United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-88/068
September 1988
&EPA
Superfund
Record of Decision
Tyson's Dump Site, PA
-------
V.0272-1011
REPORT DOCUMENTATION i. REPORT no. 2.
PAGE EPA/ROD/R03-88/068
4 Tide and Subdtfe
SUPERFUND RECORD OF DECISION
Tyson's Dump, PA
Second Remedial Action
7 Aulhor(a)
». Performing Orgamlzadon Nun* and Addroee
12. Sponsoring Organization Name and Addroae
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
1. Recipient a Aceaoelon No.
S. Report Data
09/30/88
>.
8. Parformlng Organladen Rept No.
10. ProfacVTaek/Work Unit No.
11 ContractfC) or Grant(C) No.
(C)
(0)
13. Type ol Report ft Period Covered
800/000
14.
IS. Supplementary Note*
18. Abettaet (Umt. 200 worda)
The Tyson's Dump site is located in Upper Merion Township, Montgomery
County, Pennsylvania. The site is an abandoned septic and chemical
waste disposal facility on a four-acre plot bordered on the east and
west by unnamed tributaries of the Schuylkill River. During its period
of operation from 1962 to 1970, several formerly unlined lagoons were
used to dispose of various industrial, municipal and chemical wastes.
Spills and overflows reportedly occurred, dispensing contaminants
throughout the site. Surface water runoff and seeps contributed to
offsite migration of wastes toward the Schuylkill River. In 1973 the
State ordered the original onsite disposal facility closed. As part of
the closure, the waste lagoons were emptied, backfilled, and vegetated,
and the contents transported offsite. An EPA investigation of the site
in 1983 resulted in further remedial measures including the
construction of a leachate collection and treatment system, drainage
controls, a cover over the site, and a fence around the lagoon area. A
ROD for the On-Site Area was issued in December 1984. This ROD was
(See Attached Sheet)
17. Document AnUyele a. Deacrlptora
Record of Decision - Tyson's Dump, PA
Second Remedial Action
Contaminated Media: gw
Key Contaminants: VOCs, organic
b. ManMere/Open-Ended Ti
e. COS An Reid/Croup
IB. aecufty Oaee (Thte Report)
None
20. SeoaltyClaee (Thie Page)
None
21. No. of Page*
41
33. Price
(See ANSt.Z3a.18)
See frwlruetfone on Atraree
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-38)
Department of Commerce
-------
EPA/ROD/RO3-88/068
Tyson's Dump, PA
Second Remedial Action
16. Abstract (continued)
amended in March 1988 and incorporated the use of vacuum extraction to
remove contamination from soils and bedrock underlying the On-Site Area.
Further investigations of the Off-Site Area of the site indicated a need
for remedial action. Subsequently, the Off-Site Area was divided up into
five operable units. This ROD addresses the deep aquifer operable unit
only. Contamination is believed to be migrating towards and within the
deep aquifer in the form of dense non-aqueous phase liquids.
Investigations revealed that ambient site conditions for the other four
operable units represented an acceptable level of risk, and so remediation
was considered unnecessary. The primary contaminants of concern affecting
the ground water are VOCs including 1,2,3-trichloropropane, total xylenes,
and toluene; and other organics.
The selected remedial action for this site includes pumping and treatment
of contaminated ground water from the bedrock aquifer using air stripping
with vapor-phase carbon (VPC) for treatment of gaseous emissions and, if
necessary, granular activated carbon (GAC) polishing of air stripped water
with discharge of treated water to river; offsite incineration of
organic-phase condensate produced from steam regeneration of vapor-phase
carbon beds; and ground water monitoring. The estimated present worth
cost for this remedial action is $6,170,000 with annual O&M costs of
$424,300, or $6,910,000 and $509,900 respectively, if GAC polishing is
implemented.
PERFORMANCE STANDARDS OR GOALS: The target cleanup goals for ground water
were based on acceptable risk levels of 10-6 for carcinogens, as well as
MCLs and WQC and include 1,2,3-trichloropropane 0.00035 mg/1 , xylenes
0.12 mg/1, and toluene 2.0 mg/1.
INSTITUTIONAL CONTROLS: Not applicable.
KEYWORDS: Air Monitoring; Air Stripping; Granular Activated Carbon (GAC);
Carcinogenic Compounds; Clean Air Act; Clean Water Act; Direct Contact;
Drinking Water Contaminants; Ground Water; Ground Water Monitoring; Ground
Water Treatment; Incineration; MCLs; O&M; Offsite Discharge; Offsite
Treatment; Onsite Treatment; Organics/VOCs; Safe Drinking Water Act; State
Criteria; Toluene; Treatment Technology; Water Quality Criteria; Xylenes.
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Declaration for the Record of Decision
Site Name and Location
Tyson's Dump Site
Upper Merion Township, Montgomery County, Pennsylvania
Statement of Purpose
This decision document represents the selected remedial action
for this site developed in accordance with the Comprehensive Environ
mental Response, Compensation and Liability Act of 1980, as amended
by the Superfund Amendments and Reauthorization Act of 1986
(CERCLA), 42 U.S.C. Section 9601 et. seq., and to the extent
practicable, the National Contingency Plan (NCP) 40 C.F.R. Part 300.
Statement of Basis
This decision is based upon and documented in the contents
of the Administrative Record. The attached index identifies the
items which comprise the Administrative Record. The Commonwealth
of Pennsylvania has reviewed, commented and concurred on this
Record of Decision.
Description of the Selected Remedy
The selected remedy includes interception and treatment of
contaminated groundwater from the bedrock aquifer through a
series of pumping wells to be located along the south bank of the
Schuylkill River. Most of the contaminants are being addressed
by the ongoing vacuum extraction remedial action, however, inter-
cepting groundwater from the bedrock aquifer will minimize ground-
water discharge from the contaminated area into the river. The
recovered groundwater will be treated by air stripping with Vapor-
phase Carbon (VPC) for off-gas treatment. The organic-phase
condensate from steam regeneration of the carbon beds would be
sent off-site for destruction via incineration. This selected
site remedy attempts to ensure compliance with all ARARs, but at
a minimum will be consistent to the extent practicable, with
those specified herein.
Declaration
The selected remedy is protective of human health and
environment, attains Federal and State requirements that are
applicable or relevant and appropriate, and is cost-effective as
set forth in Section 121(d) of CERCLA, 42 U.S.C. Section 9621(d)m
and Section 300.68 of the NCP. This remedy satisfies the
statutory preferences as set forth in Section 121 (b) of CERCLA, •
42 U.S.C. Section 9621(b), for remedies that employ treatment
that reduce toxicity, mobility or volume as a principle element.
Finally, it is determined that this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable.
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Because this remedy will result in hazardous substances
remaining on-site, a review will be conducted within five years
after commencement of remedial action to ensure that this remedy
continues to provide adequate protection of human health and the
environment.
Date
L. Laskowski
Acting Regional Administrator
-------
Table of Contents
for
Decision Summary
SECTION PAGE
1. SITE NAME, LOCATION AND DESCRIPTION 1
II. CHRONOLOGICAL HISTORY OF THE SITE 2
III. CURRENT SITE STATUS 3
IV. SITE CHARACTERISTICS 4
A . GEOLOGY/HYDROLOGY 4
B. EXTENT OF CONTAMINATION 9
1. Operable Unit No. 1 - Bedrock Aquifer
2. Operable Unit No. 2 - Hillside Area
3. Operable Unit No. 3 - Railroad Area
4. Operable Unit No. 4 - Floodplain/Wetland Area
5. Operable Unit No. 5 - Seep Area
6. Coraparision of Organic Compounds detected in
in on-site and off-site samples.
C. SUMMARY OF SITE RISKS 17
V. COMMUNITY RELATIONS HISTORY 18
VI. REMEDIAL ALTERNATIVE OBJECTIVES 18
VII. DESCRIPTION OF THE ALTERNATIVES 19
VIII. DESCRIPTION OF ARARS 25
IX. COMPARATIVE ANALYSIS OF ALTERNATIVES 27
X. SELECTED REMEDIAL ALTERNATIVE 33
A. DESCRIPTION AND PERFORMANCE GOALS 33
B. STATEMENT OF FINDINGS REGARDING
WETLANDS AND FLOODPLAINS 34
XI . STATUTORY DETERMINATIONS 34
APPENDIX A. - RESPONSIVENESS SUMMARY
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I. Site Name, Location and Description
Tyson's Dump Site is an abandoned septic waste and chemical
waste disposal site reported to have operated from 1962 to 1970
within a sandstone quarry. The site is located in Upper Merion
Township, Montgomery County, Pennsylvania. Several formerly
unlined lagoons were used to dispose of various industrial,
municipal, and chemical wastes during the period of operation.
Spills and overflows reportedly occurred during the period of
operation, thus allowing for the dispersal of wastes throughout
the site. Surface water run-off and seeps contributed to off-site
migration of the wastes toward the Schuylkill River. The approx-
imate 4-acre plot is bordered on the east and west by unnamed
tributaries to the Schuylkill River, a steep quarry high-wall to
the south, and a conrail railroad switching yard to the north
(Figure 1-1). North of the Conrail tracks is the Schuylkill
River floodplain. The area in which the former lagoons are
located lies above the 100-year floodplain.
II. Chronological History of the Site
The Tyson's Dump Site was owned and operated by companies
owned by Franklin P. Tyson and by Fast Pollution Treatment Inc.
(FPTI). The stock of FPTI was owned by the current owner of
the land, General Devices, Inc. (GDI) and by Franklin P. Tyson.
GDI was active in the management of Fast Pollution Control Inc.
The Pennsylvania Department of Environmental Resources (PADER)
ordered the site owners to close the facility in 1973. During
closure, the lagoons were reportedly emptied, backfilled, and
vegetated, and the contents transported off-site.
In January 1983, EPA investigated an anonymous citizen
complaint about conditions at Tyson's and subsequently determined
that immediate removal measures were required. These measures
included the construction of a leachate collection and treatment
system, drainage controls and cover over the site, and the
erection of a fence around the lagoon area.
Between January 1983 and August of 1984, EPA and its
contractors conducted a series of investigations primarily in
what is now referred to as the On-Site Area. The On-Site Area is
defined here as that area south of the railroad tracks erected
during the emergency response measures. In December 1984, EPA
issued its Record of Decision (ROD) for the On-Site Area which
recommended the following remedial actions:
- Excavation and off-site disposal of contaminated soils and
wastes to a permitted Resource Conservation and Recovery
Act (RCRA) landfill.
-------
Figure 1-1
Location Map
Tyson's Site
N.E. Exttrwion
P«nn, Tump**
-------
- Upgrading the existing air-stripping facility to treat
leachate, shallow groundwater and surface run-on
encountered during excavation.
- Excavation and off-site disposal of contaminated sediments
within the tributary which receives effluent from the
existing air stripper.
Following issuance of the ROD, EPA began remedial design for
the selected alternative in January 1985. This design included
additional borings throughout the lagoon area to define the
volume of material to be excavated. In August 1985 through
November 1985 EPA performed additional borings and magnetometer
surveys throughout the lagoon area to better delineate the areas
to be excavated.
In the fall of 1985, Ciba-Geigy Corporation agreed to conduct
a further investigation of the Off-Site Area, the need for which
was described in the December 1984 EPA ROD. The Off-Site Area is
defined here as the area outside of the security fence including
the deep aquifer (bedrock aquifer). EPA subdivided the Off-Sitev
Area into five sub-areas or "operable units." The Off-Sit
Operable Units included the following:
- Deep Aquifer (Operable Unit 1}
- Hillside Area (Operable Unit 2)
- Railroad Area (Operable Unit 3)
- Floodplain/Wetlands (Operable Unit 4)
- Seep Area (Operable Unit 5)
On May 27, 1986, an Administrative Consent Order (ACO)
signed by EPA and Ciba-Geigy Corporation was issued by EPA for
the Off-Site Operable Unit Remedial Investigation/Feasibility
Study (RI/FS).
In November 1986 Ciba-Geigy Corporation initiated an on-site
pilot study using an innovative vacuum extraction technology
process. Due to zoning restrictions, the pilot study operated for
only a short duration (less than 10 days). However, in May 1987,
the pilot study was permitted to operate for more than three
weeks.
In December 1986, Ciba-Geigy submitted a draft Off-Site
Operable' Unit RI Report to CPA. This report indicated that much
of the site-related contamination had migrated off-site and into
the deep aquifer toward the Schuylkill River.
On March 24, 1987, a second addendum to the off-site RI/FS
work plan was submitted to EPA by Ciba-Geigy Corporation. This
addendum included a detailed investigation of the Schuylkill
River and the installation of wells on the north side of the river
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In June and July 1987, four responsible parties, Ciba-Geigy
Corporation, Smith-Kline Beckman, Wyeth Laboratories, and Essex
Group submitted a proposal to EPA for clean-up of the on-site
(lagoon) areas, upgrading of the leachate collection system and
cleanup of the tributary sediments. Additionally, the parties
proposed to initiate groundwater remediation measures since the
information contained in the draft Off-Site Operable Units RI
report indicated that much of the contamination formerly in the
lagoon areas was now in the aquifer system, down gradient of the
site, and was discharging to the Schuylkill River.
The parties' proposal was based on a Comprehensive
Feasibility Study (CFS) submitted to the Agency on June 15, 1987.
The CFS was developed independently by Ciba-Geigy Corporation and
was not formally commented on by EPA. The CFS incorporated the
results of the innovative vacuum extraction process for clean-up
of the lagoon soils, preliminary results of the Off-Site RI and
additional studies for the installation of groundwater recovery
wells. Some of the results of the CFS indicated that the
contaminants in the bedrock underlying the lagoons would be a
source of continuing contamination of the backfilled soil. The
study raised the possibility that the remedy selected in the ROD
would be of limited effectiveness without the installation of a
barrier which would limit upward movement of contamination from
the underlying bedrock.
On July 29, 1987 Ciba-Geigy Corporation submitted the final
draft Operable Units RI report to EPA. This report concluded
that much of the site contamination, specifically the dense non-
aqueous phase liquids (DNAPLS), were in the underlying bedrock
and aquifer. The report also found that a dissolved portion of
the DNAPLs was discharging into the Schuylkill River.
Ill. Current Site Status
As a result of the parties proposal based on the CFS, EPA
negotiated a Partial Consent Decree with Ciba-Geigy Corporation,
SmithKline Beckman, Wyeth Laboratories, and Essex Group to
implement an innovative technology, vacuum extraction, that would
be more effective than excavation in removing the contamination
from the soils and underlying bedrock at the on-site area. The
Partial Consent Decree was signed and entered on June 20, 1988.
The vacuum' extraction process is currently in the construction
phase. Several temporary vacuum units have proved to be very
successful in reducing the contaminant levels on-site. The
complete vacuum extraction process is expected to be on line by
the end of October 1988.
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IV. Site Characteristics
A. Geology/Hydrogeology
1. Site Geology
Three types of geologic materials were encountered
during the Remedial Investigation (RI): the overburden materials
south of the railroad tracks, the floodplain deposits north of
the railroad tracks, and the Lower Member of the Stockton Formation
which underlies all of the unconsolidated materials within the
area of the investigation.
The overburden materials south of the railroad
tracks can be divided into three types of materials: undisturbed
colluvial deposits, fill material emplaced during past remedial
activities at the former lagoon areas, and construction debris
and fill material in the seep area. Figure 4-1 shows the approxi-
mate distribution of the various overburden materials. The undis-
turbed overburden deposits generally consist of a thin topsoil
overlying the colluvial deposits and weathered bedrock. The v
topsoil is an organic rich silty sand. The colluvial materials
and weathered bedrock are comprised of sandy silts with some
clays, and some fine to coarse gravel is found at depth in the
unconsolidated deposits. The thickness of the colluvial material
varies greatly over the area, from thirty-one and one half feet
at the eastern border of the site to absent where bedrock outcrops
between the eastern and western sets of lagoons.
The overburden materials within the former lagoon area were
primarily intermixed fill materials of silty, gravelly sand,
quarry rubble, possible residual sludges, construction debris,
and colluvium. These materials were emplaced during the past
disposal and remedial activities at the site. Topsoil in these
areas is thin and often discontinuous.
The overburden materials encountered during installation of
tests pits in the seep area during the RI includes a mixture of
disturbed and undisturbed colluvial deposits and construction
debris. The construction debris is comprised of cinder blocks,
wood, glass, and plastic materials. The greatest thickness of
fill material in the seep area is about six feet. Undisturbed
colluvial deposits underlie the fill material. Bedrock was not
encountered in any of the test pits.
The Schuylkill River floodplain begins at the base of the
bedrock outcrop just north of the former lagoon area, essentially
parallel to and immediately south of the Conrail tracks (Figure
4-1). With the exception of the ravine east of the lagoons, the
thickness of the floodplain deposits beneath the railroad tracks
varies from three to ten feet. The north-south geologic cross
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Figure 4-1
Distribution off Overburden Deposits
South of Railroad Tracks
Tyson's Site
Undisturbed-///:'
boftuvrturnl
Housing
Development
\
eflfr 1965 Lagoon Location
£V ~ V1973 Lagoon Location
•1* ERM Boring Location
Undisturbed Overburden Deposits Coltuvlum
Overburden Depostts Altered by
Quarry Activities, Wast*
Disposal, and Emergency
Remedial Activities
-------
section in Figure 4-2 shows that the depth to bedrock beneath the
railroad tracks drops sharply from three to ten feet at the base
of the embankment south of the railroad tracks to greater than
twenty feet on the north side of the railroad tracks.
Floodplain deposits underlying the railroad ballast are
comprised of interbedded silty, sandy clay, white coarse gravel,
and gravel sized clasts of weathered arkosic sandstone. It
appears that materials in this area actually represent a
transition between the colluvial deposits originating from the
steep hillside and the floodplain deposits. The floodplain
deposits north of the railroad tracks can be divided into three
sub-units as follows:
- The upper one to two feet of organic rich silty clay.
- Ten to fifteen feet of brownish red sandy clays, sometimes
mottled with some silt, trace gravel and cobbles.
A basal sand and gravel unit with some cobbles which lies
on top of bedrock. This unit is approximately ten feet
thick at the river, but pinches out to the south until it
is absent at the railroad tracks.
The Lower Member of the Stockton Formation beneath the site
can be divided into four lithologic units, each of which is
highly variable in thickness. These units, from shallowest to
deepest, include:
- Brownish-Red Arkosic Sandstone, dark to light brownish-red,
medium to coarse grained,arkosic sandstone, with trace
biotite and quartz cobbles; the average thickness is twenty
feet.
- Light Grey Green Arkosic Sandstone, light grey-green
arkosic sandstone with some dark green fine to medium
grained arkosic sandstone, with trace to little biotite and
trace olive green medium grained arkosic sandstone; the
average thickness is seventy-five feet.
- Red Shale, dark red silty shale with a trace biotite,
typically five to ten feet thick.
Dark Green Arkosic Sandstone, dark green fine to medium
grained arkosic-subarkosic sandstone, trace biotite,
little to some light grey green medium to coarse grained
sandstone, trace tiotite. This basal unit was found to be
at least forty feet thick.
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Figure 4-2
North-South Cross Section
Unconsolidated Deposits
Tyson's Site
North
SoUlt
•100
ITS
•ISO
CofcMa)
Lower Member of the Stockton Formation
Oveitaurden In the Former
Lagoon Areas Consists ol
FU Materials of Stty. Gravelly
Sand, Quarry Rubble, Possible
Residual Sludge. Construction
Debris and Cokwial Deposits.
EXPLANATION
100
SO
* Location of Control Points Used in Delineating flni *
Unconsolidated Deposits Thickness. sen.* F—
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In general, as shown on the geologic cross-sections, the
light grey-green and dark grey-green arkosic sandstones are the
predominant lithologies. The red shale unit was encountered in
the transitional zone between the two green sandstone units at
certain locations.
2. Hydrogeology
A. Groundwater
Groundwater at the site occurs in two principal flow
systems: a local system in the unconsolidated deposits overlying
the bedrock and a regional system in the fractures, joints and
bedding planes of the underlying bedrock. The basic hydrogeologic
characteristics of each, flow system are as follows:
1. Unconsolidated Depos.t
The unconsolidated materials that overlie bedrock
south of the railroad tracks are separated from the railroad
ballast and floodplain deposits to the north by a significant
portion of bedrock (Figures 4-1 and 4-2).
South of the railroad tracks, unconsolidated
materials surround and underlie the former lagoons between several
bedrock highs (outcrops). In the course of the Off-Site Operable
Unit RI, depth to water measurements have shown that some of
EPA's monitoring wells completed in these materials were dry for
at least some portion of the investigation. It is believed that
the occurrence of the water found in these materials is actually
"perched water" which is ponded on low permeability tar-like
materials left on the bottom of the former lagoons after closure.
This water is not perennial, but when present it slowly percolates
into the fractured bedrock beneath the lagoons. The temporarily
perched groundwater would not be capable of yielding any significant
amount of water on a sustained basis to wells or springs.
The occurrence of groundwater in the floodplain
deposits is attributed to the zone of enhanced permeability provided
by the layer of sands and gravels at the base of the floodplain
deposits. The groundwater in the floodplain deposits is recharged
by infiltration of surface runoff and groundwater recharge from
the bedrock aquifer.
Surface runoff from the south enters a series of
ponds located on the floodplain deposits north of the railroad
tracks. These ponds are considered to be "seasonal" because they
were dry during a period of minimal precipitation between mid-June
and late July, 1986. The occurrence of the ponds is due to the
low permeability of the silts and clays in the upper portion of
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the floodplain deposits and seasonally high precipitation. It is
believed that the groundwater in the floodplain deposits received
recharge as vertical leakage from the ponds/ and that water
originating from these ponds also drains to the Schuylkill River
through intermittent streams.
2. Bedrock Aquifer
The bedrock aquifer at the Tyson's Site is the
Lower Member of the Stockton Formation. Recharge to the bedrock
aquifer occurs in the areas south of the site where the Lower
member is exposed or close to the surface. During the course of
monitoring well installation, an attempt was made to complete
wells in three separate zones in the bedrock aquifer. These
zones are referred to as the shallow, intermediate, and deep
zones. The rationale for monitoring a specific interval at a
specific well location was based primarily on local stratigraphic
correlations within the Lower member and, secondly, on the
relative depth of other monitoring wells installed at the site.
Shallow zone wells were installed approximately 30 to 100 feet1
below ground surface in the brownish red arkosic sandstone that
occurs near the surface. The intermediate monitoring wells were
installed 75 to 163 feet below the land surface and were
generally completed in the light grey-green arkosic sandstone.
The intermediate wells on occasion were also installed within the
thin red shale which marked the transition zone between the
dominating green sandstone. Deep zone monitoring wells were
installed 115 to 223 feet below the surface. Lithologic
description of the deep zone varied from a dark green to light
green arkosic sandstone.
Both primary and secondary permeability are apparent
in all three zones monitored in the bedrock aquifer. Primary
permeability is contributed from the intergranular space between
grains of material comprising the matrix of the bedrock. Primary
permeability is variable depending on the competency of the
matrix between the coarser grains. The matrix experiences
variable degrees of weathering observed at the site outcrops and
in cores obtained during previous investigations. Highly
weathered portions of the aquifer provide greater primary
permeability due to the decomposition and removal of the matrix.
In less weathered intervals, the argillaceous matrix fills the
space between coarse grained material, thus reducing permeability.
Secondary permeability is contributed by
discontinuities such as joints, fractures, faults, and weathered
bedding planes. The occurrence of significant zones of enhanced
secondary permeability is represented by the fracture traces
shown on Figure 4-3. The fracture traces are indicative of
vertical planes of fracture concentration. These planes act as
conduits for groundwater flow and represent preferred paths for
the migration of contaminants in groundwater.
-------
Figure 4-3
(Fracture Trace Locations!
EXPLANATION
Fracture Trace Location
well Nest Location
Single Well Completions
0 250 500
Scale in Feet (Appro*.)
-------
3. Horizontal and Vertical Components of Groundwater
Flow
The groundwater configuration in the shallow
unconsolidated deposits of the on-site and floodplain areas is
show in figure 4-6. In general, the shallow groundwater
configuration is a subdued reflection of the surface topography
with groundwater flowing north towards the Schuylkill River. On-
site, the water table contours mimic the surface of the quarry
floor. A depression occurs in the eastern lagoon area where the
fill materials are being drained by the underlying fractured
bedrock. Steep hydraulic gradients occur south of the tracks in
the near surface bedrock while gentler hydraulic gradients occur
north of the tracks in the floodplain.
Piezometric surface maps, illustrated in Figures
4-7 to 4-9, reflect groundwater conditions in the shallow
intermediate and deep zones of the bedrock aquifers. Within the
shallow zone, the piezometric surface exhibits a reflection of
the surface topography with a gently mounding in the center of
the site. Flow is north towards the river with hydraulic gradient
ranging from 0.035 to 0.047 (dimensionless).
The intermediate piezometric surface map is
characterized by an elongated mound oriented northeast in the
center of the site. This mound extends from the on-site area to
the Schuylkill River. Groundwater flow along the flanks of the
mound is radial toward the river with hydraulic gradients ranging
from 0.035 to 0.04 (dimensionless}.
Although less defined, groundwater mounding in the
center of the site is evident within the deep aquifer and the
direction of groundwater flow is similar to the intermediate zone,
towards the Schuylkill River. Hydraulic gradients are somewhat
greater than the intermediate, ranging from 0.35 to 0.05 (dimension)
Water level elevations to determine vertical
components of groundwater flow indicate an upward flow gradient
in the bedrock aquifer. This upward gradient represents the
discharge of a regional groundwater flow system to the Schuylkill
River.
4. Relationship with the Schuylkill River
The relationship of the Schuylkill River to the
site's hydrogeology is important since upward vertical flow
gradients wece determined at certain well nests along the river.
This indicated that groundwater was discharging to the river.
Hydrostatic levels at these well locations ranged from 2.41 (in
the shallow well zone) to over 20 feet (in the deeper zones) higher
than the water level elevation of the river. Although water
levels at two well nests located along the river bank in the
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2721101
Figure 4-6
Water Table Map
in Unconsolidated Deposits
Tyson's Site
Air Skipping .
Treatment PlanP 001
63.06
0 100
Scale in Feet
AllW«t«rL«v«l«wn»asol27Apr1M«87.
LEGEND
—•— Fence
---^.—• Quarry Highwall
CUD 1965 Lagoon Location
^^J~J^ 1973 Lagoon Location
• Well Location
97.15 Water Elevation (in feel)
^ Ground Water Flow Direction
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2721101
River Elevation
5933
Figure 4-8
Piezometric Surface - Intermediate Wells
April 17,1987
Tyson's Site
/ / / X
0 200 400
lie In Feet N
Source: U.S.G.S. Topographic Quadrangle; Norrlstown, PA
Note: An Intermediate W«4I WM not
Installed at Wen Nast 12.
0-1 •WeH Nest Location
MW-1 «> Single Completion Background WeH
Ground Water Ftow Direction
81 -ft Ground Water Etevatton
In Feet (Above MSL)
Equlpotential Lines (Denotes Line
61 Equal Ground Water Elevations)
On-Srte Area
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2721101
River Elevation
5933
Figure 4-9
Piezometric Surface - Deep Wells
April 17,1987
Tyson's Site
- C. fj x~~^ LEGEND
6-1 • Wei Nest Location
Scale In Feet
Source: U.S.G.S. Topographic Quadrangle; Norrislown, PA
Note: A DMP Well was not
Installed st Well Nett 2.
MW-1 +Single Completion Background Well
Ground Water Flow Direction
81 73 Ground Water Elevation
In Feet (Above MSL)
_ Equipotential Lines (Denotes Line
of Equal Ground Water Elevations)
On Site Area
-------
in the eastern portion of the site, exhibited slight downward
gradients, the shallow zone level still indicate discharge to the
river .
In summary, the upward groundwater flow gradients
determind at most well nests long the river bank are indicative of
a groundwater discharge zone. All of the piezometers installed
along the southern river bank show an upward gradient. Only the
two deeper zone installations of well nests exhibit downward
hydraulic heads along the river bank.
B. Extent of Contamination
1. Operable Unit - Bedrock Aquifer
A. Occurrence and Behavior of Dense Non-Aqueous
Phase Liquid (DNAPL) in the Bedrock Aquifer
The lagoons used for the disposal of liquid
wastes were constructed on a bedrock terrace south of the railroad
tracks. The location and configuration of the lagoons was likely
dictated by the locally variable rippability of weathered bedrock
on the terrace. Both weathering and rippability are related to
the amount of fracturing at a specific location. The lagoons
would have been constructed in areas with a locally increased
amount of fracturing. When the liquid wastes were disposed in
the lagoons, they rapidly moved downward through the fractures.
It has been established that a proportion of the liquid waste
exists in the form of a DNAPL.
Three samples of the DNAPL were collected to
characterize its chemical properties. The results are presented
on Table 4-4. 1,2,3-trichloropropane, was determined to be 2.0
percent by weight and 73.0 percent by weight in Wells 3-1 and 8-1,
respectively. The other compounds found in these samples were
xylene, ethylbenzene and toluene. Unidentifiable petroleum
distillates constituted 20 percent of the sample at 8-1 and about
52 percent of the sample from Well 3-1.
Groundwater flow patterns in the deep aquifer
will have'-.no effect on the movement of DNAPL through the bedrock.
Under conditions where hydraulic gradients are upward such as
exist near the Schuylkill River, upward movement of DNAPL into the
River can only occur when the upward hydraulic gradient is
sufficiently large to counteract the downward force due to the
density of the DNAPL.
-------
DNAPL was measured in the bottom of many wells
and the range of measured thicknesses is represented on Figure
4-19. The ranges given do not represent the volume of DNAPL in
the formation, but indicate DNAPL accumulation in the borehole.
Table 4-4
DNAPL COMPOSITION
1,2,3-Trichloropropane
Xylenes
Ethyl Benzene
Toluene
Well 3-1 Well 8 -1
% by Weight
23.0
17.0
3.8
4.2
48.0% *
73.0
5.8
0.9
0.9
80.6% **
"The balance of the sample composition were compounds eluting
later than xylenes, but not in an elution pattern identifiable as
petroleum distilltes.
**The balance of sample composition was typical of unidentified
petroleum distillates. Petroleum distillates can be identified
as a general class of compounds because of the characteristic
hydrocarbon envelope that is obtained during gas chromatographic
analysis of samples containing these analytes.
-------
Figure 4-19
DNAPL Thickness Ranges in
Shallow and Intermediate Wells
Tyson's Site
i:-"""—-— •
EXPLANATION
• 23 WeNLocation
0.30.4 Variation in the
Thickness ol ONAPL
Measured in Feet
-------
11
Figure 4-20 is a generalized diagram illustrating
the pathway of migration of DNAPL and resultant contamination of
groundwater in an aquifer. As the DNAPL sinks, part of it becomes
entrapped in the spaces provided by primary and secondary
porosity. In the unsaturated vadose zone, above the water table,
the entrapped DNAPL occurs in available spaces with air and
water. As DNAPL continues to sink below the water table,
entrapped DNAPL occurs in available space with groundwater only.
The DNAPL sinks until it reaches a surface of relatively low
permeability. Here the DNAPL will accumulate and either pool or
move downgradient along the surface. As DNAPL accumulates, all
available space becomes saturated with the DNAPL, displacing all
groundwater.
B. DNAPL Dissolution in Groundwater
Entrapped DNAPLs provide a continuing supply of dissolved
organic constitutents to further contaminate the aquifer. Any
groundwater that comes in contact with the DNAPL becomes contaminated
with its dissolved constituents. Once the DNAPL has passed through
the aquifer, groundwater comes in contact with entrapped DNAPL
along the entire pathway of DNAPL movement: percolation from the
surface is contaminated by DNAPL entrapped in the vadose zone;
groundwater moving in the aquifer is contaminated by DNAPL entrapped
in the aquifer, above accumulated DNAPL; and, groundwater moving
across the surface of an accumulated DNAPL becomes contaminated.
The ultimate concentration of dissolved constituents is determined
by several geochemical factors which limit the solubility of the
constituent in groundwater.
C. Groundwater Quality
In all wells, 1,2,3-trichloropropane was the organic com-
pound found most frequently and at the highest concentration.
Other volatile organic compounds commonly detected at elevated
concentrations include: total xylenes, toluene, and Cis-1,3
dichloropropene. Since 1,2,3-trichloropropane was the most com-
monly detected compound in the groundwater samples and the major
component of the DNAPL, it serves a good tracer for determining
contaminant-'migration of site-related compounds. Isoconcentration
maps, Figures 10 through 12 show the distribution of 1,2,3-trichlor-
opropane in the bedrock monitoring wells. These maps have been
developed using the concentration of the compounds detected in
the groundwater and knowledge of the site hydrogeologic conditions.
The distribution of 1,2, 3-trichloropropane, as shown by Figures
24 through 26 indicates that the movement of this compound (and,
therefore, the contaminant plume) is in two dominant directions:
- directly down dip (northwest) of the former lagoons,
and
- along a zone of concentrated fracturing to the nort^i and
northeast of the eastern lagoon area.
-------
Figure 4-20
Ground Water Contamination from
Residual DNAPL and DNAPL Layers
DNAPL
Watar-Fllad
Por»Spac«
DNAPL
Air or W«t«r-Fimd
Port
Top Of
CapMary Frtngt
Qreuno>»aMr Contvnlnaibn tram
, S. and Charry, J JL, 1S66)
RaaMual DNAPL and DNAPL Laytra.
8
CM
-------
Figure 4-24
Isoconcentration Map off 1,2,3-Trichloropropane
in ShaHowWe^s <»n mg/l)
Well Location
Not Detected
— Isoconcentralion Contour
On Site Area
-------
Figure 4-25
Isoconcentration Map off 1,2,3-Trichloropropane
in Intermediate Wells (in mg/l)
Tyson's Site
EXPLANATION
2-D Well Location
NO Noi Delected
Isoconcentration Contour
On-Site Area
-------
Figure 4-26
Isoconcentration Map of 1,2,3-Trichloropropane
in Deep Wells (in mg/l)
Tyson's Site
4-D Wen Location
NO Not Delected
Isoconcentration Contour
On-Sile Area
-------
12
The movement of the plumes in these directions would be
expected given the site's geology, the physical nature of the
DNAPL, and the down dip movement of the DNAPL along weathered
bedding planes and through fracture zones.
Total xylenes and toluene were the second and third most
abundant organic compounds detected in all wells. Their overall
distribution was similar to 1,2f3-trichloropropane .
2. Operable Unit 2 - Hillside Area
A total of nine soil samples were taken from the
Hillside Area. During the RI, the Hillside Area was defined as
that area from just north of the security fence to the base of
the bedrock outcrop which separates the former lagoon area from
the railroad tracks. The purpose of this effort was to determine
if the soils in these areas had been affected by overflow from
the former lagoons or discharge from the bedrock outcrop observed
on the hillside. The Hillside Area is comprised of soils of the
Lansdale series. Because of the steepness of the hillside (15-35
percent slope), these soils are severely eroded. The erosion
tends to concentrate sandstone pebbles and fragments on the soil
surface.
Organic Compounds
Organic compounds were detected in four of the nine
hillside soil samples (Table 4-17). Sample SS017 contained three
volatile compounds including trichloroethene (0.02 mg/kg), tetra-
chloroethene (0.03 mg/kg), and 1,2,3-trichloropropane (0.20
mg/kg). One semi-volatile compound, 2,4-dimethylphenol, was also
detected in sample SS017 at 0.63 mg/kg. Sample SS020 contained
1,2,3-trichloropropane at 0.25 mg/kg, which was the highest level
detected in the hillside soils, and naphthalene at 0.23 mg/kg.
Sample SS023 contained 0.0085 mg/kg of tetrachloreothene. Sample
SS024 contained seven semi-volatile compounds including 5 Polynu-
clear Aromatic Hydrocarbons (PAHs) with a total PAH concentration
of 2.7 mg/kg and two substituted phenols with a total
concentration of 1.15 mg/kg.
Inorganic Constituents
Concentrations of inorganic constituents in soil
samples taken from the hillside area are also presented in Table
4-17. With the exceptions of copper in sample SS022 and selenium
in sample SS020, all constituents were found to be well within or
below the reported typical ranges of inorganic constituents in
eastern United States soils (Table 4-18). Elevated levels of
•these constituents were found in only two of the samples obtained
from the hillside area. Consequently, this contamination is
believed to be localized. The localized nature of the elevated
concentrations when combined with the fact that both copper and
selenium can be strongly complexed in a non-soluble organic form,
suggests that these constituents present minimal migrat/ion
potential.
-------
TABLE 4-1T
TVSON-8 SITE
HfclSK MCA SOL RESULTS
CRGAMC COMPOUNDS
ma/kg. *»
S*mc«» Numiw
D*MH«pl*d
PWttMMT
WXATUS
UMtvkM cMortd*
•MOM
CMarohMm
iMKMMOMlMft*
Takim
1.2.3-TflchloropropaM
SEM-VOUTfcES
BBh^flM^
rmnui
CfMOl*
2 MMIiylMpMlMlMic
I CMomiMuMMlan
"t>«^mn>
DI-a«ul|lpMlMtaW
FluttMUhMI*
fc.
^mw
Clm««nt
BM» |b) •uomnfMM
B«io
-------
TABLE 4-11 (MMtalMl)
Tvsom sire
HtlSDE AREA SOL RESULTS
•ttWMMC CONSTITUENTS
SMiptoNMntar M 68 01 7
AnitowM
Mumkium
AlSMk
Bcrium
teiyiDiMi
CMMUM
Omnium
CobM
Coop*
Uoa
toid
ttom»i»i»
U0TCIIiy
McM
S«Mnkiai
SIIVM
Tin
Viimtm
me
P"
TOK
(taia pitpwMt by
0010
0.7
75
OS
0.29
129
9
too
7000
000
400
0.13NV
• 0
0.798
11 1
009
403
EMI. hie.
HSSSOIO
A
0000
144
90
041
034
100
90
140
11000
70 OJ
107
0 118
•
10
929
4.50
ERU.toc
HSSSOIO
11200
10.3
97
034
034
129
49
140
0000
00 2 J
143
00
103
492
449
ERMtoc
HSSS020
A
•190
304
04
047
047
170
33
31 7
17000
120
107
023NV
• 4
2 IB
OHB
31.7
421
ERU. toe.
H8SS021
A
•930
193
32
0218
107
21
101
0920
S3.3J
34.7
94
0.008
21.4
310
4.02
ERM. toe
HSSS022
A
7270
00
43
043
OMB
11.0
04
900
10200
31 9
190
011NV
00
002NV
14.1
4.00
EMI. toe
KS&&073
A
0000
200
•3
032
Oil
110
4 2
090
0020
1J0J
101
03
130
244
4.70
ERU. toe
HSSS024
A
04«0
040
170
070
033
201
70
123
20000
ioej
240
022NV
190
0008
031B
223
114
900
EHM.IW
HSSS02S
A
11000
23 7
S8
033
022
10 7
33
100
12700
02 2J
00 1
OI1NV
00
1 MB
322
700
4 O1
ERU. he
i o Ofonntut 1000 ttfon
kJind to 0w oiMhad «unk Ml b ol <
NV. Mi
AH EMU
-------
TABLE 4-18
OBSERVED RANGE OP SELECTED INORGANIC CONSTITUENTS*
FOR SOILS IN THE EASTERN U.S.
Inorganic
Conaituent
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver (Western U.S.)
Tin
Thallium
Vanadium
Zinc
Observed
Range
<0.2-73 ppm
15-1000 ppm
-------
13
3. Operable Unit 3 - Seep Area
The seep area is small area (approximately 15? by 130 feet}
located west of the former lagoon area. When the lagoons were
active, this area was a gently sloping hillside. During the
construction of the nearby residential subdivision, soils from the
area were reportedly excavated and used as construction fill.
Sometime after the soil was removed, the EPA was notified of
seepage emanating from the area. According to the results, this
sample did not contain any contaminants. A sample of the seepage
was collected, and the area backfilled. Backfilling eliminated
obvious seepage and also created a relatively heterogeneous soil
in terms of both physical and chemical properties.
Soil developing in the area were of the Bowtnanville series,
derived from materials washed from surrounding uplands underlain
by shale and sandstone. These soils typically exhibit thin,
mottled, reddish brown silty surface horizons, and weak-red,
extensively mottled, silty subsoils. Sixteen soil samples were
collected from locations within the seep area.
Organic Compounds
Results of the HSL organic and inorganic analyses
are present in Table 4-19. The occurrence of volatile compounds
in all samples was qualitatively guestionable. Samples SS013 and
SS011, collected at depths of 3.3 and 9 feet, respectively, were
the only soil samples in which PAHs were detected. Seven compounds
ranging in concentration from 0.3 to 1.1 mg/kg with a total PAH
concentration of 5.63 mg/kg were detected in Sample SS013. Two
compounds with a total PAH concentration of 0.4 mg/kg were detected
in Sample SS011. These PAH compounds did not originate from the
former lagoon area.
The presence of the pesticide DDT was tentatively identified
and the breakdown product DDD was confirmed in sample SS011.
Total DDT and DDD concentration was 0.94 mg/kg of which 0.38
mg/kg was DDT. DDT concentration in this sample was the highest
level of DDT detected in any of the soil samples.
Inorganic Constituents
Physically, soils of the seep area exhibited signs
of disturbance and fill, e.g., the presence of cinder blocks,
wood fragments, black plastic, etc. Chemically, wide variations
in the concentration of inorganic constituents were found.
However, no depth relationship of the constituents was detected
nor was there a relationship between excavations separated by
only a few feet. Highest concentrations of chromium, cobalt,
copper, iron, manganese, nickel, vanadium, and zinc were found in
a surface sample of test pit 6 (Sample SS012). Within this pit,
dark reddish brown water was noted to be seeping from the upper
depths, suggesting that the high concentrations were
-------
TAOLf 4-11
mONI •»!
SEEP AREA MIL RESULT!
ML 080AMC COHfOUHOt
.IA
00178
0.148
00128
0.0218
0.0128
00108 0.0108
oc
00428
00128
0.0248
aaoo7
A
00220
00218
0.00028
00148
00238
OOIU
00128
SS010
A
OOI4B
00128
S3 on
A
00278
00228
S3 012
A
ooioa
OOMO
S3 Oil
A
00218
OMOB
S3 014
A
001(8
OOM8
88011
A
00248
S3 016
A
10128
021J
021J
0211
0.21J
021J
02
02
0208
OM
on
11
040
Oft*
00
Oft
OM
00
0*
OMU
OOMN
EMLte EMI-ta CMt.tac ^Ml-ta CMI.IK ERH.hK CRN. he FRU.tnc ERM.tae ERU.MC ERU Inc EW.lK CRH.tac ERU.Inc [RM.Inc tnu i«c
-------
1A81E 4-10
mOW* MTC
MEP AIHA MML MULT*
KM. IMOMUMC CONOmUENIO
PII4MMW
ffto^
An***
iMum
•nyUM
C44MMB.
Ctimirtiim
Cetao
C4JBW
H44)
L(M
UMftMM
MWCWf
MBM
SMHMBJ
SOM4
m
V*M4tM
ZM
pM
Tn
P*«"P^
V MMI
A
•770
411
74
0.17
• •
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t.9
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too
101
7.4
US
Ml
041
b, EM,*.
MOM
A
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IMM
1.04B
IM
0.40
110
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0.7
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07
171
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ERU.he
MMI
A
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12.0
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11400
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•.47
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7
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0.41
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4.0
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•14
aaa
0.1
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7.01
MOM
A
MM
3.040
M
•.94
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4.0
TOM
100
110
•
111
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7.M
E(M,h.
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A
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• MS
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140
40
• 0
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4M
101
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• 0
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til
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3.0
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7.40
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0 1
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7
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107
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A • DMA IA%M IM 0 DcoMfev tMV MBOM
-------
14
attributable to the water seepage. This seepage, however, is not
believed to have originated from the Tyson's Site as none of the
organic compounds associated with the former lagoons were found
in Sample SS0122.
4. Operable Unit 4 - Railroad Area
Soil borings were installed on both sides of the
railroad tracks . Soils developing on both sides of the railroad
are of the Rowland series. These soils are derived from the
weathering of materials washed from uplands underlain by shales
and sandstone and alluvial deposits from periodic flooding of the
Schuylkill River. These deposits include a layer of coal sediment
washed from the anthracite coal regions of Pennsylvania to the
far north of the site. Upstream coal piles have reportedly con-
tributed to coal deposition in the river during flood events.
The surface of each of the boring locations was comprised
primarily of cinder fill used in the construction of the railroad
bed. A field description of the fill material revealed that it\
consisted primarily of bottom ash from the coal combustion process.
Relative to soils typical of the Eastern United States, the con-
centrations of the inorganic constituents of cadmium, chromium,
mercury, and selenium are greater in bottom ash than in soil
material. Subsequently, in areas where bottom ash is used as
fill material, soil contamination from these and other
constituents may result.
Organic Compounds
Analytical organic analyses for the ten boreholes is
presented in Table 4-20. No organic compounds were quantitatively
confirmed in soil samples collected from borings 1, 8, 9, and 10.
Estimated concentrations of pyrene (.22 mg/kg) were detected in
boring 1, 1 and 1,2,3-trichloroporpane (.151 mg/kg),
tetrachloroethene (.0073 mg/kg), and total xylene (.0055 mg/kg)
were detected in boring 9.
Inorganic Constituents
The concentrations of inorganic constituents in the
subsurfacarsoil samples is also presented in Table 4-20. All
concentrations are well within or below the typical ranges reported
for soils in the Eastern United States. Soil pH values were
generally neutral (i.e., 6.6 to 7.3) except for the samples
collected from boring 5. Values for soil samples collected
between 4 and 14 feet ranged from moderately alkaline to strongly
alkaline (7.9 to >9.1). An explanation for these elevated pH
,values is not apparent.
-------
TABU 4-20 (Continued)
TYSONS SIIE
RAILROAD AREA SOL RESULTS
Organic Compound*
m0fcg (dry wtol* base)
BORNG1
Depth (M) *•• ••» 12- M 18-16 20-22 24 -25
PARAMETER ''
1.1.1-liteNQminm
17.3 TricMBfaprapana
1.2-Dkhloropropana
2Bu1anane 0007B 00078 0007B
2-HnanoM 0.011 B
ACMOM 0.0228 00MB OOS7B 0079B 00378 018
Carbon dbuNkte
CMorobeniene
j»t,i liin—
ufmrowin
ds 1.3 DfcNorapiapene
Elhylberuena
roluMie 00067B
tfBfls-l. ?-Qtdrioro8lhono
XytawEfloM)
4-UeUiyt-2-pertanone 0 007B
1.1-OleHaraeUiaM
SEM-VOLATILES
1.2.4-Tichknabnuaiw
1.2-DkMonbwuoiw
1.4-DkMorabwizom
2-UBthykaphmalena
B«uo(i)«dvaDiM
BamofaJpyraM
BMM |b«IO luoranlhoo*
Cteyuna
OMvButylPhOMtaW 022B
Mmaluran
FkioranUwM
Pyran* 022J 022J
1,3-DfcNaratwnzane
Wiobanzon*
PESTCDES
Gonna BHC
BORNG2
0-2 10-12 20-22
SSOS8 SSOSB SS060
A A A
015 0072 0012
0007 B
OOS9B 00608 015B
oooa
OMB 0053B 002BB
0 02 0 01
0013 B 00138
0011
004 0035 OOOB
1 1 036J
044
053
023J
023J
035J
023 J
056
04
06
048
BORING3 BORVC4
0-2 4-6 6-12 12-14 20-22 4-6
SS032 SS033 SS035 SS036 SS037 SSOS7
A A A A A A
0313J
0009B 00128
0010B 00218 015B 0118 0118 0045B
00067B
00071 002BJ
00079 0025 OOS7J
00158 0022B 00338 00188 00188 00048
0017 J
00098 00136 0072O
00078J
0013J
0046 OOOa 013 027J
38
1 57
062
045
021J
021J
021J 021J Q24 J
0818 0348
021J 021J 024 J
04SB
021J 045 022J 036 J
036J
021J 021J 045
02IJ 039 022J 024 J
024 J
024 J
B IhbiDBiAbqu
ft*
J. ThferasulhaquanllUllMBllinata
NC - This resua b not canUdM the method ol ktenMUcollon frequently o>
Blanks Mfcate none daiadad
I Oils compound was dMCMd In a Monk a • ctnuv oancantiafan
t US* patalm fasuhs Further canlrmaloiy McnmqiME (to. GC/MS) should be pertormed betoce this ruuli can be considered contMeni
-------
TABLE 4-20 (Continued)
TYSONS SITE
RAIUKMD AREA SOIL RESULTS
Organic Compounds
mgflie (iky vetpn basis)
Depend**)
Sanpto Hunter
PARAMETER
1,1.1-TffcNoroalnana
1.2.3-TrtchkiraprapaM
1.2-Dfchtoropropana
2-ButanotM
2-Haianona
Acetona
;Moroberuene
jIAktAjfin
els 1 .3-Olchlof opropana
tlhy(b«uana
falrachtofoalhana
loluana
lrans-1. 2-DkMoioalhana
— • - • ak
1 1 KMWOflliWnv
Xytanee (total)
4 Methyl 2-partanona
1.1-DfcMonMhana
SFtflVCXATIlES
t .2.4- TiKhbrabaiuana
1.2-OlcNoiabenzafw
1.4-DfcMwotMnzana
2-UMhylnapMnalana
Banzo (a) artfmGana
Banzo(a)pyiane
Banio (bftk) luonMhana
Bb P-^hylwiyl) pntMot*
CtiyMM
a-n-BulylPNhjtaM
noonzotunn
FluoranihwM
Naphlhaton*
Plwulhian*
PyrofMi
1 ,3-OlchloiolMnz4no
NtrobwuBM
PESTICIDES
Gwwn&BMC
0-2
SS03B
A
0007J
0.22 J
0007J
0011 B
016B
0.006 B
OO24 J
A fVU 1
OOB4 J
0 126
030J
0023 B
n 11 J
U T3 «l
047
033J
033B
OMJ
022J
022J
037
044
022J
OOS8NC
BORMG3
4-6 |.|f 12-14 20-22
T TO V T
0.069J 0.02 0006J
0010B 0012 B
0023B
00588 OI3B 0.0MB 00MB
000698
0018J
n m&i
II Ulakf
003J O006J
OOS7B 0037 B 0017 B 0019 B
0029J 0006
0021B
0 02 IJ
013 0027 002SJ 0007
0007B
0007J
023J
023J
027NC 03BNC
BOHNG6 BuHNG7 BOHNG6 BORNGS aORNGlO
0-2 0-2 46 8 12 12-14 05-25 25-65 4-6 8-12 12-14 30-22 0-2 6-10
SSOB1 SS044 SS045 SS047 SS046 SSOB2 SS063 SSOSt SSO&3 SS054 SSOSS SS064 SS085
A AAAA AA AAAA AA
0083 0151J
0009B 0009B 0008B OOI2B 0011JB 0012B 0008B 0008B
00078
0096B 0045B OOS9B 0024B 0073 B 0022 B 0012B 0 1SB 048B 017B OMB 0012B
001 IB
001SB 0067B 001BB 0017 B 0019B 0012B 0014B 0034B 0041 B 0012B 001SB OO14 B 0016B
014 00073 J
00098
0051
0011 00085J
024J
088 034J
024J
024J
024J 024J
04B 02B
024J 024J
0245
03BJ 044
073 022J
04S 022J 024J
024J 04J
B • Thb rasi* b ou«MI*o»r qMrtamUt Bhce thk compound «w doMcled ki a btank • a rtnter oonoonlredon
>l - Thb rasul b a quanlUlM aslbnaUL
-J*C - Ihto roMi* bnoloonlkton TlwnMhadalUMIBcalkm Mquanly gmoraMBtab*poctlM rasute. Funhwc
Blanks Mlcato non«ctot«Md.
I (Isx GCJU&) ihouU ba pertonrad betora nils rasul can to consMwed oonlUanl
-------
TABLE 4-20
TYSON'S SHE
RAILROAD AREA SOIL RESULTS
HSL INORGANIC CONSTITUENTS
"9*9. drf "Wight buto
Sample Number
Sample Daw
Pararrwler
Ahjmmim
Arsenic
Barium
Ban4bm
CaMum
Chromium
Cobal
Copper
ban
Lead
Manganese
Mercury
Metal
Setonkim
SIMT
Dn
Vanadium
Zinc
TMIum
PH
XMotslure
Data monad bv
4-6
SS026
6550
514
78
0678
11 2
4 S
201
9520
391
140
022B
112
168
307
747
ERMmc
a- 12
SS027
7080
432
122
1
155
5S
155
9130
177
159
011B
12.2
199
266
743
ERMJnc
""ff
12-14
11200
286
240
149
206
a
103
13500
B
161
149
286
269
753
ERMmc
~- - -
16-16
asm
10900
104
137
0758
249
8.7
174
23900
67
1220
012B
124
07SB
274
40
743
ERMmc
10-23
66030
13500
367
110
061 B
257
49
147
21300
98
215
11
073B
318
428
713
ERMJnc
24-25
SS031
5880
246
76
0398
11 7
30
91
8590
52
153
65
It 7
25
666
ERMJnc
0-2
SS058
8640
48
117
0358
152
47
258J
12900
293
156
007NV
7
DSB
OOSNV
238
176
437
0238
705
146
ERMJKC
BOHNG;
10-12
SSOS9
1 1300
59
179
068
215
48
203J
20900
156
170
OOSNV
84
012B
OOSNV
608
263
392
OSB
676
164
ERMJnc
2022
SS060
13900
SI
165
0478
223
47
129J
16400
71
133
003 NV
82
018
01 NV
1188
247
341
623
149
ERMnc
0-2
SS032
3770
497
S3
032B
63
42
361
9530
508
214
032B
74
063B
74
457
716
ERMJnc
4-6
SS033
7410
295
116
07<"
126
S3
264
9320
147
100
021 B
105
0748
179
449
712
ERMMC
BORING'
6-12
SS03S
9130
382
101
05S8
16
45
157
12900
112
135
022B
9
0678
202
331
716
ERMJnc
1
12-14
SS036
6920
285
80
046B
125
34
57
8720
46
771
a
0688
194
194
710
ERMnc
2022
SS037
10700
70S
129
071B
188
a?
165
23500
82
288
0128
165
259
424
667
ERMJnc
BORING
4-6
SS057
14100
548
$15
213
302
101
369
21900
2B
244
235
291
51 9
693
ERM.ITC
1
0-2
SS038
4050
126
88
033
121
55
724
17300
160
156
0118
aa
158
708
154
944
10B
657
88
ERMJnC
4-6
SS039
2790
115
069
116
93
775
26000
218
442
0218
104
068
5B
936
656
ERMnc
BORING
8-12
SS041
7920
44
72 J
024
155
48
155
29800
156
625
72
072B
9SB
179
743
915
162
ERMnc
>
12 14
SS042
10500
428
59
036B
178
7 1
119
12200
19
323
107
0718
178
302
828
ERMInc
2022
SS043
8530
4 1
36
024
155
4 a
84
11300
84
221
009NV
72
072B
72B
167
209
718
183
ERM.lnc
A - Data lahtn ton 8 Dmrnbar 1986 rapon
B - D* rasuB fe queftaMy quMtonetto ekm Oils anayu «• (Wccl«d ta a Hank d a atmUv oonoMmion
J - Thk mm b • quMMbB 4MkntH
N»- Tl* ran* k na vaH. ON laboratoiy abeotbanu dM Mlcatad DA cono«rtrallonl»tata»lh»d««cllontBpaWly
All EflM dm hM goo* through • qudlly Mwrne* ravtow.
-------
TABLE 4-20(CofitlniMd)
TYSON'S SfTE
RAILROAD AREA SOIL RESULTS
HSL INORGANIC CONSTITUENTS
B>B*B.
•^^^^^
••••••^•••••••l
M
o*fc(»i*)
PMM*
AJumknm
Alttflfc
ffcuhmi
Dwni
BoryOun
CoMum
Chromium
CoM
Copper
tan
load
kluiQBnMA
UWcuy
Mdiri
StfMfcun
S«Mr
1h
Vamdum
One
TMum
pH
•KMoteluro
Doaraporudbv
1P«
M
eaoo
936
107
03BB
13
47
1BJ
14600
427
107
107
MB
13
942
629
ERtitoc.
0-S
8S044
7870
829
135
OMB
•
66
140 J
12000
218
466
101
1MB
111
662
7.27
Emilnc.
BORNE
4-6
SS045
10630
2.6
47
024B
024B
142
Z4B
I07J
7890
95
54.9
47
024B
169
202
751
EHUInc
i7
6 12
SS047
13600
S3
16
036B
229
6
14 SJ
11900
84
104
106
21 7
336
772
ERMhc
12-14
SSM8
11600
462
36
6498
219
73
18 2J
15200
Bt
126
146
243
473
789
EHHtnc
BORNC8
05-25 25-6S
SS062 SSOM
7480 10100
223B 439
59 81
02ZB C35B
10 185
33 69
22B 104J
6330 14300
338 58
766 299
45 104
89 196
114 279
661 666
ERMjkc ERMJre
4-6
55031
9730
1 148
102
0236
159
34
114J
7590
352
ei»
57
162
26
as:
EMUnc
8-12
SS053
6880
472
60
046B
29
109
20 6J
11500
121
925
216
314
556
725
EBMhC
IQRUC<
12-14
SSOS4
11600
908
71
0368
213
9S
16 6J
13500
213
290
107
237
341
60S
EHU,(nc
•
20-23
SS055
13200
245
93
0156
396
7
1638
11200
22 t
131
105
345
357
665
ERM.tac
BOnNCIO
0-2 e - 10
SS084 SS085
4752 JBSt
25 29
84 104
04B 038
007 J 007 NV
9 13
6 5
11 J 10 J
7600 9422
6 5
107 1 155
006J 009NV
7 7
02B
012B 0128
78 2B
14 17
211 2t
028 02B
703 714
ERftUnc ERIUnc
A • DM IBkan ton 8 Dmmtar 19BB rapM
J - Thh iwu* b • quwUMlM MklHH
NV- This nuM k not nW. ita bbontary
Btortu Indtcaa nonxtetoctad
AH ERH dM» DM ggiw itowgh •
i Mkaied ttib oonctmraaon M tatM (hi tMMdtan capaWiry
-------
15
5. Operable Unit 5 - Floodplain/Wetlands
Based on topographic differences, the Floodplain/Wetlands
Operable Unit supports a diverse flora consisting of both upland
and wetland-related vegetation. The floodplain proper supports
primarily wetland related flora. The elevated portion of the
unit adjacent to the railroad access road supports a mix of
vegetation consisting of upland and wetland plants. No areas of
stressed vegetation were observed either during field
investigations or follow-up walk-overs. Examination of infrared
photographs of the site and surrounding area support the field
observations of no areas of stressed vegetation.
The site appears to support a diverse and unimpacted
flora and associated fauna. Mo areas of stressed vegetation were
observed during the site investigations or from photo interpretation
the 1974 and 1981 infrared aerial photographs. Observation of
fauna indicated random distribution with no specific area(s) of
avoidance.
The soils in the floodplain are classified by the
Soil Conservation Survey as Rowland Silt Loam/ coal overwash
with a Bowmansville hydric component. The forested component
consisted of red maple, green ash, black willow, river birch, and
panicled dogwood. The scrub-shrub component included young red
maple, green ash, bitternut hickory; spicebush, poison ivy, and
boxelder. A number of other wetland related understory plants
were located in this area, including spotted jewelweed, jack-in-the-
pulpit, and purple loosestrife. Wetland related vegetation was
observed throughout the floodplain, especially in the vicinity of
the drainage ditches and other scattered areas.
Organic Compounds
The ice-house sample, which was collected.
approximately 2000 feet west of the Floodplain/Wetlands Operable
Unit, contained a number of PAH compounds (excluding the
estimated values) including: benzo(a)anthracene, benzo(l)pyrene,
benzo(b)fluoranthene, benzo(k)fluoranthene, chrysene,
fluoranthene, phenanthrene, and pyrene. Excluding the estimated
PAH concentrations, PAHs were not found in the air stripper
outfall samples. Pyrene and Indeno (1,2,3-cd)pyrene were
reported toe-one of the two samples taken from the western swamp
area. The source of the PAO's in the ice-house sample (total PAH
concentration of 9.26 rag/kg) may be the coal sediment washed from
the anthracite region well to the north of the site. The Soil
Conservation Survey (SCS) Soil Survey for Montgomery County
states that the Rowland silt Loam, which occurs in the floodplain
of the Schuylkill River, does contain anthracite coal sediment.
-------
16
Five volatile organic compounds were detected in the
air stripper outfall samples. 1, 2, 3-trichloropropane was found
in both air stripper samples (0.022 mg/kg and 6.3 mg/kg) .
Tr ichloroethylene (0.04 mg/kg) and tetrachloroethylene (.05 mg/kg)
were found in the initial air stripper sample along with total
xylene (0.4 mg/kg) and chlorbenzene (0.09 mg/kg).
Pesticides were found only in soil samples collected
in the western swamp area. 4,4-DDD concentrations were 8.59
mg/kg and 12.9 mg/kg; and, DDE concentrations were 1.34 mg/kg and
3 mg/kg.
Inorganic Constituents
Concentrations of inorganic constituents in soil
samples taken from the west swamp (SS067, SS069) , air stripper
outfall (SS068, SS070), and ice-house (SS066), are presented in
Table 4-30. With the exception of zinc, copper, selenium, and
lead, inorganic constituent concentrations were well within or
below the commonly reported range for soils of the eastern United
States. Zinc and lead levels in the initial sample (SS068) from
the air stripper outfall were substantially higher than average
levels. This is most likely attributable to anthropogenic
sources of zinc and lead, however, these sources may not be
related to activities at the Tyson's Site as high levels of zinc,
201200 mg/kg, and lead, 218-10,900 mg/kg, are commonly reported
for similar areas of urban development. Copper concentrations
exceeded typical levels reported for soils of the eastern United
States in the initial sample (SS067) obtained from the Western
Swamp location; selenium exceeded typical levels in the September
sampling at the Western Swamp. Elevated levels of these
constituents, however, have been reported for similar organic
rich soils.
Significant variations in the concentration of a
number of these inorganic constituents including aluminum, zinc,
lead, barium, chromium, copper, iron, manganese, nickel and
vanadium were found to exist among sampling locations and between
sampling dates. These variations are thought to be the result of
the heterogeneity of the soils developing on the Schuylkill River
With regard to the sediment layer, this layer is
derived primarily from coal sediments washed from the anthracite
regions of Pennsylvania, north of the sampling area. This layer
is reported to vary in thickness from 1 to 3 feet, subsequently,
variations in the amount of sediment present may significantly
affect the concentrations of inorganic constituents. For
'example, coal sediments are typically high in iron, soil samples
taken from areas with a thicker sediment cap would be expected to
exhibit higher iron concentrations than those obtained from areas
with a thinner sediment cap.
-------
TAIL! 4.M
rrsoirt tm
riOOOPUUN AN*A tOO. RIMLTI
MW. *0«OAHC COMTTTUUrTB
wall
Air Stnp0«r
OulW
ss-ooo*
A
3«-oor
A
SC-000*
A
OuffM
S»-OTO
A
fOLATILIi
.2.3-T(lenioroprop«i«
0063S
0131
OOMI
lim.VOLATILlt
1.1
0.30J
O.ttt
1 •
1 •
O.M
1.1
0.74
O.MJ
0.30J
1
0111
024*
0.020J
0.040J
00401
e.tw
O.I7J
1 M
O.MI
0«OJ
00MB
0.4M
O.OflB
0.04VI
O.OM
O.fAl
03
0.1 M
0.27B
O.OAS
0.04
o.ot
O.OM
0.0*
0.4
OOtt
0.0071
OIM
0.0411
0.01 U
0.01 U
0.070J
1.0J
O.M
1.0
O.M
M-TTtt
-------
TAULI
TYMN1 mi
FLOOOPUUN MIA oat RUULTI
M*L INOIMAMC OOMTnVINTS
mg/ftf. *r •*•*
w of IBB HOUM MMMovn WMMM Air SvtAAty AIF
S«mm» AIM Saw Af« OutM Ouiiut
ss-007- ss-oor ss-otf ss-ara
* A A A
MunMun 11000 98 TC 19400 14440 0900
AflMOnp
*rnre (4 }| 14 0 10 if
num >0 340 14* HO }4»
ryi"V* > 7 0 • 0.7* 3 1 01
•nun otft ct as* O.N oat
«"*«" >1 10 «J O 1(4
MR 10 » ia.« o i a
M** 10 440 100 110 MO
"on IMOO 30000 14000 aSOM tlOOO
* «• no U4 $»« ss.a
rOJPMl ia7 100 aen i4j
« IMMM 31 1 7S.S
••<' 0.1 T S.01
6BM.Ha EHM.*ia »•!>«. CT^iia BBAH
AM IMI MM Mi
-------
17
6. Comparison of Organic Compounds Detected in On-
Site and Off-Site Samples
Table 4-36 is a comparison of the organic compounds
detected in the former lagoon area during the above investigations
and the organic compounds detected in the Off-Site Operable Units
during the On-Site RI and the Off-Site Operable Unit RI. A broad
suite of similar organic compounds were detected in both the
former lagoon areas and the various Off-Site Operable Units.
Possible sources of the PAHs to the Off-Site Operable Units
include the following:
- coal fines washed downriver from coal crushing/washing and
storage operations along the northern reaches of the river;
- burning of construction materials;
- bottom ash used as fill material for the railroad ballast;
- materials used for maintenance and construction of the
railroad;
- spills of coal, coal related products, and chemicals
during the transport of these materials via the railroad;
- fly ash and gaseous emissions from the coal fired
generating station on Barbadoes Island;
C. Summary of Site Risks
The following conclusions are based on the analyses
performed in the Off-site Operable Unit RI/FS.
- The maximum detected levels of numerous volatile and
semi-volatile compounds detected in the bedrock aquifer
exceeds acceptable levels.
- The potential carcenogenic risks posed by operable
unit* 2 thrugh 5 are below acceptable levels.
- The discharge of contaminants to the Schuylkill River via
the bedrock aquifer exceeds acceptable levels.
In summary, ambient site conditions for operable units 2
through 5 represent an acceptable level of risk. However, a
reduction of the toxicity, mobility and volume of the
contamination in the bedrock aquifer represents a desirable
action for protection of human health and the environment.
-------
-------
18
V. Community Relations History
Residents .living near the Tysons' Superfund site have always
been highly interested in the former lagoon area of the site
which is presently undergoing remedial action. However/ EPA has
never received questions about the operable units, or off site
areas. Upper Merion Township officials are involved with every
aspect of the site, but the local residents are more concerned
with progress in the on-site area.
EPA placed an advertisement listing cleanup alternatives for
the operable units in the Norristown Times Herald on September 4,
1988. The ad also announced the public comment period which ran
from September 4 through September 26, 1988. No written or oral
comments were received by EPA during that time.
VI. Remedial Alternative Objectives
The major objective of remedial actions to be taken at the
Off-Site Operable Units of the Tyson's Site is to recover and
treat groundwater discharging to the Schuylkill River to levels
protective of human health and the environment.
Based on the above objective, numerous groundwater treatment
technologies were screened to provide a limited number of
technologies applicable for remedial action at the site. Some of
these technologies were removed from further consideration based
on site specific information and other comparative criteria listed
below;
Effectiveness
- Reduction in mobility, toxicity, or volume
- Permanence
- Long term management
Reliability
- Operation and maintenance (O&M) requirements
- Failuce potential
-------
19
VII. Description of the alternatives
A. Remedial Alternative Evaluation - Operable Unit 1-
Bedrock Aquifer
1. No Action - This alternative will have no environmental
or public health benefits. It will not be protective in the
shortterm or long-term. This alternative would not achieve the
ARARs. There will be no reduction of toxicity, mobility or volume
since to recovery or treatment is involved. Based on the above,
this alternative will not be considered further.
2. Pump and Treatment - This involves the recovery and
treatment of contaminated groundwatec discharging into the Schuylkill
River. The treatment of groundwater reduces off-site risk to River.
Toxicity and volume of contaminants in groundwater reduced by
treatment. All contaminant specific ARARs will be met.
a. Technologies Available
The technologies that have ben retained for assembly
into remedial alternatives are described below:
1. Air Stripping
Air stripping, to remove organics from water, is per-
formed by passing air through the water to facilitate transfer of
volatile organics from the liquid phase to the gas (air) phase.
These volatiles are then removed in the stripper off-gas. The
degree to which stripping is successful at removing volatiles
from a liquid stream depends on the volatility of the compounds
present, the volumetric ratio of air to water flow, the surface
area of the air/liquid interface, and the temperature at which
stripping is conducted.
Three methods of air stripping are most prevalent:
diffused aeration, mechanical aeration/ and packed or spray tower
stripping. Countercurrent packed tower air stripping has been
most frequently employed for groundwater cleanup operations and
is generally the most efficient stripping process for removal of
volatile compounds. VOC air emission from the stripper off-gas
may cequit* further treatment to maintain acceptable ambient air
quality standards.
-------
20
2. Steam Stripping
Steam stripping requires the dissolved organic
compounds to be transferred from the influent water to steam.
The steam is then condensed and the organic compounds are stored
at the plant and then shipped out for recycling or incineration.
The water condensate is then sent back to the steam stripper and
mixed with the influent water. The condenser is vented and the
vapor is treated by passing through vapor-phase carbon adsorption
units. The volume of vapor released from the condensor and
passed through carbon is very small compared to the volume of
air passed through carbon from a conventional air stripper.
Thus, the vapor-phase adsorption units are relatively small. The
carbon is regenerated on-site periodically using steam and the
condensate from the regeneration process is handled in the same
way that the condensate from the condensor is handled. Steam
stripping is extremely efficient in the removal of volatile
and semi-volatile organic compounds. If unstrippable organic
compounds are encountered, they are removed by adding liquid-
phase carbon adsorption to the system.
3. Thermal Oxidation
(Off-Gas Control)
Thermal oxidation can be used to treat the gas-phase
discharge from an air stripper. Thermal oxidation uses high
temperature under controlled conditions to degrade a constituent
into products that may include carbon dioxide, water vapor,
hydrochloric acid, sulfur dioxide, and nitrous oxide gases.
Organic materials can ordinarily be burned if they
are mixed with air to provide oxygen content in the 10 percent
to 15 percent range, have a hydrocarbon concentration above a lower
explosive limit (LEL), and are heated above an auto-ignition
temperature. The resulting combustion can produce essentially
complete oxidation of the combustion mixture. The lower
explosive limit is the concentration of any organic material that
produces temperatures high enough to sustain flame reactions.
These reactions result in the formation of the reactive free
radical sulfur dioxide and nitrous oxides. Treatment of the air
stripper off-gas may be done thermally with or without catalytic
assistances
-------
TABLE IS
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«ii pntenunc* guunMt pnw w ipiM
M NM<*tofH9««JMMdalMMttmhMlMnM!MdnluMc
tl '"intfi Ifimi tm ii IBIIHII i< IfT m mi nuMli. 111 ifiniit m
-------
21
4. Vapor-phase Carbon Adsorption
Vapor-phase Carbon (VPC) treatment can also be
employed for treating the gas-phase discharge from an air
stripper. VPC systems consist of columns of adsorbent (activated
carbon) with a typical density of 30 lb/ft. The vapor-phase
carbon particles are larger than corresponding liquid phase
carbon particles and have large and highly permeable void spaces.
Contaminated air flows through the columns or carbon bed, and
organics adsorb onto the carbon. The treated air then leaves the
bed with reduced concentrations of contaminants until the carbon
adsorbent has reached capacity and is replaced or regenerated.
5. Granular Activated Carbon
(Liquid-phase) Adsorption
Carbon adsorption involves contacting a waste stream
with carbon, usually by flow, through a series of packed bed
reactors. Molecular adsorption by way of chemical forces adhere
volatile molecules on the surfaces of the carbon particle. ^
Activated carbon's favorable adsorptive properties are related to
its high available surface area. Contaminants are removed from
the waste stream and adsorbed from the liquid phase onto and into
the solid carbon phase pore structure. Larger, more highly
branched, less soluble compounds are most readily adsorbed. The
degree to which carbon adsorption can be used to remove
contaminants from a waste stream is dependent on the specific
compounds to be removed, concentrations of other organics in the
stream, and the choice of carbon material.
Once the micropore surfaces of the GAC are saturated
with organics, the carbon is "spent" and must either be replaced
with virgin carbon or removed, regenerated, and replaced. Carbon
"breakthrough" refers to the condition in which a specified
effluent concentration limit is exceeded. Complete exhaustion of
a bed occurs when the carbon is completely spent (no further
adsorption of the contaminants(s) can occur). The operating time
available before reaching breakthrough is the single most
critical operating parameter in carbon system design, however,
backup carbon units are employed in the rare case of failure.
6. Chemical Oxidation
The chemical oxidation process consists of adding an
oxidizing agent, such as hydrogen peroxide/ Fenton's reagent,
ozone, or hypochlorite (sometimes in conjunction with catalysts.
or ultraviolet radiation) to a waste stream to convert organics
to more highly oxidized intermediates or ultimately to carbon
dioxide and water, depending on the oxidant used. Partially
oxidized intermediates may be more or less readily treatable or
toxic than parent compounds, depending on the reaction pathways
followed.
-------
TABLE 36
Alternative Irnptemeniabtty Screening
Alternative 2 Alternatives Alternative 4 Alternative 6 Alternative 7 Alternative 9 Alternate 10
1. Atafetylo
•Construct
•Maintain
Remedy
2. Abttylo
Monk* Remedy
3. Abiry to Improve
Treatment System
Performance
4. Avaiafailyol
€qupMnl
-OG-site
Services
5. Duration ol
RemerJatEltort
my require alternative acceptable
fjtoji appropriate lor
ffJpMnl into! recovery
' system crty.may
requre custom
equipment
adwyjatp adequate adequate
good good good
adMiflfr adequate i^Pf^ti^
potenoaly
adequate inadequate (a) good
uncertain • 30 uncertain • 30 uncertain • 30
yearsassumed yearsassuned yearsassuned
may require alternative
custom appropriate tor
equpment initial recovery
system only, may
require custom
equipment
adequate adequate
adequate
good
adequate
adequate
good
uncertain -30
yearsassuned
adequate
good
adequate
adequate
potentially
inadequate (a)
uncertain • 30
yearsassumed
may require
custom
equipment
adequate
adequate
good
adequate
adequate
good
uncertain - 30
yearsassumed
alternative
appropriate lor
initial recovery
system only, may
require custom
equipment
adequate
adequate
good
adequate
adequate
potentially
inadequate (a)
uncertain • 30
yearsassumed
(a) Thermal regeneration services tor spent carbon are expected to be available over the lite ol (he remedy. The ability to dispose of residuals resulting from
-------
TABLE 3-7
CONCEPT LR/a COSTS
TYSONS SITE GROUND WATER REMEDIATION
WITIAL RECOVERY SYSTEM
Alternative Estimated Construction
Cost
2
3
4
6
7
9
10
11
Air Stripping and Thermal Oxidation
Air Stripping and Vapor Phase Carbon
Granular Activated Carbon (GACJ
Air Stripping with Thermal Oxidation;
GfC
Air Stripping with Vapor Phase Carbon;
«C
Air Stripping with Thermal Oxidation;
UV/Peroxidalion
Air Stripping with Vapor Phase Carbon;
UV/Per oxidation
Steam Stripping and Vapor Phase
* 1.85 million
2.37
0.64
1.98
2.29
1.62
1.97
765,
million
million
million
million
million
million
000
Estimated Annual
Operating Cost
$ 403.400
424
606
442
509
498
563
170,
.300
.200
.900
.900
.900
.000
000
Estimated
Present Worth (1)
$ 5.50
6 17
630
5.99
6.91
6.19
7.11
A. 85
million
million
million
million
million
million
million
million
12
Carbon Adsorption on Condenser
Vent Stack
Steam Stripping and Vapor Phase
Carbon Adsorption on Condenser
Vent Stack and Liquid-Phase Carbon
172,000
172,000
5.17 million
(1) Assumes 30 year remediation and an interest rate of 10 percent
-------
TABLE 3-8
CONCEPT LEVEL COSTS
TYSONS SITE GROUND WATER REMEDIATION
OOMPIETE RECOVERY SYSTEM
AllMMUV*
Estimated Construction
Cost
Carbon Adsorption in Condenser
Vent Stack
12 Steam Strippping and Vapor Phase
Carbon Adsorption in Condensor
Vent Stack and Liquid-Phase Carbon
1,060,000
Estimated Annual
Operating Cost
196,000
Estimated
Present Worth (1)
2
3
4
6
7
9
11
Air Stripping and Thermal Oxidation
Air Stripping and Vapor Phase
Carbon
Granular Activated Carbon (GAC)
Air Stripping with Thermal
Oxidation;
Air Stripping with Vapor Phase
Carbon; (GAC)
Air Stripping with Thermal Oxidation;
UV/Peroxldatlon
Steam Stripping and Vapor Phase
$ 2.72 million
$3.37 million
0.64 million
2.32 million
3.29 million
2.46 million
905,000
$ 623,500
$ 624,000
2.082.800
663.700
709,900
993,200
193,000
$ 8.36 million
$7.17 million
20.32 million
8.39 million
7.91 million
11.62
5.57 million
5.89 million
(1) Assumes 30 years remediation and an Interest rate of 10 percent
-------
22
Chemical oxidation processes are usually carried out
in a continuous flow mode. Water to be treated enters tank where
the water is mixed with the oxidizing agent, with or without
ultraviolet (UV) irradiation. Tank hydraulic detention time
varies, based on results obtained empirically in treatability
studies.
b. Alternative Presentation
While not one of the above technologies can remediate
the full range of contaminants at the site, combinations of these
technologies may. From the technologies discussed above twelve
remedial alternative for groundwater treatment have been developed.
1. Summary of Alternatives
Tables, 3-5, 3-6, 3-7, and 3-8 summarize the alternatives
according to the applicable assessment factors. The following is
a summary of the remedial measures.
Alternative 1 - Groundwater treatment by air stripping
Alternative 2 •
Alternative 3 -
Alternative 4 -
Alternative 5 -
Alternative 6 -
Altecnative 7 -
Alternative 8 -
Alternative 9 -
Groundwater treatment by air stripping, with
thermal oxidation for gaseous emissions treatment
Groundwater treatment by air stripping, with
vapor phase carbon (VPC) for the gaseous
emissions treatment
Groundwater treatment by aqueous-phase
granular activated carbon (GAC)
Groundwater treatment by air stripping
followed by aqueous-phase GAC polishing for non-
strippable compound removal
Groundwater treatment by air stripping in
conjunction with thermal oxidation, followed
by aqueous-phase GAC polishing
Groundwater treatment by air stripping in
conjunction with vapor phase carbon,
followed by aqueous-phase GAC polishing
Groundwater treatment by air stripping
followed by UV/Peroxidation polishing for
nonstrippable compound removal
Groundwater treatment by air stripping in
conjunction with thermal oxidation followed
by UV/Peroxidation polishing
Alternative 10 - Groundwater treatment by Air Stripping in
conjunction with vapor-phas carbon followed
by UV/Peroxidation Polishing.
-------
23
Alternative 11 - Steam stripping and vapor phase carbon
adsorption on condensor vent stack
Alternative 12 - Steam stripping and vapor phase carbon
adsorption on condensor vent stack and
liquid-phase carbon
Alternative 1 and 4 represent alternatives composed of a
means of recovering groundwater for treatment and a single tech-
nology designed to accomplish that treatment. Alternatives 2, 3
and 11 are an enhancement of Alternative 1 to provide air emissions
controls should air or steam stripper emissions exceed acceptable
criteria. Alternatives 5, 6, and 7 and 8, 9, IB and 12 build on
Alternatives 1, 2, 3 and 11 to account for non-strippable compound
removal should it be required.
B. Remedial Alternatives Evaluation - Operable Units 2
through 5
Alternatives for the remediation of off-site Operable
Units 2 through 5 were not provided in the off-site FS based on
the July 1987 Endangerment Assessment findings of acceptable risk
and also on practical considerations. The following is summary
of significant conclusions of the Remedial Investigation and
Endangerment Assessment conducted for these Operable Units.
Hillside Area (Operable Unit 2)
- compounds detected in the former lagoons were detected at
trace levels in several of the samples collected in this
area. This indicates that overland flow and/or shallow
groundwater discharge from the fractured bedrock outcrop
in this area probably occurred during operation of the
lagoons;
- the total volume of contaminated soil in the Hillside Area
is minimal, with depth to bedrock usually being one or two
feet and with exposed bedrock present in much of the area.
- exposure to contaminated Hillside soils is possible via
dermal contact with the soils and incidental ingestion of
such soils.
- the carcinogenic risk to children of exposure to con-
taminated Hillside soils is negligible (less than 10- ).
Accordingly, no significant subchronic or noncarcinogenic
hazard is present.
-------
24
Railroad Area (Operable Unit 3}
a wide variety of organic and inorganic compounds was found
throughout this area, both associated with the former
lagoon area, and with the materials used for the railroad
ballast,
exposure of railroad workers to contaminated soils via
dermal contact is possible in the Railroad Area
the carcinogenic risk to railroad workers of exposure to
contaminated Railroad Area soils is less than 10- and
is, therefore, in conformance with EPA guidelines. Ac-
cordingly no significant subchronic or noncarcinogenic
hazard is present.
Floodplain/Wetlands Area (Operable Unit 4)
trace level of site-related contaminants were detected
in the ditches and drainageways receiving runoff from the,
site and discharge from the EPA-installed air stripper.
no acute or chronic effects were observed in the fish
species studied; the results of the testing with Daphnia
were inconclusive.
results of the liquid phase elutriate chemical analysis
and bioassay show no potential acute toxicity with Daphnia
in the sediments studied.
no adverse effects on any organisms investigated during
the biological studies could be attributed to site-related
constituents.
exposure to contaminated sediments and surface water in
the Floodplain Area via dermal contact and incidental
ingestion of soils is possible. Inhalation of contaminants
volatilized from soils and surface water in the Floodplain
Area* is a negligible source of exposure.
that estimated carcinogenic risk of dermal contact with
incidental ingestion of contaminated soils and surface
water is less than 10- , conforming to EPA guidelines.
Accordingly, no significant subchronic or noncarcinogenic
hazard is present. The estimated intake due to inhalation
of contaminants volatilized from surface water and soils
in the Floodplain Area is less than one percent of the
total intake of indicator compounds. Consequently, this
pathway of exposure does not present a hazard and was not
considered further.
-------
25
Seep Area (Operable Unit 5)
- eleven of the sixteen samples taken from this area had no
detectable Hazardous Substance List (HSL) organic compounds.
The highest single concentration of HSL organics detected
consisted of non-site-related PAHs.
- the origin of the seep remains unknown but is probably
related to shallow groundwater flow in this area; the seep
has not recurred since initial restoration of the area.
- the carcinogenic risk of exposure to contaminated Seep
Area soils is estimated at less than 10~ . This risk is
within EPA guidelines. Accordingly, no significant sub-
chronic or noncarcinogenic hazard is present.
VIII. Description of ARARs
The identification of appropriate ARARs depends upon the
recognized uses and designations of the environmental resources
and media of concern. ARARs are divided into three main categories.
- Contaminant-specific ARARs;
- Action-specific ARARs; and
- Location-specific ARARs.
Contaminant-Specific ARARs
The sources or media of concern for the Off-Site FS include
air, groundwater, surface water (Schuylkill River) and wetlands/
floodplains. Contaminant Specific ARARs for air, groundwater,
surface water and wetlands/floodsplains are presented in Table 3-1.
The classification and use of each resource and the basis for the
ARARs are present as follows:
- Aic
Montgomery County, Pennsylvania, where the Tyson's Site
i» located, is in a non-attainment area for ozone as per
the National Ambient Air Quality Standards (NAAQS) promul-
gated under the Clean Air Act. The NAAQS are enforceable
standards applicable at designated ambient air monitoring
locations. State regulations, 265 PA Code Section 127.11,
require a plan approval for air strippers and other
equipment designed to remove volatile contaminants from
soil, water, and other materials. Ambient Air Quaility
Guidelines set forth by PADER under the Interim Operating
Guidelines for Air Toxic Substances (ATGs) are possible
ARARs; exemptions may be granted from the permit
requirements if:
-------
26
(1) stack concentrations of each individual air toxic
constituents do not exceed one-third of the ATG ambient
guideline concentrations, and (2) potential (before control)
emission rates of all listed air toxics do not exceed a
total of one pound per hour. For those compounds lacking
other ARARs risk-based calculated stack emissions concen-
trations (Table 3-2) are also possible ARARs. These are
calculated to be protective of human health for both
carcinogenic and noncarcinogenic effects based, for the
floodplain area, on a residential receptor 300 meters
from the stack.
Groundwater
- Groundwater cleanup standards for the bedrock aquifer have
been set by EPA and DER. These levels, based on the
Partial Consent Decree, are given in Table 3-3.
Groundwater beneath the Tyson's Site between the former
lagoon area and the river is not used for drinking water,
household, or other use. The exposure point of concern
for the groundwater considered in this study is the
Schuylkill River, to which this groundwater discharges.
For the purposes of this study, clean-up standards for
extracted, treated groundwater may be derived from those
ARARs applicable to surface water in conjunction with
PADER stated discharge limits for treated groundwater at
the site. Where more than one ARAR was available for a
given compound in surface water the most stringent of the
ARARs was employed. In addition, because a number of com-
pounds at the site did not have ARARs for protection of
human health, risk-based concentrations allowable in
Schuylkill River water for protection of human health were
developed for these compounds.
Safe Drinking Water Act Maximum Contaminant Levels (MCLs)
are possible ARARs applied "at the tap", or at the point
of human consumption. Federal Ambient Water Quality
Criteria (WQC) for the protection of human health are
ambient concentration guidelines, and are potential
ARARs. Federal WQC for the protection of aquatic life and
Pennsylvania Water Quality Criteria are also possible
ARARs and are applied.
A summary of projected allowable effluent concentration
derived from surface water ARARs and other sources is
given in Table 3-2. The risk-based concentrations for
both air and surface water ARARs were calculated using an
acceptable risk level of 1 X 10-° for carcinogens, and
"no adverse toxic effect levels" for noncarcinogens.
-------
TABLE 3-1
POTENTIALLY APPLICABLE AND RELEVANT OR APPROPRIATE REQUIREMENTS (ARARS)
TYSON'S SITE GROUND WATER TREATMENT
Compound
.. ^ff PADEH
SurUc* W*Ur
WaBfOuafelyCflKna
Treated Ground Water HimnHaatt AquaicL
ton to Tyson* SUB WatvAFeh Fen Only Acute
VoUtlU*
Action*
BMIM*
CMOfOtMAUM
Chtorafarm
t.l-OtahtooMhaM
lia-DkhtafOpiopm
d>- 1 ,3-DlBNoropTBfi«n*
Mrttytow chtonn
T^a^J_Mh^4fet^M«A
IMWniOTWnB
TftfX|«Mm
Sjmlvotolltoa
PttMQl
1>OkMarab«inno
t ,4-DhMoralMnnno
MHrobHiMM
|j2.4VTfloNvabMMM
DMMiuM (MufMi
CiMrt
I.29E+OI 500E03 660E04
488EOI
4.3sc«oo i ooe-or 1 OOE 04
8 70E 02
I.40E03
2.42EtOI
1.72E«02 8 OOE 04
1 43E*OI
7.68E*OI 2 70E-03
6 OOE*02
SOOE»02
100E«02
4.e«E»02 300E»01 3SOE-03
1 98E*Ot
4 OOE 02 530E+00
250E01
t 57E 02 2 89£»0t
230E»OI
1 41E 02 606E»00
3 28E-03 3 20E+01
8 8SE 03
4 24E.02 1 7SE«OI
• 07E02 4SOE»OI
1 02E+OI
2 70Et01
da
Chronic
SOOE 02
1 24E»00
570E«00
2 44E-Ot
2I9E.OI
2S6E»00
6 20E 01
'Total Wiakxwrthsnos
Blanto mdkato Hal ARAB* tor ftesa oompounds aw not walabte
-------
TABLE 3-3
Tyson's Site
Ground water Cleanup Levels
Compound
Ground Water Cleanup Level (i)
mg/L
Aniline
Anthracene
Benzene
Benzoic Acid
Bis(2-eihyihexyl)pnthalate
2-Butanone
Chlorobenzene
2-Chioronapmnalene
2-Chlorophenol
Chrysene
Cycioheptatnene
Cyclohexanone
Di-n-buiyl phthalate
Dioctyl phthalate
Dichlorobenzenes
2,4-Dimethylphenol
n,n-Dimethyl-l ,3-propanediamine
Oodecane
Ethylbenzene
1 -Ethyl-2-meihylbenzene
Fluoranthene
Hexadecane
Hexadecanoic acid
Methylene chloride
2-Methylnaphthalene
2-Methylphenot/4-methylphenol
4-Methyl-2-pentanone
n-Nitrosodiphenylamine
Naphthalene
Nitrobenzene
1.1 -Oxybis-(2-etrx>xyetnane)
Phenanthrene
Phenol
Pyrene
Tetrachloroethtne*
Tetramethyftm»
Toluene
1,2,4-Trichtorobemene
1,3,5-Trichlorobenzene
Trichloroethene
1,2.3-Trichloropropane
1,2,4-Trimethylbenzene
Tridecane
Undecane
o-Xylene
0.13
70
0 00022
0 70
0.051
1 B
0.06
0 11
0 10
0 0000015
0020
230
3.5
063
0,075
0.28
0.65
3.9
0.68
0.12
0.21
22.0
0.02
0.0016
0.53
1.8
1.8
0.0071
0.62
0.018
0.85
0.25
3.5
0.70
0.00023
0.76
2.0
0.23
0.23
0.0011
0.00035
3.0
0.41
0.18
0.12
(1) Cleanup Levels derived from Partial Consent Decree Acceptable Levels
-------
TABLE 3-3 (continued)
TYSON'S SITE
Groundwater Cleanup Levels
Compound
Groundwater Cleanup Level
mg/L
1,1-Dichoroethane
trans-1,2-Dichloroethene
1,2-Dichloropropane
1,2-Dihclorobenzene
1,4-Dichlorobenzene
Chloroform
Cis-1,3-Dichloropropene
0.007
0.07
0.006
0.62
0.075
0.1
0.0875
-------
27
The effluent limits listed in Table 3-2 will also serve as
interim groundwatec clean-up standards; i.e. interim clean-
up will be completed when the concentrations of the listed
compounds in untreated groundwater are below the effluent
concentrations selected for treated groundwater. At that
time, the effectiveness of the groundwater treatment
system will need to be re-evaluated.
Action-Specific ARARs
At present, there are no technology-based standards
applicable to the types of remedial actions proposed.
Location-Specific ARARs
Because the proposed treatment facility for recovered
groundwater would have to be located in the Schuylkill River flood-
plain/wetlands portion of the off-site area, location specific
ARARs are potentially applicable in the event that physical con-
struction in undisturbed areas is necessary. Executive Order
11988 mandates that floodplain development not be favored when
other feasible alternatives are available. Because the extraction
wells are, of necessity, located in the 100-year floodplain for
the Schuylkill River, the closest to the wells that the treatment
facility could be outside the floodplain would be in the Conrail
switching yard or the steep banks of the Hillside Area. These
locations do not offer adequate space for such a facility. Con-
sequently, location of the groundwater treatment system outside
the 100-year floodplain cannot be practically accomplished.
IX. Comparative Analysis
A. Operable Unit 1 - Bedrock Aquifer Alternatives
(See Table 3-5, 3-6, 3-7, and 3-8.
Alternative 1. Groundwater Treatment by Air Stripping
Air stripping without emissions control is
expected to exceed the acceptable standards
for air. Inherent compound toxicity is not
reduced but simply transferred from the
aqueous to the vapor phase. The volume of
contaminated groundwater is decreased. Non-
strippable compounds would not be destroyed
in this treatment process.
Alternative 2. Groundwater Treatment by Air Stripping,
with Thermal Oxidation for Gaseous Emissions
Treatment
-------
28
Alternative 2 is in compliance with both air
and water risk-based standards. The alternative
does significantly reduce compound toxicity
and volume, since stripper off-gas containing
organics is passed through an oxidizer unit
to destroy these compounds. Non-strippable
compounds would not be destroyed in this treat-
ment option. The estimated present worth of
this alternative is $5.50 million.
Alternative 3. Groundwater Treatment by Air Stripping, with
Vapor Phase Carbon (VPC) for the Gaseous
Emissions Treatment
Alternative 3 is in compliance with both air
and water risk-based standards. This alternative
does not reduce inherent compound toxicity,
as organics are merely concentrated on the
carbon from the stripper offgas. When the
VPC is steam regenerated and the organic
phase decanted, organics are further concen-\
trated. Only upon incineration of the organic
decant or thermal destruction of contaminants
on the spent VPA would compound toxicity and
volume be virtually eliminated. Non-strippable
compounds would not be destroyed in this
treatment option. Significant operation and
maintenance (O&M) would be required. The
estimated present worth of this alternative
is $6.17 million.
Alternative 4. Groundwater Treatment by Aqueous-Phase
Granular Activated Carbon
Alternative 4 is in .:ompliance with both air
and water risk-based standards. This alternative
also does not by itself reduce inherent compound
toxicity, as organics are simply concentrated
on the carbon from the groundwater. Upon
thermal regeneration of the carbon, these
compounds would be destroyed, thus effecting
a significant reduction in compound toxicity
and volume. Non-strippable compounds would
generally be removed in this treatment alternative,
Sizable O&M would be required due to the
frequency of carbon change out, in addition
to disposal of any backwash solids generated.
System monitoring would also be required.
The estimated present worth of this alternative
is $6.30 million.
-------
29
Alternative 5. Groundwater Treatment by Air Stripping
followed by Aqueous-Phase GAC Polishing for
Non-Strippable Compound Removal
Alternative 5 does not reduce inherent compound
toxicity, but rather transfers a majority of
the organics load to the atmosphere concentrating
the remaining organics onto GAC. Consequently,
the volume of contaminated air is increased,
although to a lesser extent than that projected
for Alternative 1. Upon thermal regeneration
of the carbon, those organics adsorbed on the
carbon would be destroyed. Because Alternative
5 employs GAC only for polishing, the volume
of organics destroyed in carbon regeneration,
and the overall toxicity reduction achieved,
would be less than that for Alternative 4. Non-
strippable compounds would generally be
removed in this process. This alternative is
not sufficiently protective of human health^
and the environment. '
Alternative 6. Groundwater Treatment by Air Stripping in
conjunction with Thermal Oxidation, followed
by Aqueous-Phase GAC Polishing
Alternative 6 is in compliance with both air
and water risk-based standards. This alternative
does significantly reduce inherent compound
toxicity and volume, although to a slightly
lesser extent than Alternative 2. This is
because the reduced removal efficiency of the
smaller stripping system proposed will increase
the proportion of volatile organics in addition
to non-strippable compounds sent to the polishing
system, and will reduce the amount of organics
routed to the thermal oxidation system for
emissions control. Upon thermal regeneration
of the GAC, however, the volume and toxicity
of the adsorbed compounds would be virtually
eliminated. Non-strippable compounds would
generally be removed in this treatment alternative
The estimated present worth of this alternative
is $5.99 million.
Alternative 7. Groundwater Treatment by Air Stripping in
conjunction with Vapor Phase Carbon, followed
by Aqueous-Phase GAC Polishing
Alternative 7 is in compliance with both air
and water risk-based standards. This alternative
does not by itself significantly reduce inherent
-------
30
compound toxicity and volume, rather, volatile
compounds would generally be transferred via
the stripper off-gas onto the vapor-phase
carbon, while non-strippable compound would
be adsorbed onto the liquid-phase carbon.
Upon steam regeneration of the VPC, offsite
incineration of the resultant organic phase
condensate, and off-site thermal regeneration
of GAG, and occasionally VPCr compound toxicity
and volume would be significantly reduced.
Non-strippable compounds would generally be
removed in this treatment process. The estimated
present worth of this alternative is $6.91
million.
Alternative 8. Groundwater Treatment by Air Stripping
followed by UV/Peroxidation Polishing for Non-
Strippable Compound Removal
Alternative 8 is expected to exceed the
acceptable standards for air. This alternative
provides a reduction in compound toxicity and
volume proportional to the concentration of
constituents oxidized in the polishing process.
Since the majority of volatile organics would
be removed by air stripping, which does not
reduce inherent compound toxicity, only a
small overall decrease in compound toxicity
would be realized. The inherent volume of
contaminants would only be reduced by that
proportion being chemically oxidized. Non-
strippable compounds would generally be
removed in this treatment alternative. This
alternative is not sufficiently protective of
human health and the environment.
Alternative 9. Groundwater Treatment by Air Stripping in
fr
conjunction with Thermal Oxidation followed
by UV/Peroxidation Polishing
Alternative 9 is in compliance with both air
and water risk-based standards. This alternative
would significantly reduce both compound
toxicity and volume via oxidation of stripped.
Non-strippable compounds would generally be
removed in this treatment option. The present
estimate worth of this alternative is $6.19
million.
-------
31
Alternative 13. Groundwater Treatment by Air Stripping in
conjunction with Vapor-Phase Carbon followed by
UV/Peroxidation Polishing
Alternative 10 is in compliance with both air
and water risk-based standards. This alternative
would in itself provide a reduction in compound
toxicity and volume proportional to the concentrati
of constituents oxidized in the polishing
step. Since the majority of volatile organics
would be removed by air stripping onto vapor-
phase carbon, which does not destroy compound
toxicity, only a small overall decrease in
compound toxicity would be effected. The
volume of contaminated groundwater be greatly
reduced, although the inherent volume of
contaminants would only be reduced by that
fraction being chemically oxidized. Upon
steam regeneration of the VPC and off-site
thermal treatment of the desorbed crganic phase
condensate or thermal regeneration of spent *
VPC, a sizeable reduction in compound toxicity
and volume would be achieved. Non-strippable
compounds would generally be removed in this
treatment process. The estimated present
worth of this alternative is $7.11 million.
Alternative 11. Steam Stripping and Vapor-Phase Carbon
Adsorption on Condensor Vent Stack
Alternative 11 achieves the ARARs; protects
health and safety during long-term operation;
eliminates mobility by separating the organic
compounds from the water, concentrate the
organic compounds into a phase product, and
either recycles the organic compounds, or
destroy them by incineration; has a track
record of proven performance; presents virt-
ually no risk of remedy replacement; and has
relatively low operation and maintenance
requirements. The estimated present worth of
this alternative is S5.57 million.
Alternative 12. Steam Stripping and Vapor-Phase Carbon
Adsorption on Condensor Vent Stack and Liquid
Phase Carbon Adsorption for Unstrippable
Organic Compounds
Alternative 12 achieves the ARARs; protects
health and safety during long-term operation;
eliminates mobility by separating the organic
compounds from the water, concentrates the
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32
organic compounds into a phase product and
either recycle the organic compounds, or
destroy them by incineration; has a track
record of proven performance; presents
virtually no risk of remedy replacement; and
has relatively low operation and maintenance
requirements. The estimated present worth of
this alternative is $5.89 million.
B. No Remediation Alternative - Operable Unit 2 through 5
1. Operable Unit 2 - Hillside Area
The total volume of contaiminated soil in the Hillside
Area is minimal, with depth to bedrock usually being one or two
feet and with exposed bedrock present in much of the area.
Compounds detected in the former lagoons were detected at trace
levels in several of the samples collected in this are. This
indicates that overland flow and/or shallow groundwater discharge
from the fractured bedrock outcrop in this area occurred during^
operation of the Lagoons. Contaminant levels would decrease over
time in this area by leaching of the soils from precipitation
passing into the interceptor trench of the seep water collection
and treatment system, and most importantly by the vacuum extraction
source control being implemented at the on-site operable unit.
2. Operable Unit 3 - Railroad Area
The Railroad Area consist of a switching yard presently
in active use. A wide variety of organic and inorganic compounds
was found throughout this area, both associated with the former
lagoon areas and with materials used for the railroad ballast,
railroad construction, and transport of materials by the railroad.
However, levels of contaminants found were below CPA's recommended
risk threshold and are therefore not required to be remediated.
Further, attempts to remediate this area could cause unacceptable
disruption of freight transport operations.
3. Operable Unit 4 - Floodplain/Wetlands Area
Trace level of site-related contaminants were detected
in the ditches and drainageways receiving runoff from the site.
PAHs, which are not site related, are generally found at the
highest concentrations of all organic compounds detected and with
the greatest distribution. The source of the PAHs is most probably
the coal fines which have been washed downriver and deposited on
the floodplain. No adverse effects on any organisms investigated
during the biological studies could be attributed to site-related
constituents as levels of contaminants were found below EPA's
recommended risk threshold. Because the floodplain is characterized
as wetlands over much of its area, the levels of contaminants in
the floodplain do not justify the extent of wetlands destruction
that would necessarily be caused by remedial action.
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TABLE 3-2
EFFLUENT LIMITS BASED ON ARARS
TYSON'S SITE GROUND WATER TREATMENT
Compound
Treated GW Effluent
Concentration
ImnaJ Recovery
jmoA)
Treated GW Effluent
Concentration
Complete Recovery
[mg/U
Treated Air Effluent
(ib/hr)
Volatllea
1 2.3-TncMoropropane
Methylene ohlonde
Acetone
t.i-OieMoroe thane
i.2-0iehioroethene (total)
Chloroform
1.2-Dichloropropane
cis- 1 ,3-Ochloropropene
Tnchloroethene
Benzene
4- Me thy l-2-pentanone
Tetrachloroeftene
Toluene
Chlorobenzene
Eihylbenzene
Total Xytena*
Semlvolalllee
Aniline
Phenol
1 ,3-Dichlorobenzene
1 ,4-Oichlarobenzene
1 ,2-Oichlorobenxene
Nitrobenzene
Benzote aad
1 .2.4-Trichlorobenzene
Naphftalene
Oi-n-butyl phftatete
Creiol
2.4-dimeftylphtnei
N-nivosodiphenylamine
6 OOE-01 (1)
388E-01
1 7SE.02
6 48E.01
4 87E»00
1 06E-01 (3)
858E-01
7a5E*00(3)
1 50E*00 (3)
3.67E-01 (3)
2 09£»01
4 4SE-01 (3)
796Et03(3)
2.78E*01 (3)
779E-01 (3)
S.OOE-01 (1)
t OOE-01 (1)
300E-02(1)
1.10E*04 (3)
9.7SE»00
4 87E»01
3.89E»01
3 93E-01
6 OOE-01 (1)
2 24E-01
1 01E»02
3 74£»01
23lE»00
6 It E-02 (3)
4 95E-01
4 53E*00 (3)
8 68E-01 (3)
2.12E-01 (3)
1 20E*01
2 57E-01 (3)
4 60E*03 (3)
1 61E*01 (3)
4 50E-01 (3)
S OOE-01 (1)
1 OOE-01 (1)
300E-02(1)
637£»03(3)
5 62E»00
281E*01
2.24E»01
2 27E-01
6 78E-01 (2)
886E*01
408E*00
1 08E-01 (2)
1 22E-01 (2)
5 20E-02
215E+00(2)
3 50E-01 (2)
1 26E»00
4 82E+00 (2)
4 43E»01
1 68E-01
2 95E«00
1 18E»01
N/A
N/A
N/A
N/A
N/A
N/A
N/A • Not applicable, ttm* eampeund* era net eomtfered ttfepable
( 1 ) Effluent KIT* provided by PAOER ton Tette 3-1
(2) Effluent tin* hated en ATOa ton Table 9>1
(3}Efflua*lR*biBa^onWa*aMiiyCntori«to
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33
4. Operable Unit 5 - Seep Area
The origin of the seep remains unknown, but is
probably related to shallow groundwater flow in this area; the
seep has not recurred since initial restoration of the area.
Eleven of the sixteen samples taken from this area had no
detectable Hazardous Substance List (HSL) organic compounds.
The highest single concentration of HSL organics detected consisted
of non-siterelated PAHs. None of the constituents found in the
seep area exceeded the soil cleanup levels set in the Partial
Consent decree. Consequently, remedial efforts in this area
could not be justified.
X. Selected Remedial Alternatives
A. Description and Performance Goals
Section 121 of SARA and the current version of the
National contingency Plan (NCP) (50 Fed. Reg. 47912, November
20, 1985) establish a variety of requirements pertaining to
remedial actions under CERCLA. Applying the current evaluation^
criteria in Tables 3-5, 3-6, 3-7, and 3-8 to the twelve remedial
alternatives for groundwater remediation of the bedrock aquifer,
we recommend that the following treatment technologies be imple-
mented for the selection of the pump and treat alternative.
Operable Unit 1 - Bedrock Aquifer
The selected technology is alternative number 3 with an
option to upgrade to alternative number 7. Alternative number 3
includes groundwater treatment by air stripping, with vapor-phase
carbon (VPC) for gaseous emissions treatment.. If, during the
design phase it is determined that GAG polishing of the stripped
water is needed, alternative number 7, which is identical to
number 3 plus GAG polishing, would be implemented.
Operable Units £ through £
The alternatives for Operable Unit 2-5 are selected based an
the discussion in sections VII and IX. Contaminants found at
Operable Units 2, 3, and 4 are below detectable levels and afford
adequate protection to the public. Furthermore, contaminants
found at Operable Units 2 and 5 will still be collected and diverted
to the groundwater treatment system. Any attempts to remediate
Operable Units 3 (Railroad area) could cause unacceptable disruptions
to the freight rail line. Any attempts to remediate Operable
Unit 4 (Floodplain/Wetlands Area) would destroy large portions of
that environment, causing more harm than good. Accordingly,
remediation of the areas discussed above is not required.
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34
B. Statement of Findings Regarding Wetlands and Floodplain
Management
All excavation and fill activities during the remedial
action shall be conducted in a manner consistent with provisions
of Appendix A of 40 CFR Part 6. The subject regulations have
been entitled "Statement of Procedures on Floodplain Management
and Wetland Protection." These procedures constitute policy and
guidance for carrying out provisions of Executive Order 11990
respectively.
The Remedial Design of the Remedial Action shall be
developed in a manner consistent with Appendix A or 40 CFR Part 6
to assure that potential harm and adverse effects to the wetlands
is minimized. The Remedial Design has not yet been initiated at
this time. Therefore, specific steps to minimize impacts have
not yet been identified. In addition, the effect of the Remedial
Action on the wetlands cannot accurately be assessed at this time.
While all remedial measures shall be designed to minimize
harm to wetlands, it is possible that some adverse effects may be
unavoidable. Should remedial activity be expected to create such
effects, restorative measures shall be developed during the
Remedial Design. Should anticipated adverse effects occur,
restorative measures shall be implemented as part of the
Remedial Action.
Schedule
The anticipated schedule is to commence the remedial
action by October 1988.
XI. The Statutory Determinations
A. Protection of Human Health and the Environment
The selected remedy will reduce the amount of
contaminants discharging into the Schuylkill River to acceptable
levels which will ensure adequate protection of human health and
the environment. No unacceptable short-term risks or cross-media
impact will, be caused by implementation of the remedy.
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35
B. Attainment of ARARs
The selected remedy will attain the applicable or
relevant and appropriate requirements and are as follows:
Federal
CWA - Wetlands Impact
- Diffetential Groundwater Policy
- Ambient Water Quaility Criteria
Executive Order 11988, - Action to avoid adverse effects,
Protection of Floodplains minimize potential harm, restore
40 CFR 6, Appendix A and preserve natural and a
beneficial value
State - Ambient Air Quality Guidelines
for Air Toxic Substances (ATGs)
C. Cost-effective
The selected remedy for groundwater remediation of
Operable Unit 1 - Bedrock Aquifer provides overall effectiveness
commensurate to its costs such that it represents a reasonable
value for the money.
D. Utilization of permanent solutions employing alternative
technologies to the maximum extent practicable.
The selected remedy is the most appropriate solution for
all Operable Units 1 and represents the maximum extent to which
permanent solutions and treatment can be practicably utilized.
E. Preference for treatment as a principal element
The preference is satisfied since treatment of the
principal threats were found to be practicable.
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APPENDIX A
RESPONSIVENESS SUMMARY
FOR THE
OFF-SITE AREA
AT THE
TYSON'S DUMP SUPERFUND SITE
UPPER MERION TOWNSHIP, PENNSYLVANIA
SEPTEMBER 28, 1988
Prepared for:
U.S. Environmental Protection Agency
Region III
Prepared by:
Booz, Allen Hamilton, Inc.
Under Subcontract Number TESK-TEAM-013, WA Number 1017
With CDM Federal Programs Corporation
THIS DOCUMENT HAS NOT YET BEEN SUBJECT TO CDM FPC
QUALITY ASSURANCE REVIEW; DO NOT QUOTE OR CITE.
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RESPONSIVENESS SUMMARY
FOR THE
OFF-SITE AREA
AT THE
TYSON'S DUMP SUPERFUND SITE
UPPER MERION TOWNSHIP, PENNSYLVANIA
TABLE OF CONTENTS
PAGE
NUMBER
INTRODUCTION 1
I. SITE DESCRIPTION AND HISTORY 2
II. COMMUNITY RELATIONS BACKGROUND 3
III. COMMUNITY INTERESTS 4
A. Comments on the Proposed Remedy 4
B. Remaining Concerns 4
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RESPONSIVENESS SUMMARY
FOR THE
OFF-SITE AREA
AT THE
TYSON'S DUMP SUPERFUND SITE
UPPER MERION TOWNSHIP, PENNSYLVANIA
INTRODUCTION
In accordance with the U.S. Environmental Protection Agency's
(EPA) Community Relations policy and guidance, the EPA Region III
Office held a public comment period to obtain consents on the
recommendations of the Remedial Investigation/Feasibility Study
(RI/FS) prepared for the Off-site Area at Tyson's Dump Superfund
site. The opportunity for a public meeting was provided, but no
interest was expressed in having one. The public comment period
ran from September 4, 1988 to September 26, 1988.
The following responsiveness summary was prepared by Booz,
Allen £ Hamilton Inc., a subcontractor to COM Federal Programs
Corporation, under contract to Region III to provide community
relations support. The first section of this document provides a
brief description and history of the site, and the second section
summarizes the community relations activities that have recently
taken place at the site. The final section. Community Interests,
summarizes the level of concern within the site community.
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I. SITE DESCRIPTION AND HISTORY
TysoniB Dump Superfund site is located in a densely populated
region 15 miles northwest of Philadelphia in Upper Merion Township,
Montgomery County, Pennsylvania. The four-acre site is bordered by
the Conrail Railroad switching yard to the north, an old quarry
highwall to the south, and the Valley Brook housing development to
the west. The Schuylkill River is located approximately 750 feet
north-northeast of the dump, and several small tributaries flow
into the river near the site. Downstream of the dump, the river is
used as a municipal and industrial water source that supplies a
number of communities.
The site is an abandoned septic and chemical waste disposal
site within a sandstone quarry that operated from 1962 to 1970
under the ownership of Frank Tyson and his company, Fast Pollution
Treatment, Inc. Several formerly unlined lagoons, or ponds,
located in the central and southern areas of the site, were used to
store various industrial, municipal, and chemical wastes. The dump
was also used for the disposal of liquid septic tank wastes and
sludges. The dump site is predominantly contaminated by a
suspected carcinogen, or cancer-causing agent, known as 1,2,3 -
trichloropropane. In addition, spills and overflows occurred
during the eight years of operation, resulting in the dispersal of
wastes throughout the site. EPA implemented emergency measures in
early 1983 and, in September 1983, the site was placed on the
National Priorities List (NPL), EPA's list of hazardous waste sites
that are eligible for Federal cleanup funds.
Between January 1983 and August 1984, EPA and its contractors
conducted a Remedial Investigation/Feasibility Study (RI/FS) in
what is now referred to as the On-Site Area. The On-Site Area is
defined as that area south of the railroad tracks and within or
immediately adjacent to the security fence erected during the 1983
emergency response measures. The purpose of the RI/FS was to
determine the type and extent of contamination at the site, to
establish criteria for cleaning up the site, to identify and screen
cleanup alternatives for remedial action, and to analyze the
technology and costs of the alternatives. Results of the On-Site
RI/FSr along with recommendations by the Pennsylvania Department of
Environmental Resources (DZR), local officials, and citizens were
used by EPA in its decision of a remedial alternative for the
on-site portion of the site.
EPA signed.the Record of Decision (ROD) for the On-Site Area on
December 31, 19t«, but later reopened the ROD to consider an
innovative soil technology that was not evaluated during the
RI/FS. The ROD is a public document that explains which cleanup
alternatives will be used at a NPL site. In 1986, Ciba-Geigy
Corporation, one of the responsible parties for the site, conducted
an independent study to explore alternate methods of cleanup. This
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study revealed that a new remedial technology, called vacuum
extraction, would be the most effective remedial alternative.
Based on these findings, EPA recommended vacuum extraction as the
remedy for cleaning up the on-site portion of Tyson's Dump, and
this alternative was well received by the Upper Merion Township
community. The revised ROD was signed by EPA on March 31, 1988.
In the Fall of 1985, Ciba-Geigy Corporation agreed to conduct a
further investigation of the Off-Site Area, the need for which was
recommended in the December 1984 EPA ROD. The Off-Site Area is
defined as that area outside of the security fence including the
deep aquifer, an underground rock formation composed of materials
such as sand, soil, or gravel that can store and supply ground
water to wells and springs. EPA subdivided the Off-Site Area into
five sub-areas or "operable units," to allow studies and subsequent
cleanup actions to focus on distinct areas of the overall site.
The Off-Site Operable Units include the following:
Deep Aquifer (Operable Unit 1)
Hillside Area (Operable Unit 2)
Railroad Area (Operable Unit 3)
Floodplain/Wetlands (Operable Unit 4)
Seep Area (Operable Unit 5).
On May 27, 1986, an Administrative Consent Order (AGO) was signed
between EPA and Ciba-Geigy Corporation for the Off-Site Operable
Unit RZ/FS. The RZ/FS was completed at the end of August 1988 and,
based on the findings of the study, EPA proposed a remedy for the
Off-site Area. The study and EPA's proposed remedy were made
available for public review from September 4, 1988 to September 26,
1988.
ZZ. COMMUNITY RELATIONS BACKGROUND
Zn meeting its public outreach responsibilities under the
Superfund program, community relations activities at the Tyson's
Dump Superfund site have been ongoing. Zn August and September of
1988, a revised Community Relations Plan (CRP), a Fact Sheet
summarizing the Off-Site Remedial Znvestigation/Feasibility Study
(RZ/FS), and a Proposed Plan'for the Off-Site Area were prepared.
A Public Notice listing the off-site cleanup alternatives and EPA's
preferred alternative was printed in the Korrietovn Times Herald on
September 4, 1989. Announcement of the public comment period also
was made in th* Public Notice. The opportunity for a public
meeting was provided, but the residents expressed no interest in
having one. The public comment period ran from September 4, 1988
to September 26, 1988.
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III. COMMUNITY INTERESTS
No community interest has been expressed in the Off-Site Area
at the Tyson's Dump Superfund site.
A. Comments on the Proposed Remedy
No written or oral comments were received from local residents
or officials during the public comment period. One comment was
received from one of the potentially responsible parties (PRPs),
Ciba-Geigy Corporation. This comment and EPA's response are listed
below.
COMMENT: since the submittal of the off-site Feasibility Study
(FS), Ciba-Geigy has continued to review potential treatment
methods for groundwater at the Tyson's Dump site. Based on this
review, Ciga-Geigy has determined that:
. Alternative 3 (Air Stripping With Vapor Phase Carbon) is
safer and possibly similar in cost to Alternative 2 (Thermal
oxidation)
. Alternative 3 is capable of meeting Applicable or Relevant
and Appropriate Regulations (ARARs),
Ciba-Geigy has also added two alternatives to the summary of
alternatives: steam stripping With vapor Phase Carbon, and Steam
Stripping With Vapor Phase Carbon And Liquid Phase Carbon.
EPA'S RESPONSE.! After careful evaluation of the above comment and
the Feasibility Study, EPA has selected a combination of treatment
alternatives which differs from those in the proposed remedial
action plan. EPA's selected alternatives consist of air stripping
and steam stripping of groundwater with different methods of
further treating the air emissions and water effluent. These
methods will be determined during the Remedial Design phase of site
response.
B. Remaining Concerns
Since actual cleanup preparations began at the On-Site Area
last May, the community has not voiced any concerns about the
on-site or off-«ite portion of the site.
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