below, the remedy for OU1 will eliminate any
potential future exposure pathways associated with domestic use of
the ground water. Stream corridor monitoring shall be conducted
annually to ensure that the OU1 remedy is mitigating adverse
impacts to the ohsite tributaries due to the migration of
contaminated soils. Costs for monitoring the stream corridor are
estimated at $45,000. This cost estimate assumes 7 years of stream
corridor monitoring.
Five-Year Review
EPA will review the Site every five years in accordance with CERCLA
§ 121 (c) to assure continued protection of human health and the
environment. EPA has the authority to revisit the No Action
decision with respect to the ground water and stream corridor
sediments even if the Site is removed from the NPL. This action
could occur if deep ground water or stream corridor contamination
associated with the Site is found to pose an unacceptable risk to
human health or the environment.
Monitoring Requirements
Stream corridor monitoring which includes surface water, sediment,
and stormwater basin sampling shall be conducted annually to ensure
that the OU1 remedy is mitigating adverse impacts to the onsite
tributaries due to the migration of contaminated soils. Monitoring
shall be conducted prior to construction of the cap, during the
construction and five years after the construction. This data will
be evaluated by EPA, in consultation with PADEP to determine the
monitoring needs for the future if needed. The exact location of
the sampling stations, and the analytical parameters and methods to
be used shall be subject to written approval by EPA during the
Monitoring Work Plan development.
State Acceptance
The Pennsylvania Department of Environmental Protection (nPADEP")
has agreed with the selection of No Further Action with Stream
Corridor Monitoring for Operable Unit Two of this Site. PADEP has
identified the Land Recycling and Environmental Remediation
Standards Act, the Act of May 19, 1995, P.L. 4, No. 1995-2, 35 P.S.
§§ 6026.101 et sea. ("Act 2") as an ARAR for National Priority List
Sites. However, EPA has determined that Act 2 is not an ARAR for
this Site, therefore PADEP has indicated non-concurrence with the
ROD.
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VIII. BASIS FOR THE ARAR WAIVER
A determination that "No Further Action" is required takes into
account both current and reasonable maximum exposure scenarios
using appropriate health and environmental criteria and standards
that relate directly to the media and hazardous substances being
addressed. A "No Further Action" decision with regard to a
particular media or operable unit is made with the understanding
that no unacceptable exposures to site-related contaminants will-
occur.
At the Revere Chemical Site the attainment of Maximum Contaminant
Levels (MCLs) enacted under the Safe Drinking Water Act 42 U.S.C.
§§ 300(f) to 300(j-26) are considered to be Relevant and
Appropriate standards, however, for the selected remedy they are
waived under Section 121(d)(4)(c) of CERCLA as technically
impracticable from an engineering perspective for the reasons
discussed below.
As discussed in the Summary of Site Risks, Section VI, the capacity
of the shallow ground water unit to recharge the wells and produce
the amount of water needed for a ground water extraction and
treatment system is not sufficient. Therefore, attainment of the
MCL standard for ground water through installation of a ground
water extraction system is technically impracticable at this Site
given .the characteristics of the shallow ground water unit.
In addition, the construction of the low permeability cap will
significantly limit or eliminate the infiltration of rainwater •
through contaminated soil and the subsequent release of additional
contamination to the ground water in the shallow zone. Because
contaminated soils at the Site present the source of ground water
impacts, the physical isolation and/or remediation of contaminated
soil will reduce or prevent potential future degradation of ground
water quality at the Site. Further, ground water sampling results
indicate the limit of the shallow ground water contamination does
not extend beyond the area to be capped under the OU1 remedy.
Therefore, the remedial action required for OU1 will have a direct
influence on improving the quality of the shallow ground water unit
at the Site.
In addition, the OU1 ROD called for institutional controls in the
form of deed restrictions and ground water use limitations. This
will present any future potential human exposure to ground water at
the Site.. Since residential wells in the vicinity of the Site draw
water from the deeper aquifer and are hydraulically upgradient of
the Process Area, they are not likely to be impacted by the
contaminated ground water in the shallow ground water unit beneath
the Process Area. Finally, the OU1 ROD requires long-term shallow
and deep ground water monitoring to evaluate the effectiveness of
the OU1 remedial actions in terms of constituent concentration
reductions and the potential migration of the impacted shallow
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ground water. Should ground water monitoring reveal that the
remedy under OU2 is no longer protective, EPA may take additional
action under the 5-year review provisions of CERCLA § 121(c).
IX. EXPLANATION OF SIGNIFICANT CHANGES
The Proposed Plan for OU2 of the Revere Chemical Site was released
for public comment on April 29, 1996. The Proposed Plan
identified "No Action" as EPA's preferred alternative for shallow
ground water remediation and stream corridor sediments. EPA
reviewed all written and verbal comments submitted during the
public comment period. Upon review of these comments, EPA
determined that no significant changes to the remedy, as originally
identified in the Proposed Plan, were necessary.
X. RESPONSIVENESS SUMMARY
This Responsiveness Summary documents public comments received by
EPA during the public comment period on the Proposed Plan for OU2
of the Revere Chemical Site and provides EPA's responses to those
comments. The Responsiveness Summary is organized as follows:
• Overview
• Summary of Citizens' Comments Received During
the Public Meeting and EPA's Responses
• Summary of Written Comments Received
and EPA's Responses
A. OVERVIEW
The public comment period on the Proposed Plan for OU2 of the Site
began on April 29, 1996 and ended on May 28, 1996. EPA held a
public meeting at the Palisades.Middle School in Kintnersville,
Pennsylvania on May 15, 1996.
At the meeting, EPA representatives summarized the results of the
additional OU2 ground water investigation and the stream corridor
sampling. EPA explained that the Proposed Plan called for no
action to be taken in response to the contaminants in the shallow
ground water unit beneath the Process Area of the Site. EPA also
explained that the OU1 Remedy for the Site which includes source
control measures is expected to prevent migration of contaminated
soil to the onsite tributaries. As a result of the source control
measures EPA expects a decline in mercury concentrations in the
stream corridor. The OU2 Remedy will require stream corridor
monitoring to measure the effectiveness of the source control
measures.
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Comments'received from the public suggest that area residents do
not object to the No Further Action Alternative. The residents'
chief concern was that deed restrictions proposed for the Site
under the OU1 Remedy may not be sufficiently protective unless the
entire parcel of property is addressed by the deed restrictions.
The residents believe the property owners will develop or use the
property in a manner which will result in harm to human health and
the environment. Specifically residents expressed the following
concerns: 1) the property owners will quarry the areas of the
property outside the areas which encompass the OU1 Site remedy; 2)
blasting will cause fractures in the shale thereby releasing
contamination to the uncontaminated deep aquifer; and 3) any use of
the property will result in migration of contaminated soil to the
onsite tributaries. These comments and EPA's responses are
addressed in more detail in the following section.
B. SUMMARY OF CITIZENS' COMMENTS RECEIVED
Comments made during the public meeting and EPA's responses are
summarized below:
Public comment #1
What remediation measures including revegetation will be used to *
stop the erosion of sediments into the stream? If the revegetation
dies, will the process be redone?
EPA Response:
As part of the remedy for OU1, a cap will be installed over the
Process Area to contain those soils that exceed performance
standards specified in the OU1 ROD. In the areas requiring the
cap, the design will include a layer of soil sufficient to sustain
vegetation. The OU1 Rod states that careful attention shall be
paid to the selection of plant species (with emphasis on use of
native grasses or vegetation indigenous to the area) and planting
patterns. Eroded areas that are outside the capped area will also
be stabilized with a soil cover and revegetated. Secondly, if the
vegetation dies the Potentially Responsible Parties (PRPs) would be
required to revegetate. The PRPs are required to maintain the
integrity of the final cover. This will be outlined in a post-
construction maintenance plan.
Public comment #2
You stated that the shallow ground water is contaminated but the
deep ground water is not and that there is very little movement
from one to the other. Where does the water come from in the deep
aquifer if it is not coming from above?
EPA Response:
The aquifer system needs to be examined as an area-wide aquifer
system. The ground water units beneath the Site are just a small
portion of an area-wide system. There maybe upgradient recharge.
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areas where water is moving underground to the lower aquifer.
Although EPA has stated there is an aquitard separating the shallow
from the deep ground water, it does not necessarily mean there is
zero percolation. However, there is not a significant amount of
water recharging the lower aquifer at this Site. This is evident
in that no contamination has been detected in the lower aquifer.
Public comment #3
Is EPA saying that the water in the lower aquifer where residential
wells draw water is being recharged from off-site?
EPA Response:
Yes, that is what EPA is saying.
Public Comment #4
A citizen commented that they thought the Boarhead Farms Site and
the Revere Site might be part of the same aquifer?
EPA Response:
The Boarhead Farms Site is upgradient of this Site and is not -
impacted by ground water flow from the Revere Site. There is also
no indication that the Boarhead Farms Site has impacted ground
water at this Site.
Public Comment #5
Is there any information about other sites that have had similar
conditions and similar remediations, i.e., the cap that EPA is
proposing here? Could we take a look at this information and see
how well the actual remediation worked in those cases?
EPA Response:
EPA does have several databases where you can search citations and
abstracts of ROD of sites with similar remedies. This can be
accessed through the Internet at http://www.epa.gov/. We also have
cap design guidance. There is currently no database on post-ROD
information. Capping is a technology that has been widely used to
isolate both.municipal and hazardous waste from the surrounding
environment. For additional information contact the EPA Region III
Hazardous Waste Technical Information Center at (215) 566-5364.
Public comment #6
A citizen commented that EPA should consider pressure-grouting the
bedrock surrounding the Site to make a concrete barrier to stop
contaminants migrating laterally offsite.
EPA Response:
The contaminated ground water at this Site is not migrating off-
site. The contaminated ground water has not migrated beyond the
limits of the former Process Area. This area will be capped which
will prevent percolation and further minimize the potential
migration of the contaminants. In addition, the natural conditions
(i.e.., the tributaries) serve as hydraulic divides for the flow of
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ground water in the shallow unit. No ground water contaminants
have been detected in the surface water. A monitoring well network
will also be developed to detect contamination long before it could
impact residential wells which is our greatest concern.
Public comment #7
When you refer to the Site you're talking about 113 acres. When
you spoke about deed restrictions on the property you said they
would relate only to areas of the cap or contaminated area. What
happens to the other remaining acres? I understand the owner's
rights are suspended? What are the property owners rights once it
is turned back to the owner?
EPA Response:
The Revere Site is located on a 113-acre parcel of property. The
extent of the Superfund Site is defined by the areas of
contamination. The owner's rights are not "suspended" for those
areas of the property not impacted by the Superfund Site. The
owners have the property rights allowable by the local and state
laws and can pursue development and use of its property pursuant to
the local and state laws so long as those pursuits do not endanger
the integrity of the remedy for the Site. Future uses of the
property must be evaluated in light of the remedial activities at
the Site.
Public comment #8
Is EPA saying that the owner could develop the remaining portions
of the property .as a quarry? Wouldn't blasting at a quarry effect
the permeability of the rock at this Site if the remaining portions
of the property were developed as a quarry?
EPA Response:
EPA does not regulate land use development. Land use is regulated
by the local government under the act of July 31, 1969 (P.L.805,
No.247), known as the Pennsylvania Municipalities Planning Code,
not by EPA. The owners would have to obtain permits at the local
level for any proposed quarrying operations. EPA will cooperate
with local officials in reviewing any permits received. The local
and state officials responsible for reviewing permits are aware of
the Superfund activities at this property. The local officials
will need to coordinate potential permitting with EPA to ensure
that any use or development of the property would not adversely
impact the selected remedies for this Site. The deed restrictions
which will be developed during the remedial design/remedial action
and which are required by the OU1 remedy for the Site will prohibit
activities that will undermine the integrity of the remedy.
If plans for a quarry are filed, the impacts of blasting and.its
impacts on the rock permeability will be evaluated by the local and
state.officials who are aware of the remediation activities at the
Site, in cooperation with EPA.
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Public comment #9
What action, if any, is being taken against the parties who are
responsible for contaminating the Site?
EPA Response;
EPA has placed a federal lien on the property until past funds that
were spent on Site cleanup are recovered. Another option would be
issuance of an administrative order which requires the PRPs to
conduct the remedy at the Site. EPA has issued a unilateral order
to the PRPs. Only a group of the PRPs identified, known as the
Revere Steering Committee, has complied. Another option is to
pursue a cost recovery action. This option is used when EPA is
aware of individuals or companies that are potentially responsible
but are not paying for the cleanup. EPA has not exercised this
option yet.
Public comment #10
Is the person who was behind this a free man?
EPA Response
No criminal charges were brought against any person with regard to
this Site.
C. SUMMARY OF WRITTEN COMMENTS RECEIVED AND EPA'S RESPONSES
Comment #1
Two commenters wrote that it is irresponsible to return the Site to
the owners given the "alleged" record of the Site owner's past use
of the Site and probable future use of the Site as a quarry.
EPA Response:
EPA has not taken the property from its owners, Harbucks Inc. EPA
has required that deed restrictions be imposed on the areas of the
Site where residual contamination will remain. Under CERCLA §
106(a) EPA has authority to issue orders or take other appropriate
actions "as may be necessary to protect public health and the
environment." Therefore, EPA can only impose deed restrictions
that are reasonable in light of the level of contamination
remaining on the Site (i.e., the contaminated portions of the
property) and which are related to the contamination. Future use
of the portions of property which are not contaminated and,
therefore, not Superfund-related, falls under the local land use
regulations imposed by the local government. However, since it is
not clear at this time what activities the landowner intends to
take and the consequences of these activities, it is unclear which
portions of the property are not Superfund-related.
Comment #2
Commenters expressed concern that any blasting for quarry on the
property could provide a migration pathway for the contamination in
the shallow ground water unit, thereby contaminating the deeper
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aquifer from which the residential wells draw water.
EPA Response:
EPA believes this is a valid concern. EPA is not aware of any
plans currently filed with the local or state governments to
develop the property as a quarry. If plans for a quarry are filed,
the impacts of blasting and the potential for ground water
contamination to> be released will be evaluated through the
permitting process. The local and state governments would need' to
coordinate with EPA to ensure that any development of the property
would not adversely impact the selected remedies for this Site.
EPA has notified the Pennsylvania Bureau of Mining and Reclamation,
Division of Permits, regarding the Superfund Site located on this
parcel of property. EPA has requested that the Bureau contact EPA
Chief of the Superfund Program if they receive a permit application
regarding this property.
Comment #3
A commenter states that the Site owners will probably quarry the
uncontaminated portions of the property. The commenter states that
activities related to quarrying (e.g., blasting, truck traffic,
etc.) could easily intrude on the contaminated areas and is
concerned that will result in a release.
EPA Response :
EPA agrees this a valid concern. However, governmental
institutional controls, by definition, involve restrictions that
are generally within the traditional police power of state and
local governments to impose and enforce. The implementation of the
deed restrictions required by the OU1 remedy will require
discussion with local and state government officials. As a result
of the deed restrictions placed on the property, additional
discussion with EPA will be required before local and state
governments may approve a quarry operation on the remaining
portions of the property. The role of the EPA may be limited to
specifying the standards for the controls, however, in order to
maintain the integrity of the remedy, EPA must be privy to any
negotiations regarding land use of the property.
Comment #4
All of the written comment letters received referred to the use of
deed restrictions. All of the commenters felt that in order to be
effective EPA should deed restrict the entire parcel of property
from future development rather than limiting the deed restrictions
to areas which encompass the remedy for the Site.
EPA Response :
The Site is located on a 113 -acre parcel of property of which a
•portion is contaminated. EPA does not have the authority to
restrict all uses of this 113 -acre property. Deed restrictions are
used to protect the public from exposure to contamination.
Although EPA cannot deed restrict the property to disallow
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quarrying on the entire 113-acre parcel, EPA can impose deed
restrictions on the Site to prevent activities that will undermine
the integrity of the remedy.
By letter dated May 22, 1996 the Tinicum Creek Watershed
Association submitted the following comments on the Proposed Plan:
Comment #5
The commenter notes that on page 10 of the Proposed Plan, EPA
stated that the ground water in the shallow ground water unit
eventually discharges to Rapp Creek. The commenter is concerned
about this contaminated ground water reaching Rapp Creek, the
headwaters of the Tinicum Creek watershed, providing an exposure
pathway for the contaminated ground water.
EPA Response:
Although the ground water in the shallow unit is contaminated with
organic chemicals, predominately TCE and TCB, sampling data
indicates that the boundary of the contaminated ground water plume
is within the Process Area and does not extend to the tributaries.
No organic contaminants have been detected in the stream corridor.
This is stated on pages 8 and page 10 of the PRAP. Therefore, the
stream is not providing an exposure pathway for the contaminated
ground water.
Comment #2
The commenter recommends that attempts to remove the contaminated
sediments from the stream corridor be included in the remedy and
more importantly that deed restrictions placed on the property
require that all vegetation be supplemented within 500 hundred feet
of each tributary and that these buffer areas be restricted from
development. The commenter recommends that the deed restrictions
placed on the 500 feet buffer prohibit all disturbance, including,
but not limited to, the installation of sewage systems, stormwater
pipes or management components, roads, and structures. The
commenter recommends that a well-defined maintenance plan be
recorded with the deed restrictions which clearly limit activities
effecting the vegetation.
EPA Response:
The natural stream bed of the onsite tributaries are composed of
bedrock outcroppings and discrete areas of sediment deposition are
rare. The stream flow is intermittent. Based on the sediment
transport and depositional characteristics of Rapp Creek, EPA has
determined that attempts to remove contaminated sediments are
impractical.
Deed restrictions are institutional controls used to protect the
public and environment from exposure to contaminants. If it will
be necessary to restore and revegetate any of the banks on the
tributaries as part of the OU1 remedy, these areas will be subject
to deed restrictions since they are within the area of Site-related
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contamination. Maintenance plans and monitoring plans are future
work requirements, therefore, they do not qualify as deed
restrictions.
Comment #3
The commenter stated that: 1) it is unacceptable that stream
corridor monitoring be discontinued; 2) it appears that the US EPA
is stating that the monitoring program provided under the ROD for
OU1 would provide 'sufficient protection to the stream; and, 3) any
monitoring program would be continued for a period of fifteen (15)
years or more to account for any release of contaminants as a
result of the future development or use of the property.
EPA response:
EPA has not stated that monitoring in itself is providing
protection of the stream. The OU1 remedy includes source control
measures. The inorganic contaminants (heavy metals) detected in
the stream corridor are due to contamination reaching the stream
via surface water runoff. Once this pathway is eliminated, there
should be no future impacts to the stream and the levels of
inorganic contaminants should decline through natural processes.
EPA has proposed that monitoring be conducted for at least seven
years to ensure that this occurs.
The cost for this monitoring program was based on seven years of
monitoring and includes: one sampling event prior to construction
of the cap and Site revegetation; one event to occur during the
construction process; and, five sampling events on an annual basis
following the completion of the cap and Site restoration and
revegetation. This data will be used in the five-year review that
is required to be conducted since hazardous waste are being left on
Site. The continuing need for stream corridor monitoring will be
re-evaluated during the five-year Site reviews conducted pursuant
to Section 121(c) of CERCLA.
Comment #4
The commenter writes that a deed restriction should be established
that requires any and all future use and development activities by
the owner to include installation and maintenance of a permanent
stream monitoring program and any other enforcement requirements.
EPA response;
EPA has no authority under the Superfund Law to require the
property=owner to establish a monitoring program when the owner
chooses to develop uncontaminated portions of this parcel of
property that are not impacted by the hazards, or the threat
thereof, that gave rise to the selected OU1 remedy. These types of
concerns should be addressed at the local and state level when the
owner is seeking permits for development of the property.
Concerns raised by the public with regard to future development of
the uncontaminated areas of this property and, therefore, the
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potential for this future activity to cause negative impacts to the
stream that are unrelated to the contaminants from this Site cannot
legally be addressed by the Superfund process, but should be
addressed by the local and state permitting processes.
Comment^ 5
The commenter states that the Tinicum Watershed Association
believes institutional controls, are the most cost effective method
available to ensure a limit of impact to the Tinicum Creek
watershed system. They requested an outline of the proposed
restrictions be provided for public comment prior to the ROD being
issued.
EPA Response:
The Deed restrictions are a component of the OU1 ROD which was
issued on December 27, 1993. The purpose of the deed restrictions
is to ensure the integrity and protectiveness of the Site remedies.
These deed restrictions will prohibit any activity that would
interfere with the integrity or compromise the effectiveness of the
selected remedies. The exact language of the deed restrictions is
not formally open for public comment by EPA. However, since
discussion with local officials will be necessary in order to
implement and enforce the deed restrictions, concerns of the .
Tinicum Watershed Association may be addressed through the local
land use zoning officials.
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, QUADRANGLE LOCATION |
0 1000 2000 3000 FEET
GRAPHIC SCALE
CONTOUR INTERVAL = 10 FEET
• REFERENCE:
A PORTION OF USGS 7.5 MINUTE TOPOGRAPHIC
. MAPS: RIEGELSVIU£ AND 8EDMINSTER QUADRANGLES.
16 PENNSYLVANIA; 1956. PHOTOREVISED 1968 AND
Ic- 1973; 1957. PHOTOREVISED 1983: RESPECTIVELY.
TITLE
SITE VICINITY MAP
PROJECT
REVERE CHEMICAL
RFVFRF. PENNSYLVANIA
DAMES & MOORE
WILJ.OW GROVE. PENNSYLVANIA
SCALE
AS SHOWN
OWN. BY
T.J.G.
JOS NO.
19142-011
Figure 1
-------
3
O
c
3)
m
10
N
V
—— nwrom BOUNDARY
*-• roMn CTOMCC UMQH
MO 900 «OOrtTT
SITE FEATURES MAP
NOTES;
i. jgni amm AND MTOK •« riAiuu MV
ON •« nwc. n*iu«n not
.
emm AT M rnn MMC ««
nnt M«A nouot UOXM, raoa
» m MO »€ ClUfCMM IMMk
CHEMFCAL ~
REVERE^PENNSYLVANIA
M man or we MMT ran mum INM
MMn or /awn monauwa MOOHD M
•»« MWLTnt mm OMWCM. ear/**r. ivoc.
KNMIUXMA* (MCPAj 1N4)l
AS_SHOWN
8-11-94
DAMES & MOORE
W1OOW OROVt. PENNSYLVANIA
OWN. 8V
R.G.B.
APPR BY
T.J.G.
JOB NO.
19142-011
Inc. NO.
-------
EXPLANATION:
—--— PROPERTY BOUNDARY
FENCE
5/0 -" TOPOGRAPHIC CONTOURS
84. PHASE I Rl STREAM SEDIMENT SAMPLING
o.*«A LOCATION SHOWING MERCURY CONCENTRATION
IN MICROGRAMS PER KILOGRAM (mg/kg)
*«A PHASE I Rl SURFACE WATER
SAMPLING LOCATION
^SOOJ* PHASE II Rl STREAM SEDIMENT SAMPLING
LOCATION SHOWING MERCURY CONCENTRATION,
* IN mg/kg
D PHASE II Rl SURFACE WATER
SAMPLING LOCATION
o BACXGROIJN°.$. BACKGROUND SEDIMENT SAMPLE LOCATION
- n^Jn0^* APPROXIMATE SEDIMENT SAMPLING LOCATION
5 °*a^2a FOR OU 2 ADDITIONAL TASKS SHOWING
MERCURY CONCENTRATION IN mg/kg
MERCURY NOT DETECTED
SHALLOW MONITORING WELL
DEEP MONITORING WELL LOCATION
PRODUCTION WELL SITE MAP SHOWING MONITORING WELL,
200 4oo 600 FEET STREAM SEDIMENT, AND SURFACE WATI
? ? ? SAMPLING LOCATIONS
GRAPHIC SCALE - FIGURE
NO
NOTE:
SAMPLING LOCATIONS ARE APPROXIMATE
BASED ON FIELD MEASUREMENT FROM
SURVEYED GRID POINTS.
-------
TABLE 1
HITS-ONLY SUMMARY OF VOLATILE ORGANIC COMPOUND ANALYTICAL DATA
ONSITE MONITORING WELLS
REVERE CHEMICAL SITE
REVERE, PENNSYLVANIA
(all concentrations in ug/l)
Well Point/ Parameter
ft
FPDVVS
PtuuelRI
Rouadl 1 Raw* 2
Nov. 1989 1 Dec. 1919
Phase II HI
Rmwdl 1 Rmud2 1 Rou»d3 1 Rnud4
JIM. 1991 1 Scot. 1991 1 Dec 1991 1 Feb. 1992
OU2
Additional
TMlu
Dec 1994
MW-2
Trichloroethene (TCE) J 5
-
MW-4
Trichloroethene (TCE)
1,1,1-Trichloroelhane
Tetrachloroethene (PCE)
5
200
5
110
-
-
ND| 7
Iior
-
-
1 5
ND
ND
119
3
2
J 1 1
*
144
1
o
J 1 4
1140
3
2
J 1 4
L | |7|
1 3
J 1 2
j
j
j
1.73
•1.9
_
-
ND
ND
MW-7
Trichloroethene (TCE)
3 1 -
ND| -
NDI 2
J 1 3
J |7
1 3
J | 17.*
MW-12
Trichloroethene (TCE) | 5
-
ND| -
ND
1
17
1 •
1 7
11.02
MW-13
Trichloroethene (TCE)
3
-
NTI -
NT
-
NT| -
NTI -
NT| -
NT |0.852| J
MW-14
Trichloroethene (TCE)
5
MW-16
Trichloroethene (TCE)
Tetrachloroethene (PCE)
5
5
-
NT| -
NT
-
-
-
NTI -
NT| -
NT
NT
-
-
NT| -
NT| -
NT| -
NTI -
NT | -
NTI -
NT| -
NT | -
NT| -
NT | 220
NT
NT
23.1
0.909
Explanation:
ug/l • micrograms per liter
ND - not delected
J - estimated value
B - compound delected in field or trip blank
L-biased low
FPDWS - Federal Primary Drinking Water Standard (MCL)
Rl - Remedial Investigation
Notes:
I. Toluene was delected at an estimated concentration of I ug/l in both MW-2 and MW-4 during Round I of the Phase II Rl.
2. Carbon disuliide was detected at a concentration of 0.778 ug/l in MW-12 during the OU 2 Additional Task sampling event.
3. Shading represents detected concentrations that exceed the FPDWS.
4. During OU 2 Additional Tasks, methylene chloride was detected in MW-13 at an estimated concentration of 0.802 ug/l, and chloroform
was detected in wells MW-13 and MW-16 at concentrations of 0.462 ug/l (estimated) and 0.947 ug/l, respcctivley.
5. Monitoring wells MW-2, MW-4, MW-7, MW-12. MW-13, MW-14, and MW-16 are shallow wells VOCs were not detected above FPDWS
in the remaining shallow wells or any of the deep wells at the Site.
Dames & Moore
-------
TABLE 2
Page 1 of 2
COMPARISON OF INORGANIC ANALYTICAL RESULTS OF
SURFACE WATER TOXICITY SAMPLES TO
BACKGROUND SURFACE WATER SAMPLES
REVERE CHEMICAL SITE
REVERE, PENNSYLVANIA
(all concentrations in ug/1)
SAMPLE DESIGNATION
TAL METALS CONCENTRATIONS'
ill.:.:
BACKGROUND CONCENTRATION'2
TEH0020A - Unfiltered
Calcium-12.200
Chromium - 4.30 J
Copper - 8.70 J
Magnesium - 5,040
Potassium - 1,550 J
Sodium - 7,300 J
11,000
4,690
1,470
6,560
TEH0020A • Unfiltered
Calcium -12,300
Copper - 6.10 J
Sodium - 7,010 J
11,000
6,080
TEH002RA - Unfiltered
Barium - 8.20 J
Calcium -12,100
Magnesium - 4,880 J
Sodium - 6,900 J
7.80
11,000
4,690
6,560
TEH002RA - Filtered
Arsenic - 2.10 JL
Calcium- 12,100
Copper - 6.40 J
Mercury- 0.10 J
Sodium - 6,810 J
2.10
11,000
0.10
6,080
TEH0030A - Unfiltered
Arsenic -1.60 JL
Barium - 8.30 J
Copper - 78.2
Lead - 2.80 J
Manganese - 51.4
Potassium -1,450 J
Sodium -16,700 J
Zinc- 17.5 J
37.7
16,700
TEH0030A - Filtered
Aluminum - 738 K
Arsenic -1.40 JL
Barium- 14.1 J
Copper - 98.1
Iron - 634
Lead - 2.50 J
Manganese - 66.6
Nickel-18.2 J
Potassium-1,530 J
Zinc - 31.3
TEH0040A - Unfiltered
Arsenic-1.10 JL
Barium - 9.70 J
Calcium -15.000
Copper - 98.8
Lead -2.10 J
Manganese - 97.7
Nickel-14.0 J
Potassium - 1,370 J
Zinc - 45.0
14,800
37.7
(PHL) 001S942.WP / 1
-------
TABLE 2
Page 2 of 2
COMPARISON OF INORGANIC ANALYTICAL RESULTS OF
SURFACE WATER TOXICITY SAMPLES TO
BACKGROUND SURFACE WATER SAMPLES
REVERE CHEMICAL SITE
REVERE, PENNSYLVANIA
SAMPLE DESIGNATION
TEH0040A - Filtered
TEHOOSOA • Unfiltered '
TEH0050A - filtered
TEH0060A - Unfiltered
TEH0060A • filtered
TEH006RA • Unfiltered
(replicate of TEH0060A)
TEH006RA - filtered
(replicate of TEH0060A)
TAL METALS CONCENTRATIONS'1'
Aluminum - 505 K
Arsenic - 1 .40 J
Barium - 1 1 .5 J
Copper - 1 69
Iron - 452
Lead • 2.50 J
Manganese - 95.8
Potassium - 1 ,440 J
Zinc • 26.3
Barium- 11.1 J
Calcium - 14,700
Copper - 54.3
Lead • 3.80
Magnesium - 5,350
Manganese • 52.3
Mercury - 0.40
Nickel - 1 8.0 J
Potassium - 1 ,470 J
Sodium - 9,850 J
Zinc - 20.3
Calcium - 1 6,200
Copper - 66.9
Mercury • 0.10 J
Sodium- 10,000
Calcium- 12,700
Copper - 66.4
Lead - 3.92 B
Magnesium - 5,1 50
Copper - 82.5
Calcium- 13,900
Copper - 1 03
Lead - 2.79 BJ
Magnesium - 5,490
Copper - 84.7
Mercury -0.1 7 J
BACKGROUND CONCENTRATION'*
-
7.80
11,000
4,690
23.0
0.20
1,470
6,560
20.1
11,000
0.10
6,080
11,000
4,690
-
1 1 ,000
4,690
0.10
Explanation:
J The associated numerical value is an estimated quantity.
B The result is qualitatively suspect because the compound was detected in a field and/or laboratory blank at a similar concentration.
K The associated numerical value is biased high.
L The associated numerical value is biased low.
0 The sample was diluted to bring the compound into the linear calibration range.
Background concentration for indicated parameter has not been established. Parameter was not detected in any of the background
samples that were used to determine the representative background concentrations.
Note:
1. This table summarizes TAL metals detected at each sampling location that exceeded the respective background concentration.
2 Background level for TEH0020A was determined based on background samples collected from the west tributary during the Phase
I Rl (two samples, each designated R1U) and the Phase II Rl (TEH0010A). Background level for TEH0030A and TEH0040A were
determined based on background sample collected from the east tributary during the Phase I Rl (2 samples, each designated R2U).
Background level for TEHOOSOA and TEH0060A was determined based on background samples collected from both tributaries
during the Phase I Rl and the Phase II Rl.
(PHL) 0015942.WP / 2
-------
TABLE 3
1 of 2
COMPARISON OF INORGANIC ANALYTICAL RESULTS OF
PHASE II Rl STREAM SEDIMENT TOXICITY SAMPLES TO
BACKGROUND STREAM SEDIMENT SAMPLES
REVERE CHEMICAL SITE
REVERE, PENNSYLVANIA
(all concentrations in mg/kg)
SAMPLE DESIGNATION
TES0020A
*
TES0020RA
(RepfeMi of TES0020A)
TES0030A
TAL METAL CONCENTRATION11'
Aluminum - 25,300 0
Arsenic -9.1 2 DJ
Barium - 305
Beryllium • 2.41
Cadmium - 0.41
Calcium - 2,070
Chromium - 86.3
Cobalt • 64.4
Coppar-111
Iron - 65.500 DJ
Load • 39.1
Magnesium- 12.500
Manganese - 6.650 O
Nickel - 48.1
Potassium- 1.270
Vanadium -117
Zinc -228
Aluminum - 24.300 O
Araanie - 12.9 J
Barium -65.1
BaryWum- 1.91
Calcium -1,490
Chromium- 104
Cobalt - 28.4
Coppar-161
Iron- 55.100 DJ
bud - 27.6
Magnaaium- 13,200
Manganaaa- 1.920 D
Mercury. 1.87 L
Nickal-48.5
Potassium -1, 000 J
Sodium- 43,0 J
Vanadium -110
Zinc- 188
Aluminum* 31. 7000
Arsenic - 44.9 DJ
BaryMum - 7.26
Chromium- 80.1
Cobalt - 73.8
Coppar- 1,500 D
Iron • 65.500 DJ
Magnesium- 14,600
Manganaaa - 3,570 D
Mercury - 0.06 JL
Nickel - 65.4
Potassium - 730 J
Sodium -51. 5 J
Vanadium- 108
Zinc- 142
BACKGROUND LEVEL"1
11.200
7.60
59.1
0.71
_
894
25.6
10.7
12.4
23.20O
13.0
3,910
534
13.2
995
47.9
78.6
11.200
7.60
59.1
0.71
894
25.6
10.7
12.4
23.20O
13.0
3.910
534
-
13.2
995
31.5
47.9
78.8
16,200
23.4
1.50
36.7
14.8
25.2
36,200
6,960
1.58O
—
18.1
-
—
73.5
106
(PHL) 0010886. W?
-------
TABLES
Pag* 2 of 2
COMPARISON OF INORGANIC ANALYTICAL RESUOS OF
PHASE B Ri STREAM. SEDIMENT TOXICfTY SAMPLES TO
BACKGROUND STREAM SEDIMENT SAMPLES
REVERE CHEMICAL SITE
REVERE, PENNSYLVANIA
SAMPLE DESIGNATION
TESOO4OA
•
TESQOSOA
TES0060A
TES006RA
(replicate Of TES0060A)
TAL METAL CONCENTRATION"1
Aluminum- 31. 700 D
Arsenic -39.1 DJ
Barium - 93.7
Beryllium- 10.2
Cadmium -1.1 2 J
Chromium- 131
Cobalt • 90.6
Copper • 2.560 D
Iron -64.1 00 DJ
LMd • 52.0
Magnesium- 17.700
Manganese • 4.610 0
Mercury -0.1 2 L
Nickel - 89.2
Potassium -1,1 10
Sodium • 60.5 J
Vanadium- 144
Zinc -219
Aluminum- 36.200 O
Arsenic - 45.7 DJ
Barium -81.7
BaryWum - 8.56
Calcium -1.1 60
Chromium- 336
Cobalt -60.1
Copper- 1.160D
Iron - 85.900 DJ
LMd • 35.4
Magnesium- 16,800
Mangarwsa - 3,440 D
Nickel - 69.3
Sodium • 32.3 J
Vanadium -206
Zinc -222
Coppar- 1,170
Marcury - 0.07 J
Coppar -1.010
Marcury -0.06
BACKGROUND LEVEL™
16.200
23.4
85.6
1.50
1.10
36.7
14.8
25.2
36.200
47.4
6.960
1.580
-
18.1
_
_
73.5
106
11.200
7.60
59.1
0.71
894
25.6
10.7
12.4
23.200
13.0
3,910
534
13.2
31.5
47.9
78.6
12.4
-
12.4
-
Explanation:
J The associated numerical value is an estimated quantity.
B The result'» qualitatively suspect because the compound was detected in a field and/or laboratory blank at a
K The associated numerical value is biased high.
L The associated numerical value is biased tow.
D The i ample waa diluted to bring the compound into the linear calibration range.
Background concentration for indicated parameter has not been established. Parame»r was not detected in any
of the background samples that were used to determine the representative background concentrations.
Notes:
1. Trus table summer las TAL metals detected at each sampling location that exceed the respective background
concentration.
2. Background level for TESO020A was determined based on background samples collected from the west tributary
during the Phase I RI (sample B1» and the Phase II RI (sample TES0010A). Background levels for TES0030A and
TESOO40A were determined based on background sample collected from the east tributary during the Phase I RI
(sample B2). Background level for TES0050A and TES0060A was deter mined based on background samples
collected from both tributaries during the Phase I RI end the Phase II RI.
(PHL) 00108M.WP
-------
TABLE 4
Page 1 of 1
EXCEEDANCE SUMMARY
COMPARISON OF ANALYTICAL RESULTS FOR SURFACE WATER
TOXICITY SAMPLES TO PENNSYLVANIA WATER QUALITY CRITERIA
FOR TOXICITY SUBSTANCES (FISH AND AQUATIC LIFE CRITERIA)
REVERE CHEMICAL SITE
REVERE, PENNSYLVANIA
(all concentrations in ug/l)
. SAMPLE-;'.;- - vvjfe-..; •.
TEHOOIOA-Unfiltered
TEH0010A- Filtered
TEH0020A - Unfiltered
TEH0020A - Filtered
TEH002RA - Filtered
TEH0030A - Unfiltered
TEH0030A - Filtered
TEH0040A • Unfiltered
TEH0040A- Filtered
TEH0050A - Unfiltered
TEHOOSOA • Rltered
TEH0060A - Unfiltered
TEH0060A- Filtered
TEH006RA - Unfiltered
TEHQD6RA - Filtered
TAL METALS CONCENTRATION
Mercury - 0.20 J
Lead - 8.30
Copper • 8.70 J
Lead - 3.40
Lead - 3.20
Copper - 78.2
Lead - 2.80 J
Copper - 98.1
Lead • 2.5 J
Copper - 98.8
Lead • 2.1 J
Copper - 1 69
Lead • 2.5 J
Copper - 53.4
Lead • 3.8
Mercury - 0.4
Copper - 66.9
Copper - 66.4
Lead • 3.92 B
Copper - 82.5
Lead - 5.61
Copper - 103
Lead - 2.79 BJ
Copper - 84.7
Lead - 3.92 J
Mercury - 0.17 J
CRITERIA CONTINUOUS*
CONCENTRATION
0.012
1.3
0.67
1.4
1.3
7.3
1.6
7.3
1.6
7.8
1.7
7.6
1.7
7.5
1.7
0.012
7.5
6.9
1.4
6.9
1.4
7.3
1.6
7.3
1.6
0.012
Explanation:
• Taken from Pennsylvania Code, Title 25 - Environmental Resources, Chapter 16 - Water Quality Toxics
Management Strategy, Appendix A, Table 1.
J The associated numerical value is an estimated quantity.
B The associated numerical value is qualitatively suspect as this compound was detected in a field and/or
laboratory blank at a similar concentration.
(PHL) 0015942.WP / 3
------- |