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

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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

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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

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                            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.

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  Figure 1-1
Location Map
 Tyson's Site
           N.E. Exttrwion
            P«nn, Tump**

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     - 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

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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.

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                              Figure 4-3
                     (Fracture Trace Locations!
                                                           EXPLANATION

                                                           Fracture Trace Location

                                                           well Nest Location

                                                           Single Well Completions
 0	  250     500

Scale in Feet (Appro*.)

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              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

-------
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

-------
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

-------
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
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CMarohMm

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SEM-VOUTfcES
BBh^flM^
rmnui
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2 MMIiylMpMlMlMic
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Clm««nt
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B«io
-------
                                               TABLE 4-11 (MMtalMl)
                                                   Tvsom sire
                                            HtlSDE AREA SOL RESULTS
                                             •ttWMMC CONSTITUENTS
SMiptoNMntar M 68 01 7
AnitowM
Mumkium
AlSMk
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-------
                            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

-------
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                                 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
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SC-000*
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 fOLATILIi
 .2.3-T(lenioroprop«i«
                               0063S
                               0131
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lim.VOLATILlt
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 O.MI
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0.1 M
0.27B
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OOtt
0.0071
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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
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  «"*«"                       >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
                                                                   M.TERNAINE EFFEClnCNESS SCREENING
                                                                                              JUhmiM6
                                                                                                                            Minuwt t      ttiMinit »     AtemilM to
                                   VM
                                                 VM
                                                                 V«
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                                    Hi


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                                                                 M>


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                                                                                                                                             VM
                     VM

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VM

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                                VMM"* I)
                 VM
VM

VM


VM
VM

VM
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YM

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                VM
                                               VM             VM
                                         VM(IMMWJIMUIMI VM
                              v«
                              Son

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                                                                                                               Uuali
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                                                                                                             M xgntetm      OM uyrfcan      MM •gnbun
 QMOMMMt
                                                          •HMCM:
                                                                          •McfcnpanM
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                                                                                                                 I Uongi
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                                                                                          ••MGACctanMoulMt spenl G«C cluiHje
                                                                         UVbmpcMn^
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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

-------
                                 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.

-------
                                      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

-------
                                 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.

-------
                                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.

-------
                                 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.

-------
                       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.

-------
                        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

-------
                        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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