-------
D. Buried Waste
Historical waste sample analysis identified several categories of waste (see Figure 2) at the Site:
Desvljurization Waste: Approximately 3,700 cubic yards of desulfurization waste is
present at the Site. This waste was generated by washing light oils with sulfuric acid or
by removing sulfur from coke oven gas. (These wastes consist of iron oxide, wood chips,
and granular media.) *
Pesticides and Herbicides: Small concentrations of pesticides and herbicides were
detected at various locations at the Site. (Three bags of 2,4-D were removed in 1982.)
Coke Process Waste: The Site contains approximately 10,000 to 20,000 cubic yards of
coal coking process waste containing tar, particles of coal, ash, bitumen, pitch and slag.
These wastes were disposed in trenches five to ten feet deep primarily on the south-
central portion of the Site. One tar-like seep, approximately 25 feet long, was observed
150 feet south of boring NB-46.
Table 5 - SVOCs in Subsurface Soils
I <' V
COMPOUND
2,4 - Dichlorophenol
Phenol
2-Methylphenol
4-Methylphenol
2,4,6 - Trichlorophenol
Diethylphtfialate
Di-n-birtylphthalate
Bis (2-ethylhexyl) phthalate
Carbazole
Diebenzofuran
2-Methytnaphthalene
Naphthalene
Fluorene
Phenanthrene
DETECTION
FREQUENCY
AT 9 LOCATIONS
1
1
1
1
3
2
4
2
2
3
3
4
2
3
MINIMUM
DEzTECTEQ
CONCENTRATION
(ppb)
_
__
260J
67J
51J
840J
390J
350J
270J
1,1 OOJ
400J
3,1 OOJ
MAXIMUM
DETECTED
CONCENTRATION
fopbi
12,000
5,200
430J
2,1 OOJ
8,100
120J
1.500J
14,000
740J
1.700J
1.800J
5,000
1.500J
5,600
18
-------
COMPOUND
Acenaphthene
Anthracene
Fluoranthene
Pyrene
Benzo (g,h,i) peryiene
Benzo (a) anthracene
Chrysene
Benzo (b) fluoranthene
Benzo (k) fluoranthene
Benzo (a) pyrene
Indeno (1,2,3-cd) pyrene
Dibenz (a,h) anthracene
DETECTION,
FREQUENCY
AT 0 LOCATIONS
2
3
, 3
3
2
2
3
2
2
2
/
2
1
MINIMUM
DETECTED
CONCENTRATION
(ppb)
320J
620J
1 ,900J
1.400J
2.500J
5,000
530J
6,000
940J
2.000J
1 ,300J
_
MAXIMUM
DETECTED
CONCENTRATION
(ppb)
2.700J
1,1 OOJ
8,500
7,300
2,600
5,900
3,500
6,200
1.300J
2,300
2,800
800J
Data qualifer: "J" - The reported concentration is an estimated value.
Foundry Sand: Approximately 87,000 cubic yards of foundry sand used to mold iron to a
desired shape is present at the western end of me Site.
Dry Ash: The incombustible residue remaining after combustion of coal in the coal
coking process is known as dry ash and was found at the Site.
Slag: Impurities that rise to the top of molten steel during the coke production process are
known as slag. Slag, which is primarily composed of calcium and silica with smaller
quantities of metals, was found at the Site.
Miscellaneous wastes, including cement operation wastes, municipal wastes, demolition
rubble and others, were also found at the Site.
Three waste material samples were collected from the former disposal trenches during the
Remedial Investigation at locations shown in Figure 8. The waste material included slag, pieces
of tar, ash, stained soil, calcium carbonate waste, metal pipes, wire, bricks, and coal coking
waste. Laboratory results of waste material in the trenches are presented in Table 6. These
results showed the following:
VOCs were found in high concentrations: benzene (170 ppm, 2300 ppm, 8900 ppm),
toluene (2400 ppm), xylenes (220 ppm);
19
-------
N8-4I-7
IJ-14 II
PHEN
PHtH
PAH
MAP
an*
NO
NO
NO
.'HP
W>
^^
HS-HI-7
IJ-I
PltfN
PIIIH
PAH
HAP
ft*
-v^ .
Jl.
NO
NO
NO
NO
NO
MB- 48-1
10-1
PHEN
PHIH
PAH
HAP
BoA
II.
260
840
i2J60
5000
5900
100 200
400
SCALE IN FEET
Figure 7
Total SVOC Concentration
at Each Sampling Location
PHCN
PHIH
PAH
NAP
BoA
NO
KI/FS SOIL BORING
RESULTS REPORTED IN ug/kg
TOTAL PHENOLIC COMPOUNDS
TOTAL PHTHALATE COMPOUNDS
TOTAL POLYNUCLEAR AROMATIC HYDROCARBONS
NAPHTHALENE
BENZO (a) ANTHRACENE
NOT DETECTED
SUAPLE WAS COLLECTED BELOW THE WATER TABLE
ANALTYICAL RESULTS FOR SEMIVOLATILES IN SUBSURFACE
SOIL SAMPLES ARE PRESENTED ON TABLE 5-4
-------
ppppddn
0 150 300
600
SCALE IN FEET
APPROXIMATE LOCATION
OF "TART SEEP
LEGEND:
APPROXIMATE: WASTE: SAMPLE LOCATION
APPROXIMATE LOCATION OF FORMER DISPOSAL TRENCH
21
Figure 8 - Location of Waste Material Samples
OHIO RIVER SITE RI/FS
NEVILLE TOWNSHIP. PENNSYLVANIA
Drawni
MSH
Appr'di
KB
Dat*' 8/23/93
8/3Q/93
Project
Nunbvn
4920-OOJ
Rev,
1
-------
SVOCs presented similar concentrations to the maximum concentrations found in the
subsurface soils;
Among eleven detected pesticides, most presented similar concentrations to the
maximum concentrations found in subsurface soil. The only herbicide found was 2,4-D
at a concentration approximately ten times higher than in subsurface soil.
VII. SUMMARY OF SITE RISKS *
Following the Remedial Investigation, analyses were conducted to estimate the human health
and environmental hazards that could result if contamination at the Site is not cleaned up. These
analyses are commonly referred to as risk assessments and identify existing and future risks that
could occur if conditions at the Site do not change. The Baseline Human Health Risk
Assessment ("BLRA") evaluated human health risks and the Ecological Risk Assessment
("ERA") evaluated environmental impacts from the Site.
A. Human Health Risks
The BLRA assesses the toxicity, or degree of hazard, posed by contaminants related to the Site,
and involves describingthe routes by which humans and the environment could come into
Table 6 - Analytical Results for Waste Material Samples
Sample)!};
Collection Date:
Sample Deptft (ft.):
Units:
NWIM
3/5/93
4-6 feet
ppra
NWP-2
3/5/93
2-4 feel
ppm
NWP-3
3/5/93
flW^ wW*.
ppm
VOLATILES
Benzene
Toluene
Ethyfbenzene
Xylenes (total)
170
19J(a)
N0(b)
4.9J
2,300 .
ND
38J
ND
8,900
2,400
ND
220J
SEMIVOLATILES
Phenol
2,4-Dicholorphenol
Bis(2-ethylhexyl)phthalate
Dibenzofuran
2-Methylnaphthalene
Naphthalene
0.62J
2.7J
ND
ND
ND
ND
12J
ND
4.6J
4.5J
ND
39J
19J
ND
ND
ND
12J
320
22
-------
Table 6 - Analytical Results for Waste Material Samples
Sample ID;
Collection Date:
Sample Depth (ft*):
Units:
Fluorene
}
Acenaphthene
Phenanthrene
Anthracene
Pyrene
Fluoranthene
Benzo(a)pyrene
Chrysene
/
Benzo(b)fluoranthene
Benzo(a)a,nthracene
fiWP-1
3/5/93
4-6 feet
ppm
2.2J
ND
ND
ND
ND
ND
ND
ND
NWP-2
3/5/93
2-4 feet
ppm
3.6J
2.7J
16J
16J
7.6J
11J
2.1J
5.2J
4.3J
3.9J
NWP-3
3/5/93
4-6 feet
ppm
ND
ND
68J
ND
37J
58J
ND
23J
19J
21J
PESTICIDES
alpha-BHC
detta-BHC
Aldrin
Methoxychlor
Dieldrin
Heptachlor Epoxide
4,4'-DDE
Endosulfan II
4,4'-DDD
Endrin Ketone
gamma-Chlordane
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.026P
0.065P
0.0066JP
0.054JP
ND
ND
ND
ND
ND
ND
ND
ND
0.19
ND
ND
0.045P
0.032P
0.036P
0.01 5JP
0.045J
0.024JP
0.0049JP
HERBICIDES
2,4-D
13J
17J
ND
23
-------
Table 6 - Analytical Results for Waste Material Samples
Sample ID:
Collection Date:
Sampfe Depth (ft):
Units:
NWP-1
3/5^3
4-feet
ppm
NWP-2
3/5/93
2-4 feet
ppm
NWP-3
3/993
4-6 feet
ppm
Data Qualifiers:
"J" - Estimated value, the compound was detected at less than the
minimum detection limit.
"ND" - The compound was not detected.
"P" - There was greater than 25% difference between gas chromatograph
columns.
contact with these substances. Separate calculations are made for those substances that can
cause cancer (carcinogenic) and for those that can cause non-carcinogenic, but adverse, health
effects.
In general, a baseline risk assessment is performed in four steps: (1) data collection arid
evaluation, (2) exposure assessment, (3) toxicity assessment, and (4) risk characterization. Each
of these steps is explained further below.
1. Data Collection and Evaluation
The data collected and described in the previous section (Section VI - Nature and Extent of
Contamination) were evaluated for use in the BLRA. This evaluation involved reviewing the
quality of the data to determine which are appropriate to use to quantitatively estimate the risks
associated with Site soil, sediment, surface water, and groundwater. The concentrations used to
determine human health risks are derived by averaging the data for each media and men
calculating the upper 95th percentile confidence limit. By using this upper confidence limit,
EPA can be 95% certain that the true average concentration does not exceed mis level. This
concentration is referred to as the reasonable maximum exposure ("RME") concentration
because an individual would not reasonably be expected to be exposed to a higher concentration.
The RME values calculated based on the Site data are summarized in Table 7.
Table 7 - Reasonable Maximum Exposure Point Concentrations
Contaminant
2,4-D
alpha-BHC
beta-BHC
Surface
Soil
(mg/kg)
2.32E-01
1.95E-01
Sub-
surface
Soil
(mg/kg)
3.78E+00
3.22E+00
Ground-
water
(mg/L)
7.24E-02
Surface
Water
(mg/L)
Sediment
(mg/kg)
Fish
(mg/kg)
24
-------
Table 7 - Reasonable Maximum Exposure Point Concentrations
Contaminant
delta-BHC
gamma-BHC
Aldrin
Dieldrin
Endosulfan sulfate
gam ma-chlordane
Arochlor-1254
Arochlor-1260
Phenol
2-Chlorophenol .' ^
2-Methylphenol
4-Methylphenol
2,4-Dichlorophenol
2,4,6-Trichlorophenol
Carbon bisulfide
1 ,2-Dichloroethane
Trichloroethene
1 ,1 ,2-Trichloroethane
Benzene
Chlorobenzene
Naphthalene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Surface
Soil
(mg/kg)
2.69E-01
5.35E-02
5.59E-02
8.78E-02
5.21 E-01
2.39E+01
6.36E+00
5.55E+01
8.32E+00
2.98E+00
5.10E+00
Sub-
surface
Soil
(mg/kg)
'
3.16E-01
1.77E+00
2.03E+00
2.54E+00
1.37E+00
Ground-
water
(mg/L)
1 .54E-03
3.09E-09
5.26E+01
5.23E+00
4.01 E+01
5.37E+01
2.47E+01
1.08E+02
1.45E+00
1.44E+00
1.45E+00
1.45E+00
2.19E+01
1.45E+00
Surface
Water
(mg/L)
2.51 E-05
1
.
Sediment
(mg/kg)
1.52E-01
Fish
(mg/kg)
3.51 E-01
25
-------
Table 7 - Reasonable Maximum Exposure Point Concentrations
Contaminant
lndeno(1 ,2,3-cd)pyrene
Dibenz(a,h)anthracene
Benzo(g,h,i)perylene
Aluminum
Antimony
Arsenic
Barium .
Beryllium
Cadmium
Chromium ;,
* *V
Cobalt
Copper
Cyanide
Manganese
Mercury
Nickel
Thallium
Silver
Vanadium
Zinc
Surface
Soil
(mg/kg)
3.82E+00
1.84E+00
3.53E+00
1.55E+04
1.18E+01
2.31 E+02
1.67E+00
'
2.80E+01
6.72E+01
1.84E+01
1.95E+03
8.27E-01
8.62E-01
3.88E+01
Sub-
surface
Soil
(mg/kg)
1 .OOE+00
9.53E-01
1.78E+04
2.45E+00
1.58E+03
Ground-
water
(mg/L)
1.77E+01
1.32E-02
4.19E-03
3.67E-01
3.54E-03
7.46E-03
9.44E-03
2.20E-01
7.82E+01
1 .56E-01
1024E-02
3.32E+00
Surface
Water
(mg/L)
9.85E-03
3.49E-04
Sediment
(mg/kg)
2.25E+00
1 .48E+01
2.91 E+00
7.57+01
2.62E+03
1.77E+03
Fish
(mg/kg)
1.55E-02 .
8.80E-02
9.50E-03
1.58E-01
3.50E-03
1.80E+01
1.92E+00
2. Exposure Assessment
An exposure assessment involves three basic steps: 1) identifying the potentially exposed
populations, both current and future; 2) determining the pathways by which these populations
could be exposed; and 3) quantifying the exposure. Under current Site conditions, the BLRA
identified the following populations as having the potential for exposure to Site-related
contaminants, either currently and/or in the future:
26
-------
future residents living on the Site;
current and/or future off-site residents;
current and/or future recreational users of the Site;
future commercial or industrial workers at the Site; and
trespassers.
Future residents living on the Site have the potential for exposure to Site-related contaminants
through 1) ingestion of soil, sediments, surface water, and groundwater, and fish; 2) direct
contact with surface water; and 3) inhalation of water vapor during showering. If the future
residents obtain drinking water through a public drinking water supply, the groundwater
ingestion and inhalation pathways would be eliminated. For off-site residents, similar exposure
pathways exist, however, the overall potential for exposure is less. Off-site residents would only
be exposed to Site soils during recreational use of the Site and Site-related contaminants in
drinking water supplies from groundwater or the river would be substantially reduced.
Recreational users of the Site have the potential for exposure to Site-related contaminants
through ingestion offish, surface water, soil, and sediment as well as through direct contact with
surface water. Workers at the Site could be exposed to contaminants through ingestion of Site
soil and by drinking groundwater unless drinking water is provided through a public water
supply. Trespassers-have potential for exposure through ingestion and direct contact with Site
surface water and through ingestion of Site soil.
In order to quantify the potential exposure associated with each pathway, assumptions must be
made for the various factors used in the calculations. Table 8 summarizes the values used in the
BLRA.
3. Toxicity Assessment
The purpose of the toxicity assessment is to weigh available evidence regarding the potential for
particular contaminants to cause adverse effects in exposed individuals. Where possible, the
assessment provides a quantitative estimate of the relationship between the extent of exposure to
a contaminant and the increased likelihood and/or severity of adverse effects.
A toxicity assessment for contaminants found at a Superfund site is generally accomplished in
two steps: 1) hazard identification, and 2) dose-response assessment Hazard identification is
the process of determining whether exposure to an agent can cause an increase in the incidence
of a particular adverse health effect (e.g., cancer or birth defects) and whether the adverse health
effect is likely to occur in humans. It involves characterizing the nature and strength of the
evidence of causation. Dose-response evaluation is the process of quantitatively evaluating the
toxicity information and characterizing the relationship between the dose of the contaminant
administered or received and the incidence of adverse health effects in the administered
population.
27
-------
Table 8 - Exposure Assessment Factors
Exposure
Factors
Soil
Sediment
Surface
Water
Ground water
Fish
INGESTION EXPOSURE PATHWAY
Ingestion Rate:
Adult
Child
Adult Worker
Adolescent1
Exposure Fre-
quency (EF):
Resident
Recreational
Worker
Trespasser1
100 mg/day
200 mg/day
50 mg/day*
100 mg/day
350 days/year
20 days/year
250 days/year4
50 days/year
100 mg/day
200 mg/day
20 days/year
2 liters/day3
1 liter/day3
0.5 liters/day
350 days/year3
7 days/year
7 days/year
2 liters/day
1 liter/day
2 liters/day
350 days/year
250 days/year
54 g/day
20 g/day
350 days/year
DERMAL CONTACT EXPOSURE PATHWAY
Skin Surface
Area:
Adolescent1
EF:
Recreational
Trespasser1
Child Bathing
Bath Duration:
-.'-:
/
18,000cm3
7,200 cm3
16,000 cm3
7 days/year
7 days/year
350 days/year
0.33 hours/day
7,200 cm3
350 days/year
0.33 hours/day
INHALATION EXPOSURE PATHWAY
Inhalation
Rate: Adult
EF:
Shower
Duration:
0.0139m3/min
350 days/year
12 min/day
0.0139m3/min
350 days/year
12 min/day
Trespasser use by adolescent
Ingestion rate of subsurface soil estimated at 100 mg/day
Drinking water use
Exposure duration to subsurface soil estimated to be 120 days/year
28
-------
Table 8 Exposure Assessment Factors
Exposure
Factors
Soil
Sediment
Surface
Water
Ground water
Fish
EXPOSURE ASSESSMENT CONSTANTS
Exposure
Duration:
Adult resident
Adult worker
Child resident
Adolescent
trespasser
Body Weight:
Adult
Child
Adolescent
Averaging
Time:
Adult resident
Child resident
Adult worker
Trespasser
24 years
25 years
6 years
6 years
*
24 years
1 year
6 years
24 years
25 years
6 years
70kg
15kg
55kg
Carcinogens: / Noncarcinogens:
70 years 24 years
70 years 6 years
7D years 25 years
70 years 6 years
From this quantitative dose-response relationship, toxicity values (e.g., reference doses and slope
factors) are derived that can be used to estimate the incidence or potential for adverse effects as a
function of human exposure to the agent. These toxicity values are used in the risk
characterization step to estimate the likelihood of adverse effects occurring in humans at
different exposure levels.
For the purpose of the risk assessment, contaminants were classified into two groups: potential
carcinogens and noncarcinogens. The risks posed by these two types of compounds are assessed
differently because noncarcinogens generally exhibit a threshold dose below which no adverse
effects occur, while no such threshold can be proven to exist for carcinogens. As used here, the
term carcinogen means any chemical for which there is sufficient evidence that exposure may
result in continuing uncontrolled cell division (cancer) in humans and/or animals. Conversely,
the term noncarcinogen means any chemical for which the carcinogenic evidence is negative or
insufficient.
Slope factors have been developed by EPA's Carcinogenic Assessment Group for estimating
excess lifetime cancer risks associated with exposure to potentially carcinogenic contaminants of
concern. Slope factors, which are expressed in units of (kg»d/mg) are multiplied by the
estimated intake of a potential carcinogen, in mg/kg/day, to provide an upper-bound estimate of
the excess lifetime cancer risk associated with exposure at that intake level. The term "upper-
bound" reflects the conservative estimate of the risks calculated from the slope factor. Use of
29
-------
this approach makes underestimation of the actual cancer risk highly unlikely. Slope factors are
derived from the results of human epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been applied to account for the use
of animal data to predict effects on humans. Slope factors used in the baseline risk assessment
are presented in Table 9.
Reference doses ("RfDs") have been developed by EPA for indicating the potential for adverse
health effects from exposure to contaminants of concern exhibiting noncarcinogenic effects.
RfDs, which are expressed in units of mg/kg/day, are estimates of acceptable lifetime daily
exposure levels for humans, including sensitive individuals. Estimated intakes of contaminants
of concern from human epidemiological studies or animal studies to which uncertainty factors
have been applied to account for the use of animal data to predict effects on humans. Reference
doses used in the baseline risk assessment are presented in Table 9.
4. Human Health Effects
The health effects of the Site contaminants that are most associated with the unacceptable risk
levels are summarized below. In most cases, the information in the summaries is drawn from the
Public Health Statement in the Agency for Toxic Substances and Disease Registry's (ATSDR)
toxicological profile forthe chemical.
Aldrin & Dieldrin: The carbamate insecticide Aldrin exists as a colorless crystalline solid at
room temperature, having a molecular weight of 365 and melting point of 104 C. It is highly
soluble in non-polar solvents but only slightly soluble in water. Aldrin is readily taken into the
body via inhalation, dermal absorption, ingestion or eye contact.
EPA considers aldrin to be a Class B2 carcinogen because it causes tumors in rats and mice.
Aldrin also causes birth defects and damage to the reproductive system, liver toxicity, and
central nervous system abnormalitites following chronic exposure. It is also acutely toxic, wit
Aldrin also causes birth defects and damage to the reproductive system, liver toxicity, and
central nervous system abnormalitites following chronic exposure. It is also acutely toxic, with
an oral LDSO (i.e., dose which is lethal to 50% of the test animals in research studies) of about
50 mg/kg. Aldrin is highly toxic to aquatic organisms, and has been associated with large-scale
kills of terrestrial wildlife in treated areas.
Table 9 - Slope Factors and Reference Doses
Chemical
2,4-D
alpha-BHC
beta-BHC
delta-BHC
Slope factors (kg*d/mg)
Oral
6.30E+00
1.80E+00
1 .80E+00
Inhaled
6.30E+00
1.80E+00
1.79E+00
Reference Doses (mg/kg/d)
Oral
1.00E-02
Inhaled
30
-------
Table 9 - Slope Factors and Reference Doses
Chemical
gamma-BHC
Aldrin
Dieldrin
Endosulfan sulfate
gamma-chlordane
Arochlor-1254
Arochlor-1260
Phenol
2-Chlorophenol
2-Methylphenol
... V«V'
4-Methylphenol
2,4-Dichlorophenol
2,4,6-Trichlorophenol
Carbon disulfide
1 ,2-Dichloroethane
Trichloroethene
1 ,1 ,2-Trichloroethane
Benzene
Chlorobenzene
Naphthalene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
lndeno(1 ,2,3-cd)pyrene
Slope factors (kg*d/mg)
Oral
1.30E+00
1.70E+01
1 .60E+01
1.30E+00
7.70E+00
7.70E+00
/
1.10E-02
9.10E-02
1.10E-02
5.70E-02
2.90E-02
7.30E-01
7.30E-03
7.30E-01
7.30E-02
7.30E+00
7.30E-01
Inhaled
1.72E+01
1.61E+01
1.30E+00
1.09E-02
9.10E-02
6.00E-02
5.60E-02
2.91 E-02
6.10E-01
6.10E-03
6.10E-01
6.10E-02
6.10E+00
6.10E-01
Reference Doses (mg/kg/d)
Oral
3.00E-04
3.00E-05
5.00E-05
6.00E-03
6.00E-05
6.00E-01
5.00E-03
5.00E-02
5.00E-03
3.00E-03
1.00E-01
6.00E-03
4.00E-03
2.00E-02
4.00E-02
Inhaled
2.86E-03
2.86E-03
1.43E-04
5.71E-03
31
-------
Table 9 - Slope Factors and Reference Doses
Chemical
Dibenz(a,h)anthracene
Benzo(g,h,i)perylene
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt .'.-
Copper
Cyanide
Manganese
Mercury
Nickel
Thallium
Silver
Vanadium
Zinc
Slope factors (kg*d/mg)
Oral
7.30E+00
1.75E+00
4.30E+00
Inhaled
6.10E+00
1.51E+01
8.40E+00
6.30E+00
4.20E+01
Reference Doses (mg/kg/d)
Oral
2.90E+00
4.00E-04
3.00E-04
7.00E-02
5.00E-03
5.00E-04
5.00E-03
3.71 E-02
5.00E-03
5.00E-03
3.00E-04
2.00E-02
8.00E-05
5.00E-03
7.00E-03
3.00E-01
Inhaled
1.43E-04
1.14E-04
8.57E-05
Antimony: Antimony can enter the body by absorption from the gastrointestinal tract following
ingestion of food or water containing antimony, or by absorption from the lungs after inhalation.
Ingestion of high doses of antimony can result in burning stomach pains, colic, nausea, and
vomiting. Long-term occupational inhalation exposure has caused heart problems, stomach
ulcers, and irritation of the lungs, eyes, and skin. The critical or most sensitive noncarcinogenic
effects of exposure to antimony are shortened life span, reduced blood glucose levels, and altered
cholesterol levels. Existing data suggest that antimony may be an animal carcinogen but are not
sufficient to justify a quantitative cancer potency estimate at this time. In laboratory rats,
inhalation of antimony dust can increase the risk of lung cancer. However, there is no evidence
32
-------
of increased risk of cancer to animals from eating food or drinking water containing antimony. It
is not known whether antimony can cause cancer in humans.
Arsenic: Arsenic is a metal that is present in the environment as a constituent of many organic
and inorganic compounds. Arsenic is a known human carcinogen implicated in skin cancer in
humans. Inhalation of arsenic by workers is known to cause lung cancer. Arsenic compounds
cause chromosome damage in animals, and humans exposed to arsenic compounds have an
increasesd incidence of chromosomal aberations. Arsenic compounds are reported to be
teratogenic, fetoxic, and embryotoxic in some animal species. Dermatitis and associated lesions
are attributable to arsenic coming into contact with the skin, with acute dermatitis being more
common man chronic. Chronic industrial expsoures may be characterized by hyperkeratosis,
and an accompanying hyperhidrosis (excessive sweating usually of the palms and soles of the
feet).
Benzene: Benzene is readily absorbed by inhalation and ingestion, but is absorbed to a lesser
extent through the skin. Most of what is known about the human health effects of benzene
exposure is based on studies of workers who were usually exposed for long periods to high
concentrations of benzene. Benzene is, toxic to blood-forming organs and to the immune system.
Excessive exposure (inhalation of concentrations of 10 to 100 ppm) can result in anemia, a
weakened immune system, and headaches. Occupational exposure to benzene may be associated
with spontaneous abortions and miscarriages (supported by limited animal data), and certain
developmental abnormalities such as low birth weight, delayed bone formation, and bone
marrow toxicity. Benzene is classified as a Group A human carcinogen based on numerous
studies documenting excess leukemia mortality among occupationally exposed workers.
Beryllium: The respiratory tract is the major target of inhalation exposure to beryllium. Short-
term exposure can produce lung inflammation and pneumonia-like symptoms. Long-term
exposure can cause berylliosis, an immune reaction characterized by noncancerous growths on
the lungs. Similar growths can appear on the skin of sensitive individuals exposed by dermal
contact. Epidemiological studies have found that an increased risk of lung cancer may result
from exposure to beryllium in industrial settings. In addition, laboratory studies have shown that
breathing beryllium causes lung cancer in animals. However, it is not clear what cancer risk, if
any, is associated with ingestion of beryllium. EPA has classified beryllium as a Group B2
probable human carcinogen based on the limited human evidence and the animal data
Chlordane: Chlordane can be absorbed by the body through dermal contact, inhalation of
particulates in ambient air, and ingestion of contaminated food or soils. It may remain stored for
months or years in the blood plasma or the body fat of the liver, spleen, brain, and kidneys.
Little data are available on the adverse health effects of chlordane exposure in humans.
Symptoms associated with human overexposure to mis compound include headache, dizziness,
lack of coordination, irritability, weakness, and convulsions. In humans, an acute oral lethal
dose of chlordane was estimated to be between 25 and 50 mg/kg. Experimental studies
exploring the health effects on animals exposed to various levels of chlordane showed an
association between exposure and immunologic dysfunction, reproductive dysfunction, nervous
33
-------
system damage, liver damage, convulsions, liver cancer, and death. The lethal dose of chlordane
in rats is estimated to be between 85 and 560 mg/kg, Some occupational epidemiology research
suggests an increased cancer risk associated with human exposure to chlordane. Chronic oral
treatment with chlordane resulted in significant increases in hepatocellular carcinomas in mice.
The EPA has classified chlordane as belonging to Group B2 probable human carcinogens.
Chlorobenzene: Chlorobenzene is a colorless liquid with a mild aromatic odor. It is used in the
manufacture of aniline, phenol, and chlorooitrobenzene and as an intermediate in the
manufacture of dyestuffs and many pesticides. Exposure to Chlorobenzene can occur through
inhalation, ingestion, eye and skin contact. Direct contact exposure can lead to eye, nose and
skin irritation. Long term exposure may cause liver damage. Chlorobenzene is not classifiable
as to carcinogenicity.
2-Chlorophenol: 2-Chlorophenol exists as a light amber liquid. It is used as an intermediate
in the manufacture of dyestuffs, higher chlorophenol, and preservatives.
2-Chlorophenol is toxic by all routes (i.e., ingestion, inhalation, dermal contact). Effects from
exposure include bums to the skin and eyes, weakness, headache, dizziness, damage to the
lung, liver, and kidneys, and death from cardiac or pulmonary failure. Ingestion caused
increase then decrease of respiration; blood pressure; urinary output; fever; increased bowel ~
action; motor weakness; collapse with convulsions and death. Ingestion causes lung, liver,
kidney damage an'd Contact dermatitis. Acute exposures by all routes may cause muscular
weakness, gastroenteric disturbances, severe depression and collapse. Although effects are
primarily on the central nervous system, edema of the lung and injury of pancreas and spleen
also may occur. Oral exposure may produce rapid circulatory collapse and death. Chronic
poisoning from oral or percutaneous absorption may produce digestive disturbances, nervous
disorders with fainmess, vertigo, mental changes, skin eruptions, jaundice, oliguria, and
uremia. 2-Chlorophenol has been shown to increase conception rate, decrease litter sizes of
exposed rats and to increase the percent of stillborn pups.
Cresols: Three types of closely related cresol exist: ortho-cresol (o-cresol), meta-cresol (m-
cresol), and para-cresol (p-cresol). Pure cresol are colorless chemicals, but they may be found in
brown mixtures such as creosote and cresylic acids (e.g., wood preservatives). Cresol in air
quickly change and break down into smaller chemicals, some of which irritate the eyes.
If you were to eat food or drink water contaminated with very high levels of cresol, you might
feel a burning in the mouth and throat as well as stomach pains. If your skin were in contact
with a substance containing high cresol levels, you might develop a rash or severe irritation. In
some cases, a severe chemical bum might result. If you came into contact with high enough
levels of cresol, for example, by drinking or spilling on your skin a substance containing large
amounts of cresol, you might become anemic, experience kidney problems, become
unconscious, or even die. Studies in animals have not found any additional effects mat would
occur after long-term exposure to lower levels of cresol. It is possible mat some of the effects in
humans listed above, such as kidney problems and anemia, might occur at lower levels if
exposure occurs over a longer time period. Effects on the nervous system, such as loss of
coordination and twitching of muscles, are produced by low levels of cresol in animals, but we
34
-------
do not know whether low levels also cause such effects in humans. Cresol may enhance the
ability of carcinogenic chemicals to produce tumors in animals, and they have some ability to
interact with mammalian genetic material in the test tube, but they have not been shown to
produce cancer in humans or animals. The EPA has determined that cresol are possible human
carcinogens. Animal studies suggest that cresol probably would not produce birth defects or
affect reproduction in humans.
1.2-Dichloroethane (1.2-DCA): The lungs, heart, liver, and kidneys are the organs primarily
affected in both humans and animals exposed to 1,2-DCA. Short-term exposure to 1,2-DCA in
air may result in an increased susceptibility to infection and liver, kidney, and/or blood disorders.
Effects seen in animals after long-term exposure to 1,2-DCA included liver, kidney, and/or heart
disease, and death. 1,2-DCA has caused increased numbers of tumors in laboratory animals
when administered in high doses in the diet or on the skin, and is classified as a Group B2
probable human carcinogen.
2.4-Dichlorophenol: 2,4-Dichlorophenol is a white solid, the form in which it is usually sold
and used. 2,4-Dichlorophenol evaporates slightly faster than water, which evaporates slowly.
It can also burn. Most of the 2,4-dichlorophenol made is used directly to make other
chemicals, especially chemicals that kill weeds and other plants. 2,4-dichlorophenol also is
used to kill'germs..'-.Reports describing possible 2,4-dichlorophenol poisoning of factory
workers suggest that if you breathe air containing 2,4-dichlorophenol for several years, you
may damage your liver, skin, and possibly your kidneys. Skin contact with it over a long
period may cause the same effects. Animals that have eaten large amounts of 2,4-
dichlorophenol in food immediately developed rapid breathing, muscle tremors, convulsions,
weakness, hunched posture, loss of consciousness, and some even died. Animals that took
smaller amounts of it in food or water over a long period of time had damaged livers,
kidneys, spleens, bone marrow, and may also have damaged their respiratory tracts (although
this may have been from breathing in the chemical rather than from swallowing it). Rats that
drank water containing 2,4-dichlorophenol had some changes in the immune system, but the
effects of 2,4-dichlorophenol on the immune system have not been fully studied. It is not
known whether the same effects would happen hi people if they were exposed in the same
way. Some pregnant animals that drank water containing high levels of 2,4-dichlorophenol
died, and those that drank enough to become sick had spontaneous, abortions or gave birth to
offspring that had low birth weights. Therefore, pregnant women who unknowingly eat or
drink 2,4-dichlorophenol could harm themselves and their unborn babies. The EPA has not
classified 2,4-dichlorophenol as a carcinogen.
Hexachlorocvclohexane (HCH): Hexachlorocyclohexane (HCH), formerly known as benzene
hexachloride (BHC) and other common names, is a synthetic chemical that exists in eight
chemical forms (called isomers). One of these forms, gamma-HCH (or Y-HCH, commonly
known as lindane), was once used as an insecticide on fruit, vegetable, and forest crops. It is
still used in the United States and in other countries as a human medicine to treat head and
body lice and scabies, a contagious skin disease caused by mites. It is a white solid that may
evaporate into the air.
35
-------
The effects of breathing gamma-HCH and/or alpha-, beta-, and delta-HCH seen in humans are
blood disorders, dizziness, headaches, and changes in the levels of sex hormones. These
effects have occurred in workers exposed to HCH vapors during pesticide manufacture.
People who have swallowed large amounts have had seizures and even died. A few people
who have used very large amounts of gamma-HCH on their skin have had blood disorders or
even seizures. Animals that have been fed gamma- and alpha-HCH have had convulsions,
and animals fed beta-HCH have become comatose. All isomers can produce liver and kidney
disease. Reduced ability to fight infection was reported in animals fed gamma-HCH, and
injury to the ovaries and testes was reported in animals fed gamma-HCH or beta-HCH. In
animals, exposure by mouth to gamma HCH during pregnancy may cause an increas ed
number of fetuses with extra ribs. HCH isomers are changed by the body into other chemical
products, some of which may be responsible for the harmful effects. Long-term oral
administration of alpha-HCH, beta HCH, gamma-HCH, or technical-grade HCH to laboratory
rodents has been reported to result in liver cancer. The EPA has classified HCH as a Group
B2 probable human carcinogen.
Manganese: Following inhalation of manganese dust, absorption into rne bloodstream occurs
only if particles are sufficiently small t6 penetrate deeply into the lungs. Long-term inhalation of
manganese dust may result in a neurological disorder characterized by irritability, difficulty in
walking, and speech'disturbances. Short-term inhalation exposure has been associated with
respiratory disease. There are few reports of negative health effects in humans exposed to
manganese in drinking water or food. Laboratory studies of animals exposed to manganese in
water or food have demonstrated adverse health effects including changes in brain chemical
levels, low birth weights in rats when mothers were exposed during pregnancy, slower than usual
testes development, decreased body weight gain, and weakness and muscle rigidity in monkeys.
There are no human carcinogenicity data for manganese exposure. The data from some animal
studies have shown increases in tumors in a small number of animals at high doses of
manganese, but the data are inadequate to judge whether manganese can cause cancer. EPA has
judged manganese not classifiable as to human carcinogenicity (Group D).
Mercury: Human exposure to inorganic mercury is mainly through inhalation or ingestion. Most
dietary inorganic mercurials dissociate to divalent mercury in the gastrointestinal tract and are
poorly absorbed. Occupational studies have demonstrated that chronic exposure to metallic
mercury vapor via inhalation primarily affects the central nervous system and the kidneys.
Human exposure to organic (usually methyl) mercury is mainly through ingestioa Methyl
mercury compounds are known to be toxic via oral exposure, and fetuses and newborn infants
are particularly susceptible. Subchronic methyl mercury poisoning occurred in humans eating
contaminated fish from Minamata Bay, Japan, from 1953 to the 1960s. The medial level of total
mercury in fish in Minamata Bay was estimated to be about 11 mg/kg fresh weight. Methyl
mercury poisoning also occurred from eating bread produced from seed grain dressed with
methyl mercury fungicide. Nerve damage causing "pins and needles" sensations in the hands
and feet occurred at an estimated body burden of 25 mg of methyl mercury. No confirmed
positive reports of methyl mercury carcinogenicity in humans has appeared to date, and animal
experiments have generally yielded negative results.
36
-------
Polvcvclic Aromatic Hydrocarbons (PAHs): PAHs are a group of chemicals that are formed by
the incomplete burning of coal, oil, gas, garbage, tobacco, or almost any other organic substance.
Natural sources include forest fires and volcanoes. Consequently, PAHs occur naturally
throughout the environment in the soil and other environmental media Reproductive effects
have occurred in animals that were fed certain PAHs. Long-term ingestion of PAHs in food has
resulted in adverse effects on the liver and blood in mice. Those effects may also occur in
humans, but there is no exposure data to substantiate that adverse impacts in humans have, in
fact, occurred. No information is available from human studies to determine what non-cancerous
adverse health effects, if any, may result from exposure to specific levels of the individual PAHs,
although inhalation and skin exposures to mixtures containing PAHs have been associated with
cancer in humans. The levels and lengths of exposure to the individual PAHs that effect human
health cannot be determined from the human studies available. Therefore, evaluation of non-
cancer adverse health effects mat may result from exposure is somewhat uncertain.
EPA classifies a small group of PAHs as B2 probable human cacinogens. Benzo(a)pyrene is the
most potent of the carcinogenic PAHs. Serveral PAHs have caused cancer in laboratory animals
through ingestion, skin contact, and inhalation. Reports from human studies show that
individuals exposed to mixtures of other compounds and PAHs by breaming or through skin
contact for a long period of time can also develop cancer.
Polvchlorinated Biphenvls fPCBsk PCBs can enter the body when fish, other foods, or water
containing PCBs are ingested, when air mat contains PCBs is breathed, or when skin comes in
contact with PCBs. Skin irritations characterized by acne-like lesions and rashes and liver
effects were the only significant adverse health effects reported in PCB-exposed workers.
Epidemiological studies of workers occupationally exposed to PCBs thus far have not found any
conclusive evidence of an increased incidence of cancer in these groups. Effects of PCBs in
experimentally exposed animals include liver damage, skin irritations, death, low birth weights,
and other reproductive effects. Some strains of rats and mice that were fed PCB mixtures
throughout their lives showed increased incidence of cancer of the liver and other organs. Based
on these animal studies, the EPA has classified PCBs as Group B2 probable human carcinogens.
1.1.2-Trichloroethane (1.1.2-TCA): No case reports or epidemiological studies regarding human
occupational or environmental exposure are available. Studies with various animals, however,
suggest that 1,1,2-TCA can enter the body following inhalation of contaminated air, ingestion of
or dermal contact with contaminated drinking water, or through dermal contact with the solvent
itself. 1,1,2-TCA is a central nervous system depressant. It has narcotic properties and can act
as a local irritant to the eyes, nose, and lungs. 1,1,2-TCA is also associated with bom liver and
kidney damage. 1,1,2-TC A may be carcinogenic. It caused liver tumors in mice, but not rats,
chronically fed 1,1,2-TCA. No other studies have shown evidence of carcinogenicity, however.
Further studies with rats using higher concentrations, and other species would improve the
knowledge of 1,1,2-TCA carcinogenicity. Based upon the present evidence from animal studies,
the EPA considers 1,1,2-TCA a Group C possible human carcinogen.
Trichloroethvlene: Trichloroethylene is a colorless, nonflammable, noncorrosive liquid
primarily used as a solvent in vapor degreasing. It is also used as a dry-cleaning agent, and as a
37 .
-------
chemical intermediate in the production of paints and varnishes and other chemicals.
Trichloroelhylene has low acute toxicity. Chronic inhalation exposure to trichloroethylene has
been shown to cause liver, kidney, and nervous system disorders and skin irritation in animals.
The EPA has classified trichloroethylene as a Group B2-C carcinogen.
2.4.6-Trichlorophenol: 2,4,6-Trichlorophenol is a man-made chemical that appears as a
yellow solid. It has a strong, sweet smell and does not bum easily. It does not occur
naturally. In the past, the major uses of 2,4,6-trichlorophenol were as an antiseptic and
pesticide. Its uses also included preserving wood, leather and glue, and preventing the
buildup of mildew on fabric. In the environment, 2,4,6-trichlorophenol is found most
frequently in water, especially near hazardous waste sites contaminated with 2,4,6-
trichlorophenol. 2,4,6-Trichlorophenol can evaporate into the air. The human health effects
of 2,4,6-trichlorophenol are not known. However, it is possible that health effects observed in
animals following exposure to 2,4,6-trichlorophenol could occur in humans. No information
was found on short-term animal studies. However, results of long-term animal studies show
that 2,4,6-trichlorophenol causes changes in liver and spleen cells, and lowers body weight.
Long-term exposure to high levels of 2,4,6-trichlorophenol causes death in some animals.
This suggests that high levels of 2,4,6-trichlorophenol may be life-threatening to humans.
Cancer occurs in animals after continued long-term oral exposure to 2,4,6-trichlorophenol.
Whether or not 2,4^6-trichlorophenol causes cancer in humans.has not been adequately
studied. However, because 2,4,6-trichlorophenol causes cancer in animals, it is possible that
2,4,6-trichlorophenol could cause cancer in humans. The EPA has classified 2,4,6-
trichlorophenol as a Group B2 probable human carcinogen. 2,4,6-Trichlorophenol has not
been studied to determine if it causes birth defects, but 2,4,6-trichlorophenol has been shown
in animals to cause lowered body weight in newborns and a decrease in the number of
offspring. The higher the level of exposure and the longer the exposure to 2,4,6-
trichlorophenol, the greater the chance for adverse health effects.
5. Risk Characterization
The risk characterization process integrates the toxicity and exposure assessments into a
quantitative expression of risk For carcinogens, the exposure point concentrations and exposure
factors discussed earlier are mathematically combined to generate a chronic daily intake value
that is averaged over a lifetime (i.e., 70 years). This intake value is men multiplied by the
toxicity value for the contaminant (i.e., the slope factor) to generate the incremental probability
of an individual developing cancer over a lifetime as a result of exposure to the contaminant.
The National Oil and Hazardous Substances Pollution Contingency Plan ("NCP") established
acceptable levels of carcinogenic risk for Superfund sites ranging from one excess cancer case
per 10,000 people exposed to one excess cancer case per one million people exposed. This
translates to a risk range of between one in 10,000 and one in one million additional cancer
cases. Expressed as scientific notation, this risk range is between 1 .OE-04 and 1 .OE-06.
Remedial action is warranted at a site when the calculated cancer risk level exceeds 1. OE-04.
However, since EPA's cleanup goal is generally to reduce the risk to 1. OE-06 or less, EPA also
may take action where the risk is within the range between 1 .OE-04 and 1 .OE-06.
38
-------
The potential for noncarcinogenic effects is evaluated by comparing an exposure level over a
specified time period (i.e., the chronic daily intake) with the toxicity of the contaminant for a
similar time period (i.e., the reference dose). The ratio of exposure to toxicity is called a hazard
quotient. A Hazard Index ("HI") is generated by adding the appropriate hazard quotients for
contaminants to which a given population may reasonably be exposed. The NCP also states that
sites should not pose a health threat due to a non-carcinogenic, but otherwise hazardous,
chemical. If the HI exceeds one (1.0), there may be concern for the potential non-carcinogenic
health effects associated with exposure to the chemicals. The HI identifies the potential for the
most sensitive individuals to be adversely affected by the noncarcinogenic effects of chemicals.
As a rule, the greater the value of the HI above 1.0, the greater the level of concern.
Table 10 summarizes the total risk levels from all appropriate exposure routes calculated for
each group of individuals.
B. Ecological Risk Assessment
Neville Land Company and EPA collectively evaluated the ecological risks associated with the
Site. Based on these evaluations, contamination in all media (i.e., surface water, sediment, soil,
and groundwater) have the potential to have significant adverse impacts on the aquatic
ecosystem of the river.: ;In surface water, concentrations of mercury, copper, and chromium (VI)
Table 10 - Human Health Risks at the Site
Group of Individuals
On-Site Residents consuming groundwater
On-Site Residents on public water supply
Off-Site Residents consuming groundwater from
the Site
Off-Site Residents consuming river water that
came from the Site
Recreational Site Users
On-Site Workers consuming groundwater
On-Site Workers on public water supply
Trespassers
Cancer Risk
4.54E-02
3.00E-04
2.24E-04
1.86E-04
1.85E-04
1.48E-02
1.45E-05
3.35E-06
Hazard Index
10,000
26.3
1,710
25.3
25.0
732
0.0234
0.0294
are potentially harmful to the Main Channel of the Ohio River while chromium and copper
present an ecological risk in the Back Channel. Contaminants of ecological significance in the
sediment adjacent to the Site in both the Main Channel and the Back Channel include heavy
39
-------
metals, pesticides, PCBs, and SVOCs, particularly phenols. In soil at the Site, metal
contaminants including arsenic, copper, lead, manganese, mercury and zinc are present at levels
that have a high potential to affect ecological receptors. Other soil contaminants, mostly PAHs
and pesticides, were found above background levels and could also result in adverse impacts.
Groundwater, which is a pathway by which soil contaminants reach the river, is contaminated by
several contaminants of ecological concern, particularly mercury, zinc, phenols and phthalates.
Pesticides and chlorocarbons are also of concern. Given the level of contamination in surface
water and sediment, soil contaminants from the Site are suspected to have contributed to
degradation of the river.
VHI. DESCRIPTION OF ALTERNATIVES
In the Feasibility Study ("FS"), engineering technologies applicable to remediating the
contaminated media were screened according to their effectiveness and implementability. Those
technologies remaining after the screening process were then developed into remedial
alternatives. The alternatives in the FS address the following media: soil, groundwater, surface
water, and sediment This ROD focuses exclusively on soil and buried waste remediation;
therefore, the FS alternatives were revised to include only cleanup activities associated with soil
and buried waste remediatioa
Alternative 1: No Action
Capital Cost:5 0
Present Worth Cost: 0
Annual O&MCost 0
Time to Implement: 0
Section 300.430(e)(6) of the NCP requires that EPA consider a "No Action" alternative for every
Superfund site to establish a baseline or reference point against which each of the remedial
action alternatives are compared. In the event that the other identified alternatives do not offer
substantial benefits in the reduction of toxicity, mobility, of volume of the constituents of
concern, the No Action alternative may be considered a feasible approach. This alternative
leaves the Site undisturbed and all current and potential future risks would remain.
The costs provided in this document are estimates to be used solely for the purpose of
comparative analysis.
40
-------
Alternative 2: Multilayer Cap, Surface Water Runoff Controls, Monitoring, and
Institutional Controls
Capital Cost: $2,127,981
Total Present Worth Cost: $3,647,981
Annual Cost: Monitoring6 $ 80,000
O&M1 $ 40,000
Time to Implement: > 1 year
This Alternative is based upon Alternative 4C from the FS, as modified by EPA, and includes
the following components:
A multilayer cap designed in accordance with Pennsylvania Residual Waste Management
Regulations would be installed over the area of the Site where wastes are buried (Figure 2). This
multilayer cap would reduce the rate at which precipitation infiltrates through the soil and buried
waste and into the groundwater. The multilayer cap would also reduce the risk of direct
exposure to the soil contaminants and control migration of contaminated soils. The actual size
and location of the multilayer cap would be determined during the remedial design phase of the
project. The multilayer cap would cover areas where concentrated wastes are present, including
the trench areas. - .;
-, ' *v*.
Areas that are not covered by the multilayer cap but still exhibit low levels of Site contaminants
would be covered by an erosion cap consisting of a soil cover and vegetatioa In some areas, the
existing soil cover and vegetation provides an adequate erosion cover. Other areas will require
improvement. Areas used in the future for commercial/industrial development would need to
establish and maintain an erosion cap in areas where low level contamination is present.
To ensure the integrity of the multilayer cap, the on-site oil well would need to be properly
abandoned in accordance with Pennsylvania Oil and Gas Well Regulations. In addition, the
remedial design for the multilayer cap would need to permit access to the active oil pipeline for
maintenance or provide for relocation of the pipeline.
A passive type of gas collection system using gas vents would be designed in accordance with
Pennsylvania Residual Waste Management Regulations and installed to ensure the integrity of
the cap.
An engineered surface water runoff and erosion control system would be designed and installed
to control transport of surface soil both on- and off-site. The system would consist of grass
The cost for monitoring in Alternatives 2, 3, and 4 was estimated for three years.
7 The cost for O&M in Alternatives 2,3, and 4 was estimated for 30 years.
41
-------
drainage swales constructed along the perimeter of die Site near the Main and Back Channel
shorelines. The swales would be designed in accordance with applicable regulations and design
standards and would be connected directly with three sedimentation basins constructed near the
existing storm water runoff outfall structures.
Operation and Maintenance of the multilayer cap, erosion cap, gas collection system, and
surface water control system would be routinely performed to ensure all components of the
remedy continue to function properly and achieve their performance requirements.
A monitoring program would be implemented to assess the remedy's effectiveness in limiting
further migration of Site contaminants into the groundwater, surface water and sediment at the
Site. The sample collection locations and analytical requirements would be developed during the
remedial design. This monitoring program may be expanded based on the finding in the OU3
investigation to include additional groundwater monitoring to ensure that off-site migration of
contaminants is being adequately controlled.
Institutional controls would be implemented to restrict land and groundwater use at the Site and
reduce the potential for human exposure to contamination. Deed restrictions would be required
to eliminate the future possibility of residential development and/or use of groundwater at the
Site. Permanent warning signs would also be posted at the Ohio River banks to warn potential
fishermen against eating bottom-feeding fish.
Alternative 3: Waste Material Stabilization, Multilayer Cap, Surface Water Runoff
Controls, Monitoring, and Institutional Controls
Capital Cost. $13,073,031
Total Present Worth Cost: $14,593,031
Annual Cost: Monitoring $ 80,000
O&M $ 40,000
Time to Implement: 2 years
This alternative is based upon Alternative 7 in the FS with modifications by EPA. This
alternative is similar to Alternative 2 described above with the exception of the remedy for the
concentrated waste buried in trenches at the Site. These buried wastes would be stabilized under
mis alternative prior to being covered with a multilayer cap as in Alternative 2. Stabilization
would be accomplished on-site by large-scale mechanical mixing of waste materials (and the soil
in the areas contiguous to the waste materials) with chemical reagents and/or cements of various
types. Stabilization decreases the mobility and direct exposure potential of surface soil and
buried waste. Additional sampling to determine die range of composition of the waste materials
would be required before a suitable selection of binding materials could be made. Because the
wastes were deposited at various times over a long period, their compositions may not be
homogeneous. Therefore, stabilization may require the use of a variety of binding materials
specific to each trench and possibly to various regions within each trench. Additional analysis
and treatability testing would be required during the remedial design to locate and characterize
42
-------
the type and the volume of material to be stabilized.
Alternative 4: Waste Material Removal, Multilayer Cap, Surface Water Runoff
Controls, Monitoring, and Institutional Controls
Capital Cost: $22,082,556
Total Present Worth Cost: $23,602556
Annual Cost: Monitoring $ 80,000
O&M $ 40,000
Time to Implement: 2 years
This Alternative is based upon Alternative 8 in the FS, as modified by EPA. Under this
alternative, the concentrated waste buried in the on-site trenches would be excavated and
transported off-site for subsequent disposal in a licensed waste facility. Following excavation,
the trench areas would be backfilled with clean soil. The remaining components of the remedy,
including the multilayer cap and the groundwater extraction and treatment requirements, would
be the same as those described in Alternative 2.
IX. COMPARATIVE EVALUATION OF ALTERNATIVES
Each of the four (4) remedial alternatives summarized in this ROD has been evaluated against
the nine (9) evaluation criteria set forth in the NCP, 40 C.F.R. Section 300.430(e)(9). These nine
criteria can be categorized into three groups: threshold criteria, primary balancing criteria, and
modifying criteria. A description of the evaluation criteria is presented below:
Threshold Criteria:
1. Overall Protection of Human Health and the Environment addresses whether a remedy
provides adequate protection and describes how risks are eliminated, reduced, or
controlled.
2. Compliance -with Applicable or Relevant and Appropriate Requirements (ARARs)
addresses whether a remedy will meet all of the applicable, or relevant and appropriate
requirements of environmental statutes.
Primary Balancing Criteria:
3. Long-term Effectiveness refers to the ability of a remedy to maintain reliable protection
of human health and the environment over time once cleanup goals are achieved
4. Reduction ofToxicity, Mobility, or Volume through Treatment addresses the degree to
which alternatives employ recycling or treatment that reduces toxicity, mobility, or
43
-------
volume of contaminants.
5. Short-term Effectiveness addresses the period of time needed to achieve protection and
any adverse impacts on human health and environment that may be posed during the
construction and implementation period until cleanup goals are achieved.
6. Implementability addresses the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement a particular
option.
7. Cost includes estimated capital, operation and maintenance costs, and present worth
costs.
Modifying Criteria:
8. State Acceptance indicates whether, based on its review of backup documents and the
Proposed Plan, the State concurs with, opposes, or has no comment on the preferred
alternative.
9. Community Acceptance includes assessments of issues and concerns the public may have
regarding each alternative based on a review of public comments received on the
Administrative Record and the Proposed Plan.
A. Overall Protection of Human Health and the Environment
A primary requirement of CERCLA is that the selected remedial alternative be protective of
human health and me environment. A remedy is protective if it reduces current and potential
risks to acceptable levels under the established risk range posed by each exposure pathway at the
Site.
Alterative 1 would not adequately reduce direct exposure to contaminants present in soil and
would not control migration of these contaminants from the Site. Both current and potential
future users of the Site would be exposed to elevated human health risks as indicated previously
in Table 10 in this ROD. In addition, adverse ecological impacts would continue unabated at the
Site. Because this alternative does not meet the threshold criteria of protection of human health
and the environment, it will not be considered further in this analysis.
Alternatives 2,3 and 4 are all protective of human health and the environment. Each of these
alternatives reduces the potential for exposure to and migration of Site contaminants, but each
does it in a different way. Under Alternative 2, the wastes and contaminated soil remain in
place, but their potential for further migration is reduced by placing an impermeable multilayer
cap over them. Alternative 3 stabilizes the concentrated wastes to immobilize the contaminants
prior to construction of the multilayer cap. Alternative 4 removes the concentrated waste,
backfills the excavated areas with clean soil, and covers these areas along with other areas of
44
-------
contaminated soil with a multilayer cap. The alternatives also include institutional controls to
restrict use of the Site to prevent potential exposure to any remaining contaminants. Although
Alternatives 2, 3 and 4 are all effective in protecting human health and the environment, each
does involve different tradeoffs as to other factors such as permanence and cost which will be
discussed below under those criteria.
B. Compliance with Applicable or Relevant and Appropriate Requirements (ARARS)8
>
Any cleanup alternative considered by EPA must comply with all applicable or relevant and
appropriate federal and state environmental requirements. Applicable requirements are those
substantive environmental standards, requirements, criteria, or limitations promulgated under
federal or state law that are legally applicable to the remedial action to be implemented at the
Site. Relevant and appropriate requirements, while not being directly applicable, address
problems or situations sufficiently similar to those encountered at the Site that their use is well-
suited to the particular site. Alternatives 2, 3, and 4 would be required to comply with me
following ARARs, as appropriate:
Chemical-Specific ARARs /
There are currently no ARARs establishing acceptable concentrations for contaminants in soil at
the Site. However/the Pennsylvania Land Recycling Technical Manual, Appendix B2, is a
guideline to be considered in implementation of the remedy.
PADEP has identified the Land Recycling and Environmental Remediation Standards Act ("Act
2") as an ARAR for this remedy. EPA has determined that Act 2 does not, under the facts and
circumstances of this remedy, impose any requirements more stringent than the federal
standards.
Location Specific ARARs
Floodplain:
Federal Executive Order 11988 on Floodplain Management, which requires federal agencies to
reduce the risk of flood loss, to minimize the impact of floods, and to restore and preserve the
natural and beneficial values of floodplains, is "to be considered" during any remedial activity
under Alternatives 2, 3 and 4. 40 C.F.R. Part 6, Appendix A sets forth the "Statement of
Procedures on Floodplain Management and Wetlands Protection."
The Pennsylvania Solid Waste Disposal Act (SWDA) and its implementing regulations at 25 Pa.
8 Under Section 121(d) of CERCLA, 42 U.S.C. § 9621 (d), and EPA guidance, remedial actions at
CERCLA sites must attain legally applicable or relevant and appropriate federal and promulgated state
environmental standards, requirements, criteria and limitations which are collectively referred to as
"ARARs", unless such ARARs are waived under Section 121(d)(4) of CERCLA, 42 U.S.C. § 9621(d)(4).
45
-------
Code Chapter 269, Subchapter A sets forth requirements for siting hazardous waste treatment
and disposal facilities. Section 269.22 prohibits the siting of surface impoundments, landfills,
land treatment facilities, and treatment and incineration facilities within the 100-year floodplain.
These regulations are applicable to any hazardous waste treatment activity in Alternative 3, since
a portion of the Site is within the 100-year floodplain.
Action-Specific ARARs
>
Multilayer Cap:
The Pennsylvania Residual Waste Management Regulations, 25 Pa. Code Chapter 288,
Subchapter C, regarding the closure of landfills are relevant and appropriate to the covering or
capping of the landfilled industrial waste materials in Alternatives 2, 3, and 4. Relevant
provisions include 288.212 (access control), 288.234 (final cover and grading), 288.262 (gas
control monitoring), 288.236 (revegetation), 288.237 (standards for successful revegetation),
288.242 (soil erosion and sedimentation control), and 288.181 and 288.291 (postclosure land use
plan). Additional maintenance requirements for caps set forth in 25 Pa, Code Section 264.117
(30-years time frame) are relevant and Appropriate in Alternatives 2,3 and 4.
Erosion cap:
«, *"**'
The Pennsylvania Residual Waste Management Regulations, 25 Pa. Code Chapter 288,
Subchapter C, regarding the closure of landfills are relevant and appropriate for capping of areas
containing low-level contaminants. Relevant provisions include Sections 288.234 (d), (e), (f),
and (g) (final cover), 288.236 (revegetation), 288.237 (standards for successful revegetation),
and 288.242 (soil erosion and sedimentation control).
Erosion Control/Surface Water Runoff.
Erosion control shall also be accomplished in accordance with 25 Pa .Code Chapter 102 (erosion
control), Sections 102.4-24. 25 Pa Code, Chapter 105, Subchapter B, Dams and Reservoirs,
Sections 105.102-107 and 105.131-136 (for sediment pond construction and maintenance) are
applicable, and §§ 288.242 and 288.243 of the Pennsylvania Residual Waste Management
Regulations are relevant and appropriate.
Handling Hazardous Waste:
The Pennsylvania Hazardous Waste Management Regulations, 25 Pa Code, Chapters 261, and
262, and 40 C.F.R. Section 261.24 (toxicity characteristic), would be applicable for the
identification, generation, and handling of hazardous waste generated during stabilization
activities in Alternative 3 or during excavation of buried waste in Alternative 4, and hazardous
liquid wastes generated during decontamination of equipment. Applicable Sections include:
262.22 (hazardous waste determination); 262.20 and 23 (manifests); and 262.30 and 33
(pretransport requirements). Regulations at 25 Pa Code Chapter 273 are applicable to the
46
-------
disposal of wastes determined not to be hazardous in Alternatives 3 and 4.
25 Pa. Code Chapter 264, Subchapter G, Section 264.114 (disposal or decontamination of
equipment, structures and soils) is applicable to the decontamination of equipment used in the
excavation and treatment of contaminated materials in Alternatives 3 and 4.
25 Pa Code Chapter 264 Subchapters B, C, D, F and G contain provisions that would be relevant
and appropriate to the stabilization of buried wastes in Alternative 3, if any such waste is
determined to be hazardous. These provisions include: Sections 264.14 and 17 (general facility
standards); Sections 264.31-34 and 37 (preparedness and prevention), Sections 264.51, 52, 55
and 56 (contingency plan and emergency procedures); Section 264.97 (general ground water
monitoring requirements); Sections 264.111,112,114,117, and 118 (Closure and Postclosure).
25 Pa. Code Chapter 264 Subchapters I, J and L contain provisions that would be relevant and
appropriate to the temporary storage of hazardous wastes on-site in containers, tanks or waste
piles during excavation and treatment of buried wastes in Alternative 3 and prior to
transportation of excavated wastes off-site in Alternative 4. These provisions include: Sections
264.171-179 (use and management of Containers); Sections 264.192-194, 197-199 (tanks); and
Sections 264.251-258 (waste piles).
Oil \vellAbandonnierit.
The Pennsylvania Oil and Gas Well Regulations, 25 Pa. Code Chapter 78, Subchapter D,
Sections 78.91-98, would be applicable to the abandonment of the on-site oil well in Alternatives
2, 3 and 4.
Air Emissions:
The State Implementation Plan (SEP) for Pennsylvania as incorporated at 40 C.F.R. Part 52,
Subpart NN, Section 52.2020 et seq.. includes substantive State regulations, including
Pennsylvania Air Quality Control Regulations, which are applicable to remedial activities
generating air emissions at the Site, including earth moving activities and the construction of the
gas venting system in Alternatives 2, 3 and 4. Applicable Sections include: 25 Pa. Code
Sections 123.1 (prohibition of certain fugitive emissions), 123.2 (fugitive participate matter),
123.31 (limitations on odor emissions, 123.41 (limitations on visible emissions), 123.43
(measuring techniques for opacity), 127.1 (purpose) and 127.12(a)(3)-(8) (substantive elements
of permit application for anew or modified source, including use of Best Available Technology
(BAT) to limit emissions) and 131.2-3 (ambient air quality standards).
The federal Clean Air Act, 42 U.S.C. Section 7412, and its implementing regulations at 40
C.F.R. Part 61, establish National Emission Standards for Hazardous Air Pollutants (NESHAPs).
Subpart FF (Benzene Waste Operations), Sections 61.342-345,348,351, 354 and 355 may be
relevant and appropriate to the excavation, treatment and temporary storage of soils and buried
wastes contaminated with benzene in Alternatives 2, 3 and 4.
47
-------
C. Reduction of Toxicity, Mobility, or Volume through Treatment
Section 121(b) of CERCLA, 42 U.S.C. Section 9621(b), establishes a preference for remedial
actions which include treatment that permanently and significantly reduces the toxicity, mobility,
or volume of contaminants. The multilayer cap required in Alternatives 2, 3, and 4 would stop
infiltration of water through the soil, immobilizing buried waste and soil contaminants beneath
the cap, and controlling further spread of contamination from the soil into groundwater, surface
water, and sediment. Capping would also control the mobility of soil contaminants in the air
(e.g., in dust) and create a barrier protecting Site users from direct contact with soil
contaminants. Alternative 2 would not reduce the toxicity and volume of soil contaminants.
Alternative 3 requires use of a treatment technology (i.e., stabilization) which would further
reduce the mobility of the contaminants present in the concentrated waste buried in the trench
areas. Alternative 4 requires excavating the concentrated waste and transporting it to an off-site
permitted landfill specifically designed to prevent migration of contamination. If the
concentrations of contaminants in the waste exceed levels established under the RCRA Land
Disposal Restrictions, treatment would be required prior to landfilling.
D. Im piementability
This evaluation criterion addresses the difficulties and unknowns associated with implementing
the cleanup technologies associated with each alternative, including the ability and time
necessary to obtain required permits and approvals, the availability of services and materials, and
the reliability and effectiveness of monitoring.
The installation of a multilayer cap in Alternative 2, 3 and 4 utilizes well-known construction
methods. Necessary services and materials are readily available. Additional information would
be required during the remedial design to determine the exact location of buried waste in order to
design the cap appropriately.
The stabilization technology used in Alternative 3 is more complicated to implement than the
multilayer cap alone. Additional sampling and bench-scale laboratory treatability studies would
be performed during the remedial design to determine the type and amount of solidification
reagent required to adequately stabilize the waste material. Because the wastes were deposited
at various times over many years, and because of their different characteristics, stabilization will
require the use of a variety of binding materials, specific to each type of waste. There may be
wastes present that cannot be successfully immobilized using the stabilization technology.
The excavation of waste required in Alternative 4 is a straightforward process. As with the other
alternatives, additional sampling and waste characterization will be necessary to determine the
location of concentrated wastes to be excavated and the appropriate landfill(s) for disposal.
Because of the large volume of waste involved, transportation costs could substantially increase
if appropriate landfill faculties with capacity for the waste are located at a significant distance
from the Site.
48
-------
E. Short-Term Effectiveness
Alternatives 2, 3 and 4 could pose an increased short-term health risk to on-site construction
workers and/or trespassers during earth-moving activities to construct the multilayer cap. These
activities have the potential to release volatile contaminants that may be present in the soil or
waste material. Alternative 3 has the potential for somewhat higher short-term health risks
because the stabilization process requires mixing contaminated wastes with the binding agents
and a greater release of volatile contaminants could occur. Alternative 4 could pose short-term
risks similar to or higher than Alternative 3* because the concentrated wastes will be excavated.
In all cases, however, these short-term risks could be minimized using standard safety measures.
F. Long-term Effectiveness and Permanence
Alternatives 2,3 and 4 provide a permanent and effective long-term remedy by requiring regular
and continuing maintenance of the multilayer cap. The construction of the multilayer cap would
eliminate the risk associated with direct contact with contaminants at the Site and would reduce
mobility of groundwater contaminants.' The degree of long-term effectiveness and permanence
increases with Alternatives 3 and 4. By immobilizing the contaminants through treatment,
Alternative 3 relies less on continued maintenance of the multilayer cap to achieve long-term
effectiveness and permanence. Similarly, Alternative 4 completely removes the concentrated
wastes from the Site, thereby eliminating the possibility of any.future risks at the Site from these
wastes and further increasing the long-term effectiveness and permanence. The monitoring
program would evaluate the ongoing effectiveness and permanence of Alternatives 2, 3 and 4.
G. Cost
Evaluation of costs of each alternative generally includes the calculation of direct and indirect
capital costs and the annual operation and maintenance (O&M) costs, both calculated on a
present worth basis. The total present worth cost of Alternatives 2, 3 and 4 has been calculated
for comparative purposes and is presented in Table 11.
fable 11
Estimated Cost of Alternatives
Alternative -
2
3
4
Total Present Worth Cost
$3,647,981
$14,593,031
$23,602,556
49
-------
Direct capital costs include costs of construction, equipment, building and services, and waste
disposal. Indirect capital costs include engineering expenses, start-up and shutdown, and
contingency allowances. Annual O&M costs include labor and material; chemicals, energy, and
fuel; administrative costs and purchased services; monitoring costs; costs for periodic site review
(every five years); and insurance, taxes, and license costs. For cost estimation purposes, a period
of 30 years has been used for O&M. In reality, maintenance of a multilayer cap would be
expected to continue beyond this period. The actual cost for each alternative is expected to be in
a range from 50 percent (50%) higher than the costs estimated to 25 percent (25%) lower than
the costs estimated. The evaluation was based on the FS cost estimates, as modified by EPA.
H. State Acceptance
The Commonwealth of Pennsylvania has had the opportunity to review and comment on all the
documents in the Administrative Record and has participated in selecting the remedy for this
Site. The State has had the opportunity/to comment on the draft ROD and, to the extent possible,
the Commonwealth's comments have been incorporated into the ROD. The State's formal
position on the selected remedy is forthcoming.
I. Community Acceptance
The community has been in general agreement with the alternative selected in this ROD.
Coraopolis Township and Neville Land Company have been familiar with EPA's preferred plan
for soil remediation at the Site and voiced no opposition. Oral and written comments on the
remedial alternatives evaluated by EPA for the implementation at the Site are included in Part
ffl of this ROD.
X. SELECTED REMEDY AND PERFORMANCE STANDARDS
Based upon consideration of the requirements of CERCLA, the detailed analysis of the
alternatives using the nine criteria, and public comments, EPA has determined that Alternative 2:
Multilayer Cap, Surface Water Runoff Controls, Monitoring and Institutional Controls is the
most appropriate remedy for the Ohio River Park Superfund Site. The major components of the
remedy and the required performance standards are listed below.
A. Multilayer Cap Performance Standards
The multilayer cap shall achieve the following:
1. The multilayer cap shall cover the areas where waste material has been disposed
including the trench area shown in Figure 2 and shall cover surrounding soil where the
50
-------
following contaminant concentrations are exceeded9:
Benzo(a)anthracene 7,800 ppb
Benzo(a)pyrene 780 ppb.
2. The multilayer cap shall protect Site users from being exposed to the soil contaminants,
listed in Table 6, that pose an unacceptable human health risk either by the direct contact
with contaminated waste/soil or by/inhalation/ingestion of soil dust
3. The multilayer cap shall achieve a permeability of 10"7 cm/sec or less to minimize
infiltration of water through the buried waste and into the groundwater.
4. The multilayer cap shall control water and air erosion of the soil into surface water,
groundwater and air.
5. The multilayer cap shall be designed and constructed in accordance with the
Pennsylvania Residual Waste Management Regulations, 25 Pa. Code Chapter 288,
Subchapter C, regarding the closure of landfills. Relevant provisions include, but are not
limited to, 288.212 (access control), 288.234 (final cover and grading), 288.262 (gas
control monitoring), 288.236 (revegetation), 288.237 (standards for successful
revegetation)," 288.242 (soil erosion and sedimentation control) and 288.181, 288.291
(cap maintenance). In the event the future use of the Site would require an alternate cap
design, this alternate cap design shall meet industry standards for stability, compressive
strength and bearing capacity.
6. The multilayer cap shall be designed and constructed to function with minimum
maintenance, to minimize water and air erosion of the cover into surface water,
groundwater and air, to accommodate settling so that the integrity of the cover is
maintained, and to provide adequate freeze protection for the liner.
7. The mulilayer cap shall sufficiently overlap the area of the former disposal trenches to
minimize infiltration of water through the buried waste.
8. The multilayer cap shall be revegetated and vegetation maintained in such a way as to
provide habitat for indigenous and migratory terestrial resources to the maximum extent
practicable without endangering the cap's integrity.
9. In the event that the future use of the Site would require an alternate cap design, this
alternate cap design shall meet industry standards for stability, compressive strength and
bearing capacity. Areas proposed for future commercial/industrial development would
need to be designed to preserve the integrity of the cap.
9 These concentrations are the acceptable levels for industrial use identified in the EPA Region III
Risk-Based Concentration Table dated April 19,1996.
51
-------
B. Erosion Cap Performance Standard
An erosion cap shall be constructed over any areas not covered by the multilayer cap where Site-
related contaminants have been detected if a vegetative cover adequate to prevent erosion does
not currently exist or if the existing vegetative cover is disturbed by future commercial/industrial
development Adequacy or non-adequacy, existence or non-existence of a vegetative cover shall
be determined during remedial design. The erosion cap shall include placement of soil, as
necessary, and establishment of a vegetative cover to prevent erosion of contaminants. Areas
proposed for future commercial/industrial development would need to be designed to establish
and maintain an erosion cap in areas where low level contamination is present.
C. On-Site Oil Well Performance Standard
The on-site oil well shall be abandoned in accordance with the Pennsylvania Oil and Gas Well
Regulations, 25 Pa Code Chapter 78, Subchapter D.
D. Gas Collection System Performance Standard
/
The gas collection system shall be implemented in accordance with the Pennsylvania Air Quality
Control Regulations,-25; Pa. Code Sections 123.1,123.31,127.1,127.12(a) and 131.2-3, and the
Pennsylvania Residual Waste Management Regulations, 25 Pa. Code Section 288.262 (gas
control monitoring).
E. Surface Water Runoff And Erosion Control System Performance Standards.
The system shall be designed in accordance with 25 Pa Code, Chapter 105, Subchapter B,
Dams and Reservoirs (for sediment pond construction and maintenance), and §§ 288.242 and
288.243 of the Pennsylvania Residual Waste Management Regulation. The system shall consist
of grass drainage swales constructed along the perimeter of the Site near the Main and Back
Channel shorelines. The swales shall be connected directly with three sedimentation basins
constructed near the existing storm water runoff outfall structures. The system shall be inspected
and maintained at least twice a year for at least 30 years. The maintenance shall include, at a
minimum, reseeding and clearing debris from the swales and cleaning the sedimentation basins.
F. Operation and Maintenance Performance Standard
The multilayer cap shall be maintained in accordance with the requirements set forth in 25 Pa
Code Sections 264.117, and 288.234. The cap should be inspected and maintaned at least twice
a year for at least 30 years. . .
G. Monitoring Program Performance Standards
The monitoring program shall include, as a minimum, collection and laboratory analysis of the
following:
52
-------
» Twelve groundwater samples from existing monitoring wells and, pending further
evaluation, installing additional monitoring wells both upgradient and downgradient of
the waste trench location between the Ohio River and Coraopolis water supply wells;
these samples will be analyzed for VOC, SVOC, pesticides, herbicides , and inorganics;
Two water samples from the Coraopolis drinking water supply wells and any other
municipal water supply wells found in close proximity to the Site; these samples will be
analyzed for VOC, SVOC, pesticides, herbicides, and inorganics;
Three sediment samples collected from the surface water runoff and erosion control
system sedimentation basins and one sample from the Back Chanel; these samples shall
be analyzed for PAHs, insecticides, herbicides, and metals;
Four surface water samples from the Ohio River, both upstream and downstream of the
Site, and water samples from any seeps discovered at me Site; these samples will be
analyzed for VOC, SVOC, pesticides, herbicides, and inorganics.
Groundwater samples shall be collected quarterly to evaluate potential contamination in different
seasons and surface water and sediment samples semianuaUy. The monitoring program shall be
reevaluated after three years to determine if changes are necessary. Monitoring will be
continued for 30 years. If the OU-3 ROD does not require any further remedial action at the
Site, but requires additional monitoring, the OU-3 monitoring requirements shall be incorporated
into mis monitoring program.
H. Institutional Controls Performance Standards
Institutional controls shall be implemented to restrict land and groundwater use at the Site and
reduce the potential for human exposure to contamination. Deed restrictions shall be required to
prohibit residential development, any use incompatible with the multilayer cap, and/or use of
groundwater at the Site. Permanent warning signs shall be posted at the Ohio River banks to
warn potential fishermen against eating bottom-feeding fish.
XL STATUTORY DETERMINATIONS
This remedy satisfies the remedy selection requirements of CERCL A and the NCP. The remedy
is expected to be protective of human health and the environment, complies with ARARs, is cost
effective, and utilizes permanent solutions. Because the contaminated materials will stay at the
Site, the remedy does not include treatment as a principal element of the remedy for soils. The
following is a discussion of how the selected remedial action addresses the statutory
requirements.
A. Overall Protection of Human Health and the Environment
The selected remedy will provide adequate protection of human health and the environment by
containing the concentrated waste and contaminated soils beneath the multilayer cap; controlling
53
-------
exposure to soil contaminants through water and air erosion by constructing surface water runoff
controls and an erosion cap; and assuring appropriate usage of the Site by imposing institutional
controls. These actions will reduce the carcinogenic risk from exposure to contaminated
waste/soils to commercial, industrial, and recreational Site users to within the acceptable EPA
risk range of 10^ to 10 "*, and will reduce the Hazard Index to less than one for non-carcinogenic
risks. This remedy will also minimize further migration of contamination into groundwater,
surface water and sediment by controlling surface water infiltration through the contaminated
waste/soil. >
B. Compliance with Applicable or Relevant and Appropriate Requirements (ARARS)
The selected remedy will comply with the action-specific ARARs for covering landfilled
industrial materials established by the Commonwealth of Pennsylvania in 25 Pa. Code, Chapter
288, Subchapter C.
C. Cost Effectiveness
EPA has determined that the selected remedy most effectively addresses contaminated
waste/soils while minimiTJng costs. The estimated present worth cost is $3,647,981. Other
alternatives were either less expensive, but ineffective, or more expensive, but only marginally
more protective man" the selected remedy.
D. . Utilization of Permanent Solutions and Alternative Treatment (or Resource
Recovery) Technologies to the Maximum Extent Practicable
EPA has determined that the selected remedy represents the maximum extent to which
permanent solutions and alternative treatment technologies can be utilized in a cost-effective
manner at the Site. The selected remedy does not require treatment because the treatment
alternative considered, stabilization of waste, would achieve only marginal additional protection
for more than triple the cost
E. Preference for Treatment as a Principal Element
As stated above, the selected remedy does not require treatment because the treatment alternative
considered, stabilization of waste, would achieve only marginal additional protection for more
man triple the cost
XII. DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan identified remedial alternatives to address all aspects of contamination at the
Site including buried waste, soils, groundwater, surface water, and sediments. During the public
comment period, the Neville Land Company provided information indicating that the
contaminated groundwater at the Site may be naturally attenuating and, therefore, not migrating
beyond the Site. The Neville Land Company requested an opportunity to collect additional site-
54
-------
specific information to evaluate this possibility further before EPA makes a decision on the
appropriate groundwater remedy for the Site. EPA agreed to allow this additional investigation.
Although this investigation is being performed on an expedited schedule, EPA did not want to
delay a decision on the remedy for the buried waste and contaminated soils at the Site.
Therefore, the remedy selected in this ROD addresses the buried waste and contaminated soils
consistent with the Proposed Plan, but does not address groundwater. EPA will select the
appropriate remedy for groundwater in a subsequent ROD after considering the findings from the
additional investigation. >
RECORD OF DECISION
OHIO RIVER PARK
PART III - RESPONSIVENESS SUMMARY
Comments raised during the public comment periods on the Proposed Plan for the Ohio River
Site are summarized in mis Responsiveness Summary. The first comment period was initially
held from April 2,1996 to May 1,1996 to address the Proposed Plan. Upon request, the public
comment period was extended until June 1,1996.
Oral comments were presented at the Proposed Plan Public Meeting on April 15,1996. These
comments and EPA's responses are presented in Section I of the Responsiveness Summary.
During the Proposed Plan Public Meeting, EPA received two written statements; EPA responses
to these statements are also presented in Section I. A transcript of the first public meeting has
been included in the Administrative Record for the Site.
EPA received five letters from concerned parties on the cleanup alternatives or other aspects of
Site activity during the public comment period Three letters were from local residents
concerned about the potential impact of Site-related contamination on their residences. The
other two letters were from a volunteer organization of residents and from the Buckeye Pipe Line
Company. The comments presented in these letters and EPA's responses are presented in Section
If of the Responsiveness Summary. These letters have been included in the Administrative
Record for the Site.
Neville Land Company ("NLC") submitted two sets of comments on the Proposed Plan. EPA
has reviewed and responded to these comments in Section El of the Responsiveness Summary.
These comments have also been included in the Administrative Record for the Site.
During the public comment period, NLC volunteered to start an additional study on groundwater
modeling and natural attenuation at the Site. EPA responded to mis initiative by postponing a
final decision pertaining to the groundwater and groundwater-related contamination until the
additional study is completed. Correspondence pertaining to the additional study which was
received from the NLC during the public comment period has also been included in the
Administrative Record for the Site.
55
-------
I. ORAL COMMENTS AND WRITTEN STATEMENTS FROM THE APRIL
15,1996 PUBLIC MEETING
A. Remedial Alternative Preferences
1) Several residents had general questions regarding the construction and design of the cap.
Response: A multilayer cap will be constructed over the areas of concentrated waste. The
cap will isolate surface soil and reduce the rate at which precipitation over the waste areas
infiltrates the soil and buried waste to reach the groundwater below. The cap also will
reduce the risk of direct exposure to contaminated soil. The cap will be constructed in
accordance with procedures that adhere to all applicable Pennsylvania regulations. The
details of the cap design will be completed during the remedial design phase of the project.
2) Residents did not understand how vegetation would be able to grow over the cap if
contaminated soil is present.
Response: EPA responded that contamination of soil does not automatically prevent plant
growth. Some plants can actually accumulate high concentrations of contaminants in their
cells. In areas of the Site to be capped, however, revegetation will occur in clean soil cover
that will be brought to the Site.
3) One resident stated that people grew crops and raised livestock on the Site during and after
the period that pollutants were deposited there (the 1930's). He said that people ate the
crops and consumed dairy products from the cows raised on the land without adverse
health affects. The resident also stated that it appeared that contaminants were not
migrating from the Site. Considering these issues, the resident believed that EPA should
not be spending millions of dollars to clean up the Site.
Response: The contaminant levels present at the Ohio River Park Site have the potential
to pose an unacceptable risk to human health and the environment. EPA is required by law
to respond to these contaminant levels, and also to develop long-term solutions for the
cleanup for sites such as mis one where hazardous substances pose a threat.
4) Residents wanted to know why Alternative 2, which involves capping the waste, was
chosen instead of Alternative 4, which calls for removal of the waste from the Site.
Response: EPA considered several criteria during the process of evaluating remedial
alternatives for the Ohio River Park Site. Alternative 2 provides the most reasonable
balance between the risk posed by this Site and costs required to implement each
alternative. The added risks and cost associated with excavating the material and/or
transporting it off-site do not provide a corresponding increase in overall effectiveness
since the wastes present at the Site can be reliably contained by capping.
56
-------
5) One resident wanted to know how the cleanup that will be performed at the Ohio River
Park Site will differ from the one that will be performed at the Herr's Island Site.
Response: Waste at Herr's Island was excavated and physically removed to another
portion of the island where it was consolidated in a lined waste cell and capped. Waste
areas at the Ohio River Park Site will be covered in place with a multilayer cap.
6) Residents asked about the anticipated life expectancy of the cap.
Response: Although caps do degrade over time, with proper maintenance they will last for
many years. The current property owner and all successive property owners will be
responsible for ensuring that the waste areas remain capped and that the cap is properly
maintained.
7) A resident was concerned about the durability of the cap and asked if capping was a
commonly used technology.
Response: Capping is a common technology which has been in existence for over 30
years. Caps have been used at many Superfund sites and municipal landfills. Additionally,
EPA will perform< a mandatory review of the remedial system every five years to ensure
that it remains protective of human health and the environment.
B. Future Use
8) A resident stated that EPA should consider implementing Alternative 4 if it will lessen
restrictions on land use once the cleanup is complete.
Response: Under Alternative 2, future land use will be restricted to prevent residential
development or future use of the groundwater. Under Alternative 4 (waste excavation),
these same restrictions would apply because only the concentrated wastes present at the
Site would be removed. Low level contamination would remain and would be covered
with clean soil and revegetated. While less contamination would remain at the Site under
Alternative 4, use of the Site for residential purposes would still be prohibited.
9) Several residents had questions regarding the planned future use of the Site for me park.
Response: The property that is occupied by the Ohio River Park Site is owned by the
NLC. The future use of the Site will be determined by the Site owners, in compliance with
any restrictions or prescriptions (e.g., zoning ordinances or master plans) of the local
government. The remedy required by EPA does include two important restrictions on the
future use of the Site. First, the remedy will include deed restrictions to prohibit future
installation of groundwater wells. Second, future residential use or any use incompatible
with me multilayer cap will be prohibited.
57
-------
10) A resident asked what the best-case and worst-case scenarios for future use of the Site
might be.
Response: In the past, some remediated Superfund Sites have been used as parks, ball
fields, and parking lots. Sites also have been used for light industrial purposes (e.g.,
warehouses, maintenance sheds). The worst-case scenario would probably involve
installation of a security fence and "No Trespassing" signs at the Site.
T
C. Cost/Funding Issues
11) A resident wanted to know why the NLC was not being held responsible for the cleanup.
Response: NLC is a responsible party at the Site and will be sent a Special Notice Letter
inviting them to make a good faith offer to perform the Site cleanup and pay for EPA's past
costs. EPA's preference is for responsible parties to finance and perform the cleanup of a
Superfund site. If the responsible parties do not perform the work willingly, EPA has
several enforcement options mat would compel them to clean up the site. Alternatively,
EPA could perform the cleanup and attempt to recover the costs from responsible parties
later.
12) A resident asked what assurance local residents have that a source of funding for the
proposed future monitoring will exist.
Response: Following implementation of the selected remedy, EPA will negotiate with the
responsible parties to compel implementation of this remedy, including the future
monitoring. EPA currently has substantial authority to require potentially responsible
parties to conduct necessary cleanup actions. Furthermore, according to Section
104(c)(3)(A) of CERCLA, 42 U.S.C. § 9604(c)(3)(A), and the NCP at 40 C.F.R. § 300.
510(c)(l), the State must provide assurance up front that it will assure all future
maintenance of the remedial action.
13) A resident wanted to know if any consideration was given to tax revenues mat could be
generated by industrial or residential tenants that may be able to occupy the Site if
Alternative 4 was implemented.
Response: As discussed in Question #8 above, future land use at the Site under Alternative
4 would not be significantly different than that allowed under Alternative 2. Even if higher
valued use could be made of the Site, tax revenues from potential development are not
considered when estimating the cost of Superfund cleanups. EPA only estimates those
costs necessary to clean up me Site.
D. Risk to Human Health and the Environment
14) A resident asked what health hazards the Site presents to local residents.
58
-------
Response: Currently, the greatest hazard presented by the Site is ingestion of
contaminated groundwater. Eating fish caught in the river near the Site also poses a health
hazard. Less probable causes of risk from the Site include direct contact with contaminated
soil and showering with contaminated groundwater.
E. Technical questions
15) A representative of the County Commissioner's Office wanted to know if the use of
ozonolysis was considered as an alternative to air stripping.
Response: Ozonolysis is the treatment of water through the use of ozone. Ozone is
sometimes used as a disinfectant for municipal applications instead of chlorine. Since the
ground water at the Ohio River Park Site will require the removal of volatile organic
compounds, not disinfection, ozonolysis was not considered as an alternative to air
stripping.
16) A resident wondered if the capture zone of the extraction wells for the pump-and-treat
system would affect the capture zone of the Coraopolis well field if the number of
Coraopolis wells were to increase.
Response: The extraction well network for the pump-and-treat system could be designed to
avoid an impact to the capture zone of the Coraopolis well field. Of greater concern is the
potential for the capture zone of the Coraopolis wells to impact the plume of contaminated
groundwater at the Site, especially in the event of Coraopolis wells being overproduced.
17) A resident inquired about the effect of flooding on the cap.
Response: The potential for flooding will be taken into consideration during the Remedial
Design. If the cap would be damaged in any way during a flood event, repairs would be
made as part of the cap maintenance requirements.
18) A resident was unsure what was meant by the stabilization described in Alternative 3.
Response: Stabilization of wastes involves mixing them with a compound, such as cement,
which makes the waste material immobile. The stabilized waste is then placed in a cell
which has a geosynthetic liner on the bottom and soil cover on the top.
19) The Township engineer provided a statement suggesting that off-site migration of
contaminants may not be occurring and, as a result, groundwater extraction and treatment
may not be necessary.
Response: The information collected during the Remedial Investigation is insufficient to
determine me extent of off-site migration of contaminated groundwater. In the Proposed
Plan, EPA identified additional groundwater studies that would be needed to better assess
59
-------
the potential for migration of groundwater contamination. If groundwater contamination
was found to be migrating off-site, extraction and treatment of the groundwater would be
required. During the public comment period, NLC requested an opportunity to collect
additional groundwater information before EPA selects a groundwater remedy. EPA
agreed to wait for the additional information if the work was completed on an expedited
schedule. NLC is currently completing this study and EPA expects to receive a report in
September 1996. EPA decided to proceed with issuance of mis ROD to address the buried
waste and contaminated soil at the Site. EPA will select a remedy for groundwater, surface
water, and sediments (OU-3) in a subsequent ROD after review and evaluation of the
additional groundwater information.
20) A resident wanted to know if the groundwater treatment facility would be located onsite
and if the chosen treatment method would be effective in removing the majority of Site
contaminants, such as benzene and toluene. The resident also expressed concerns that the
facility would have an unpleasant appearance.
Response: In the event that a groundwater treatment remedy is selected in the ROD for
OU-3, the treatment facility would need to be located onsite. An air stripper would be used
to remove volatile contaminants like benzene and toluene. It is possible to design
treatment facilities in ways such mat their appearance is homogeneous with their
surroundings..' .*.;:
21) A resident asked about the size of the aquifer beneath the Site.
Response: The Site monitoring wells and the Coraopolis water supply wells intercept the
same coarse-grained sand and gravel aquifer that extends beneath the Ohio River Back
Channel. The distance between the edge of the island and the Coraopolis wells is
approximately 700 feet. The boundaries of the unconfined surficial aquifer beneath the
river have not been determined.
22) A resident wanted to know how many monitoring wells are located at the Site.
Response: There were approximately 27 monitoring wells at the Site used during different
phases of Site assessment.
23) A resident inquired whether EPA noticed an increase or decrease in the concentration of
benzene and phenolic compounds in groundwater at the Site. The same resident wanted to
know whether the plume is extending underneath the river and whether there are any wells
in the plume.
Response: The remedial investigation analytical data does not indicate that the
concentrations of benzene and phenolic compounds in groundwater at the Site present
noticeable changes in time. Because the Site is bordered by the Ohio River, there are no
wells in the plume between the Site and Coraopolis wells. The current data pertaining to
60
-------
the concentration of contaminants beneath the river was obtained from Barcad samplers
placed in the bed of the Back Channel. Benzene was detected in one round of groundwater
samples between the Site and Coraopolis wells, however, it cannot be determined that the
presence of this contaminant is Site-related, and there is not enough evidence to evaluate
potential movement of the plume. This information will be obtained prior to issuing the
ROD for OU-3.
24) The same resident pointed out that dumping of hazardous wastes began at the Site
approximately 50 years ago. He stated that it seems logical that if the contaminants were
going to reach the Coraopolis well field, they would be there by now. He also stated that
he is employed by an environmental laboratory that has analyzed water from the
Coraopolis wells, and there is no evidence of Site contaminants in the water.
Response: While much of the groundwater at the Site is expected to discharge to the river,
the potential for some migration beneath the river may exist. The remedial investigation
did not provide sufficient information to conclusively state that contaminated groundwater
from the Site cannot reach the Coraopolis wells. Although the aquifer that underlies the
Ohio River Park Site may not be/used on Neville Island at the present time, it is used as a
drinking water source throughout the Ohio River Valley. Allegheny County Health
Department reports identifying drinking water protection areas indicate a potential for
Coraopolis wells to be contaminated by the Site. This potential could be increased by
overproduction of Coraopolis wells. The additional studies currently being conducted by
the NLC are expected to provide a better understanding of groundwater flow at the Site.
Therefore, this ROD does not include a decision on the appropriate groundwater remedy
for the Site.
25) A citizen inquired about what analyses would be performed at the Coraopolis wells during
the long-term monitoring.
Response: The details of the long-term monitoring plan will be determined during the
remedial design. However, EPA expects that samples collected from the Coraopolis wells
as part of the long-term monitoring program will be analyzed for volatile organic
compounds, semi-volatile organic compounds, and selected metals.
26) The same resident requested mat monitoring of the Coraopolis well fields be performed
monthly rather man quarterly during the construction phase of remediation. He believed
that construction activities may cause contaminants to migrate to water more readily.
Response: Since the required remedial action will not consist of major excavation
activities which would disturb the buried waste, a more frequent sampling schedule such as
the requested monthly sampling at Coroapolis would not be beneficial. Quarterly sampling
should be adequate in evaulating any impact from the Site to the Coroapolis well field. If
contamination at the Coroapolis wells is detected and suspected to be originating from the
Site, the frequency of groundwater monitoring can be increased as necessary. The details
61
-------
. and schedule of remedial action sampling will be determined during the remedial design
phase of the project.
27) Another resident stated that the most hazardous chemicals found at the Site, specifically
2,4-D, benzene, and hexachloride, were not dumped at the Site until after World War H
Response: EPA acknowledged this information.
>
28) A citizen asked how many extraction wells would be needed for the pump-and-treat
system.
Response: Additional groundwater information would be required to determine the
appropriate number of wells needed to extract the contaminated groundwater. This
information would normally be collected during the design phase of the remedy.
information currently being collected by the NLC may assist in this determination if a
pump-and-treat system is required. This decision will be made in the subsequent OU-3
ROD.
/
29) A citizen asked what percentage of the Site the cap will cover.
Response: Although the exact dimensions of the multilayer cap will not be finalized until
the Remedial Design has been completed, Figure 2 in the ROD identifies the general areas
mat EPA expects to be covered by the multilayer cap.
30) A resident asked how many samples have been collected from the Coraopolis wells to date.
Response: One well from die Coraopolis well field was sampled twice during the
Remedial Investigation.
31) One resident asked if the pesticide parathion had been detected at the Site.
Response: The results of the analyses of Site soil, groundwater, surface water, and
sediment do not indicate the presence of parathion.
32) A resident asked which wells from the Coraopolis well field were sampled during the
Remedial Investigation.
Response: The Remedial Investigation included sampling from Coraopolis well #2.
F. Written statements
33) Bill Nickles, the Chairman of Neville Township Board of Commissioners appealed to EPA
to present "significant flexibility to allow for the best future development" of the Site. Mr.
Nickles mentioned mat by opening a new bridge Unking the Neville Island with
62
-------
Coraopolis, and utilizing "the future potential of this property" (the Site), the Township
could attract new businesses and increase its tax base. The Township fully supports NLC's
study hoping that "money not spent on clean up can be spent instead to create a more
valuable development of the Township".
Response: Since the beginning of this project, EPA has been very concerned about the
economical development and recreational needs of Neville Island residents. EPA's
decision to create a separate operablft unit (OU-2) for the Bridge Portion of the Site
allowed for timely construction of a new bridge, which conveniently connected the island
with Coraopolis. EPA has demonstrated flexibility by allowing NLC to continue its
additional groundwater attenuation study before EPA makes a decision on the appropriate
groundwater remedy for the Site. At the same time, EPA is issuing this ROD in order to
move forward with the necessary actions to address the buried waste and contaminated soil
at the Site. This ROD allows cleanup to proceed so that future use of the Site is not
delayed while evaluation of the groundwater conditions at the Site continues. While
residential use of the Site is not permitted under the ROD, commercial, industrial, and/or
recreational use is possible provided that adequate precautions are taken to protect the
integrity of the multilayer cap. ,-
34) Dr. James E. Barric, P.E., Neville Township Engineer presented his opinion mat
Alternatives 3 and 4 are "prohibitively expensive and would not effectively remove the
contamination plume that has been detected." For this reason, he supports capping as "a
viable and effective approach to remediation". Dr. Barric also supports the NLC's study
and believes that "accurate hydrogeologic modeling" can replace current conservative
assumptions and allow the responsible parties to direct "resources required for extraction
and treatment" to "development and productive use of the site".
Response: EPA's own analysis of the remedial alternatives agrees with Dr. Bank's, and
EPA has chosen Alternative 2, the multilayer cap. EPA, the Commonwealth, and the NLC
have been working cooperatively to ensure that the additional groundwater study will
present reliable data on the current and potential migration of the contaminated plume.
Following EPA's review of the NLC study, EPA will decide on the appropriate remedial
action pertaining to the groundwater contamination at the Site. Future use of the Site and
the type of development that the Neville Island community wants for the area is an
important factor mat EPA has considered in mis ROD and will consider in deciding an
appropriate groundwater remedy in the OU-3 ROD.
63
-------
II. WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD
A. Comments from General Public
1) A volunteer organization of Neville Island residents opposed alternatives presented by
EPA which required excavation of contaminants or capping, and supported natural
attenuation as the best way to return-the Site to its recreational uses.
Response: Biological degradation of Site contaminants in the buried waste and soils at the
Site would require an extended period of time. Particularly, PAHs and toxic metals in the
soil require an especially long time to be naturally remediated or may not be naturally
remediated at all. Many of the wastes present at the Site were disposed of fifty years ago,
yet they still contain contaminants at levels of concern. EPA has agreed to allow the NLC
the opportunity to evaluate the possibility of natural attenuation occuring with
contaminants in the groundwater at the Site. However, EPA is requiring mat multilayer
and erosion caps be placed over the buried waste and contaminated soil to prevent
individuals from being potentially exposed to the contaminants present in these materials.
2) A resident expressed concern mat the multilayer cap and groundwater extraction and
treatment proposed as EPA's Preferred Alternative in the Proposed Plan would not be
sufficiently reliable. This person was also concerned that groundwater from the Site may
contaminate Coraopolis wells, and, therefore, proposed that EPA would test fish for
contamination, and reconsider Alternative 4.
Response: Multilayer caps, by virtue of combining different types of natural and synthetic
materials in their construction, are less vulnerable to damage or degradation than caps
which are of homogeneous construction. For this reason multilayer caps are often used to
cover and protect hazardous waste sites and disposal areas. Since the toxic materials at the
Site are not concentrated in any one area, excavation of all the contaminated areas would
be difficult, and would be several times more expensive man capping. The construction of
a multilayer cap provides a practical and effective means of isolating contamination from
human contact A properly designed multilayer cap is highly durable and should continue
to protect people from contact with residual contamination into the distant future. The
permeability of a multilayer cap is low, therefore, the cap will greatly reduce the rate of
infiltration and help control the migration of contaminated groundwater. The NLC is
conducting additional field investigations and groundwater flow modeling to better
evaluate the potential for offsite migration. Currently, EPA does not have plans to conduct
any additional analysis offish since the additional groundwater studies should provide
better information for evaluating contaminant migration from the Site.
3) Buckeye Pipeline Company expressed concern pertaining to the cost of eventual relocation
of its pipeline, and, in the event the pipeline is allowed to remain at the Site, requested an
opportunity to have input on the design of the cap and the need for access to the pipeline
64
-------
during maintenance and emergencies .
Response: EPA does not anticipate that the pipeline will need to be relocated to construct
the multilayer cap. EPA will coordinate with Buckeye Pipeline Company on the design
and access issues during the remedial design process.
4) A resident expressed concern mat Alternative 4 should include relocation of residents
during remedial work, and the selection of an alternative should be based on the
duplication of testing results by an independent firm.
Response: Under Alternative 4, all necessary precautions would be taken to ensure that the
buried waste would be excavated and transported off-site in a safe manner. Contingency
plans would be developed to address any potential spills which could occur. Temporary
relocation of nearby residents would not be necessary to ensure safely under Alternative 4.
EPA has, however, selected Alternative 2 which does not require any excavation or off-site
transportation of buried waste. During the remedial investigation at the Site, EPA collected
and analyzed in EPA's approved laboratories duplicate samples ("split samples") to assure
the quality of the data generated by the NLC. The same procedure took place during the
additional groundwater study which followed the Proposed Plan. Therefore, further testing
to duplicate the results is not necessary.
5) A resident asked why EPA has not started cleaning up the Site and suggested combining
Alternatives 2, 3, and 4 into one alternative.
Response: After EPA has identified its preferred cleanup alternative based on a completed
RI/FS, EPA is required to solicit public comment on its plan prior to finalising the remedy
selection. This ROD now completes mat process and EPA can proceed with the final
stages of designing a permanent remedial solution for this Site. The process has at times
seemed long; however, the objective has been to evaluate thoroughly all the sources of risk
to human health and the environment, and then to select an optimal alternative. Combining
alternatives would not be feasible or cost-effective: Alternatives 3 and 4 cannot be
combined because stabilizing the contaminated soil prior to off-site disposal would result
in significant materials handling and transportation problems. Alternatives 2 and 4 cannot
be combined, because they are mutually exclusive. Either the waste is capped in place
(Alternative 2) or it is excavated and transported off-site (Alternative 4).
B. Written comments received from Neville Land Company
The comments from NLC were received in two transmissions. Below, EPA responds to the
comments from the March 14,1996 letter.
1. Footnote 1 is inconsistent with the spirit of NLC's agreement with EPA resolving a
dispute over the acceptability of the Ecological Risk Assessment ("ERA"). This footnote
65
-------
should be modified to state that the administrative record contains the full draft
ecological risk assessment, which sets forth additional data on the extent to which the
Site may pose risks to fish and wildlife.
Response: The footnote is consistent with the EPA's position expressed in a letter to
NLC, dated November 18,1994. This letter concludes the dispute resolution on the ERA
by stating that NLC acknowledges that it remains EPA's position that the draft ERA was
not fully prepared in accordance with the terms of the AOC in mis matter, that only
sections 1.0-3.0 thereof have been formally approved by EPA, and that EPA's data
interpretation along with sections 1.0 - 3.0 of the draft ERA together constitute the EPA
approved ERA for the Ohio River Park Site. Footnote 1, therefore, is written in
accordance to the resolution ending the dispute between the two parties.
2. The Proposed Plan should state that the Buckeye Pipeline easement is located both on
NLC land and the County's land.
Response: Correction was made in the ROD.
3. The Proposed Plan should note that EPA determined after completion of an RI/FS for
OU-2 that "No Action" was the appropriate response for mis portion of the Site.
Response: Information regarding the results of the OU-2 RI/FS and the subsequent "No
Action" ROD.was added to the ROD.
4. There is no evidence mat agricultural chemical wastes were disposed of in the waste
trenches.
Response: The RI Report on page 1-5 presents the information on agricultural chemical
production and states that one container of waste pesticide was discovered at the Site in
the early 1980's. This discovery suggests mat pesticide-containing wastes were
intentionally disposed in some trenches. Furthermore, contamination by trichlorophenol,
a raw material in the manufacture of pesticides, is well documented. One instance of
bulk disposal of 2,4-D was also documented. Section 10.1.2 of the RI Report adds that
"information gathered from interviews [indicated] that agricultural chemical disposal was
infrequent, random and involved relatively small quantities." Therefore, the
characterization of the pattern of disposal activities as resulting in the disposal of
"occasional agricultural chemical wastes" appears warranted by the data
5. This statement regarding transfer of the Buckeye Pipeline easement is misleading. See
comment 2, above.
Response: Clarification was made in the ROD.
6. The Proposed Plan should clarify that EPA prepared the baseline human risk assessment
for the Site and that the baseline human risk assessment has been modified by EPA since
the January 1995 issuance date cited above.
Response: This information is included in the Administrative Record for the Site, but
was not deemed necessary for includion in the Proposed Plan.
66
-------
7. . PCBs should not be discussed in the Proposed Plan because the RI documents that PCBs
do not appear to be constituents of concern in surface soils at the Site.
Response: EPA typically includes a list of contaminants encountered in the course of an
investigation, without regard to whether a particular contaminant is a primary source of
human health risk. PCBs were selected in the baseline risk assessment as contaminants
of concern in the surface soil media
8. The Proposed Plan incorrectly indicates mat the highest concentration of PAHs in the
subsurface soil is 22 ppm. The RI, pages 5-18 and 5-19 and Table 5-4, indicates the
highest concentration of PAH detected in subsurface soil was Naphthalene in boring NB-
44-5atl7ppb.
Response: The PAH concentration of 22 ppm originally included in the Proposed Plan
was incorrect. However, the correct concentration of total PAHs was actually 38 ppm as
indicated in Figure 5-7 of the RI Reprt. The Proposed Plan was corrected to include this
information.
9. The Proposed Plan states that an estimated value of 0.024 ppb was reported for the
pesticide gamma-chlordane in only one of the eleven surface water samples collected
adjacent to the Site. The Proposed Plan should also state the conclusion reached in the
RI on Site surface water quality (page 6-8): "In summary, surface water quality adjacent
and downstream of the [Site] is similar to surface water quality upstream of the [Site]."
Response: This section of the Proposed Plan provides a brief summary of the data
collected during the RI. EPA's interpretation of the data is summarized in the section
summarizing Site risks.
10. The Proposed Plan implies that contamination in sediment samples originates from the
Site. However, the contamination of riverbed sediments cannot be specifically attributed
to releases from the Site.
Response: The Proposed Plan acknowledges that similar contaminant concentrations
were found upstream as well as downstream of the Site. While mere are likely to be
multiple sources contributing to the sediment contamination in the river, the samples
collected in the vicinity of the Site did exhibit elevated concentrations of contaminants
that have been found at the Site.
11. This DNAPL analysis in the Proposed Plan neglects the co-solubility effect of benzene
also found in groundwater at this location. Trichlorophenol exhibits several orders of
magnitude greater solubility in benzene man in pure water. Within the normal Site
groundwater temperature range of 10-15 degrees Celsius, the pure condensed phase of
trichlorophenol is a solid, as is die condensed phase of most other phenolic compounds.
Response: The RI does not provide sufficient information to evaluate the co-solubility
effect of benzene on trichlorophenol. Additional information currently being collected
by NLC may provide further clarification as to the presence of DNAPL at the Site.
Trichlorophenol is moderately soluble in water (solubility equals 900 ppm or 0.09
67
-------
percent). Observed concentrations of trichlorophenol are plausibly related to dissolution
of pure phase accumulations which are localized in the shallow subsurface; probably in
the near vicinity of wells NERT-20,27 & 41.
12. The Proposed Plan states that a small percentage of the groundwater (approximately 2%)
may flow beneath the river and could potentially reach the Coraopolis Borough water
supply wells. The groundwater modeling reported in Section 9.8 of the RI Report
showed that the capture zone of the Coraopolis water supply wells extends no further
toward the western end of Neville island than approximately midway across the back
channel of the Ohio River. To NLC's knowledge, there are currently no other analyses in
the Administrative Record that suggest a more extensive capture zone. If such analyses
exist and have been used by EPA in the development of this Proposed Plan, NLC
requests an opportunity to evaluate them.
Response: EPA based me above statement in the Proposed Plan on Table 9-10 (page 9-
72) of the RI Report which estimates the mean flow rate of water leaving the sand/gravel
aquifer beneath the Site and flowing under the Ohio River to be <2 %. EPA recognizes
that mis estimate is based on conservative assumptions. The issue of the potential
impact of the Site on the Coraopolis well field can be evaluated more fully upon
completion of NLCs additional groundwater study which includes further field
investigation; and groundwater flow modeling.
*. '*"*'
13. The Proposed Plan states that EPA can take action where the human health carcinogenic
risk is within the range between 1 .OE-04 and 1 .OE-06. The BLRA states (page 3) that the
acceptable Superfund risk level is 1E-04 for carcinogens. While EPA may take action
where the risk is below the statutory acceptable limit of 1E-04, such action should be
predicated on a site-specific assessment of risks, costs, and benefits.
Response: Section 300.430(e)(2)(i)(A)(2) of the NCP states that "for known or suspected
carcinogens, acceptable exposure levels are generally concentration levels mat represent
an excess upper bound lifetime cancer risk to an individual of between 10"4 (i.e., 1. OE-04)
and 10"6 (i.e., 1. OE-06) using information on the relationship between dose and response.
The 10"* risk level shall be used as the point of departure for determining remediation
goals for alternatives when ARARs are not available or are not sufficiently protective
because of the presence of multiple contaminants at a site or multiple pathways of
exposure". All of the exposure scenarios presented in the Proposed Plan (Table 1) and
this ROD (Table 10) exceed the ID"6 risk level set as the point of departure for
remediation goals. Six of eight exposure scenarios exceed the 10"4 risk level and a
outside of the acceptable risk range. Therefore, action is warranted at this Site.
14. The Proposed Plan identifies eating fish from the river as an exposure route included in
the risk assessment. Contamination offish taken from the Ohio River cannot be
attributed to the Site.
Response: Contaminants in sediments and surface water include 11 contaminants of
concern associated with the Site. EPA acknowledges mat this industrialized reach of the
Ohio River has many potential sources of contamination and that, in general, surface
68
-------
water quality adjacent and downstream of the Site is similar to surface water quality
upstream of the Site. However, the fact remains mat the Site is a contributor to
contamination of the river and its sediments. In the BLRA, eating fish was an
appropriate pathway to include in several exposure scenarios. In the absence offish tissue
analyses, conservative assumptions were incorporated which pertain to the potential for
bioconcentration of contaminants in fish.
15. This risk table (Table 1) in the Proposed Plan presents a distorted view of the current and
future risk for the Site. Almost the entire human health risk associated with exposure to
Site contaminants is attributable to the use of Site groundwater. There is presently no
direct use of Site groundwater for drinking, bathing, or showering purposes. All Neville
Island consumers are supplied water from off-site water authorities, as are all off-site
consumers. This fact needs to be stated in the Proposed Plan.
Response: The Proposed Plan explains that the exposure scenarios include a range of
possible future Site conditions and uses, without regard to present restrictions on land
use. The BLRA followed EPA guidance to develop exposure scenarios which are
appropriate for the evaluation of potential remedial actions. The approach is inherently
conservative to be protective of human health and to account for uncertainties in Site
information.
16. The lifetime jcaicer risk attributable to fish consumption in the BLRA is based on a
calculation of bioconcentration of contaminants in fish, and further on only one detection
(at an estimated level) of the pesticide gamma-chlordane in surface water during the RI.
There has been no demonstration that fish in the Ohio River surrounding the Site are
contaminated with gamma-chlordane to the levels assumed in the BLRA, or that the Ohio
River has been contaminated by releases from the Site.
Response: Gamma-chlordane has been identified as a contaminant of concern at the Site
and was detected in a surface water sample during the RI. Since this contaminant is
known to bioconcentrate in fish, EPA made the conservative assumption that the
contaminant could be present in fish which are consumed from the river. EPA guidelines
for the screening of contaminants of concern and estimation of exposures risks are
intentionally conservative to be protective of human health and to account for
uncertainties in Site information.
17. Excluding the risk calculated for consumption of contaminated fish, the BLRA results
show that risks to off-site residents consuming untreated river water, and to recreational
Site users, are both below the statutory limits for Sites. These facts need to be stated in
the Proposed Plaa
Response: Consumption offish is an appropriate exposure pathway to use for mis Site.
The potential carcinogenic risk to off-site residents and Site recreational users exceeds
l.OE-06, the statutory point of departure for remediation goals at Superfund sites,
whether or not the fish consumption exposure pathway is included in these scenarios.
18. Excluding the risk calculated for consumption of contaminated fish, the BLRA cancer
69
-------
risks for on-site residents utilizing a public water supply are below the statutory limit for
Superfund sites. This fact needs to be stated in the Proposed Plan.
Response: See response to comment #17 above.
19. The risk levels computed for off-site residents using groundwater taken from the Site are
based on assumed ingestion of contaminated fish and use of groundwater with
contaminants at the concentrations found in well 6D (river well near the Site). Excluding
the risk calculated for consumption of contaminated fish, the BLRA cancer risk for this
scenario is below the statutory limit for Superfund sites. The hazard index for this
scenario is driven by elevated manganese concentrations detected in well 6D. Elevated
manganese concentrations are potential indicators of anaerobic digestion of petroleum
hydrocarbons.
Response: See response to comment #17 above concerning the fish consumption issue.
Contaminant concentrations in well 6D were considered to represent reasonable
maximum exposure point concentrations appropriate for use in the risk calculatioa In
addition, manganese was identified as a contaminant of concern at the Site using
standarized screening criteria. No systematic investigation has been conducted at the
Site to establish that the Site is not a source of manganese in groundwater. Furthermore,
if elevated manganese concentrations are the result of intrinsic biodegradation processes,
Site-related-wastes could still be responsible for this manganese increase.
20. The ERA concluded that any potential ecological risk from the Site would be in the low
to moderate range. No demonstration of actual harm to organisms or habitats adjacent to
or downstream of die Site as a result of releases of contaminants from the Site has been
made. Acknowledgment of the differing assessments should be made.
Response: Actual harm to the environment does not have to be documented to establish
that the potential for significant adverse impacts exists. Based on the contaminant
concentrations found in the surface water and sediment at the Site, the potential for
adverse impact exists. The conclusions presented in the draft ERA were not accepted as
part of the EPA-approved Ecological Risk Assessment for die Site. See comment #1 in
this section above.
21. The Proposed Plan states that given the level of contamination in surface water and
sediment, contaminants from the Site are suspected to have contributed to degradation of
the river. This is an overstatement. There is no evidence that the Site is contributing to
the "degradation" of the Ohio River.
Response: The RI Report concludes that most, if not all, unattenuated contaminants
from the Site which are migrating with groundwater will discharge to the Ohio River. In
addition, the potential for the erosion of contaminated sediments during flood events is
undisputed. Contaminants in sediments and surface water include 11 contaminants of
concern which are related to the Site. EPA acknowledges that many sources have
ultimately contributed to degradation of the Ohio River. However, the presence of other
sources does not justify discounting contributions from mis Site to the river's overall
70
-------
degradation.
22. It remains NLC's understanding that a cap designed to isolate the areas where wastes are
buried would be acceptable to EPA and PADEP if it achieved the permeability
performance standard required of multilayer caps described in the relevant portions of the
PA Residual Waste Management Regulations.
Response: The details of the design of the multilayer cap will be developed and
approved by EPA and PADEP dunng the remedial design phase of die Site cleanup. The
performance standards for the multilayer cap have been established in Section X
(Selected Remedy and Performance Standards) of the ROD.
23. NLC intends to properly abandon the on-site oil well in accordance with Pennsylvania
Oil and Gas Well Regulations. The well is unlikely to threaten the integrity of the
multilayer cap to be placed over waste trench areas. Hence, linking its abandonment to a
requirement to ensure the integrity of the cap is unnecessary.
Response: Depending upon the design of the cap, the presence of the well may interfere
with the construction of the cap and, therefore, may detrimentally affect the cap's
performance. Also, the oil well construction may act as a conduit for further migration of
groundwater contamination. EPA has included abandonment of this well as part of the
remedy selected in this ROD.
24. The manner in which the cap design will address the presence of the on-site oil pipeline
should be determined during remedial design.
Response: EPA agrees.
25. Materials to be covered by the cap are not expected to generate any substantial quantity
of gas. The need for the gas ventilation system component of the remedy should be
determined during the remedial design.
Response: The two sources of "gas" generation which are relevant to the design of a cap
are: 1) carbon dioxide, nitrogen, hydrogen sulfide, or methane gas generated as a by-
product of the biodegradation of organic matter or organic contaminants; and 2) pore air
displaced by episodes of rising water table. EPA anticipates that vents will have to be
designed to allow the escape of air which would otherwise be trapped below a low
permeability cap during flood events. Without the installation of vents, the cap may be
severely distorted and permanently damaged by flooding events. EPA can waive the
requirement for a gas vent system during the remedial design if the following
requirements are met:
1. Field measurements are conducted which convincingly demonstrate that the rate of
gas generation by biological activity will not require passive venting; and
2. Engineering calculations are presented that show how the cap system will
accommodate the pressures associated with the displacement of pore air trapped
between the rising water table and the cap.
71
-------
26. NLC requested a meeting with EPA to discuss the viability of intrinsic remediation as a
component of the groundwater remedy at the Site. Groundwater sampling was performed
on March 10 and 11,1996 to obtain current data on Site conditions which could serve as
indicators of the existence and effectiveness of natural attenuation processes.
Response: EPA agreed to allow NLC the opportunity to provide additional groundwater
data for the Site to better evaluate the hydrogeologic conditions and the potential natural
attentuation of groundwater contamination. NLC will submit a supplemental
hydrogeologic study report for EPA's consideration, which will include results of field
investigations and additional groundwater flow modeling. A decision on the appropriate
groundwater remedy for the Site will be documented in a subsequent ROD for this Site.
27. A limited-term monitoring program will provide sufficient data with which to evaluate
local and regional groundwater flow.
Response: See response to comment #26 above.
28. DNAPL are unlikely to exist within the Site water-bearing zone.
Response: See response to comment #1 in NLC letter, dated May 30,1996.
29. It was earlier recognized by EPA that sampling of river sediments and Ohio River surface
water in the vicinity of the Site would disclose nothing about the Site's condition because
of its hydrogeologic setting. Sediment sampling should not be required.
Response: EPA has acknowledged that many sources likely contribute contamination to
the Ohio River, however, sediment samples in the vicinity of the Site continue to be the
best mechanism for determining possible contaminant contribution from the Site. EPA
has no record or recollection of stating that such samples would not be useful in further
characterizing conditions at the Site. Therefore, on-going monitoring of river sediments
is required as part of the monitoring program for the Site.
30. The requirement for erection of warning signs along the boundaries of the Site is
unjustified, given the lack of evidence that the Site is contributing to fish contamination
in the Ohio River.
Response: Unless additional data is collected which can show that the Site is not
affecting fish (e.g., fish tissue analysis) then this requirement will stand.
31. The natural attenuation of benzene and phenolic compounds is not necessarily a slow
process. Table 11-1 of the RI documents the longest observed physical degradation half-
lives of the most significant Site contaminants. This table indicates that benzene exhibits
a degradation half-life of two years and 2,4,6-Trichlorophenol a degradation half-life of
five years in groundwater. The RI also indicates that phenols may degrade within a
matter of days in certain groundwater conditions.
Response: EPA has provided NLC with the opportunity to document whether natural
attenuation is occurring at the Site. NLC will submit a supplemental hydrogeologic study
72
-------
report for EPA consideration, which will include results of additional field investigation
and groundwater flow modeling. After evaulating this additional information, EPA will
make a final decision on the appropriate groundwater remedy for the Site in a subsequent
ROD.
32. No adverse ecological impacts have been demonstrated at the Site.
Response: See responses to comments #14, #20, and #21 above.
>
33. Migration of groundwater contaminants away from the Site can also be prevented by
natural attenuation processes acting in the water-bearing zone.
Response: See response to #31 above.
34. A mechanical means for achieving an inward hydraulic gradient will not be required if
natural attenuation processes are shown to contain the groundwater contamination plume
under normal site groundwater flow patterns
Response: See response to #31 above.
/
Below, EPA responds to the comments from NLC and Wilmington Securities from the May
30,1996 letter .\^
1) Dense Non-Aqueous Phase Liquids (DNAPLs). The Proposed Plan asserts (page 6) that
the detection of 2,4,6-trichlorophenol at concentrations exceeding 10% of its pure phase
solubility in water at one location of the Site "suggests a strong likelihood" that DNAPLs
may be present within the Site water-bearing zone. In response to NLC's request, Dames
& Moore evaluated the available evidence in the Site record following the protocols
recommended in the document DNAPL Site Evaluation (EPA/600/R-93/022). Dames &
Moore's evaluation concludes that 2,4,6-trichlorophenol is not present as a dense,
separated phase liquid in the Site water-bearing zone, primarily for the following reasons:
Over a 15 year history of Site sampling, separated phase liquids have never been
observed in soil or groundwater samples collected at the Site; and
2,4,6-trichlorophenol is a crystalline solid within the ambient temperature range
measured in the Site water-bearing zone.
NLC and Wilmington Securities believe that the weight of evidence presented in the Site
record, including the EPA-approved RI, and in the evaluation attached and submitted
hereby, eliminate the need for additional investigations to determine whether DNAPL
might be present on me Site. NLC does not believe it is cost effective to continually
search for something when the available evidence indicates it is not present. Such an
investigation would clearly not be an effective use of time nor of scarce remediation
funds.
73
-------
Response: EPA agrees that 2,4,6-trichlorophenol, as well as phenol and many phenol
derivatives, will not occur as the pure liquid phase at the ambient temperatures
encountered in the subsurface. Rather these compounds will occur as solids.
Technically, therefore, these pure compounds are not dense non-aqueous phase liquids
(DNAPLs). Trichlorophenol and dichlorophenol are contaminants of this type which
were observed at high concentrations in groundwater recovered from wells NERT-20,
NERT-27, NERT-41, and soil borings NB-42, NB-44, & NB-46. The high
concentrations are strongly suggestive that a pure (or nearly pure) phase source exists for
these contaminants.
If disposed as a solid, trichlorophenol might occur as granules or as a resinous mass (e.g.,
containerized) in the shallow subsurface. It is also possible that it was disposed in
solution with a non-aqueous solvent, such as benzene. Trichlorophenol contamination is
associated with benzene in wells NERT-20, 27 & 41 and at borings NB-42,44, and 46.
However, where trichlorophenol was observed at concentrations exceeding 20% of its
solubility in water, benzene concentrations in these same wells did not exceed 2% of its
water solubility. Therefore, the association of these chemicals may be coincidental.
Nonetheless, without further Site investigation, the possibility cannot be ruled out that at
least some trichlorophenol was' at one time present as a mixture with benzene. In a
concentrated solution, the density of the mixture may have been greater than water. In
this form, the-solution could have migrated as a true DNAPL.
If present in solution with benzene, trichlorophenol could occur in flowable pools of non-
aqueous phase liquid (NAPL), either above or below (in the special case of a DNAPL
mixture) the water table. Alternatively, it may be widely disseminated as droplets or
films. Even as a stationary source of contamination (e.g., solid phase or NAPL
trichlorophenol), trichlorophenol may continue to pose a risk for an indefinite time
period.
Insufficient data is available to establish the nature of the source of trichlorophenol.
Therefore, it may be present as a solid in the shallow subsurface or in a NAPL mixture
(or both). Data from soil borings NB-42,46 & 48 are not useful in distinguishing
between these alternatives. Trichlorophenol was reported in these borings at
concentrations ranging up to 8,100 ug/kg. The equivalent concentration of
trichlorophenol in pore water (30 ppm) is consistent with concentrations observed in
groundwater in this area of the Site. Therefore, it is likely that the analysis detected
trichlorophenol which was dissolved in groundwater occupying the pore space of the
sample. No effort was made to determine the presence of DNAPL in these samples.
The presence and spatial distribution of DNAPL has been inferred at many contaminated
industrial sites without direct observation of the DNAPL. Previously collected
groundwater and soil data, along with data currently being collected for me supplemental
intrinsic remediation study, could be used to assess the potential presence and
distribution of DNAPL at the Site. In order to better document the potential presence (or
absence) of DNAPL, EPA recommends that, where possible, NLC employ techniques
described in An Integrated Approach For Assessing The Potential Presence And
74
-------
Distribution OfDNAPLs At A Superjund Site In New Jersey (Watkins et al.). Empirical,
analytical (utilizing standard equilibria and partition coefficient equations),
observational, and anecdotal techniques were applied to an existing database at the
CIBA-GEIGY Superfund site in Toms River, New Jersey.
Whether present as solid or in NAPL, the moderate solubility of trichlorophenol in water
has resulted in the generation of a prominent contaminant plume. A condensed phase or
NAPL source for the plume must Ije somewhere in the vicinity of wells NERT-20, 27, &
41. The highest concentrations have been observed at depths of between 25 and 47 feet.
It is possible that a source for trichlorophenol, which was originally located in the
shallow subsurface, has been removed during previous Site activities. In this case, the
observed plume may be the residue of this source which is currently migrating downward
into the aquifer. However, the existing data cannot rule out the continued presence of a
source. Additional drilling and subsurface sampling necessary during the remedial
design process to determine the dimensions of the RCRA cap should incorporate methods
to distinguish the presence of solid or NAPL containing trichlorophenol.
Regardless of the source of the trichlorophenol, construction of the multilayer cap
required in the ROD will reduce the rate of percolation through the buried waste and
contaminated sqil and into the groundwater. The need for further remedial action for the
groundwater will be determined following review of the additional groundwater studies
being performed by NLC.
2) Need for Groundwater Extraction and Treatment. In the Summary of Alternatives
section of the Proposed Plan (page 11), EPA describes the general characteristics of a
groundwater extraction and treatment system .which is proposed as an element of the
Preferred Remedy for the Site, denoted Alternative 2. By letter dated March 27,1996,
Dames & Moore submitted its evaluation of the results of a geochemical sampling
program performed at the Site on March 10 and 11,1996, to determine whether active
bioremediation of groundwater contaminants was occurring at the Site. At NLC's
request, the data obtained from this sampling program was also independently evaluated
by Dr. James Mercer of GeoTrans, Inc., a recognized expert in me field of intrinsic
remediation. Both Dames & Moore and Dr. Mercer concluded mat intrinsic remediation
of the major contaminant groundwater plume (benzene plume) has been occurring and
continues to occur, and that the measured geochemical parameters of the Site water-
bearing zone are characteristic of those which can support an effective intrinsic
remediation process.
NLC submitted a Work Plan dated April, 6,1996, for an expanded intrinsic remediation
study. The Work Plan describes a detailed program (including extensive Site
investigation and detailed flow and fate and transport modeling of the ORS water-bearing
zone and connected aquifers) to confirm the extent to which natural processes are
containing and reducing the size of the groundwater contaminant plume beneath the
southeastern portion of the Site, and to further document mat mere is no threat to the
Coraopolis municipal well field
75
-------
NLC and Wilmington Securities requested that EPA fully consider the finding of the
proposed Site Intrinsic Remediation Study before coming to a final decision on the
Preferred Remedy for the Site.
Response: EPA has agreed to review results of NLC's supplemental hydrogeologic
study which is currently in progress and includes field investigations and additional
groundwater flow modeling. The purpose of this study will be to more fully investigate
the processes of groundwater transport and intrinsic remediation at the Site. Following
review and evaluation of this additional information, EPA will identify its preferred
alternative for remediating groundwater, surface water, and sediment at the Site and,
following an opportunity for public comment, issue a subsequent ROD for OU-3.
3) The value of the December 1,1995 Wellhead Protection Program Report prepared by
Moody and Associates ("Moody report") is limited because, unlike the focused
hydrogeologic modeling effort reported in the RI, it was designed to provide merely a
general overview of the potential for contamination of drinking water supplies for a
series of well fields located throughout Allegheny County.
The flow model.used for the Moody report is a single layer (two-dimensional) model
similar in design to the (two-dimensional) FLOWPATH model used to develop
information reported in Chapter 9 of the ORS Remedial Investigation (RI) Report. It
appears mat the major assumptions of both modeling efforts were reasonably similar,
with the exception of the assumed value of hydraulic conductivity used in each of the
analyses. In addition, the FLOWPATH model was predicated upon the assumptions that
time and distance are relevant factors to determine "risk", while the Moody report
assumes nothing with respect to time and distance and does not endeavor to assess "risk".
Response: Weakness and limitations exist in the models used in both the Moody report
and the RI in terms of predicting the fate of contaminants in groundwater. The
supplemental hydrogeologic report to be submitted by NLC will include results of
additional field investigations and groundwater flow modeling using a properly validated
and calibrated, multilayer, three-dimensional model which should help resolve remaining
uncertainties about the fate of Site contaminants.
4) The Moody report identifies over 30 potential sources of well water contamination for
Coraopolis, all located much nearer to the municipal well field than the Site.
Response: The existence of other potential sources of contamination does not eliminate
the potential impact of the Site on me Coraopolis well field. To date, the Coraopolis
wells have not been significantly affected by contamination from any potential source.
The objective of the supplemental groundwater studies is to gain a more accurate
understanding of the potential future impact of the Site on groundwater in the area.
76
-------
5) Initial sampling of the Coraopolis sentinel well documented in the Moody report
(performed on June 21,1995) indicated that.no volatile compound was found to be
present above detection limits. Review of historical sampling records maintained by the
Coraopolis Municipal Water Authority also confirms that no volatile compounds
(including benzene and other potential Site-related contaminants) have been detected in
the Coraopolis production wells during the past several years. These results provide the
best current evidence that the Coraopolis well field is not being affected by the Site and is
of a quality which meets all maximum contaminant level criteria.
EPA's Proposed Plan (page 11) suggests the need for NLC to obtain additional
information to better characterize the nature of groundwater flow beneath the Site and in
the surrounding region. A major element of the proposed Site Intrinsic Remediation
Study is the development, calibration, and exercise of groundwater flow and fate and
transport models for the Site and surrounding regions (including the Coraopolis
municipal well field). As part of the modeling effort, a revised value of hydraulic
conductivity for the region being modeled will be determined and applied using the best
available data for the local hydrogeologjc regime and the results of testing being
performed at the Site. The gro;undwater flow model is being structured as a 3 or 4 layer
(i.e., three-dimensional) model. When appropriately validated, the model will be capable
of accurately, simulating groundwater flow specifically within the ORS/Coraopolis
region.
Response: The "best current evidence" pertaining to existing contamination of the
Coraopolis well field consists of the validated analytical results from Well #2 which are
included in the RI. This sample shows elevated concentrations of five contaminants
which are associated with the Site. Water quality data available from the purveyor
which has not undergone similar quality control cannot be regarded as being equally
reliable.
The Site cannot be ruled out as a contributor to the low-level contamination observed at
Well #2 without more detailed information about the fate of contaminants which are
presently migrating beneath the back channel of the Ohio River. As stated in the
response to comment #3 above, the modeling being performed as part of NLC's
additional groundwater studies should help resolve remaining uncertainties about the fate
of Site contaminants.
6) Design of Multilayer Cap. Any approved multilayer cap should allow for reasonable
future Site development, principally by permitting the use of a low permeability cap
design. It is possible to meet the applicable performance standards of the Pennsylvania
Residual Waste Management Regulations (25 Pa Code Chapter 288), allow for regular
monitoring of cap performance, and still support a broad range of Site development
scenarios.
Response: EPA agrees. Detailed cap specifications will be finalized during the remedial
design process.
77
-------