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UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY

REGION III

RECORD OF DECISION

OPERABLE UNIT ONE - RESIDENTIAL PORTION
OPERABLE UNIT TWO - FACILITY PORTION

PRICE BATTERY SUPERFUND SITE

Berks County, Pennsylvania

September 2015

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Table of Contents

List of Acronyms	.	iii

I.	THE DECLARATION				 1

A.	Site Name and Location			1

B.	Statement of Basis and Purpose			1

C.	Assessment of the Site						1

D.	Description of the Selected Remedy..				1

E.	Statutory Determination...					4

F.	ROD Data Certification Checklist	5

G.	Authorizing Signature...	5

II.	DECISION SUMMARY							6

A.	SITE NAME, LOCATION, AND DESCRIPTION				6

B.	SITE HISTORY AND ENFORCEMENT ACTIVITIES..			6

1.	History of Activities that Led to Contamination	6

2.	History of Previous Environmental Investigations and Removal Actions	8

3.	History of Enforcement Activities							11

C.	HIGHLIGHTS OF COMMUNITY PARTICIPATION	12

D.	SCOPE AND ROLE OF OPERABLE UNIT......			13

E.	SITE CHARACTERISTICS			14

1.	Overview of the Site	14

2.	Operable Unit One (OU-1) - Residential Portion			14

3.	Operable Unit Two (OU-2) - Facility Portion					16

4.	Conceptual Site Model							23

F.	CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES.... 23

G.	SUMMARY OF SITE RISKS					.:			24

1.	What is Risk and How is it Calculated?	25

2.	Calculating Risks from Exposure to Lead			26

3.	Summary of Site-Related Risks for OU-2			26

4.	Estimated Cancer and Non-Cancer Risks					1	28

5.	Ecological Risks					31

6.	Basis for Action				34

H.	REMEDIAL ACTION OBJECTIVES				35

1.	Determination of Risk-Based Concentration for Lead			36

2.	Determination of Risk-Based Concentrations for Arsenic and Antimony	. 37

3.	Principal Threat Wastes in Soils.							37

4.	Contaminants of Concern in Sediment				38

I.	SUMMARY OF REMEDIAL ACTION ALTERNATIVES	38

1.	Suiiimary of Major ARARS.							39

2.	Remedial Alternatives for OU-2			40

J. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES			47

K. PRINCIPAL THREAT WASTES							55

L. SELECTED REMEDY			,			55

1.	Summary of the Rationale for the Selected Remedy		55

2.	Description of the Selected Remedy and Performance Standards...	56

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3.	Cost Estimate for the OU-2 Selected Remedy	59

4.	Expected Outcome of the OU-2 Selected Remecsfy.....		59

M. STATUTORY DETERMINATIONS			60

1.	Protection of Human Health and the Environment	60

2.	Compliance with Applicable or Relevant and Appropriate Requirements	60

3.	Cost Effectiveness						. 61

4.	Utilization of Permanent Solutions and Alternative Trejatment Technologies

to the Maximum Extent Practicable					61

5.	Five Year Review Requirements			61

6.	Documentation of Significant Changes					62

7.	State Role								62

III.THE RESPONSIVENESS SUMMARY									 63

APPENDIX A: ADMINSITRATTVE RECORD INDEX

APPENDIX B: FIGURES	1

APPENDIX C: CONCEPTUAL SITE MODEL and RISK TABLES

APPENDIX D: ARARS TABLES

APPENDIX E: ESTIMATED COST TABLES

APPENDIX F: PADEP CONCURRENCE LETTER

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ACRONYMS AND ABBREVIATIONS

ALM

Adult Blood Lead Methodology

AOC

Administrative Order on Consent

ARAR

Applicable or Relevant and Appropriate Requirement

ATSDR

Agency for Toxic Substances and Disease Registry

BD

Business Development

bgs

below ground surface

BHHRA

Baseline Human Health Risk Assessment

BLL

Blood Lead Level

BTAG

Biological Technical Assistance Group

BTEX

Benzene, Toluene, Ethylbenzene, and Xylene

BW

Bedrock Well

CAMU

Corrective Action Management Unit

CDC

Centers for Disease Control and Prevention

CERCLA

Comprehensive Environmental Response, Compensation, and Liability Act

CFR

Code of Federal Regulations

COC

Contaminant of Concern

COPEC

Contaminant of Potential Ecological Concern

CSM

Conceptual Site Model

cy

cubic yard

EPA

U.S. Environmental Protection Agency

EPC

Exposure Point Concentration

HI

Hazard Index

HQ

Hazard Quotient

IC

Institutional Control

IEUBK

Integrated Exposure Uptake Biokinetic

KC-SED

Kaercher Creek Sediment

LBP

Lead-Based Paint

Mn

Manganese

MCL

Maximum Contaminant Level

MP

.MainParcel v

MW

Monitoring Well

NA

Not Applicable

NCP

National Oil and Hazardous Substances Contingency Plan

NEIC

National Enforcement Investigation Center

NOAA

National Oceanic and Atmospheric Administration

NPL

National Priorities List

O&M

Operations & Maintenance

OU

Operable Unit

PADEP

Pennsylvania Department of Environmental Protection

PADOH

Pennsylvania Department of Health

PAH

Polynuclear Aromatic Hydrocarbon

PCB

Polychlorinated Biphenyl

PRG

Preliminary Remediation Goal

PTW

Principal Threat Waste ,

ppni

part per million

PRP

Potentially Responsible Party

RAL

Remedial Action Level

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RAO

Remedial Action Objective

RBC

Risk-Based Concentration

RCRA

Resource Conservation and Recovery Act

RI/FS

Remedial Investigation and Feasibility Study

ROD

Record of Decision

RSLs

Regional Screening Levels

SARA

Superfund Amendments and Reauthorization Act

SLERA

Screening Level Ecological Risk Assessment

SVOC

Semivolatile Organic Compound

TAL

Target Analyte List

TBC

To-be-Considered

TCLP

Toxicity Characteristic Leaching Procedure

TEC

Threshold Effects Concentration

TPH

Total Petroleum Hydrocarbon

UET

Upper Effects Threshold

Hg/dl

micrograms/deciliter

Hg/ft2

micrograms/square foot

Hg/1

micrograms/liter

UST

Underground Storage Tank

VC

Village Center

VOC

Volatile Organic Compound

WH

Warehouse

XRF

X-Ray Fluorescence

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I. THE DECLARATION

A.	Site Name and Location

The Price Battery Superfund Site (Site) is located in the Borough of Hamburg, Berks County,
Pennsylvania. The Site includes the former Price Battery manufacturing facility, adjacent
residential areas, and other areas within and near Hamburg, Pennsylvania. The historical
operation of the Price Battery manufacturing facility and secondary lead smelter resulted in
contamination of soil and sediment with antimony, arsenic, and lead. The National Superfund
Database Identification Number is PAN000305679.

B.	Statement of Basis and Purpose

In this Record of Decision (ROD) EPA has selected the final remedy for Operable Unit One
(OU-1), Residential Portion, and Operable Unit Two (OU-2), Facility Portion, of the Site
(Selected Remedy). The Selected Remedy for OU-1 and OU-2 was selected in accordance with
the requirements of the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), 42 U.S.C. § 9601 et seq.. as amended, and to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R. Part 300,
as amended.

This ROD is based on the Administrative Record for the Site, which has been developed in
accordance with Section 113(k) of CERCLA, 42 U.S.C. § 9613(k). This Administrative Record
File is available for review online at http://www.epa.gov/arweb, at the U.S. Environmental
Protection Agency (EPA) Region III Records Center in Philadelphia, Pennsylvania, and at the
Hamburg Public Library in Hamburg, Pennsylvania. The Administrative Record Index
(Appendix A) identifies each document contained in the Administrative Record upioh which the
Selected Remedy for OU-1 and OU-2 is based.

The Commonwealth of Pennsylvania has concurred with the Selected Remedy.

C.	Assessment of the Site

The response action selected in this ROD is necessary to protect the public health or welfare or
the environment from actual or threatened releases of hazardous substances into the
environment.

D.	Description of the Selected Remedy

The Selected Remedy for OU-1 is No Further Action. The remedial actions selected in the
September 30,2009, Interim ROD have been completed. EPA completed cleanup of the
Residential Portion of the Price Battery Site in October 2013. As the comprehensive remedial
investigation (RI) for OU-1 progressed, EPA identified additional residential properties for
cleanup, and EPA incorporated these properties into the residential remedial action that was
ongoing pursuant to the September 2009 Interim ROD for OU-1. EPA has completed the
residential cleanup at all eligible properties for whose owners provided access. There are no

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known additional residential properties (for which owners provided access) requiring cleanup.
The September 2009 Interim ROD also provided for institutional controls and ongoing public
education regarding lead exposure risks. Therefore, because no additional cleanup measures are
necessary, EPA's Selected Remedy for OU-1 is No Further Action, and to establish the OU-1
interim remedy as the final remedy for the Price Battery Site OU-1, Residential Portion.

The Selected Remedy for OU-2, Facility Portion, is a combination of Alternative S-4A,
Alternative SD-3, and No Action with Monitoring for ground water. The Selected Remedy is
excavation of Principal Threat Waste (PTW) leadrcontaminated soils and soils exceeding the
Remedial Action Level (RAL) cleanup levels for lead calculated specifically for the Facility
Portion of the Price Battery Site. Contaminated soil will be excavated to required cleanup levels,
stabilized (on-site or off-site), and disposed of in an approved off-site disposal facility. The
resulting excavations will be backfilled with reclaimed concrete and/or imported clean soils and
graded for potential future commercial/industrial redevelopment of the properties.

Contaminated sediment in Kaercher Creek, on the Facility property, will be removed and the
current gabion mattress liner system will be reinforced to further stabilize the gabion mattress
liner system. Underground pipes currently containing contaminated sediment beneath the
Facility will be cleaned out and grouted closed to prevent any additional contamination from
entering Kaercher Creek.

The Selected Remedy for OU-2 includes the following major components:

I.

Soil	,

1.	Removal of concrete pavement, floor slabs, and foundations overlying the RAL and PTW
contaminated soils. The concrete pavement, floor slabs, and foundations will be
segregated, cleaned to remove residual contamination (based on visual observations)
pursuant to the requirements of the Resource Conservation and Recovery Act (RCRA),
crushed, and stockpiled. Crushed material will be analyzed for inorganic constituents and
the results compared against the Pennsylvania Department of Environmental Protection
(PADEP) Statewide Health Standards for non-residential soils (direct contact) prior to
reuse as backfill.

2.	Excavation of soils from the Main Parcel and the Warehouse Parcel that exceed the
lowest calculated RAL (8,669 parts per million [ppm]) for lead-in-soil, including PTW
soils, except to the extent that contaminated soil cannot be removed because of field
conditions (i.e., physical constraints, proximity of building foundations, maintaining safe
excavation slopes, encountering ground water, etc.).

3.	Excavated soils shall be sampled and analyzed using the Toxicity Characteristic Leaching
Procedure (TCLP) to determine the appropriate off-site disposal facility. Soils which
exceed the TCLP criteria may be stabilized on-site to render the soil non-hazardous or
transported to an off-site RCRA-permitted facility for appropriate treatment and disposal.

If stabilization is conducted on-site, the soil shall be mixed with a reagent (i.e. trisodium
phosphate or other reagents) to render it non-hazardous. Confirmation sampling shall be

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conducted on the stabilized soils to ensure the soil is non-hazardous prior to off-site
disposal.

4.	Post-excavation confirmation sampling of excavation floor and sidewalls to ensure RAL
levels have been achieved. Recalculate the exposure point concentration (EPC) utilizing
confirmation sample results collected after excavation.

5.	Backfill of resulting excavations with reclaimed crushed concrete and clean fill material
to levels at or near existing grades except as coordinated with Site redevelopment
activities. Any crushed material used for backfilling will be overlain by imported clean
fill. Reclaimed crushed concrete must meet backfill concentrations identified in the "•
Baseline Human Health Risk Assessment (BHHRA) for lead (<50 ppm), arsenic (< 100
ppm),, and antimony (< 46 ppm). If reclaimed concrete exceeds 50 ppm lead (but is
below the PADEP Statewide Health Standards for non-residential soils for direct contact
of 1,000 ppm lead), the RAL must be recalculated utilizing the actual concentration for
the proportion of backfilling completed using recycled concrete and additional soil
remediation performed as appropriate to achieve the desired risk-based concentration
(RBC). Clean soil must meet Pennsylvania Criteria for Management of Fill, or the
backfill concentrations identified in the BHHRA, whichever is more stringent.

6.	Restore Site surfaces using concrete, asphalt, buildings, and landscaping in a manner
consistent with plans for Site redevelopment and suitable for preventing.erosion of soils
above residential remediation standards and as specified'by erosion and sediment control
requirements.

7.	Implement institutional controls (ICs) to ensure that the remedy provides an adequate
measure of protection in light of current and anticipated commercial/industrial future use
of the Site. Such additional institutional controls will include notification to future
property owners that contaminated soils remain in-place and that special handling of
these soils would be required if these soils are disturbed during redevelopment
construction activities. No residential use of the properties will be permitted. ICs will
include activity and use restrictions enacted through proprietary (e.g., easements,
covenants) and/or governmental (e.g., zoning requirements) controls to prevent use of the
property that will pose an unacceptable risk to receptors. TTie exact type of IC
implemented will be determined by EPA in consultation with PADEP and local
government agencies. The restrictions in the current Declaration of Use and Deed
Restriction will be incorporated into any new institutional controls.

Sediment

1. Remove accumulated sediment from the gabion mattress, to the extent possible, using a
vacuum truck or equivalent. Remove sediment from underground pipes and penetrations
including, but not limited to, Pipes 1,2, and 3. Grout any underground" pipes, as
necessary, to further prevent contaminated sediment within any pipes from entering
Kaercher Creek.

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2.	Dispose of accumulated sediment off-site or use as backfill in on-site soil excavation
areas if coordinated with soil remediation and sediment meets the same requirements for
other soils under Alternative S-4A, above.

3.	Grout gabion mattress to ensure long-term stability of the Creek bed.

4.	Perform annual inspections to confirm that the gabion mattress and channel walls remain
stable, and remove accumulated trash and debris to maintain the hydraulic capacity of the
channel.

5.	Implement ICs to prohibit removal of the gabion mattress or excavation of soils within or
along the Creek in conjunction with the IC requirements of Alternative S-4A.

Ground Water

No active cleanup measures will be taken for ground water at the Site.

1.	Install new monitoring wells to the current monitoring well network after soil remediation
is implemented. Redevelop or replace monitoring well BW-3 to address turbidity
problems within the monitoring well.

2.	Conduct quarterly ground water sampling. After eight consecutive quarters of
monitoring, conduct a statistical evaluation to determine contaminant concentration
trends and continue statistical analysis annually. Reevaluate need for continued
monitoring at five-year intervals.

The estimated cost of the Selected Remedy is $3,222,823.

E. Statutory Determination

The Selected Remedy for OU-1 and OU-2 is protective of human health and the environment;
complies with all Federal and State requirements that are legally applicable or relevant and
appropriate to the remedial action; is cost-effective; and utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable.

This remedy also satisfies the statutory preference for treatment as a principal element of the
remedy, because the remedy reduces the toxicity, mobility, or Volume of hazardous substances,
pollutants, or contaminants, as a principal element through treatment.

The final remedy for OU-1. will result in hazardous substances, pollutants, or contaminants
remaining within OU-i above levels that allowunlimited use and unrestricted access for those
residential properties which declined participation in the cleanup or where cleanup performance
standards could not be achieved. The final selected remedy for OU-2 will result in hazardous
substances, pollutants, or contaminants remaining within the Facility properties above levels that
allow unlimited use and unrestricted access. Therefore, an assessment of the Site will be
conducted no less often than every five years after initiation of the original interim remedial

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action in accordance with Section 121(c) of CERCLA, 42 U.S.C. § 9621(c), to ensure that the
remedy is, and will be, protective of human health and the environment.

F.	ROD Data Certification Checklist

The following information is included in the Decision Summary (Part II) of this ROD, while
additional information can be found in the Administrative Record File for the Site:

•	Contaminants of concern (COCs) and their respective concentrations;

•	Baseline risk represented by the COCs;

•	Cleanup levels established for COCs and the basis for these levels;

•	How source materials constituting principal threats are addressed;

•	Current and reasonably anticipated future land use assumptions and current and potential
future beneficial uses of ground water used in the baseline risk assessment and ROD;

•	Potential land and ground water use that will be available at the Site as a result of the
Selected Remedy;

•	Estimated capital, annual operation and maintenance (O&M), and total present worth costs,
discount rate, and the number of years over which the remedy cost estimates are projected;
and

•	Key factors that led to selecting the remedy.

G.	Authorizing Signature

'	1	\

This ROD documents the Selected Remedy for OU-1 and OU-2 at the Price Battery Site and is
based on the Administrative Record for the Site. EPA selected this remedy with the concurrence
of PADEP. The Director of the Hazardous Sites Cleanup Division for EPA Region III has
approved and signed this ROD.

Q Qjrx*

Cecil Rodrigdes, Direi
Hazardous Site Cleanup Division
EPA Region III


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II.

DECISION SUMMARY

A.	SITE NAME, LOCATION, AND DESCRIPTION

The Price Battery Superfund Site is located approximately 20 miles north of the City of Reading,
in the central to southern portion of the Borough of Hamburg, Berks County, Pennsylvania
(Figure 1). The Borough of Hamburg is located at the foot of the Blue Mountains, along the
Schuylkill River, just south of Schuylkill County. The Price Battery Superfund Site includes the
former Price Battery manufacturing facility, adjacent residiential areas, and other areas within and
near Hamburg, Pennsylvania that were contaminated with antimony, arsenic, and lead. The Site
is within a mixed commercial/iridustrial/residential area: which is approximately 1.2 square miles
in size. The commercial/industrial land makes up the minority of the area. The Price Battery
facility is zoned industrial, and the residential properties are located north, northwest, northeast,
east, southeast, and south of the former facility.Hie land use in the immediate area outside of the
Price Battery Site is mostly residential or agricultural. Commercial properties make up the
minority of the adjacent property area. The geographic coordinates of the approximate center of
the Site are 40.550 degrees north latitude and 75.98 degrees west longitude.

The former Price Battery facility is located at 246 and 251 Grand Street in the Borough of
Hamburg. Kaercher Creek flows through the Borough of Hamburg and through the former Price
Battery facility before joining the Schuylkill River located to the southwest of Hamburg. The
former Price Battery facility and its related properties cover approximately nine acres of land in
the Borough. These properties include the following: Warehouse Parcel, Broom Works Parcel,
Main Parcel, and Parking Lot (Figure 2).

The United States Environmental Protection Agency (EPA) is the lead agency and has identified
the Site as CERCLA ID# PAN000305679. The Pennsylvania Department of Environmental
Protection (PADEP) is the support agency. The cleanup of the residential properties at the Price
Battery Site was funded from the Superfund Trust under the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980, as amended (CERCLA). Exide
Technologies, Inc. (Exide) signed an agreement with EPA in 2007 to conduct a comprehensive )
investigation and develop potential cleanup alternatives for OU-2 (Facility Portion) of the Site.
Exide prepared the Remedial Investigation/Feasibility Study (RI/FS) for OU-2 and provided
technical assistance to EPA throughout the process.

B.	SITE HISTORY AND ENFORCEMENT ACTIVITIES

The "Proposed Rule" proposing the Site to the National Priorities List (NPL) was published in
the Federal Register on September 23,2004. The "Final Rule" adding the Site to the NPL was
published in the Federal Register on April 27,2005.

1. History of Activities that Led to Contamination

Price Battery Corporation (Price Battery) was founded in 1918 and has occupied at least a
portion of its current location since its inception. The Price Battery facility is currently not in
operation. The Facility formerly consisted of three large manufacturing buildings (east building,

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west building, and the oxide department), including a secondary lead smelter [Main Parcel]; a
one-quarter-acre lot located between Peach Alley and Third Street [Parking Lot]; a one-acre plot
of land located between Walnut and Pine Streets [Broom Works Parcel]; and a large warehouse
and parking lot located on a parcel to the west of Second Street [Warehouse Parcel]. The
secondary lead smelter ceased operation in 1971. The majority of the buildings, except the
warehouse building, were demolished in 2007 and 2008. Since the demolition of the buildings
on the Main Parcel, the Main Parcel is currently covered with the former building floors and
foundations, concrete, and bituminous pavement. A chain link fence encompasses the entire
boundary of the Main Parcel. All four parcels are shown in Figure 2.

The former east building contained a battery storage room, a warehouse room, a loading dock,
north and central dry formation rooms, a plate drying room, a plate storage room, a lead oxide
pasting area, a battery assembly area, a grid-casting room, and a laboratory. Interior walls had
been degraded by acid corrosion and damaged by heavy equipment in several areas. Several 55-
gallon drums, sumps, and trenches containing various materials were formerly located in this
building. The former west building consisted of a warehouse room, a loading dock, a wet
formation area, a finishing room, and an enveloping room. Drums were formerly located in the
enveloping area and the wet formation area. Trenches were located in the wet formation area and
the finishing room.

The Warehouse Parcel is situated on an approximate 3.12-acre parcel of land west of Second
Street and consists of a 30,000-square-foot steel-frame warehouse constructed in the early 1980s
and a parking lot which still remain on the property. The warehouse is the only building on the
Exide-owned properties. The parking lot area, which lies south of the warehouse, is covered
primarily with asphalt and partially by gravel. Historical maps indicate that portions of this area
were once the boat basin of the Hamburg section of the Schuylkill Navigation Canal. Aside
from the storage of products and materials for the manufacturing operations, which occurred on
the Main Parcel, no other activities are known to have been performed at the Warehouse Parcel.
The warehouse was used, for document and equipment storage, and a nearby business had been
granted permission to utilize the paved areas in front of the building for temporary staging of
equipment.

The Broom Works Parcel is a 90-foot wide former right of way of the Pennsylvania Railroad
Company (later known as the Penn Central Railroad). There is no information that indicates that
this parcel was ever used in conjunction with Site manufacturing operations. Historical deed
book information indicates that the railroad was constructed in the mid- to late 1880s.

The Parking Lot Parcel1, located between Peach Alley and Third Street, is currently paved and
used by nearby residents. A review of historical aerial photographs indicates that this parcel was
vacant in 1937 and 1971, and no indications of industrial operations are visible on this parcel.

From the 1940s to approximately February 1956, Price Battery owned and operated the lead
battery recycling and manufacturing facility located at 246 and 251 Grand Street in Hamburg,

1 The Borough of Hamburg, Pennsylvania, acquired the Parking Lot Parcel from Exide on December 18,2013.
EPA understands that the Borough of Hamburg will be using the property as additional public parking.

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Pennsylvania. As part of the battery recycling process, Price Battery also owned and operated a
secondary lead smelter at the Facility. The Facility recycled lead-acid batteries and also produced
approximately 15,000 new batteries per year. New batteries from the Price Battery facility were
delivered to customers, and junk batteries were brought back to the Price Battery facility for
recycling. Employees at the Price Battery facility split open the used batteries at the smelter at
the Facility and reused the lead plates from the junk batteries in the smelter. Price Battery reused
only the lead plates from the batteries. The rest of the battery was considered to be waste and
was stored in a dump truck. The waste consisted of asphalt, hard rubber, and plastic casing that
may have been contaminated with lead. The bottom of the junk battery casings normally
contained a lead residue that had settled to the bottom of the battery casing during the battery's
lifetime. This residue resulted from the lead oxide and acid that had been placed in the battery as
it was being manufactured. When the dump truck was full of waste battery casings, Price Battery
employees drove the truck to Various locations in and around Hamburg to dump the waste
battery casings. Waste battery casings were also made available for people to pick up from the
Facility for use as fill,

Noxious odors and acid fumes were reportedly emitted from the Price Battery facility. In 1941, a
citizens' group contacted the Borough of Hamburg with concerns about the Facility's operations.
The group's legal counsel indicated that smoke stacks on the Facility emitted lead-contaminated
ash produced during the melting of old batteries.

From the 1940s until approximately 1961, Price Battery contracted with Blue Mountain Coal
Company (Biue Mountain) to compact battery casing waste after it was dumped in and around
Hamburg and to remove slag from the Price Battery facility. The slag was left over from the lead
smelting operations at the Facility. Blue Mountain dumped the slag at the locations in Hamburg
where Price Battery had dumped the battery casings. Beginning in the early 1960s, Price Battery
entered into an agreement with Brown's Battery (Brown's) to send junk batteries that were
returned from Price Battery's customers to the Brown's breaking facility located in
Shoemakersville, Pennsylvania. Brown's broke open the junk batteries and removed the lead
plates for return to the smelter at the Price Battery facility, where the lead plates were reused.

In 1956, General Battery Corporation (General Battery) acquired the Facility from Price Battery.
General Battery continued Price Battery's battery-making operations at the Facility, making the
same products and using the same equipment until 1971, when General Battery closed its smelter
operation. In 1987, General Battery merged into Exide Technologies Inc. (Exide). Exide has
been held as a corporate successor-in-interest to General Battery Corporation. Exide ceased
manufacturing at the Site in 1995.

2. History of Previous Environmental Investigations and Removal Actions

Exide Removal Actions

EPA conducted removal assessment activities at the Price Battery facility from July through
October 2002. The assessment included multi-media sampling, test pit excavations, monitoring
well installation, and x-ray fluorescence (XRF) analysis. Based on EPA sampling results, the
Price Battery facility was found to be heavily contaminated with lead, arsenic, and antimony. On

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June 23,2003, pursuant to Section 106 of CERCLA, EPA entered into an Administrative Order
on Consent (AOC) with Exide to perform a removal action (Removal AOC) at the Price Battery
facility including restricting access to the Price Battery facility and mitigating the threat due to
the presence of hazardous substances, among other things. Under the Removal AOC, Exide
capped soils on the Broom Works Parcel, paved previously unpaved areas on the Warehouse
Parcel, capped sediments in Kaercher Creek on the Main Parcel, and removed waste materials
from the Facility including from within any sumps or trenches. A more detailed description is
provided below:

- 1	i	.

Broom Works Parcel Capping: Pursuant to the Removal AOC, Exide was required to mitigate
the threat of direct exposure to lead contamination greater than 1,000 parts per million (ppm)
within any fenced area. Since surface soils on the Broom Works Parcel contained total lead
concentrations as high as 120,000 ppm, the Broom Works Parcel soils were capped, and the
parcel was fenced. The cap consisted of a non-woven geotextile installed over a smoothly
graded and compacted soil subgrade and covered by 8 inches of crushed stone.

Kaercher Creek Sediment Capping: Exide capped sediments in Kaercher Creek within the
property boundary of the Main Parcel. Total lead concentrations detected in the sediments
ranged from 4,867 ppm to 24,090 ppm. The cap consisted of approximately 6,500 square feet of
6-inch thick gabion mattresses grouted in place to ensure stability.

Main Parcel Building Cleanout: This process included the pumping and removal of liquid and
solid residual waste materials from the Facility sumps, pits, and trenches. After removal of the
residual waste materials, the sumps, pits, and trenches were cleaned until their surfaces were
visually absent of waste, dirt, or sediment. The areas were subsequently backfilled with stone
and capped with 4 to 6 inches of concrete. Liquid and solid wastes were transported off-site for
disposal.

Institutional Controls: A Declaration of Use ahd Deed Restriction (Deed Restriction) was
placed on all of the Exide-owned parcels in 2004 as required by the November 12, 2002
Removal Action Memorandum and the Removal AOC. Among other things, the Deed
Restriction prohibited use of the Exide properties for residential, recreational, schools; day care
facilities, or other uses which could potentially expose children to contamination.

Building Decontamination and Demolition: Although not a specific requirement of the Removal
AOC, Exide had the existing buildings on the Main Parcel decontaminated and demolished to
grade in the summer and fall of 2007. The decontamination and demolition activities consisted
of steam cleaning/pressure washing all remaining equipment ahd structural components to
remove visual contamination pursuant to the requirements of the Resource Conservation and
Recovery Act (RCRA) "Debris Rule" codified at 40 C.F.R. §268.45. Following
decontamination, the buildings were demolished, and the demolition debris was segregated for
off-site disposal or recycling, as appropriate. The remaining floor slabs and paved surfaces of
the Main Parcel were swept and pressure washed.

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EPA Removal Actions

A separate EPA removal action began on May 12, 2003, to address residential properties
contaminated with lead in the vicinity of the former Price Battery facility. From May 2003
through Octbber 2004, this removal action entailed the excavation of residential soils
contaminated with lead above 400 ppm from residential yards and the decontamination of
residential interiors. An action level for lead dust on floors of 40 micrograms per square foot
(lig/fit2) was used for interior decontamination consistent with EPA regulations for lead-based
paint abatement. In the absence of a site-specific cleanup level for lead-in-soil at the
commencement of the removal actions, EPA conservatively used the 400 ppm screening level for
lead-in-soil at residential properties as the cleanup level in order to start work as quickly as
possible Until a residential site-specific lead-in-soil cleanup level was determined for the Price
Battery Site, Residential Portion.

During the course of EPA's 2004 removal activities, EPA collected additional information in
order to develop a risk assessment and calculate a residential site-specific cleanup level for lead-
in-soil that would be protective of children who might be exposed to lead contamination in the
soils. This site-specific risk assessment ultimately eistablished a residential cleanup level for
lead-in-soil of 572 ppm, as well as 15 ppm for arsenic and 31 ppm for antimony. The correlation
between lead and arsenic or lead and antimony was sufficiently strong that any remediation
which addressed lead contamination in soil and interior dust would also address unacceptable
concentrations of arsenic and antimony in soil. Therefore, EPA only used the lead-in-soil action
level of 572 ppm as its basis for determining if the cleanup goals had been achieved.

Beginning in April 2005, the removal action entailed the excavation of lead-contaminated soils
above 572 ppm for lead to "clean" soil (lead soil levels below 572 ppm), unless physical barriers
such as tree roots, foundations, etc., prohibited excavation of soils to "clean". In such cases
where all lead-contaminated soil above 572 ppm could not be removed, a visual hairier (i.e.,
orange construction fencing) was placed to indicate the remaining soils potentially contained
lead above 572 ppm. The removal action was completed on September 30,2010, and thereafter,
EPA utilized its remedial authority, pursuant to the 2009 Interim ROD for OU-1, for the
remediation of the remaining residential properties.

Remedial Response

EPA divided the Price Battery Superfund Site into three operable units (OUs). OU-1 addresses
lead-contaminated-residential soils and interiors within and near the Borough of Hamburg; OU-2
addresses the Facility Portions of the Price Battery Site (i.e., the Exide owned properties); and
OU-3 is a site-wide ecological assessment. These OUs and actions taken are further discussed
below.

Operable Unit One (OU-1) - Residential Portion

Beginning in 2005, and concurrent with the ongoing residential removal actions described above,
EPA also initiated a RI/FS for OU-1 to determine the full nature and extent of residential
contamination at the Site, to characterize the risks to human health and the environment, and to

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evaluate alternatives to cleanup the residential contamination. The initial findings of the RI/FS
are presented in an Interim Remedial Investigation Report for OU-1 (February 2009) and Interim
Feasibility Study Report (May 2009) and are documented in an Interim ROD for OU-1, dated
September 30,2009.

The selected remedy in the Interim ROD entailed residential exterior soil excavation and
specialized interior cleaning to remove lead-contaminated soils and dust at impacted residential
properties, consistent with the ongoing EPA removal action at the time. The Interim ROD
authorized work to be performed under remedial authority, instead of removal authority, and
enabled EPA to continue to address immediate Site risks while additional work was performed to
determine the full nature and extent of residential contamination at the Site. The cleanup of
residential properties was completed by EPA in October 2013. The Final Comprehensive RI
Report detailing the full nature and extent of the residential contamination and documenting
EPA's sampling and cleanup efforts was finalized in February 2014. Cleanup at all known
contaminated residential properties, whose owners provided access to EPA for cleanup, has been
completed. EPA demobilized from the Site in October 2013 after the completion of the
residential cleanup.

Operable Unit Two (OU-2) - Facility Portion

OU-2 addresses all Exide-owned properties within the Borough of Hamburg, including ground
water below the properties, which includes the Main Parcel, Warehouse Parcel, Broom Works
Parcel, and Parking Lot. On May 30,2007, EPA entered into an RI/FS AOC with Exide to
perform the OU-2 RI/FS. Exide made the determination to demolish the buildings on the Main
Parcel. Pursuant to the AOC, Exide was to initiate the RI/FS after demolition activities were
completed. Exide began demolition activities in June 2007 and completed demolition and debris
disposal in early 2008. Exide began the RI/FS fieldwork pursuant to the May 30,2007 RI/FS
AOC in September 2008. The RI was completed in February 2011, followed by the FS in
September 2013.

Operable Unit Three (OU-3) - Ecological Assessment

OU-3 addresses potential ecological risks associated with former operation of the Price Battery
facility with the focus being the investigation of Mill Creek, Kaercher Creek, the Schuylkill
River, and an assessment of any remaining pbtential ecological risk in residential areas. EPA is
currently performing the OU-3 RI; OU-3 will be the subject of a separate Proposed Plan and
ROD when the RI/FS is completed.

3. History of Enforcement Activities

EPA has identified Exide as a potentially responsible party (PRP) at this Site. Exide filed for
bankruptcy in 2002, and EPA filed a proof of claim in that bankruptcy for several sites, including
the Price Battery Site. Given the nature of the bankruptcy proceeding, EPA did not seek to have
Exide conduct the cleanup on residential properties addressed by the 2009 Interim ROD (i.e.,
properties that are not owned by Exide). However, Exide and EPA executed an AOC on May
30,2007, under Section 104 of CERCLA, for Exide to perform a RI/FS (RI/FS AOC) of all

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Exide-owned properties. Exide filed for bankruptcy again in 2013, and EPA has filed a
subsequent claim against Exide to, among other things, ensure Exide completes its cleanup
obligation at the Exide-owned properties.

C. HIGHLIGHTS OF COMMUNITY PARTICIPATION

EPA has been performing outreach to the citizens of Hamburg, Borough of Hamburg officials,
health officials, the media, non-profit groups, and others since becoming involved at the Site in
2002 in an effort to convey information about the hazards of lead exposure and particularly how
lead affects the health of children. EPA has participated in numerous formal and informal
meetings to explain EPA's role and commitment in Hamburg, convey information about the
Superfund process, and provide general information about the Site and lead contamination,
including non-Site-related lead paint hazards. EPA has participated in local events such as
Hamburg Community Days and Safety Day by setting up booths or information stands regarding
lead hazards. EPA has also participated with the Pennsylvania Department of Health (PADOH)
in child blood lead screenings in Hamburg arid discussions with local pediatricians' offices
regarding lead contamination within the Borough. EPA also responded to inquiries on a daily
basis regarding the Site and individual homeowners' sampling results and personally met with
every resident or tenant who had been scheduled for a residential cleanup. EPA also maintained
full-time community relations support for approximately 10 years on-site during the residential
cleanup.

On July 15,2015, pursuant to section 113(k)(2)(B) of CERCLA, 42 U.S.C. §113(k)(2)(B), EPA
released for public comment the Proposed Remedial Action Plan (Proposed Plan) setting forth
EPA's proposed remedial decision for OU-1 and preferred remedial alternatives for OU-2 of the
Site. The Proposed Plan was based on documents contained in the Administrative Record File.
EPA made these documents available to the public in the EPA Administrative Record Room in
EPA Region Ill's office located at 1650 Arch Street in Philadelphia, Pennsylvania, and at the
local information repository at the Hamburg Public Library located at 35 North Third Street in
Hamburg, Pennsylvania. A notice of availability of these documents was published in the
Hamburg Item on July 15,2015. EPA opened a 30-day public comment period on July 15,2015,
to receive comments on EPA's proposed remedial decision and preferred alternatives and the
other alternatives identified in the Proposed Plan. Comments received during this public
comment period, as well as EPA's response to such comments, are summarized in the
Responsiveness Summary section of this ROD. EPA and PADEP also held a public meeting on
July 30,2015 at the Hamburg Borough Building located at 61 North Third Street in Hamburg. A
detailed discussion of the recent community activities is presented in Section J under the
subheading Community Acceptance.

More detailed documentation on the information contained in this ROD may be found in the
Administrative Record which contains the Remedial Investigation (RI) for OU-2, the Feasibility
Study (FS) for OU-2, the Final Comprehensive RI for OU-1, and other information used by EPA
in the decision making process. EPA encourages the public to review the Administrative Record
in order to gain a more comprehensive understanding of the Site and the activities that have been
and will be conducted there. The Administrative Record can be viewed at the Hamburg Public
Library located at 35 North Third Street in Hamburg, Pennsylvania and is also available at the

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EPA Region III Office located at 1650 Arch Street in Philadelphia, Pennsylvania. To review the
Administrative Record at EPA's Philadelphia office, contact Mr. Paul Van Reed, Administrative
Record Coordinator, at (215) 814-3157. The Administrative Record can also be accessed on the
web at www.epa. gov/arweb. Copies of this ROD are available for public review in these
information repositories.

EPA will continue to work with the community in an effort to provide enhanced communication
and education on lead prevention through outreach, public availability sessions, attendance at
local gatherings, and mailings.

D. SCOPE AND ROLE OF OPERABLE UNIT

EPA's initial response actions for lead-contaminated residential properties at the Price Battery
Site commenced in 2003 under CERCLA removal authority. As EPA was conducting the soil
and interior residential cleanup under CERCLA removal authority, it also began planning for
continued response under CERCLA remedial authority. EPA organized the remedial response
into three operable units:

•	Operable Unit One (OU-1):	Residential Portion

•	Operable Unit Two (OU-2):	Facility Portion (Exide-owned properties)

•	Operable Unit Three (OU-3): Ecological Assessment

On September 30,2009, an Interim ROD was issued for OU-1 for the cleanup of residential
exteriors and interiors consistent with previous removal actions. The 2009 Interim ROD
converted the ongoing residential cleanup at the time from removal authority to remedial
authority, As EPA continued to delineate the full nature and extent of the residential
contamination, newly identified residential properties were included in the ongoing remedial
action. EPA completed the cleanup of the last residential property, whose owner provided access
to EPA for cleanup, in September 2013, and EPA subsequently demobilized from the Site in
October 2013. Human health risks at these residential properties were addressed pursuant to the
Interim ROD. Therefore, because all known contamination exceeding cleanup criteria at
contaminated residential properties (whose owners provided access) has been addressed, EPA's
final Selected Remedy for OU-1 is No Further Action and to establish the OU-1 interim remedy
as the final remedy for the Price Batteiy Site, OU-1 in this ROD.

OU-2 addresses all Exide-owned properties within the Borough of Hamburg, including ground
water below the properties, which includes the Main Parcel (Facility property), Warehouse
Parcel, Broom Works Parcel, and Parking Lot. Contaminated soils and sediments pose a
potential risk, because EPA's acceptable risk range is exceeded and contaminant concentrations
in soil and sediment are above levels protective of human health and the environment under both
residential and commercial risk scenarios. This ROD presents the final remedy for OU-2 at this
Site and addresses a principal threat at the Site through the removal and treatment of lead-
contaminated soils and sediment. Ground water contamination at the Site, however, has been
found not to be related to battery manufacturing operations and, therefore, will not be addressed

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by this decision. The final remedy for ground water for OU-2 at this Site is No Action with
Monitoring.

OU-3 addresses potential ecological risks associated with former operation of the Price Battery
facility with the focus being the investigation of Mill Creek, Kaercher Creek, the Schuylkill
River, and an assessment of any remaining potential ecological risk in residential areas. EPA is
currently performing the OU-3 RI; OU-3 will be the subject of a separate Proposed Plan and
ROD when the RI/FS is completed.

E. SITE CHARACTERISTICS

This section of the ROD describes the Conceptual Site Model and provides an overview of the
Site's characteristics, the sampling strategy used during the Site investigations, and the nature
and extent of contamination for OU-2. Additional information regarding the nature and extent of
contamination can be found in the Administrative Record.

1.	Overview of the Site

< ' . "

The Price Battery Site is located within a mixed commercial/industrial/residential area which is
approximately 1.2 square miles in size and includes the former Price Battery manufacturing:
facility, adjacent residential areas, and other areas within and near Hamburg, Pennsylvania that
were contaminated with antimony, arsenic, and lead. The commercial/industrial land makes up
the minority of the area. The Price Battery facility is zoned industrial, and the residential
properties are located north, northwest, northeast, east, southeast, and south of the former
Facility. The land use in the immediate area outside of the Price Battery Site is mostly residential
or agricultural.

The former Price Battery facility itself, including all Exide-owned properties, covers
approximately nine acres of land in the Borough. The Exide-owned properties (Facility Portion)
include the following: Warehouse Parcel, Broom Works Parcel, Main Parcel, and Parking Lot.
The majority of these parcels are covered with an impermeable surface, including asphalt and
concrete, except for the Broom Works parcel which is covered with eight inches of crushed
stone.

Kaercher Creek flows through the former Price Battery facility, and Mill Creek flows north of
the facility before joining the Schuylkill River southwest of Hamburg. Public water is provided
by the Borough of Hamburg from municipal supply wells located outside of the Borough in
Windsor Township.

2.	Operable Unit One (OU-1) - Residential Portion

The primary objectives of the OU-1 RI were to determine the extent of residential lead
contamination due to lead battery manufacturing and smelting activities at the former Price
Battery facility. Subsequent to the completion of the interim RI/FS in 2009, the aerial extent of
the Residential Portion of the Site was expanded and additional residential sampling was
conducted to define the full extent of residential contamination. It became clear during the
interim RI/FS that contamination extended beyond the original estimated boundaries of the Site.

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The interim approach was used to convert the ongoing cleanup from removal authority to
remedial authority as quickly as possible while additional sampling continued to further define
the boundaries. Ultimately, the fixll aerial extent of contamination from deposition of lead dust
from the former Price Battery facility encompassed an approximate 1.2-square mile area
comprised of the following locations (Figure 3):

•	A large area east of the Schuylkill River, bounded by Girard Avenue, Mulberry Alley,
and Port Clinton Avenue to the north; Front Street, PA Route 61, and the Schuylkill
River to the west; Hawk Ridge Drive to the south; and Kaercher Creek Park and some
properties east of the Hamburg Borough in Windsor Township to the west;

•	A small eastern area, along Windsor Castle Road; and

•	An area west of the Schuylkill River primarily along West State Street and Diamond
Drive in Tilden Township.

EPA believes these areas represent the full extent of aerial lead deposition from the Price Battery
facility operations. Because EPA suspected that the source of lead contamination in the outer
fringes of this area may not be attributable to deposition of air-borne particulates from the former
smelter (based on previous air modeling conducted during the Interim RI), alternate source
contributions to the lead contamination in these fringe areas were investigated in two additional
studies. These studies included a lead-based paint (LBP) assessment of residential homes and a
lead speciatibn study performed by EPA's National Enforcement Investigation Center (NEIC).
The results of the LBP assessment and the NEIC lead speciation study are included in the
Administrative Record for the Site.

The general conclusion of these studies was that properties in the northernmost and westernmost
fringe areas of the OU-1 portion of the Site were impacted, at least partially, by air-borne
deposition of lead particulates. NEIC determined that potentially between 16 percent and 33
percent of the lead in the northernmost properties was likely from the battery smelter emissions.
EPA determined that, although this contribution was small, as a conservative approach, these
properties would nonetheless be eligible for remedial action. However, based on these results,
EPA did not expand its investigation any further beyond these properties. EPA believes the
lateral extent of lead in surface soil primarily due to smelter operations has been determined.

In total 6,467 surface soil samples were collected from 1,145 properties, 449 subsurface soil
samples were collected from 160 properties, and 4,934 interior dust samples were collected from
500 houses during the OU-1 RI. EPA has completed significant cleanup of lead-contaminated
soil and interior dust at residential properties within the Borough of Hamburg and adjacent areas
utilizing both removal and remedial cleanup authorities. As of September 12,2013, EPA had
conducted cleanups at 555 residential property exteriors. This is 92 percent of all known
contaminated residential properties where lead concentrations were above the lead preliminary
remediation goal (PRG) of 572 ppm in residential soil. Similarly, EPA had conducted removal
and remedial actions that cleaned the interiors at 402 residential properties. This is 81 percent of
the homes identified as having lead-contaminated indoor dust above the hazard level of 40 (ig/ft2
for lead dust on floors. The remaining properties with lead contamination were not made

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accessible to EPA. No additional properties are scheduled for cleanup. EPA completed the
remedial action for OU-1 in October 2013.

3. Operable Unit Two (OU-2) - Facility Portion

Exide conducted the OU-2 RI/FS for the Exide-owned portions of the Price Battery Superfund
Site. The OU-2 RI was conducted in two phases (Phase I and Phase II) and consisted of
multimedia sampling including soils, sediments, and ground water. A Baseline Human Health
Risk Assessment (BHHRA) and a Screening Level Ecological Risk Assessment (SLERA) were
also completed as part of the OU-2 RI/FS. A summary of the findings of these investigations is
provided below.

a) OU-2 Geology and Site Soils

The bedrock in the area of the Price Battery Site consists of the Ordivician Hamburg Sequence
formation, which consists predominately of gray, greenish-gray, purple, and maroon shale,
siltstone, and greywacke. The shallow soils beneath the majority of the Main Parcel and all of
the Broom Works Parcel and Parking Lot are "made land" consisting of soils derived from
miscellaneous shales and sandstone materials. The western edge of the Main Parcel and the
Warehouse Parcel is underlain by the Philo Silt, which is associated with the floodplain deposits
of the Schuylkill River. Previous Site investigations have identified additional types of fill
containing cinders and ash believed to be derived from coal-fired furnaces and steam engines,
cinders and stone fill placed by the railroad as ballast within tlie railroad right-of-way, and zones
of fill containing varying amounts of battery casings and slag.

Soil samples from on-site soil borings were collected on each of the four Exide-owried properties
and analyzed for lead, arsenic, and antimony with a subset of the soil samples also analyzed for
the full target analyte list (TAL) metals, volatile organic compounds (VOCs), semivolatile
organic compounds (SVOCs), total petroleum hydrocarbons (TPH), and polychlorinated
biphenyls (PCBs). In general, soil borings were completed to a depth of 12 feet below ground
surface (bgs) or 4 feet below the native soil/fill interface, whichever was deeper; and samples
were collected from various depths within that range. Soil boring logs and geologic cross-
sections may be found in Appendix A and Plate 2, respectively, of the February 2011 RI Report.
Table 1 summarizes the occurrence of the most commonly detected contaminants in the fill
during the OU-2 RI.

Table 1: Soil Contaminant Detections











S8Sfppri»)S

Antimony

Main

109/106

0.18

14,300

335.5

Arsenic

Main

109/109

1.9 .

4.530

53.1

Lead

Main

109/109

9.8

125;000

7,435

PAHs*»

Main

8/12

0.09

189.4

16.2

—W—B

I





• HkMSI

—g

Antimony

Warehouse

30/30

0.13

447

88.3

Arsenic

Warehouse

30/30

2.6

68

14.5

Lead

Warehouse

30/30

26.5

32,000

6,892

PAHs»»

Warehouse

5/5

0.78

. *9.50 -

5.25







-	®	-

:	K	¦

16

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Hieh (dddi)

Mean (ppm)

Antimony

Broom Works

23/23

0.7

119

i5;o

Arsenic

Broom Works

23/23

1.2

26.4

11.4

Lead

Broom Works

23/23

14.1

2,280

524.8

PAHs**

Broom Works

3/3

2.29

10.9

6.00

: Antimony

Parking Lot

13/13

0.95

10.2

2.90

Arsenic

Parking Lot

13/13

3.6

80.2

25.5

Lead

• Parking Lot

13/13

11.9

1,210

258.6

PAHs**

Parking Lot

3/3

0.64

21.1

11.8

PAHs = Polycyclic Aromatic Hydrocarbons
** Sum of individual PAH concentrations detected

Consistent with previous investigations, soil borings encountered a layer of fill material
immediately beneath the pavement of the floor slabs of the Main Parcel. The thickness of the fill
material encountered on the Main Parcel during the OU-2 RI varied from 1.5 to 7.5 feet. Native
soils encountered beneath the fill were comprised of a gray to brown silt with varying amounts of
clay and/or sand and, generally, did not exhibit impacts from historic Site operations, although
some specific impacts were noted.

In general, analytical results for shallow fill that post-dates commencement of manufacturing
operations at the Price Battery facility shows elevated concentrations of lead, arsenic, and
occasionally antimony. The occurrence of lead, antimony, and arsenic at the high concentrations
observed at the Site is linked to the soil fill materials (often containing slag and/or battery
casings), surficial deposits believed to be the result of fugitive dust, and/or the management of
lead-bearing wastes on the ground surface.

Shallow fill that predates manufacturing operations is generally lacking in inorganic constituents
above the residential soil screening levels but did contain elevated concentrations of polycyclic
aromatic hydrocarbons (PAHs). PAHs are a broad range of organic compounds resulting from
the incomplete combustion of fossil fueis, including coal. The PAHs occur in fill material
comprised of cinders and ash believed to be utilized for construction of the railroad bed and
minor filling, and do not appear to be related to past battery manufacturing operations. Coal ash
and cinders are fairly ubiquitous in the area and also were found in multiple residential yards
during the OU-1 residential cleanup. PAHs were found in 100% of the fill samples analyzed for
PAHs on the Broom Works Parcel (a former railroad right-of-way north of the Main Parcel) and
the Parking Lot Parcel (a residential parcel east of the Main Parcel). Neither the Broom Works
Parcel nor Parking Lot Parcel were ever subject to Site manufacturing operations. On the Main
Parcel, there is ho correlation between elevated leaci concentrations in soil and elevated PAH
concentrations in soil.

VOC results identified elevated levels of benzene, toluene, ethylbenzene, and xylene (BTEX
compounds) in the southeast corner of the Main Parcel. These soils occur in the vicinity of a
former gasoline underground storage tank (UST) and will be addressed outside the context of the
CERCLA remedial action contemplated in this ROD. Closure of the UST and remediation of the
BTEX-contaminated soils will be conducted under PADEP authority and requirements.

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b) OU-2 Sediment

Sediment samples from the stream bed of Kaercher Creek were collected from depositional
locations based on field observations and analyzed for lead, arsenic, and antimony. During the
OU-2 Phase IRI, sediment samples were collected from five locations on the Main Parcel and
three locations upstream of the Main Parcel. Four additional upstream sediment samples were
subsequently collected from sediment depositional areas in the general vicinity of the Apple
Alley Bridge during the OU-2 Phase IIRJ (Figure 4). Sediment sampling results are provided in
Table 2 below.

Table 2: Kaercher Creek Sediment Sampling Results



Level*

EPA Freshwater

On-site

"If- 1 : || ^ ?

M

!J On-site

KC-SED-3
aw8J-site

KC-SED-4
On-site

Antimony

31

¦ 2 '

10.5

6.3

4.6

10

Arsenic

15

9.8

3.4

10.6

8.3

5.1

Lead

572

35.8

850

1150

851

1540





©eaikii'i^

KC-SED-5

_

On-site

laesHi

KC-SED-7

lisli!,n

Upswam

Antimony

31

2

5.2

3.6

2.7

1.2

Arsenic

15

9.8

6.5

39.1

7.2

, 4.1

Lead

572,

35.8

1770

401

243

131

1

¦asr

r

Level*

EPA Freshwater
Sediment Screening

Le«l|§}fQ§|

SB ¦ ¦
gp Apple

l§i /.t * \ 'IttPi
g ley (Upstream)

Pfi&p

1

ID

IP!!!

3

JpfflpIP

Antimony

31

2

5.8

1.2

2.7

0.87

2

Arsenic

15

9.8

7.5

5.7

6.7

4.9

4

Lead

572

35.8

545

226

330

175

230

All results in ppm

~OU-1 site-specific soil cleanup levels

On-site - sediment samples collected within Main Parcel

KC-SED - Kaercher Creek Sediment Sampling Location

Sediment sampling results were compared to the OU-1 residential site-specific soil cleanup
levels for potential human health impacts and to the EPA Region III Biological Technical
Assistance Group (BTAG) freshwater sediment screening levels for potential ecological impacts.
The Kaercher Creek sediment sampling identified concentrations of lead and antimony in the
Creek sediment on the Main Parcel above the gabion mattress liner system installed during the
removal action which were found to be typically higher than metals concentrations in sediments
upstream. Lead results from sediment samples collected from upstream of the Main Parcel
revealed lead levels below the OU-1 residential site-specific soil lead cleanup level of 572 ppm
in all upstream samples. Lead results in Kaercher Creek sediment samples collected within the
Main Parcel were above the established OU-1 site-specific residential cleanup value of 572 ppm
with a maximum result of 1,770 ppm of lead. All of the Kaercher Creek sediment samples
(upstream and on the Main Parcel) exceeded the freshwater sediment screening level for lead of
35.8 ppm. No Kaercher Creek sediment samples exceeded the OU-1 residential site-specific soil

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cleanup level for antimony of 31 ppm for residential soil; however, 9 of 12 sediment samples
exceeded the antimony freshwater sediment screening level of 2.0 ppm. One sediment sample
upstream exceeded both the residential site-specific soil cleanup level and freshwater sediment
screening level for arsenic with a concentration of 39.1 ppm. One sediment sample within the
Main Parcel exceeded the freshwater sediment screening level for arsenic with a concentration of
10.6 ppm. All other sediment samples were below both the residential site-specific soil cleanup
level and freshwater sediment screening level for arsenic. Kaercher Creek sediment samples
collected by EPA in 2002, prior to capping of the Kaercher Creek sediments with the gabion
mattress liner system under the 2003 Removal AOC, showed lead levels ranging from 4,867 ppm
to 24,090 ppm.

In addition, an investigation within the covered area of Kaercher Creek (the portion of Kaercher
Creek underlying the Facility foundation) within the Main Parcel was performed to evaluate the
sidewalls of the Creek for pipes and penetrations (other openings). A total of 12 pipes were
identified as part of this investigation, and the sediment in a representative number of those pipes
was sampled (Figure 5). Sampling identified sediment in two pipes with antimony and lead
concentrations an order of magnitude or more greater than the concentrations observed upstream.
The results of sediment sampling in several pipes (identified as Pipes 1, 2, 3, and 12) revealed
lead concentrations exceeding the residential site-specific human health lead cleanup level of 572
ppm'. The highest lead result (26,300 ppm) was recorded in a 12-inch-diameter corrugated metal
pipe (Pipe 3). All seven of the pipe sediment samples collected exceeded freshwater sediment
screening levels for lead. The highest arsenic result (94.4 ppm) and the highest antimony result
(85.2 ppm) were in Pipe 2. Five of the seven samples exceeded the freshwater sediment
screening level for antimony of 2.0 ppm, and two of the seven samples exceeded the freshwater
sediment screening level for arsenic of 9.8 ppm.

Although the amount of Creek bed sediment data is very limited and no evaluations have been
conducted related to stream sedimentology, the information suggests that sediment in the 12-inch
diameter corrugated metal pipe identified as "Pipe 3" may, in particular, be a source of
contaminated sediment containing elevated levels of lead and antimony that discharges to the
Creek. Ultimately the bedload from upstream sediment and the contributions from the pipes may
be contributing to elevated metals concentrations observed in sediment which re-aCcumulated
within the gabion mattress liner system on the Main Parcel. However, the gabion mattress liner
system itself appears to be in good condition and functioning as a cap for the impacted sediment
beneath the gabion mattress liner system addressed during the 2003 removal action. If the
gabion mattress liner system were to be damaged or otherwise breached, the underlying sediment
could become exposed to the erosive forces of the Creek and be transported downstream
constituting a potential release of contaminated materials.

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Table 3: Pipe Sediment Sampling Results

—

¦Pips

Industrial

||ion III

W-fel

Residential*
Soil

1111 II





2

Si

Pipejl

isfif







Antimony

470

31

2

9.9

85.2

53.4

3.8

0.48

2.0

4.4

Arsenic

480

15

9.8

3.8

94.4

10.2

5.7

3.9

7.4

4.6

Lead

800

572

35.8

670

6130

26300

542

116

350

647

All results in ppm

*0U-1 site-specific cleanup levels

c) OU-2 Ground Water

Ground water was sampled from seven overburden and four bedrock monitoring wells on the
Exide-owned properties during the OU-2 RL Monitoring well construction logs arid geologic
cross-sections may be found in Appendix A and Plate 2, respectively, of the February 18,2011
RI Report. Depth to ground water ranged from approximately 4 to 8 feet bgs for the overburden
wells. The potentiometric ground water surface is 1 to 2.5 feet below the Kaercher Creek stream
bed (Figure 6). Therefore, ground water is not discharging into Kaercher Greek. Ground water
flow in both the overburden and the shallow bedrock is generally west-southwest towards the
Schuylkill River which is consistent with regional ground water flow. In addition, a downward
gradient was documented between the overburden and bedrock wells ranging from
approximately 2.2 feet along the east side of the Main Parcel to less than 0.1 feet in the
southwest corner of the Warehouse Parcel.

Lead exceeded the EPA Region III risk-based screening level of 15 micrograms per liter (ng/1)
for lead in tap water (there currently is no maximum contaminant level (MCL) promulgated
pursuant to the Safe Drinking Water Act, and codified at 40 C.F.R. Part 141, for lead) in one
unfiltered sample from bedrock well 3 (BW-3) at a concentration of 57.3 (ig/1. The associated
filtered sample, however, was non-detect for lead (<3.0 jig/l). Unfiltered samples measure the
total concentration of metals in ground water, whereas filtered samples measure the dissolved
metals in ground water. Samples for metals analysis are often filtered to remove suspended
particulate matter in the water sample. Lead has a strong affinity towards soil particles, and in
general, the smaller the soil particle, the greater the affinity. Once adsorbed to a soil particle,
lead is not easily released. The variability between the filtered and unfiltered lead result for BW-
3 is likely a reflection of turbidity (i.e., suspended particulate matter) in the well resulting from
well development difficulties. Arsenic and antimony analytical results did not exceed their
respective MCL in any ground water sample collected during the OU-2 RI, although the arsenic
results in monitoring well 7 (MW-7) were above the tap. water EPA risk-based screening level.

Several PAHs were detected in the ground water sample from MW-2 above their corresponding
MCLs and/or risk-based screening levels for tap water during the second round of ground water
sampling, although they were below detection limits during the first round. PAH impacts in

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MW-2 were not observed in MW-3 situated approximately 90 feet downgradient, suggesting that
the PAH ground water contamination is very isolated in nature. MW-2 is located in the former
railroad right-of-way which extends south from the Broom Works Parcel through the Main
Parcel. As discussed earlier, PAHs appear to be related to "historic" fill containing cinders and
ash that predate Facility operations. The PAHs are believed to be associated with the
construction of the railroad tracks in the mid to late 1880s and localized filling using cinders and
ash from coal fired heaters, and therefore, are not Site-related.

A few VOCs were detected during the OU-2 ground water sampling events, although they were
typically below the reporting limits with the only noteworthy exceptions being BTEX
compounds in nested well pair MW-6 and BW-6, which are an overburden well and bedrock
well, respectively. Benzene was detected in overburden well MW-6 at 67 (j.g/1; although in
bedrock well BW-6, benzene was only detected at 6.0 (j.g/1. The BTEX compounds are
associated with an UST in the southeastern corner of the Main Parcel, and the ground water
impacted by BTEX compounds appears to be limited in extent to the southeastern corner of the
Main Parcel. Exide represents that the UST was a gasoline storage tank; therefore, closure of the
UST is deferred to PADEP authority.

Detailed monitoring well analytical results may be found in the February 18,2011, RI Report
located in the Administrative Record.

The depth of ground water beneath the Site occurs below the bottom of the fill except at the west
end of the Warehouse Parcel and possibly in a portion of the Main Parcel. Therefore, ground
water interaction with the contaminated fill is limited. Furthermore, based on the ground water
sample results, it can be inferred that, even after the many decades the fill material has been in
place, very limited ground water impact has occurred. The contaminants which may be present
in the fill are not prone to dissolution and transport by ground water in contact with the fill
material or surface water infiltrating from the surface through the fill material to ground water.

The potential drinking water aquifer in the vicinity of the Site is the Ordovician sandstone and
siltstone bedrock. The overburden in the vicinity of the Site, and regionally, consists of inter-
fingering, low permeability silts, clays and sand lenses. Under EPA's ground water
classification guidelines, ground water at the Site would be classified as a Class II aquifer. A
Class II aquifer is defined as a current and/or potential source of drinking water and water having
other beneficial uses. Ground water in the overburden unit above bedrock, however, is not used
for supplying drinking water, because bedrock ground water is used as the drinking water source
in that area. . •

The former Facility and the surrounding community are serviced by a public water supply for
potable water, although industrial and manufacturing operations along Route 61 south and west
of the Facility were purported to have private water supply wells. Public water is provided by
the Borough of Hamburg from municipal supply wells located outside of the Borough in
Windsor Township, The Borough of Hamburg requires that users within 150 feet of a public
supply waterline connect to public water. A detailed well search performed as part of the OU-2
RI identified 11 industrial withdraw wells, 3 unused wells, and 1 overburden ground water
monitoring well within 0.5 miles of the intersection of Grand Street and Second Street. The

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search also identified one domestic well 0.46 miles away situated on the north side of State
Street on the west side of the Schuylkill River (Tilderi Township). All of the wells identified
(except the overburden well) have casings that extend through the overburden unit into bedrock;
and the wells extend to depths typically between 200 feet bgs to 500 feet bgs. Water production
occurs within distinct bedrock zones.

In addition to the OU-2 ground water sampling, a limited amount of sampling of private
residential wells was conducted by EPA during the OU-1 RI in areas within the lead depositional
areas, but where public water is not available (i.e., Tilden Township). The ground water results
did not indicate that Site-related metals are impacting residential ground water quality in OU-1
(outside the Exide-owned properties). Concentrations of Site-related metals in the residential
ground water samples were all below MCLs.

d) Biota

An ecological evaluation of the Exide-owned properties of the Site determined that no terrestrial
or aquatic habitat exist on the Warehouse Parcel, Broom Works Parcel, or the Parking Lot
Parcel, as these areas are entirely covered with pavement, crushed stone, and/or buildings.
Therefore, no further evaluation was conducted of the ecological habitat within these parcels.

An initial ecological screening evaluation was also conducted on the Main Parcel. The only
potential ecological habitat identified on the Main Parcel is Kaercher Creek, a perennial stream
which crosses the Main Parcel portion of the Site. Within the boundary of the Main Parcel, the
Creek is approximately 470 feet long and flows through a manmade channel from the northeast
to the south. The enclosure/channel containing the Creek is characterized by vertical structural
walls made of masonry block or concrete and a stream bed lined with gabion mattresses or
concrete. The uppermost 200 feet of the Creek is enclosed/covered by former building floor
slabs which extend across the channel. The depth of the channel is approximately five feet and
averages sixteen feet in width.

The sediment surface area outside the covered portion of the Creek is approximately 2,300
square feet, most of which is covered by vegetation. Only a small area of approximately 900
square feet is available as aquatic substrate in this area. Small mussels, larval fish, minnows, and
crayfish have been observed in this area. Although no other aquatic animals were observed, the
possibility exists that other small transient fish, invertebrates, reptiles, and amphibians may
occasionally be present. However, given its size, highly modified benthic structure (gabion
mattresis liner system), and limited resources (shallow water depth, absence of cover/habitat, lack
of consistent food/prey), it is unlikely that significant resident populations of these animals are
present. Higher order animals that may also transiently inhabit this area include small mammals
and birds. Mammals may include rodents, raccoons, fox, and squirrels. Birds may include
passerines, piscivorous birds (e.g., heron), and an occasional raptor. As noted for other possible
inhabitants in this area, habitat and other resources are too limiting to accommodate resident
populations, and all would be expected to be transient.


-------
4. Conceptual Site Model

A Conceptual Site Model (CSM) was developed to identify which human exposure pathways
were complete or could be potentially complete in the future. A CSM provides a convenient
format to present an overall understanding of a site. A CSM may be developed at the start of a
project and refined and updated throughout the life of the site activities.

The current and likely future use of the Site is commercial/industrial. The Site is zoned for non-
residential land uses, and it has a deed restriction against disturbing the existing cover or using
the property for residential or recreational use or for day cares or schools. Currently the majority
of the Site is paved, covered with buildings or a stone cap, limiting access to Site soils. Future
exposure to soil may occur if the Site is redeveloped or the asphalt/stone cap is removed for
utility maintenance. Therefore, risks from exposure to Site soils were evaluated. Residential soil
risks were assessed by comparison of Site concentrations to the residential regional screening
levels (RSLs) developed during the OU-1 residential cleanup. The results of the screening
analysis show that the residential risks from soil exposures under baseline conditions would be
unacceptable. However, a deed restriction prevents residential development of the Site. Contact
with shallow ground water could occur by future construction workers during construction
activities. Although the, former Facility and surrounding community are served by a public water
supply, hypothetical future residential exposures to ground water were also evaluiated. The CSM
showing potential receptors, exposure media, and exposure pathways is presented in Appendix
C.

F. CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES
Operable Unit 1

The Price Battery OU-1 Site is located in the central to southern portion of the Borough. The Site
is located in a mixed commercial/industrial/residential area approximately 1.2 square miles in
size in the vicinity of the former Price Battery facility. The commercial/industrial land makes up
the minority of the OU-1 area. The Price Battery facility is zoned industrial; and the residential
properties that make up the OU-1 area are located north, northwest, northeast, east, southeast,
and south of the facility. Based on the 2010 U.S. Census data (County of Berks 2013) the total
population of Berks County is 411,442 people and consists of 164,827 households. The total
population of the Borough of Hamburg is 4,289 people and consists of 2,019 households.

The land use in the immediate area outside of the OU-1 target area is mostly residential or
agricultural. Commercial properties make up the minority of the adjacent property area.

The continued residential use of property can reasonably be assumed for the majority of the OU-
1 properties that comprise the Site through local zoning control. It is also reasonable to assume
that, at some point in the future, interest may arise in converting some of the residential
properties to non-residential use. Future non-residential use of remediated residential properties
will remain protective of human health, because the completed OU-1 remedial action and
residential lead cleanup level of 572 ppm provides for unrestricted residential and non-residential
future use.

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Residential properties that were contaminated with lead resulting from historic industrial
emissions were the only types of properties that were addressed by this cleanup. Residential
properties were defined as any area with high accessibility to sensitive populations (children
under six years of age and pregnant and nursing women), and included properties containing
single and multiple family dwellings, apartment complexes, vacant lots in residential areas,
schools, child care facilities, community centers, churches, parks, greenways, and any other areas
where children might be exposed to site-related contaminated media. Residential yards
contaminated solely from other sources, such as lead-based paint, cannot be addressed under
CERCLA authority and were not addressed under this cleanup action^

Operable Unit 2

Borough of Hamburg Redevelopment Planning

Existing zoning of the Exide-owned properties is Business Development (BD) which allows for
a variety of commercial and industrial uses; new residential uses are specifically prohibited by
the 2004 Deed Restriction implemented by Exide pursuant to the Removal AOC. The properties
surrounding the Exide-owned properties are similarly zoned, with the exception of the Peach
Alley frontage, which is zoned Borough and Village Center (VC). According to the Borough's
Redevelopment Area Plan, the zoning maps may be modified to implement the goals of the plan.
The proposed map amendments would include a rezoning of the Main Parcel to VC Borough and
Village Center.

Although ho specific plans or proposals have been put forth, permitted uses within the VC
District would include a variety of commercial, residential, and institutional uses, as well as the
creation of a recreational trail through the area. At the request of the Borough of Hamburg, the
potential for a recreational trail crossing the Main Parcel, Broom Works Parcel, and Parking Lot
Parcel was considered in the development of alternatives for OU-2. However, during recent
discussions with Borough officials regarding the recreational trail, Borough officials indicated
that the proposed location of the recreational trail has changed, and it is currently envisioned to
follow Front Street and not cross the Exide-owned parcels, as originally contemplated. Deed
restrictions already in-place for the Exide-owned properties are intended to preclude residential
development on those properties, and therefore, the preferred alternatives for OU-2 focus on
non-residential exposure scenarios, which would be consistent with the VC District rezoning.

G. SUMMARY OF SITE RISKS

The Summary of Site Risks for OU-1, Residential Portion, is presented in the 2009 Interim ROD.
This section summarizes the results of the human health risk assessment and the ecological risk
assessments that were performed during the OU-2 RI for the Facility portions of the Site.

These baseline risk assessments (before any cleanup) provide the basis for taking response action
and indicate the exposure pathway(s) that need to be addressed by the remedial action. The
potential risks related to the no-action scenario are also described. As part of the risk
assessment, the current and future risks posed to human and ecological receptors by

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contamination at the Site were evaluated. The risk assessment evaluated the potential for health
risks, based on current and potential future conditions, to people exposed to Site contamination,
such as the risk of developing cancer and the risk of non-cancer impacts (such as adverse impacts
to organs). The screening level ecological risk assessment evaluated facility conditions with
respect to potential risks to ecological receptors.

i

1. What is Risk and How is it Calculated?

!-

A Superfund human health risk assessment estimates the "baseline risk." The baseline risk is the
estimate of the likelihood of health problems occurring if no cleanup action were taken at a site.
To estimate a baseline risk, EPA undertakes a four-step process:

Step 1: Analyze Contamination
Step 2: Estimate Exposure
Step 3: Assess: Potential Health Dangers
Step 4: Characterize Site Risk

In Step 1, EPA looks at the concentration of contaminants found at a site as well as past
scientific studies on the effects these contaminants have had on people (or animals, when human
studies are unavailable). Comparisons between site-specific concentrations and concentrations
reported in past studies help EPA to determine which contaminants are most likely to pose the
greatest threat to human health.

In Step 2, EPA considers the different ways that people might be exposed to the contaminants
identified in Step 1, the contaminant concentrations that people might be exposed to, and the
potential frequency and duration of exposure. Using this information, EPA calculates a
reasonable maximum exposure scenario which portrays the highest level of human exposure that
could reasonably be expected to occur.

In Step 3, EPA uses the information from Step 2 combined with information on the toxicity of
each chemical to assess potential health risks. EPA considers two types of risk: cancer risk and
non-cancer risk. The likelihood of any kind of cancer case resulting from a Superfund site is
generally expressed as an Upper bound probability, for example a "1 in 10,000 chance (1E-04)."
In other words, for every 10,000 people that could be exposed, one extra cancer case may occur
as a result of exposure to site contaminants. Ah extra cancer case means that one more person
could get cancer than would normally be expected from all other causes. For non-cancer human
health effects, EPA calculates a "hazard index (HI)." The key concept here is that a "threshold
level" (measured usually as a Hazard Index of 1.0) exists below which non-cancer health effects
are no longer predicted.

In Step 4, EPA determines whether site risks are great enough to potentially cause health
problems for people at or near the site. The results of the three previous steps are combined,
evaluated, and summarized. EPA adds up the potential risks from the individual contaminants
and exposure pathways and calculates a total site risk.

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2.	Calculating Risks from Exposure to Lead

The risk assessment for lead is unique. Lead does not lend itself to traditional risk assessment
methods described above because there are no scientifically agreed upon toxicity values for lead.
Due to the inability to use traditional risk assessment methods, lead is regulated based on blood
lead levels (BLL). EPA's health protection goal is to limit exposure to soil lead levels to ensure
that a typical (or hypothetical) child, or group of similarly exposed children, would have an
estimated risk of no more than a 5% probability of exceeding a BLL of 10 micrograms per
deciliter (ng/dl). The Centers for Disease Control and Prevention (CDC) recommends that the
goal of all lead poisoning prevention activities should be to reduce children's BLLs below 10
jig/dl. Blood lead concentration can be correlated with both exposure and adverse health
effects. Existing evidence indicates that adverse health effects occur even at very low exposures
to lead (e.g., subtle neurological effects in children have been observed at low doses). To predict
blood lead concentration and the probability of a child's blood lead concentration exceeding 10
(xg/dl based on a given exposure scenario from multiple sources, a model can be applied which
considers lead exposure and toxicokinetics (the absorption, distribution, metabolism, and
excretion of lead in the body) in a child to calculate an exposure level that satisfies the risk
reduction goal. The Integrated Exposure Uptake Biokinetic (IEUBK) Model for Lead in
Children is used to predict the risk of elevated BLLs in children and to establish cleanup ,levels
for lead.

The IEUBK Model was used for developing the Site-specific lead-in-soil cleanup level of 572
ppm for the Price Battery OU-1 residential cleanup. However, because the future use of the
various parcels comprising the Exide-owned properties of the Price Battery Site OU-2 is
expected to remain commercial/industrial, and not residential, EPA's Adult Lead Methodology
(ALM) was used for assessing risks from lead exposures at OU-2. BLLs in adolescents and
adults are assessed using the ALM. EPA's target.for an adult female is to protect a developing
fetus to ensure that the fetus has no more than a 5% probability of having a BLL above 10 jug/dl.
This goal is based on protecting the fetus of a pregnant site worker.

3.	Summary of Site-Related Risks for OU-2

The current and likely future use of the Exide-owned properties is commercial/industrial.
Currently the majority of the parcels are paved, covered with buildings, or covered with a stone
cap that limits access to soils. These parcels currently have deed restrictions against disturbing
the existing cover or using the properties for residential or recreational use or for day cares or
schools. However, risks from exposure to contaminated soil for a hypothetical future resident
were assessed by comparison of detected concentrations to the EPA residential Site-specific
cleanup levels for lead (572 ppm), arsenic (15 ppm), and antimony (31 ppm) in soils developed
during the Price Battery OU-1 residential cleanup. The results of this screening analysis show
that residential risks from soil exposures under baseline conditions at the Exide-ownied parcels
would be unacceptable.

In addition, risks from exposure to contaminated sediment were also evaluated. In the absence
of establishing a screening level for recreational exposure to lead, arsenic, and antimony in
sediment, sediment contaminant concentrations were screened against the residential soil Site-

26

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specific cleanup numbers developed during OU-1. Using residential soil cleanup numbers as
screening criteria for recreational sediment exposure is a very conservative approach and
overestimates the potential recreational use exposure risk to sediment. The results of this
sediment screening analysis show that risks from sediment exposures under baseline conditions
at the Exide-owned parcels would also be unacceptable.

Future exposures to soil may occur if the parcels are redeveloped or the asphalt/stone cap is
removed for utility maintenance. Therefore, a detailed exposure assessment was performed for
various commercial/industrial scenarios that included specific users and exposure conditions for
each of the Exide-owned parcels. The results of a "hot spot" (i.e., areas of high contamination
relative to other areas of the Site) analysis showed that soil lead concentrations on the Main
Parcel are generally higher in the northeast quadrant of the Main Parcel, both in surface soils and
subsurface soils. The Main Parcel was divided into two areas for the purposes of evaluation:
Main Parcel A and Main Parcel B (Figure 7). Main Parcel B occupies the northeast quadrant of
the Main Parcel, and Main Parcel A occupies the remainder of the Main Parcel. These two areas
were each evaluated as a separate exposure area, although the division was based on differences
in lead concentrations rather than expectations of exposure patterns. The other three parcels
evaluated included the Warehouse, Broom Works, and Parking Lot.

Four receptors were evaluated based on exposure assumptions on each parcel as follows:

•	Current Utility Worker (exposed to soil depths 0-5 feet)

•	Hypothetical Future Office Worker 1 (exposed to soil depths 0 - 1.25 feet)

•	Hypothetical Future Office Worker 2 (exposed to soil depths 0-10 feet)

•	Future Construction Worker (exposed to soil depths 0 -17 feet, including dermal
exposure to ground water)

•	Hypothetical Residential Exposure to Ground Water as a Drinking Water Source

Dermal contact with overburden ground water could occur by Construction Workers during
construction activities. In addition, although the Site is not currently and will not likely be used
for residential use (the former Facility and surrounding community are served by a public water
supply), overburden, and bedrock ground water risks were evaluated for a future hypothetical
residential exposure scenario. There is no widespread ground water contaminant plume at the
Site. The residential exposure scenario aissumed that a hypothetical residential well could be
placed anywhere1 on-site, and that a resident would be exposed to the concentrations from only
that well. Thus, ground water risks were evaluated for individual wells, rather than averaging
across all wells within an exposure area. Individual wells were selected from each exposure area
that represented the greatest potential risk.

a) Contaminants of Concern

EPA considers lead, arsenic, and antimony as the primary Site-related contaminants of concern
(COCs) in soil that will be addressed for the Price Battery Site.

The BHHRA for OU-2 of the Price Battery Site identified manganese, PAHs, and BTEX
compounds as contributing to the potential risks from the exposure to soils and ground water at

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.)

the Site. However, manganese concentrations in ground water are comparable to background
concentrations and are likely not Site-related. The PAHs appear to be related to coal ash and
cinders in the fill material which pre-dates battery manufacturing operations at the Site and are
therefore not Site-related. The BTEX compounds are associated with a gasoline UST. Exide
represents that the UST was a gasoline storage tank; therefore, closure of the UST will be
addressed by the responsible party pursuant to PADEP's UST regulatory authority. Although
manganese, PAHs, and BTEX compounds proceeded through the risk assessment process, they
are not considered to be Site-related COCs, and EPA will not be proposing any further action to
address these contaminants. CERCLA does not provide the authority to take remedial action for
non-site related contaminants that may be present.

4. Estimated Cancer and Non-Cancer Risks

The estimated cancer and non-cancer risks are discussed below by exposure area for the non-lead
contaminants. Cancer and non-cancer risks are summarized in Table 4. Table 4 presents the
total risk for each receptor. The total risk is the sum of all the risk pathways (i.e., ingestion,
inhalation, and dermal contact with contaminants). Detailed risk calculation tables for each
receptor and each individual pathway are presented in Appendix C of this ROD. Specifically,
Appendix C provides a detailed risk summary and includes the percent contribution of each
exposure pathway to the total risk, as well as the contaminant contributing the majority of the
risk of each pathway. Further information concerning Site risks is provided in the .
Administrative Record.

Table 4 presents calculated total risks for both Site-related and non-Site-related contaminants
(i.e., with and without PAHs, BTEX, and manganese included in the risk calculations) for
comparison purposes. The following discussions on cancer and non-cancer risks focus on total
risks without PAHs, BTEX, and manganese included in the risk calculations.

a) Cancer Risks

In order to evaluate carcinogenic risk, EPA has identified an acceptable risk range of 1 in 10,000
(1E-04) to 1 in 1,000,000 (1E-06), which represents the increased risk of cancer from exposure
to site-related contaminants. Cancer risks posed to all Worker receptors were determined to be
less than or equal to 1E-05 in the Broom Works Parcel, Parking Lot, and Warehouse Parcel
(Table 4). In Main Parcel A, cancer risks posed were found to be at or below 4E-06 for both
Office Workers and the Utility Worker. Cancer risk for the Construction Worker in Main Parcel
A was determined to be 4E-07 (the Construction Worker risk is 1E-04 if non-Site-related
contaminants were included). In Main Parcel B, cancer risk was determined to be 1E-05 for the
Utility Worker and the Construction Worker, and 1E-04 for Office Worker 2. Cancer risk for
Office Worker 1 was determined to be 4E-04; about 80% of the risk is from the soil ingestion
pathway, and all of the cancer risk is posed by exposure to arsenic.

For the hypothetical Resident exposed to ground water on the Exide-owned properties, cancer
risk is below 6E-05 for all the wells evaluated, except for MW-7 which is at the upper bound risk
range of 1E-04 primarily due to the ingestion of arsenic. However, arsenic concentrations in
MW-7 are below the drinking water MCL for arsenic which is 10 ppb, as codified at 40 C.F.R.

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§141.11. If PAHs and BTEX compounds were included in the risk analysis, then MW-2 (8E-02)
and MW-6 (1E-04) would exceed or be at the upper bound of EPA' is acceptable risk range for
exposure to overburden ground water; the majority of the risks posed would be from ingestion of
and dermal contact with dibenzo(a,h)anthracene in MW-2 and from the ingestion of benzene in
MW-6. Dibenzo(a,h)anthracene is a PAH likely from the coal ash and cinders deposited at the
Site and not Site-related, because it appears that the coal ash and cinders were used as fill
material prior to the commencement of battery manufacturing operations. The benzene is
associated with a gasoline UST and not-Site-related. Exide represents that the UST was a
gasoline storage tank; therefore, closure of the UST will be addressed by the responsible party
pursuant to PADEP's UST regulatory authority.

b) Non-Cancer Risks

Non-cancer risks were found to be less than or equal to the target HI of 1 for all receptors in the
Broom Works Parcel and Parking Lot (Table 4). Non-cancer risks were below 1 for the Utility
Worker in all exposure areas. In the Warehouse Parcel, non-cancer risks are at or less than 1 for
all receptors. In Main Parcels A and B, the total HI for both Office Workers ranged from 3 to
11, and the His for the Construction Worker were 24 and 18, respectively. For the Office
Worker and Construction Worker, nearly all the risk posed was found to be from the soil
ingestion pathway, and the major risk contributor is antimony.

For the hypothetical resident exposed to on-Site ground water, non-cancer risks were at or below
1 in all monitoring wells. If non-Site-related contaminants were included, non-cancer risks were
greater than 1 for exposure to ground water from bedrock monitoring wells BW-3 and BW-7,
and overburden monitoring wells MW-1, MW-6, and MW-7. Non-cancer risks for the
hypothetical resident exposed to ground water from these wells (if non-Site-related contaminants
are included) ranged from 2 to 18 for the child and 1.5 to 8 for the adult. The majority of the
risks posed from exposure to non-Site-related contaminants in ground water in overburden well
MW-6 were from the ingestion of benzene and inhalation of xylenes (BTEX compounds) while
showering. The benzene and xylenes are associated with a gasoline UST and non-Site-related
COCs. Exide represents that the UST was a gasoline storage tank; therefore, closure of the UST
will be addressed by the responsible party pursuant to PADEP's UST regulatory authority.

Manganese (which is not Site-related) accounts for 75 to 99% of the non-cancer risks to residents
hypothetically exposed to ground water from wells MW-1, MW-7, BW-3, and BW-7. However,
manganese concentrations in ground water are comparable to background concentrations.
Manganese concentrations exceed their respective background concentration only in overburden
well MW-7 and bedrock well BW-7, in the southwest corner of the Warehouse Parcel.

Therefore, the manganese risks from the other wells are likely due to naturally occurring
background concentrations. If manganese were eliminated from the risk assessment, the HI for
the child resident would be 1. or below for these wells.

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Table 4: Summary of Cancer and Non-Cancer Risks

Exposure

" ^

Receptor

With PAHs, BTEX and Mn

Without PAHs, BTEX and Mn





Total Excess
Lifetime Cancer
Risk

Total
Hazard
Index

Total Excess
Lifetime Cancer

Total
Hazard
Index













Broom Works

Office Worker 1

4E-06

0.2

3E-06

0.2



Office Worker 2

5E-06 .

0.1

3E-06

0.1



Utility Worker

5E-07

0.01

3E-07

0.009



Construction Worker

4E-07 -

0.8

3E-07

0.8

Main Parcel-A

Office Worker 1

5E-06

.5

4E-06

5

-

Office Worker 2

1E-05

4

3E-06

4



Utility Worker

2E-06

0.3

3E-07

0.3



Construction Worker

1E-04

25

4E-07

24

Main Parcel-B

Office Worker 1

4E-04

11

4E-04

11

' V

Office Worker 2 /

1E-04

3

1E-04

3



Utility Worker

1E-05

0.3

1E-05

0.3



Construction Worker

1E-05

18

1E-05

18

Parking Lot

Office Worker 1

2E-05

0.2

1E-05

0.1



Office Worker 2

1E-05

0.1

9E-06

0.1

-

Utility Worker

2E-06

0.01

1E-06

0.01



Construction Worker

1E-06

1

9E-07

0.8

Warehouse

Office Worker 1

5E-06

0.3

4E-06

0.3



Office Worker 2

4E-06

0.2

3E-06

0.2



Utility Worker

6E-07

0.02

3E-07

0102



Construction Worker

6E-07

2 ,

5E-07

1

Resident*

MP Well BW-3

NA

3

NA :

"•NA



/ MP Well BW-6

1E-05

0.2

4E-06

0.004



MP Well MW-1

6E-05

. 7

6E-05

1



MP Well MW-2

8E-02

0.0009

5E-07

0.0009



MP Well MW-6

1E-04

2

NA

NA



WH Well BW-7

5E-06

9

5E-06

0.06



WHWellMW-7

1E-04

18

1E-04

1

Main Parcel-A
Hot Spot

Construction Worker

3E-08

0.4

2E-08

0.2



Office Worker 2

3E-07

0.005

2E-07

0.003

~The Hazard Index reflects non-cancer risks to a child resident exposed to ground water on the Exide-owned
properties. Results for the Adult Resident are in the BHHRA and/or addendums.

NA = Not applicable because there were no carcinogenic or non-carcinogenic COCs in this well
Mn = Manganese

Bolded values indicate exceedance of EPA risk ranges.

30

AR307505


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c) Lead Risks in Soil

Risks associated with lead exposure were also evaluated and are presented as a probability that
predicted BLLs would exceed target ranges (Table 5). Unacceptable risks posed by lead-
contaminated soil were found to exceed the target probability of 5% for Office Worker 1, Office
Worker 2, arid the Construction Worker in Main Parcel A, Main Parcel B, and the Warehouse
Parcel. Lead risks did not exceed the target probability for any receptor in the Broom Works
Parcel or the Parking Lot Parcel. Lead risks for the Current Utility Worker did not exceed the
target probability of 5% in any of the five exposure areas.

Table 5: Summary of Soil Lead Risks

Office Worker 1
(0-1.25 feet)

Exposure Are

(0-10«

•11

i&p. ,,

m I

Worker
(0-17 feet)

Main Parcel A
Main Parcel B
Warehouse
Broom Works
Parking Lot

58%
97%
60%

0.2%
0.02%

18%
78%
14%

0.06%
0.01%

0.05%

2%
0.06%
0.003%
0.003%

64%
98%
59%
0.7%
0.05%

Note: Lead risk given as the predicted probability offetal blood lead > 10 ug/dl
5. Ecological Risks

An ecological exposure evaluation was conducted of the Exide-owned properties to determine if
any ecological habitat existed, and a SLERA was completed for sediment sampling results for
the Main Parcel portion of Kaercher Creek.

Results for soil and sediment were screened against their respective EPA Region III BTAG
Screening Levels (for soil and freshwater sediment benchmarks for sediment) to determine the
nature and extent of potential environmental contamination at the Main Parcel. Based on these
results, and for the purpose of the SLERA, lead, arsenic, and antimony were selected as
contaminarits of potential ecological concern (COPECs) in soil and sediment at the Exide-owned
properties that make up part of the Site.

The results of the ecological exposure evaluation of the terrestrial portions of the Exide-owned
properties supported the conclusion that the barrier created by the pavement, concrete, structures,
and crushed stone and geotextile cap covering the parcels prevented a complete exposure
pathway between ecological receptors and OU-2 Site soils. Therefore, no complete ecological
pathways for soils exist on the property, and the soil pathway was not further evaluated.

The ecological exposure evaluation of the Kaercher Creek portions of the Main Parcel identified
ecological habitat containing limited amounts of vegetative cover and potential foraging areas.
Sediment deposits along and within Kaercher Creek resulted in metals contaminant levels for
lead, arsenic, and antimony above the EPA Region HI BTAG Freshwater Sediment Screening
levels. Outside the covered portion of the Creek (where exposure to receptors would be expected
to be highest), sediment deposits were largely limited to the Creek edges and along the walls of

31

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the channel. Sediment depths ranged from less than an inch to approximately 12 inches along
the channel wall, where terrestrial vegetation was observed. This sediment is entirely isolated
from the original Creek channel sediments, which are now covered by the gabion mattress liner
system installed as part of the 2003 removal action.

In order to evaluate the sediments that have accumulated in the Creek since installation of the
gabion mattress liner system, sampling wais conducted on the Main Parcel and upstream portions
of Kaercher Creek. The possible source of the sediments deposited since the capping of the
Creek bottom include bed load from areas upstream of the Main Parcel, sediment laden
stormwater discharged to the Creek by the municipal storm sewers, and sediment contributed by
pipes discharging at the Exide owned properties that border the Creek. Because the levels of
metals contamination found on the Main Parcel portion of Kaercher Creek are higher than those
found in sediment samples immediately above the point at which flow enters the Main Parcel,
sources other than sediment transport from upstream may be responsible. The pipe sediment
sampling results, especially sediment in Pipe 3, suggest those sedimients as possible source
materials to the Main Parcel portion of Kaercher Creek. Potential downstream migration and
deposition of these contaminated sediments is possible.

To determine which contaminants (i.e., lead, arsenic, and antimony) posed a risk, a Hazard
Quotient (HQ) was calculated, where HQ = sediment concentration/EPA Region III freshwater
sediment screening levels. If the HQ is greater than or equal to 1, contaminant concentrations
are considered sufficiently high that they could produce adverse ecological effects and are,
therefore, retained as ecological COCs. Based on sediment sampling results previously
discussed, concentrations of arsenic (1/5 samples), lead (5/5 samples), and antimony (5/5
samples) sampled on Main Parcel Creek sediments exceeded freshwater sediment screening
levels.

Risks were estimated by comparing single-points of exposure (i.e., sediment concentrations) with
media specific (i.e., sediment) benchmarks. Screening level results indicate that potential
ecological risks exist for sediment-based aquatic life, and to a lesser extent, direct and indirect
exposure by higher trophic-level organisms. Although HQs are not a risk measure in terms of
likelihood or probability of adverse effects, they do provide a benchmark for assessing potential
risk.

The results of the ecological risk characterization are summarized in Table 6. The highest
measured sediment contaminant concentrations were used and resulted in HQs of 49.44,1.08,
and 5.25 for lead, arsenic, and antimony, respectively, for the on-Site Main Parcel portions of
Kaercher Creek. The highest levels are typically used to help ensure that potential threats to the
environment are not missed and that the levels of risk are not underestimated. On that basis, lead
represented the highest risk to organisms. Because arsenic was observed only slightly above an
HQ of 1, in only one sample within the Main Parcel, it is relatively insignificant as an ecological
COC and not expected to have a significant potential for risk or effect among exposed ecological
receptors. Antimony was detected in all five Main Parcel samples with HQ results ranging from
2.3 to 5.25. Antimony has a very diverse level and manifestation of effect among biota, but at
the low levels observed, antimony is not expected to pose a significant adverse effect to
ecological receptors.

32

AR307507


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Lead, arsenic, and antimony were also detected in the three sediment samples collected upstream
of the Main Parcel portions of Kaercher Creek, particularly at KC-SED-6 immediately upstream
of the Main Parcel. Upstream sediment sample results resulted in HQs ranging from 3 .66 to 11.2
for lead, 0.42 to 3.99 for arsenic, and 0.6 to 1.8 for antimony. Those portions of Kaercher Creek
that are not located within the Main Parcel will be evaluated and addressed under OU-3. EPA is
currently performing the OU-3 RI; OU-3 will be the subject of a separate Proposed Plan and
ROD when the RI/FS is completed.

Table 6: Kaercher Creek Sediment Ecological Risk Characterization

Main Parcel Portion

i'

EPA Freshwater

llissf&ic

fmspggppjtif)
On-site

PplpgiilRpi'

On-site

KC-S
On-

fe"" '''



IS!?3

m



«

iMesuItjS

HQ

iFlesuiifS

HO

iRiswiB

ho

Result

HQ

Antimony

2

10.5

5.25

6.3

3.15

4.6

2.3

10

5

Arsenic

9.8

3.4

0.35

10.6

1.08

8.3

0.85

5.1

0.52

Lead

35.8

850

23.74

1150

32.12

851

23.77

1540

43.02



pEPA Freshwater
Scr™,'n7!lcl



SED-5

l§ilic6-SfeS>6

:

Off-site

KC-S

p

ED-7
site

KC-SED-8



!il8iSI3

iResult*



Result

HQ

Result



Result



Antimony

2

5.2

2.6

3.6

1.8

2.7

1.35

1.2

0.6

Arsenic

9.8

6.5

0.66

39.1

3.99

7.2

0.73

4.1

0.42

Lead

35.8

1770

49.44

401

112

243

6.79

131

3.66

All results in ppm

On-site - sediment samples collected within the Main Parcel
Off-site - sediment samples collected outside the Main Parcel
KC-SED - Kaercher Creek Sediment Sampling Location

In summary, ecological COCs include lead, arsenic, and antimony. EPA believes that the
potential for direct and indirect sediment-based ecological effects is present, but the limited
habitat and likely future remediation of contaminant sources precluded the need to further
quantify ecological risk. EPA believes that sediment contained in pipes beneath the Main Parcel
could contribute contaminated sediment to the Kaercher Creek bed load in areas downstream
from the Main Parcel; therefore, remediation of the sediment in the pipes and within the gabion
mattress liner system is necessary.

A comprehensive ecological assessment has also been initiated by EPA for Kaercher Creek
(other than on Exide-owned properties), Mill Creek, the Schuylkill River, and an assessment of
any remaining potential ecological risk in residential areas. EPA is currently performing the
OU-3 RI; OU-3 will be the subject of a separate Proposed Plan and ROD when the RI/FS is
completed.

33

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6. Basis for Action

The BHHRA and ecological risk characterization assessment found that the former Price Battery
facility manufacturing operations contaminated soil and sediments with lead, arsenic, and
antimony above levels that are protective of human health and the environment and are
summarized below.

Soils

For soils on the Exide-owned portions of the Price Battery Site OU-2, EPA has determined there
is a basis for action for the following reasons:

•	Lead results were above the established OU-1 Site-specific residential cleanup value of
572 ppm; therefore, residential risks from soil exposures under baseline conditions at the
Exide-owned parcels would be unacceptable.

•	Unacceptable risks posed by lead-contaminated soil were found to exceed the target
jprobability of 5% for Office Worker 1, Office Worker 2, and the Construction Worker in
Main Parcel A, Main Parcel B, and the Warehouse Parcel.

•	Unacceptable cancer risks posed primarily by arsenic-contaminated soil were found to
exceed the acceptable cancer risk range for Office Worker 1 and Office Worker 2 in

„ Main Parcel B.

•	Unacceptable non-cancer risks posed by antimony and arsenic were found to exceed an
HI of 1 for Office Worker 1, Office Worker 2, and the Construction Worker in Main
Parcel A and Main Parcel B.

Sediment

For sediment in Kaercher Creek within the Main Parcel of the Exide-owned portions of the Price
Battery Site OU-2, EPA has determined there is a basis for action for the following reasons:

•	Lead results were above the established OU-1 Site-specific residential cleanup value of
572 ppm, with a maximum result of 1,770 ppm of lead.

•	Lead, arsenic, and antimony exceed EPA freshwater sediment screening levels for
ecological receptors.

•	Unacceptable ecological risks posed primarily by lead and arsenic were found to exceed
an HQ of 1 for ecological receptors.

•	Accumulated contaminated sediment in Kaercher Creek and pipes may be transported to
downstream ecological receptors.

34

AR307509


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Ground Water

For ground water on the Exide-owned portions of the Price Battery Site OU-2, EPA has
determined there is no basis for action for the following reasons:

•	PAH contamination in overburden monitoring well MW-2 appears to be isolated in
nature and related to fill material containing coal ash and cinders used as railroad ballast,
which pre-dates operation of the Price Battery facility and is therefore not Site-related.
Monitoring well MW-2 is located in the former railroad right of way.

•	BTEX compounds detected in overburden well MW-6 and bedrock well BW-6 appear to
be isolated in nature and attributable to a gasoline UST in the southeastern corner of the
Main Parcel. Exide represents that the UST was a gasoline storage tank; therefore,
closure of the UST will be addressed by the responsible party pursuant to PADEP's UST
regulatory authority.

•	Elevated detections of lead in bedrock monitoring well B W-3 are believed to be the result
of turbidity within the well resulting from well development difficulties and are not
representative of ground water quality.

•	Arsenic was detected above its risk-based screening level in only one well (MW-7) but
was below its" corresponding MCL.

•	Manganese concentrations in ground water are comparable to background concentrations
and are likely not Site-related.

CERCLA does not provide the authority to take remedial action for non-site related
contaminants that may be present.

H. REMEDIAL ACTION OBJECTIVES

To protect human health and the environment from potential current and future health risks,
remedial action objectives (RAOs) have been developed to address contaminated soil and
sediment and for monitoring of ground water at the Price Battery Site OU-2.

The RAOs developed for Price Battery OU-2 are presented in Table 7 below:

35

AR307510


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Table 7: Price Battery OU-2 Remedial Action Objectives

MEDIUM

OBJECTIVE :

Soil:

Prevent direct human exposure to soils above the preliminary remediation
goals (PRGs) for lead and risk-based concentrations (RBCs) for antimony
and arsenic.

Prevent potential future impact to stream sediment and surface water by
soil erosion from the Facility.

Protect ecological receptors from exposure to contaminated soils above
ecologically protective values.

Ground Water:

Monitor ground Water to ensure that the isolated ground water contaminant
concentrations do not change.

Sediment:

Minimize the potential for exposure of human receptors to sediment
containing COCs in exciess of the residential soil screening levels.
Eliminate existing on-site accumulations of contaminated sediment in
Kaercher Creek and pipes, which sediments could be transported to
downstream ecological receptors.

Prevent on-site exposure of ecological receptors to sediment containing
COCs above EPA freshwater sediment screening benchmarks.

1. Determination of Risk-Based Concentration for Lead

A risk-based concentration (RBC) is the average concentration in an exposure area that will
result in an acceptable risk to a particular receptor (for lead, this term is referred to as the
preliminary remediation goal (PRG), but the term RBC will be used for consistency). Lead-in-
soil RBCs are risk-based target cleanup levels that must be met on average throughout the
exposure area. It is acceptable to leave concentrations that exceed the cleanup level (RBC) for
lead-in-soil, as long as the post-remediation average concentration in an exposure area does not
exceed the RBC for lead-in-soil. The soil lead RBC calculated for the Office Worker is 2,240
ppm, and the soil lead RBC was calculated as 941 ppm for the Construction Worker.

The Remedial Action Level (RAL) is the concentration above which soil must be addressed so
that the post-remediation average concentration meets the specified target cleanup level (i.e.,
meets the RBC). The RAL is a cleanup level (i.e., a remedial trigger concentration) that ensures
the post-cleanUp average concentration within an exposure area achieves the target cleanup level
with a specified level of confidence.

The RBCs and corresponding RALs for lead calculated for the exposure scenarios with
potentially unacceptable risk are presented in,Table 8. To be conservative, the lowest lead
RAL (8,669 ppm) will be applied as the target remedial level for all parcels and all soil
depths, except to the extent that contaminated soil cannot be removed because of field
conditions (i.e., physical constraints, proximity of building foundations, maintaining safe
excavation slopes, encountering ground water, etc.).

36

AR307511


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Table 8: Soil Lead RBCs and RALs

¦ , ti A « «. " m - ¦>».. r/1. —>1

.'^1

fi. %A.TT-iWijek^-JtLSi &/"^»WmI

12,285
25,300

8,669

28,500

9,313

2.	Determination of Risk-Based Concentrations for Arsenic and Antimony

The OU-2 BHHRA includes calculations of arsenic and antimony RBCs in soil for each of the
exposure scenarios evaluated. The lowest calculated RBCs were 100 ppm for arsenic (Office
Worker) and 46 ppm for antimony (Construction Worker). Elevated levels of antimony and
arsenic were generally correlated with elevated levels of lead, and the BHHRA concluded that
performing a remedial action to meet the RALs for lead-in-soil will result in average
concentrations of antimony and arsenic below the RBCs identified above.

No unacceptable risk from lead, arsenic, or antimony was identified for the commercial
exposure scenarios evaluated in the BHHRA on the Broom Works Parcel or the Parking
Lot.

3.	Principal Threat Wastes in Soils

For the purposes of Price Battery OU-2 only, principal threat wastes (PTW) are defined as those
materials containing antimony, arsenic or lead at concentrations two orders of magnitude (i.e.,
100 times) higher than the RBCs calculated in the OU-2 BHHRA. Although the BHHRA
calculated RBCs for a number of exposure scenarios, for simplicity, the lowest calculated RBCs
were used to calculate PTW levels. PTWs are defined as those soils with concentrations of one
or more constituents above the concentrations in Table 9.

Table 9: Principal Threat Waste Levels

Antimony

46 / ..

4,600

Arsenic

100

10,000

Lead

941

94,100

Relative to these concentrations, PTWs have been identified to exist only on Main Parcels
A and B. No PTWs have been identified on the Warehouse, Broom Works, or Pairking Lot
Parcels.

37

AR307512


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4. Contaminants of Concern in Sediment

The COCs in sediment are antimony, arsenic, and lead. Sediment contained in the pipes and
penetrations (openings in the Kaercher Creek concrete channel wall), and sediment within and on
top of the gabion mattresses, must be removed, sealed, or otherwise mitigated to prevent the
potential for contaminated sediment transport to downstream ecological receptors and prevent
on-site exposure of ecological receptors to sediment containing COCs above levels of concern.
Based on a determination in the SLERA that the Main Parcel portions of Kaercher Creek have
limited ecological value, remedial action will focus on eliminating contaminated sediment
accumulations in the Main Parcel portions of Kaercher Creek and in pipes with the potential to
become eroded and transported to downstream ecological receptors. Although Kaercher Creek
within the Main Parcel has limited ecological value, this action will also prevent exposure of
ecological receptors within the Main Parcel portion of Kaercher Creek to sediment containing
COCs above EPA freshwater sediment screening levels. Therefore, the following ecological
freshwater sediment screening levels (Table 10) hiave been identified as the cleanup levels for
sediment for the Main Parcel portions of Kaercher Creek and sediment contained in the pipes:

Table 10: Sediment Cleanup Levels

l:*.*

	

ftEiSological

Lead

572

35,8 (TEC)

Arsenic

15 ' ¦ .

9.79 (TEC)

Antimony'

31

3.0 (UET)

All results in ppm

~Site-specific residential levels developed by EPA for OU-1

TEC = National Oceanic and Atmospheric Administration (NOAA) Threshold Effects Concentrations
UET = Upper Effects Threshold

Because the freshwater sediment screening levels are lower than the Site-specific residential
cleanup levels developed during OU-1, EPA will use the more stringent of the two as cleanup
levels for protection of human health and ecological receptors2

I. SUMMARY OF REMEDIAL ACTION ALTERNATIVES

CERCLA requires that any remedy selected to address contamination at a hazardous waste site
must be protective of public health and welfare and the environment, cost-effective, in
compliance with regulatory and statutory provisions that are applicable or relevant and
appropriate requirements (ARARs), and consistent with the NCP to the extent practicable.

2 Site-specific ecological sediment cleanup values were not calculated for Kaercher Creek. EPA believes that the
potential for direct and indirect sediment-based ecological effects is present, but the limited habitat and likely future
remediation of contaminant sources by addressing sediment found in the open pipes discharging to Kaercher Creek
precluded the need to further quantify ecological risk and the results of the SLERA sufficed. Therefore, the use of
the sediment screening ecological values as sediment cleanup levels is reasonable given the limited extent of
remediation necessary in Kaercher Creek within the Main Parcel.

38

AR307513


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1. Summary of Major ARARS

a)	Operable Unit One

ARARs for OU-1 were identified in the September 30,2009 Interim ROD for the Residential
Portion of the Price Battery Site. No additional ARARs for OU-1 have since been identified.
The remedial action at OU-1 is complete, and all ARARs identified in the OU-1 Interim ROD
were met during the remedial action.

b)	Operable Unit Two

EPA has identified the following substantive federal and state requirements as ARARs or
otherwise worthy of consideration during the evaluation of the remedial alternatives in this ROD.

The appropriate off-site disposal of excavated soil from Site remediation activities will be
determined by whether or not the soil passes the Toxicity Characteristic Leaching Procedure
(TCLP) for lead and arsenic. If excavated soils pass the TCLP, then the soil may be disposed of
in a permitted nonhazardous RCRA waste storage, treatment, or disposal facility. If excavated
soils do not pass the TGLP, the soils may be stabilized on-site until confirmed to pass TCLP and
then disposed of in a permitted nonhazardous waste storage, treatment, or disposal facility.
Stabilization involves the mixing of a reagent (i.e., trisodium phosphate or other reagents) with
the contaminated soil to render the soil nonhazardous. Otherwise, excavated soils that do not
pass the TCLP will be disposed of at a permitted RCRA Subtitle C hazardous waste storage,
treatment, or disposal facility for stabilization and/or disposal.

The Commonwealth of Pennsylvania has promulgated standards for lead, antimony, and arsenic
for soil cleanup under Pennsylvania Act 2, Title 25 PA Code 250; however, for the Price Battery
Superfund Site OU-2, a risk-based Site-specific cleanup standard was determined through the
Superfund risk assessment, which is also consistent with Pennsylvania Act 2, Title 25 PA Code
250.

In addition to ARARs, EPA may implement other federal or state policies, guidelines, or
proposed rules capable of reducing the risks posed by a site. Such To-Be-Considered (TBC)
standards, while not legally binding (because they have not been promulgated), may be used in
conjunction with ARARs as part of the risk assessment conducted for each CERCLA site to set
protective cleanup levels and goals. EPA considered the Area of Contamination Policy and its
applicability to the remediation of the Exide-owned properties of the Price Battery Superfund
Site, specifically the Warehouse Parcel and the Main Parcel. The Area of Contamination Policy
allows RCRA hazardous waste to be managed within an Area of Contamination without
triggering the RCRA Land Disposal Restrictions (which require further treatment of such waste)
if the waste is solely managed for consolidation on-site. The Area of Contamination policy was
first articulated in the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). See 53 FR 51444 for detailed discussion in proposed NCP preamble; 55 FR 8758-8760,
March 8,1990 for final NCP preamble discussion. See also, most recent EPA guidance, March
13,1996 EPA memo, "Use of the Area of Contamination Concept During RCRA Cleanups." See
also, "Management of Remediation Waste under RCRA," EPA530-F-98-026 (October 1998).


-------
In the case of the Warehouse Parcel and the Main Parcel, EPA has determined that, consistent
with the Area of Contamination Policy, although these parcels are separated by a public right-of-
way, the parcels may be considered as one Area of Contamination for the purposes of
consolidating excavated soil from one parcel to another. This decision is based, in part, on the
discovery of some lead contamination above background values for the area in subsurface soils
below the paved public right-of-way.

Additional ARARs concerning minimization of any effects of remediation on historic properties,
or landmarks; consideration of flood plain hazards and flood plain management; avoiding
adverse impact to wetlands; clean backfill requirements; and best practices to prevent fugitive
dust emissions during any remedial activity were all identified during the evaluation of remedial
alternatives. A more detailed description of these ARARs can be found in Appendix D of this
ROD.

2. Remedial Alternatives for OU-2

Remedial alternatives for Price Battery OU-2 are presented below. The alternatives are
numbered to correspond with alternatives presented in the 2013 Final FS for the Exide-owned
portions of the Price Battery Site.

Common Components to all Alternatives

•The Declaration of Use and Deed Restriction (Deed Restriction) placed on all of the Exide-
owned parcels in 2004 as required by the November 12,2002 Removal Action Memorandum
and 2003 Removal AOC is incorporated as a common component in all of the alternatives
discussed below. Among other things, the Deed Restriction prohibited use of the Exide
properties for residential, recreational, schools, day care facilities, or other uses which could
potentially expose children to contamination. Additional institutional controls (ICs) will be
required limiting access for future development, improvement, and use of the Exide-owned
properties where residual risk may remain after cleanup. ICs will include activity and use
restrictions enacted through proprietary (e.g., easements, covenants) and/or governmental (e.g.,
zoning requirements) controls to prevent use of the property that will pose an unacceptable risk
to receptors. The exact type of IC implemented will be determined by EPA in consultation with
PADEP and local government agencies. The restrictions in the current Declaration of Use and
Deed Restriction will be incorporated into any new institutional controls.

In addition, Five-Year Reviews are an element common to all the remedial alternatives. Five-
Year Reviews are required on all Superfund sites when there is waste left in place. In the case of
this Site, lead-contaminated soils and sediments will be left in place for all of the alternatives
above levels that allow for unlimited exposure and unrestricted use of the Exide-owned
properties.

40

AR307515


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SOIL ALTERNATIVES

Alternative S-l: No Action

Estimated Capital Cost: $0
Estimated Annual O&MCost: $0
Estimated Present Worth Cost: $0
Estimated Construction Timeframe: NA
Estimated Time to Achieve RAOs: NA

The NCP requires that EPA include a "No Action" Alternative in its remedy selection decision •
making process. Under the No Action Alternative, no cleanup measures would be implemented.
The purpose of the No Action Alternative is to provide a baseline to compare the other cleanup
alternatives. The No Action Alternative would not meet any of the cleanup objectives described
earlier in this ROD. Furthermore, the No Action Alternative would not provide the controls
necessary to protect human health and the environment from the Site-related lead, arsenic, and
antimony soil contamination other than the current deed restriction on the property which
prohibits residential use. There are no costs to implement, operate, and maintain this Alternative.
However, because existing contaminated soils would remain in place, EPA will conduct Five-
Year Reviews as required by Section 121(c) of CERCLA.

Alternative S-2: Institutional Controls

Estimated Capital Cost: $20,900
Estimated Annual O&M Cost: $5,400
Estimated Present Worth Cost: $87,909
Estimated Construction Timeframe; 1 Week
Estimated Time to Achieve RAOs: NA

Alternative S-2 would control risks primarily through limitation of access to areas of
contamination. Debris remaining from past Site operations would be removed. The perimeter
fence around the Main Parcel would remain for security and general safety purposes, at least
until the property is sold or redeveloped. ICs would provide notice that contamination is known
to exist and that uncontrolled intrusive activities are limited or restricted. Future excavation for
redevelopment or utility work would be limited to depths and locations where contamination has
been shown not to present unacceptable risks or would be performed only within carefully
developed procedures approved by EPA in consultation with PADEP. No residential use of the
properties would be permitted. ICs would include activity and use restrictions enacted through
proprietary (e.g., easements, covenants) and/or governmental (e.g., zoning requirements) controls
to prevent use of the property that would pose an unacceptable risk to receptors. The exact type
of IC implemented would be determined by EPA in consultation with PADEP and local
government agencies. The restrictions in the current Declaration of Use and Deed Restriction
would be incorporated into any new institutional controls.	-

Activities would include semi-annual inspections of overall Site conditions to confirm no
disturbance is occurring, evaluating the integrity of the Site cover system (including the existing

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gabion mattress liner system), and ensuring that the institutional controls remain protective.
EPA would conduct Five-Year Reviews as required by Section 121(c) of CERCLA.

Alternative S-3: Excavation, Stabilization, and Off-Site Disposal of Soils Defined as
Principal Threat Waste; Capping Remaining Soils In-Place;
Institutional Controls

Estimated Capital Cost: $1,109,994
Estimated Annual O&M Cost: $4,050
Estimated Present Worth Cost: $1,160,251
Estimated Construction Timeframe: 22 Weeks
Estimated Time to Achieve RAOs: 22 Weeks

Alternative S-3 improves the Site for potential re-use and/or redevelopment while minimizing
the amount of excavation and soils management. Under this alternative, PTW soils would be
excavated, stabilized, and disposed off-site at an approved disposal facility. Stabilization of
excavated PTW soils could occur either on-site or off-site, as necessary, to meet disposal
requirements. Any soils exceeding the RAL which overlay the PTW soils would be removed
and managed consistent with the PTW soils. Other RAL soils not overlying the PTW soils
would not be excavated arid would remain in-place. Approximately 1,540 cubic yards (cy) and
1,310 cy of soil would be excavated from Main Parcel A and Main Parcel B, respectively. Soils
would be excavated to depths ranging from approximately 2 feet to 6 feet below ground surface.
No excavation would occur on the Warehouse Parcel, because there are no identified PTW soils
on this parcel.

The excavations would be backfilled with reclaimed concrete and soils segregated during
excavation of the PTW soils (and proven to be below the PADEP non-residential statewide
health standards) and/or imported clean fill material. Backfilling would be performed to levels at
or near existing grades except as coordinated with Site redevelopment activities. Imported clean
soil must have maximum concentrations of no more than 50 ppm and 15 pprn for lead and
arsenic, respectively. All other chemical parameters for the imported soil would meet
Pennsylvania Clean Fill criteria. The existing concrete/asphalt cover over RAL soils would be
maintained as a cap, or buildings and pavement associated with future redevelopment, if they
occur, function as a cap. Any future redevelopment, if known, would be incorporated into the
cap design. If the scope of future redevelopment is not known, the cap would be designed to the
extent possible to accommodate a variety of potential redevelopment options. The IC
requirements of Alternative S-2 are included in this Alternative. Because existing contaminated
soils will remain in place, EPA would conduct Five-Year Reviews as required by Section 121(c)
of CERCLA.

Alternative S-4A: Excavation, Stabilization, arid Off-Site Disposal of Soils defined as
Principal Threat Waste and Soils Exceeding the Remedial Action
Level; Institutional Controls

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Estimated Capital Cost: $2,731,416
Estimated Annual O&M Cost: $3,713
Estimated Present Worth Cost: $2,777,484
Estimated Construction Timeframe: 54 Weeks
Estimated Time to Achieve RAOs: 54 Weeks

Alternative S-4A also would improve the Site for potential re-use and/or redevelopment.
Alternative S-4A goes beyond Alternative S-3 in that all PTW and RAL soils would be
excavated, stabilized, and disposed off-site at an approved disposal facility. Soils below the Site-
wide RAL would remain in-place. Stabilization of excavated PTW and RAL soils could occur
either on-site or at an off-site disposal facility, as necessary, to meet disposal requirements.
Approximately 1,820 cy, 2,470 cy, and 3,900 cy of soil would be excavated from Main Parcel A,
Main Parcel B, and the Warehouse Parcel, respectively (Figures 8 and 9).

Concrete pavement, floor slabs, and foundations overlying the RAL and PTW soils would be
removed, segregated, cleaned to remove residual contamination (based on visual observations)
pursuant to the requirements of RCRA, crushed, and stockpiled. Crushed material would be
analyzed for inorganic constituents and the results compared against the PADEP Statewide
Health Standards for non-residential soils (direct contact) prior to reuse as backfill. Imported
clean soil must have maximum concentrations of no more than 50 ppm lead and 15 ppm arsenic.
All other chemical parameters for the imported soil would meet Pennsylvania Criteria for
Management of Fill. Backfilling would be performed to levels at or near existing grades except
as coordinated with Site redevelopment activities. Any crushed material used for backfilling
would be overlain by imported clean fill. Institutional controls would be imposed that protect or
control future redevelopment/land use at the Site and would require control of soils generated
during future construction activities as such soils (i.e., soils above the RBC but less than the
RAL) could represent a risk if not properly managed. Residential redevelopment would be
prohibited. The IC requirements of Alternative S-2 are included in this Alternative. Because
existing contaminated soils would remain in place, EPA would conduct Five-Year Reviews as
required by Section 121(c) of CERCLA.

Alternative S-4B: Excavation, Stabilization and Off-Site Disposal of Soils defined as

Principal Threat Waste; Excavation and On-Site Consolidation of
Soils Exceeding the Remedial Action Level; Institutional Controls

Estimated Capital Cost: $1,691,585
Estimated Annual O&M Cost: $13,500
Estimated Present Worth Cost: $1,859,107
Estimated Construction Timeframe: 56 Weeks
Estimated Time to Achieve RAOs: 56 Weeks

Alternative S-4B also would improve the Site for potential re-use and/or redevelopment. This
alternative is similar to Alternative S-4A in that all PTW soils and RAL soils would be
excavated. Excavated PTW soils would be stabilized and disposed off-site. However, RAL soils
would not be disposed off-site, but rather they would be consolidated into a single capped area
on-site. Soils below the RAL would remain in-place. The excavated RAL soils would be placed
in a designated consolidation area on one of the Exide-owned properties without stabilization.

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All four Exide-owned parcels are considered one Area of Contamination. Consolidation within
the Area of Contamination would not represent hazardous waste generation, and would not
trigger RCRA Land Disposal Restrictions or minimum technology requirements. RCRA
Corrective Action Management Unit (CAMU) requirements would not be triggered, because the
RAL soils would not be stabilized. The specific location for the consolidation area could be
adapted to fit future land development concepts, but would most likely result in a consolidation
area in the northeast corner of the Main Parcel. The consolidation area would be created by
excavating an area and depth to accommodate the volume of RALs soil and the cap. A 24-inch
thick cap (consisting of soil and/or pavement) would be placed across the consolidation area.
The edges of the cap would be flush with surrounding grades, and grading would be designed to
avoid sharp changes in grade, slopes greater than a ratio of 3 horizontal to 1 vertical and finished
grades greater than 5+/- feet above surrounding grades. The depth of the consolidation area
would be limited by ground water. In addition, other soils (i.e., soils with concentrations below
the Site-wide RAL) excavated during creation of the consolidation area could be utilized for
backfill of the excavation areas and for capping. The IC requirements of Alternative S-2 are
included in this Alternative. EPA would conduct Five-Year Reviews as required by Section
121(c) of CERCLA.	,	'

SEDIMENT ALTERNATIVES

Alternative SD-1: No Action

¦ ( ' '

Estimated Capital Cost: 0
Estimated Annual O&MCost: 0
Estimated present Worth Cost: 0
Estimated Construction Timeframe: NA
Estimated Time to Achieve RAOs: NA

The No Action Alternative is required by CERCLA as the basis for comparison with other
alternatives. This alternative involves no action to reduce the risks posed by sediments at the
Site. None of the contaminated sediments would be addressed. Utilizing the No Action
Alternative, the contaminated sediment above and below the gabion mattresses and within piping
that discharges into Kaercher Creek at the Site would remain in-place, and the current deed
restrictions would remain in-place. EPA would conduct Five-Year Reviews as required by
Section 121 (c) of CERCLA.

Alternative SD-2: Institutional Controls

Estimated Capital Cost: $20,900
Estimated Annual O&M Cost: $5,400
Estimated present Worth Cost: $87,909
Estimated Construction Timeframe: 1 Week
Estimated Time to Achieve RA Os: NA

Alternative SD-2 is a limited construction alternative that would control human health risks
primarily through limitation of access to areas of contamination. The perimeter fence around the
Main Parcel would remain for security and general safety purposes, at least until the property is

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sold or redeveloped. The gabion mattress liner system in the Creek would be included in this
alternative, ensuring that the integrity of the stream liner system is documented and maintained.
The gabion mattress stream liner system is approximately 6,500 square feet and includes an
estimated 100 cy of impacted stream sediment within the gabions. Sediment in the underground
pipes would remain under this alternative. Periodic maintenance and inspection of the Site are
included in the cost estimate for this alternative. Activities include semi-annual inspections of
overall Site conditions, including soil and sediment areas to confirm that no disturbance is
occurring and to evaluate the integrity of the Site cover system (including the gabion mattress
liner system). Institutional controls would be implemented to provide notice that contamination
is known to exist and to prohibit removal of the existing gabion mattress or excavation of soils
within or along the Creek. EPA would conduct Five-Year Reviews as required by Section
121(c) of CERCLA.

Alternative SD-3: Sediment Removal and Stream Liner; Institutional Controls

Estimated Capital Cost: $265,605
Estimated Annual O&M Cost: $2,700
Estimated Present Worth Cost: $299,109
Estimated Construction Timeframe: 14 Weeks
Estimated Time to Achieve RAOs: 14 Weeks

Alternative SD-3 is specific to addressing sediment in Kaercher Creek on the Main Parcel,
including contributions from the Site drainage pipes (Figure 10). The former building floors
enclosing (across the topof) the Creek and the loose sediment contained within or oh the gabion
mattresses would be removed. The accumulated sediment in the mattresses would be removed to
the extent practicable using a vacuum truck. The gabion mattress would be filled with grout or
concrete to encapsulate any remaining sediment that cannot be removed from within the gabion
mattresses and bolster the structural stream liner system. Existing walls of the channel or
portions thereof may need to be reconstructed to ensure long-term stability. Existing pipes that
open into the Creek and the sediment contained within them would be cleaned, removed, and/or
sealed. Any accumulated sediment that is removed would be disposed off-site, placed in the on-
site consolidation area, or used as backfill in on-site soil excavation areas. The gabion
mattresses would then be grouted to ensure long term stability and permanence. The estimated
volume of sediment to be removed would be approximately 100 cy and 10 cy from the gabion
mattresses and the pipes, respectively. Institutional controls would be implemented to prohibit
removal of the existing gabion mattress or excavation of soils within or along the Creek. EPA
would conduct Five-Year Reviews as required by Section 121 (c) of CERCLA.

Alternative SD-4: Stream Realignment

Estimated Capital Cost: $817,742
Estimated Annual O&M Cost: $6,075
Estimated Present Worth Cost: $893,126
Estimated Construction Timeframe: 61 Weeks
Estimated Time to Achieve RAOs: 61 Weeks

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Alternative SD-4 was originally developed to complement and enhance the recreational trail
envisioned by the Borough of Hamburg crossing the Main Parcel portion of the Price Battery
Site. However, since the development of Alternative SD-4 in the FS, recent discussions with
Hamburg Borough officials regarding the recreational trail indicated that the proposed location
of the recreational trail has changed and is currently envisioned to follow Front Street and not
cross the Exide-owned parcels as originally contemplated. Nonetheless, Alternative SD-4
remains a viable Alternative to address sediment contamination in Kaercher Creek within the
Main Parcel.	'

Under Alternative SD-4, Kaercher Creek on the Exide parcels would be relocated and
reconstructed along the original alignment for the trail envisioned by the Borough of Hamburg
within the Main Parcel. The Creek would have been integrated with the trail by creating a
natural stream bank approaching the Creek from the proposed trail. The area available for
redevelopment would be maximized by creating a retaining wall along the west and northwest
side of the Creek. A 75 +/- foot wide buffer would be created along Peach Alley for the walking
trail, and the Creek would be relocated along the west side of proposed buffer. The cross-
sectional area for the new channel would be increased to increase flow capacity. Pipes 2 and 3
and the accumulated sediment within these pipes would be removed. Efforts would be made to
naturalize the new stream bed and vegetate the stream banks to enhance ecological habitat and
improve surface water quality. The original channel alignment would be backfilled with
structural fill, abandoning the existing gabion mattress and contaminated sediments in-place. The
existing concrete walls would be demolished and recycled for use as backfill, or the walls would
be abandoned in-place. The approximate volume of sediment abandoned-in-place (primarily
beneath the gabion mattress) would be 350 cy with lead concentrations ranging from 4,867 ppm
to 24,090 ppm with an average of 14,787 ppm. The volume of sediment within the gabion
mattress to be abandoned-in-place would be approximately 100 cy. Because contaminated
sediment would be abandoned in place, EPA would conduct Five-Year Reviews as required by
Section 121(c) of CERCL A.

GROUND WATER PREFERRED DECISION

EPA's preferred decision for ground water is No Action with Monitoring. CERCLA does not
provide the authority to take remedial action for non-site related contaminants that may be
present. Ground water contamination observed at the Price Battery Site is either not Site-related,
or it is related to petroleum contamination that will be deferred to PADEP under its authorities
for appropriate action. PAH contamination in overburden monitoring well MW-2 appears to be
isolated in nature and related to fill material containing coal ash and cinders used as railroad
ballast, which pre-dates operation of the Price Battery facility and is not Site-related. Monitoring
well MW-2 is located in the former railroad right of way. BTEX compounds detected in
overburden well MW-6 and bedrock well BW-6 appear to be isolated in nature and associated
with a gasoline UST in the southeastern corner of the Main Parcel. Exide represents that the
UST was a gasoline storage tank; therefore, closure of the UST will be addressed by the
responsible party pursuant to PADEP's UST regulatory authority. Elevated detections of lead in
bedrock monitoring well BW-3 is the result of turbidity within the well resulting from well
development difficulties and is not representative of ground water quality. Arsenic was detected
above its risk-based screening level in only one well (MW-7) but was below its corresponding

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MCL. Manganese concentrations in ground water are comparable to background concentrations
and are likely not Site-related.

However, ground water monitoring would be conducted to ensure that contaminant
concentrations remain stable at the Site and would serve as an early indicator should ground
water contaminant concentrations change following implementation of the remedial action. At a
minimum, approximately two additional ground water monitoring wells would be installed for
monitoring (after soil remediation, if selected). Monitoring well BW-3 would also be
redeveloped or replaced to address turbidity issues within that well. Quarterly ground water
sampling would be conducted. Monitoring data would be reviewed annually for statistical
trends beginning after 2 years (eight quarters). The need for continued ground water monitoring
would be re-evaluated at 5-year intervals concurrent with Five-Year Reviews as required by
Section 121(c) of CERCL A.

J. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Criteria Used To Compare Cleanup Alternatives

The remedial alternatives summarized in this ROD have been evaluated against the nine decision
criteria set forth in the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP) (see 40 C.F.R. §300.430(e)(9)). These nine criteria are organized into three categories
which include: threshold criteria, primary balancing criteria, and modifying criteria. Threshold
criteria must be satisfied in order for an alternative to be eligible for selection. Primary
balancing criteria are used to weigh major trade-offs between alternatives. Modifying criteria are
formally taken into account after public comment has been received. The criteria are set forth
below:

Threshold Criteria

1.	Overall Protectiveness of Human Health and the Environment addresses whether a
remedy provides adequate protection of human health and the environment from
unacceptable risks posed by hazardous substances or pollutants or contaminants and
describes how risks are eliminated, reduced, or controlled through treatment, engineering
controls, or institutional controls.

2.	Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
addresses whether a remedy will meet all of the applicable, or relevant and appropriate
requirements of Federal and State environmental statutes and regulations and/or whether
there are grounds for invoking a waiver.

Primary Balancing Criteria:

3. Long-Term Effectiveness refers to the ability of a remedy to maintain reliable protection
of human health and the environment over time once cleanup goals are achieved.

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4.	Reduction of Toxicity, Mobility, or Volume Through Treatment addresses the degree to
which treatment will be used to reduce the toxicity, mobility, or volume of the
contaminants causing site risks.

5.	Short-Term Effectiveness addresses the period of time needed to achieve protection and
any adverse impacts on human health and the environment that may be posed during the
construction and implementation period until cleanup goals are achieved.

6.	Implementability addresses the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement a particular
option.

7.	Cost includes estimated capital and operation and maintenance costs. Costs are evaluated
on a present worth basis.

Modifying Criteria:

8.	State Acceptance indicates whether the State concurs with, opposes, or has no comment
on the remedy.

9.	Community Acceptance considers whether the community agrees with the remedy.

The above criteria are used to evaluate the advantages and disadvantages of each alternative in
order to select an appropriate'remedy. The following is a brief summary evaluating and
comparing each alternative against the nine criteria.

. (''

1. Overall Protection of Human Health and the Environment

Soil Alternatives

The No Action Alternative does not provide protection of human health and the environment,
because it does not eliminate or control the current and future risks from exposure to
contaminated soils. The No Action Alternative will not be discussed further in the nine criteria
analysis because it does not satisfy the threshold criterion of providing overall protection of
human health and the environment. Alternative S2, Institutional Controls, provides some
protection of human health and the environment through monitoring of areas of concern and
instituting controls to prevent exposure. Alternative S-2 relies on institutional controls rather
than physical means of addressing contamination and does not address PTWs. Therefore,
Alternative S-2 does not achieve the degree of protectiveness afforded by the other alternatives
evaluated.

Alternative S-4A, Excavation and Off-Site Disposal, provides protection at the Site through the
removal of all soils with lead concentrations in excess of the Site-wide RAL, including PTW
soils. This provides the most permanent means of risk reduction among the soil alternatives
evaluated and produces a Site that can be redeveloped without posing an unacceptable risk to
construction workers or future users or requiring overly restrictive controls for material handling.

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Alternative S-3, Excavation and Off-Site Disposal of PTW, would require special procedures to
protect human health during redevelopment, because it leaves materials on the Warehouse Parcel
and Main Parcels A and B that can represent an unacceptable risk to future construction workers.
Alternative S-4B provides protection by consolidating varying amounts of RAL soils in an on-
site consolidation unit under an engineered cap to provide protection by preventing future
exposure instead of being sent for off-site disposal. Although Alternative S-4B is protective, it
does not achieve the same protectiveness as Alternative S-4A.

Sediment Alternatives

The No Action Alternative does not provide protection of human health and the environment,
because it does not eliminate or control the current and future risks from contaminated sediment
on the Main Parcel or potential transport of contaminated sediment downstream. The No Action
Alternative will not be discussed further in the nine criteria analysis, because it does not satisfy
the threshold criterion of providing overall protection to human health and the environment.
Alternative SD-2 provides protection to human health and the environment by relying on
institutional controls to prevent exposure and disturbance of the current gabion mattress system.
However, because Alternative SD-2 does not include removal of sediments from the gabion
mattresses and pipes, there is the potential for continuing contamination of downstream ,
sediments. Contaminated sediment could potentially be released during storm events thereby
potentially affecting downstream ecological habitat. Both Alternatives SD-3 and SD-4 are
protective of human health and the environment, because contaminated sediment would be
removed (Alternative SD-3) or the Creek channel would be relocated (Alternative SD-4), thereby
decreasing the potential for contaminated sediment release downstream. Alternative SD-4
provides protection because the stream channel would be relocated; contaminated sediment
would remain capped in-place under the current gabion mattress system liner of Alternative SD-
3, even though contaminated sediment would be removed from within the gabion mattresses.
Alternative! SD-4 provides protection at a higher cost and would be more difficult to implement.

2. Compliance with ARARs

Any cleanup alternative selected by EPA must comply with all applicable or relevant and
appropriate federal and state environmental requirements or provide the basis upon which such
requirement(s) can be waived. Applicable requirements are those environmental standards,
requirements, criteria, or limitations promulgated under federal or state law that are legally
applicable to the remedial action to be implemented at the Site. Relevant and appropriate
requirements, while not being directly applicable, address problems or situations sufficiently
similar to those encountered at the site that their application is well-suited tp the particular
circumstance.

EPA will also consider to-be-considered material (TBCs) along with ARARs. TBCs are non-
promulgated advisories or guidance issued by federal or state governments that are not legally
binding and do not have the status of potential ARARs. However, EPA may use the TBCs in
determining the necessary level of cleanup for protection of human health and the environment.

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A complete listing of ARARs and TBCs for the preferred alternatives for OU-2 of the Price
Battery Site is presented in Appendix D to this ROD.

Soil Alternatives

Alternative S2, Institutional Controls, would not meet chemical-specific ARARs, because
contaminated PTW soils and RAL soils would remain in-place without further treatment. In
addition, the coyer provided by the existing pavement floor would be less than the two-foot
thickness called for by PADEP requirements (25 PA Code 288.234); therefore, the action-
specific ARAR for capping would not be met unless provisions for demonstrating the
acceptability of utilizing alternative cover systems are implemented. Alternatives S-3, S-4A and
S-4B would meet action-specific ARARs related to erosion and sediment control, contact water
discharge, Land Disposal Restrictions, off-site waste handling, and on-site waste handling.
Alternatives S-4A and S-4B would meet chemical-specific ARARs related to soil and air.
Alternative S-3 would meet chemical-specific ARARs related to air, but would not meet
chemical-specific ARARs related to soil if RAL soils are allowed to remain on-site without a
permanent cover.

Sediment Alternatives

Alternative SD-2 would not mfeet chemical-specific ARARs (i.e., EPA freshwater sediment
screening levels) for freshwater sediment, as the risk associated with the potential release of
contaminated sediments downstream would not be addressed. Alternative SD-3 would meet the
freshwater sediment chemical-specific ARAR, because sediment oil the gabion mattress liner
system and within the pipes beneath the Main Parcel would be addressed. Alternatives SD-3 and
SD-4 would meet the action-specific ARAR for work in waterways and location-specific ARARs
of the Clean Water Act by bypassing flow during the work and implementing sediment controls.
Alternative SD-3 would further meet Clean Water Act requirements by incorporating measures
to collect and treat pore water from within the sediment/gabion matrix. Alternatives SD-3 and
SD-4 would meet the freshwater sediment chemical-specific ARAR, because sediment within the
pipes beneath the Main Parcel would be removed, and sediment within the gabion mattress liner
system would be abandoned in-place.

3. Long-Term Effectiveness and Permanence

Soil Alternatives

Alternative S-2 by itself would not provide long-term effectiveness and permanence. The most
significant potential sources of contamination would remain even though institutional controls
would be implemented to require special management of impacted soils during intrusive
activities. Alternative S-4A would provide the highest degree of long-term effectiveness and
permanence, because all RAL and PTW soils would be excavated and disposed off-site.
Alternatives S-3 and S-4B would also provide long-term effectiveness arid permanence, but not
to the same degree as Alternative S-4A, because RAL soils would remain on-site under a cap or
within a capped on-site consolidation unit. Although Alternatives S-3, S4A, and S-4B could be
susceptible to future disturbance, properly implemented institutional controls and routine

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monitoring/inspections would mitigate potential problems. Long-term effectiveness and
permanence would be dependent on the ability to enforce and maintain ICs; however, any ICs
necessary for Alternative S-4A would be less burdensome than the ICs for the other soil
alternatives, because Alternative S-4A would leiave the least contamination in-place of all the soil
alternatives.

Sediment Alternatives

Alternative SD-2 would not provide long-term effectiveness and permanence, because the most
significant potential sources of contamination would remain. Although institutional controls
could provide some measure of protection against disturbance of contaminated sediment in the
pipes and Kaercher Creek, contaminated sediment transport downstream could remain a
possibility during storm events. Alternative SD-3 would achieve long-term protectiveness
through removal of contaminated sediment, stabilizing the gabion mattress system, and
addressing contaminated sediment in the underground pipes. Although SD-3 could be
susceptible to fixture disturbance, properly implemented institutional controls and routine,
monitoring/inspections would mitigate potential problems. Alternative SD-4 would also provide
long-term protectiveness and would be most conducive with the permanent, long-term use of the
Site.	,	.

4. Reduction of Toxicity, Mobility, or Volume Through Treatment

Soil Alternatives

Alternative S-2 would not provide any reduction in toxicity, mobility or volume through
treatment, because it would rely solely on institutional controls. Alternatives S-3, S-4A and S-
4B would provide for varying amounts of reduction in toxicity, mobility or volume through
treatment (i.e., stabilization) and off-site disposal of PTW soils. However, Alternatives S-3 and
S-4B would both allow RAL soils to remain on Site untreated, either under the existing cover or
under an engineered cap. Alternative S-4A would provide for the greatest reduction in toxicity,
mobility, or volume through treatment (i.e., stabilization) by excavating all RAL soils, in
addition to the PTW soils, arid treating these soils (pending TCLP results) via stabilization, either
on-site or off-site, prior to disposal of thesis soils in an approved off-site disposal facility.

Sediment Alternatives

Alternative SD-2 would not reduce the toxicity, mobility, or volume of contaminants in Kaercher
Creek, because it would rely solely on institutional controls. Alternatives SD-3 and SD-4 would
reduce the toxicity, mobility, or volume of contamination in the Creek through the removal of
contaminated sediment or relocation of the Creek, but not through treatment of the
contamination. However, Alternative SD-3 could reduce the toxicity and mobility of
contaminants in sediment removed from the gabion mattresses and pipes through treatment, if
the sediment would require stabilization prior to off-site disposal based on TCLP results.
Alternative SD-4 would not reduce the mobility, toxicity or volume of contaminated sediment
through treatment, because the current channel, including the contaminated sediments within the
gabion mattresses, would be abandoned-in-place underneath a cap. However, Alternative SDr4

51

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could reduce the toxicity and mobility of contaminants in sediment removed from the pipes
through treatment, if the sediment would require stabilization prior to off-site disposal based on
TCLP results.

5. Short-Term Effectiveness

Soil Alternatives

Alternative S-2 would hot have significant short-term effectiveness issues. Little or no field
activities would be necessary to implement Alternative S-2, and the implementation of
institutional controls would not take long. Alternatives S-3, S-4A, and S-4B would pose short-
term impacts related to construction activities, but impacts to workers and the community could
readily be controlled. During soil excavatibri, consolidation, stabilization (if conducted on-site),
and handling activities, there is the potential for the spreading of contaminants as airborne dust.
The construction specifications would include specific measures to control dust, and, when
properly implemented, exposures would be significantly reduced to workers and the local
community. Dust suppression measures including water sprays or manufactured dust-
suppression products would be used. Air monitoring would be conducted during activities with
the potential for dust generation. Additionally, the potential remains for off-site migration of
Site materials via sediment erosion during construction. Specific erosion and sediment control
measures such as silt fences, silt socks, or hay bales would be taken to mitigate this possibility.
Erosion arid sediment control measures would be selected during preparation of the construction
specifications. Impacts on traffic on the local roads by vehicular traffic between the Site and the
highway would be limited to delivery of construction materials and equipment, contractor
personnel and truck traffic being sent off-site for disposal, and hauling clean soil fill and cap
materials back to the Site. Alternative S-4A and S-4B would have greater short-term impacts
than Alternative S-3 because of the amount of material to be handled and transported. The
number of trucks for off-site disposal of contaminated soil could be approximately 200 to 300
trucks over one to two months with an equal amount for import of clean soil for Alternatives S-3
and S-4B and as much as 500 to 800 trucks over a two to four month period for Alternative S-
4 A.

The time to implement Alternative S-2 would be approximately 1 week and would be associated
with the administrative requirements to implement new or revised ICs. Alternative S-2 would
take approximately 22 weeks to implement followed by Alternatives S-4A and S-4B requiring
approximately 54 weeks and 56 weeks, respectively, to implement. The RAOs for soil would be
met at the completion of construction for Alternatives S-3, S-4A, and S-4B.

Sediment Alternatives

Alternative SD-2 would not have any significant short-term impact on the community, workers,
or the environment. For Alternative SD-3, during removal and handling of sediment, there could
be the potential for the spreading of contaminants in suspended sediment washing downstream,
dust (for dry sediment accumulated in pipes), or tracking by workers and equipment. These
short-term impacts could be adequately controlled through appropriate erosion and sediment
control measures. There would be some truck traffic associated with the removal of sediment,

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but it would not be expected to be significant and could be controlled with the implementation of
appropriate traffic safety measures. The short-term impacts due to construction would likely be
similar for Alternative SD-3 and Alternative SD-4, but impacts to workers and the community
could be readily controlled,similar to Alternative SD-3. The time to implement Alternative SD-2
would be approximately 1 week and would be associated with the administrative requirements to
implement new or revised ICs. Alternative SD-3 would take approximately 14 weeks to
implement followed by Alternatives SD-4 requiring approximately 61 weeks to implement
because of the relocation of Kaercher Creek. The RAOs for sediment would be met at the
completion of the construction activities for Alternatives SD-3 and SD-4.

6.	Implementability

Soil Alternatives

Alternative S-2 is essentially already implemented at the Site. Institutional controls are currently
in place; however, they would need to be re-evaluated and modified to account for possible
future redevelopment of the properties. Alternatives S-3, S-4A, and S-4B would be readily
implementable with proper planning and design. The excavation and management of soils and
construction of the cap are common environmental construction activities and would not require
the use of speciialized equipment, techniques, or labor resources. Implementation of a capping
solution would optimally be coordinated with a specific redevelopment plan to determine site
grading requirements. Administrative implementability would not be a concern for on-site
construction and post-construction administrative/institutional controls, because Exide owns all
of the properties to be remediated.

Sediment Alternatives

All of the sediment alternatives would be implementable. Alternative SD-2 is essentially already
implemented at the Site. However, the current institutional controls would need to be re-
evaluated and/or modified to provide the greatest degree of protection. Alternative SD-3 would
be the most readily implementable with proper planning and design. Alternative SD-4, Creek,
Realignment, would be the most difficult to implement, but could provide the greatest overall
benefit relative to optimizing the contiguous usable areas of the Main Parcel and integrating
community plans. However, SD-4 would be more difficult to implement than Alternative SD-3
and would provide only marginally more long-term protectiveness than SD-3 at a higher cost.

7.	Cost

Alternative S-4A would have the highest cost due to the volume of soil being removed and sent
off-site for disposal. Alternative S-2 involves minimal construction, and therefore Alternative S-
2 costs would be much lower. Alternative SD-4 would be more expensive than Alternative SD-3
by approximately $600,000 arid would be more difficult to implement than Alternative SD-3
with little additional risk reduction beinefit. The only costs associated with the No Action with
Monitoring alternative for ground water would be the annual monitoring costs and the costs

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associated with the installation of approximately two additional monitoring wells. The cost of
the Alternatives is provided in Table 11 below.

Table 11: Remedial Alternative Costs



Capital Costs



HSIBiiiig

SOIL







Alternative S-l

$0

$0

$0

Alternative S-2

$20,900

$5,400

$87,909

Alternative S-3

$1,109,994

$4,050

$1,160,251

Alternative S-4A

$2,731,416

$3,713 .

$2,777,484

Alternative S-4B

$1,691,585

$13,500

$1,859,107

SEDIMENT







Alternative SD-1

$0

$0

$0

Alternative SD-2

$20,900

$5,400

$87,909

Alternative SD-3

$265,605

$2,700

$299,109

Alternative SD-4

$817,742

$6,075

$893,126

GROUND WATER







No Action w/Moriitoririg

$6,380

$11,270

$146,230;

~Discount rate of 7% was used in calculation of Present Worth Costs

8.	State/Support Agency Acceptance

The Commonwealth of Pennsylvania supports the selection of No Further Action for OU-1 and a
combination of Soil Alternative S-4A, Sediment Alternative SD-3, and No Action with
Monitoring for ground water for OU-2 and has concurred on this ROD.

9.	Community Acceptance

A thirty-day public comment period on EPA's Proposed Plan for the Price Battery Site began on
July 15,2015. An advertisement announcing the issuance of the Proposed Plan and a public
meeting to discuss the Proposed Plan was placed in the Hamburg Item. The public meeting was
held on July 30,2015, at the Hamburg Borough Building, 61 North Third Street, Hamburg, Pa.
The meeting was attended by approximately 25 members of the community.

The community appeared to support EPA's findings and EPA's proposed remedial decision for
OU-1 and EPA's proposed remedy for OU-2. No one objected to EPA's preferred alternative,
nor did anyone recommend an alternative approach. EPA received several written comments
during the public comment period. EPA's responses to these comments are presented in the
Responsiveness Summary of this ROD.

A copy of the transcript of the public meeting is included in the Administrative Record. EPA's
written responses to questions/comments posed during the public meeting are provided in the
Responsiveness Summary of this ROD.

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K. PRINCIPAL THREAT WASTES

Principal threat wastes are source materials containing lead contamination that require
remediation based on toxicity, mobility, and the potential to create unacceptable human health or
ecological risks. The principal threat wastes at the Site consist of lead-contaminated soils above
94,100 ppm. The NCP (Section 300.430(a)(l)(iii)(A)) establishes a preference for treatment to
be used to address principal threat wastes when practicable. Treatment will be employed for the
remedy described in this ROD. Stabilization/solidification has traditionally been used in other
applications to stabilize lead-containing materials prior to disposal, and this methodology will be
used to treat lead-contaminated soils prior to off-site disposal. Stabilization/solidification is well
demonstrated and effective for eliminating site risks present at the Site.

L. SELECTED REMEDY

Following consideration of the requirements of CERCLA, a detailed analysis of the alternatives
using the nine criteria set forth in the NCP, and careful review of public comments, EPA's
Selected Remedy for OU-1 and OU-2 is as follows:

•	Operable Unit 1: No Further Action

•	Operable Unit 2: Combination of Soil Alternative S-4A, Sediment Alternative SD-3,

and No Action with Monitoring for Ground Water

1. Summary of the Rationale for the Selected Remedy
Operable Unit One - Residential Portion

On September 29,2009, EPA issued an Interim ROD selecting interior decontamination and
exterior yard remediation of residential properties while a more comprehensive RI/FS continued
to define the full extent of the residential contamination. However, as this comprehensive RI
progressed and additional properties were identified, these properties were incorporated into the
ongoing remedial action. EPA remediated these additional residential properties, and no further
action is necessary. The interim remedy selected in the 2009 Interim ROD may be considered
the final remedy for OU-1. The risks associated with exposure to interior lead-contaminated dust
and exterior soils has been addressed, and all ARARs associated with the remedy have been met.
EPA will continue public education and outreach as specified in the 2009 Interim ROD. EPA
has provided the Borough of Hamburg with a Registry which documents the cleanup status of
individual properties. Because some residential property owners declined participation in the
cleanup, EPA will perform Five-Year Reviews of the OU-1 remedy to ensure continued
protection to human health and the environment.

Operable Unit Two - Facility Portion

The Selected Remedy for OU-2 provides for the excavation, stabilization, and off-site disposal of
PTW and RAL lead-contaminated soils. Under Alternative S-4A, the Selected Remedy will
remove lead-contaminated soils to levels protective for future commercial redevelopment of the

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Exide-owned parcels of the Site and will result in a Site which requires less burdensome
institutional controls compared to the other alternatives evaluated. Alternative SD-3 provides for
the removal of lead-contaminated sediment from within the gabion mattresses and underground
pipes of the Main Parcel portion of the Kaercher Creek stream channel to levels protective of
human and ecological receptors both on-site and downstream of the Main Parcel.

EPA has selected No Action with Monitoring for ground water beneath the Exide-owned
portions of the Site. Only isolated well impacts have been noted in ground water and there is no
widespread ground water plume. The majority of contamination detected in ground water is
either not Site-related or will be addressed under other regulatory authorities. CERCLA does not
provide the authority to take remedial action for non-site related contaminants that may be
present. Continued ground water monitoring will ensure that Site ground water conditions do
not change.

EPA and PADEP believe the Selected Remedy will be protective of human health and the
environment, complies with ARARs, is cost effective, and utilizes permanent solutions to the
maximum extent practicable.

2. Description of the Selected Remedy and Performance Standards
Operable Unit One - Residential Portion

The Selected Remedy for OU-1 is No Further Action. The: remedial actions selected in the
September 30,2009, Interim ROD have been completed. EPA completed cleanup of the
Residential Portion of the Price Battery Site in October 2013. As the Comprehensive RI for OU-
1 progressed, EPA identified additional residential properties for cleanup, and EPA incorporated
these properties into the residential remedial action that was ongoing pursuant to the September
2009 Interim ROD for OU-1. EPA has completed the residential cleanup at all eligible
properties whose owners provided access. There are no known additional residential properties
(for which owners provided access) requiring cleanup. The September 2009 Interim ROD also
provided for institutional controls and ongoing public education regarding lead exposure risks.
Therefore, because no additional cleanup measures are necessary, EPA's Selected Remedy for
OU-1 is No Further Action, and to establish the OU-1 interim remedy as the final remedy for the
Price Battery Site OU-1, Residential Portion.

Operable Unit Two - Facility Portion

The Selected Remedy for OU-2, Facility Portion is a combination of Alternative S-4A,
Alternative SD-3, and No Action with Monitoring for ground water. The Selected Remedy is
excavation of PTW lead-contaminated soils and soils exceeding the RAL cleanup levels for lead
calculated specifically for the Facility Portion of the Price Battery Site. Contaminated soil will
be excavated to required cleanup levels, stabilized (on-site or off-site), and disposed of in an
approved off-site disposal facility. The resulting excavations will be backfilled with reclaimed
concrete and/or imported clean soils and graded for potential future commercial/industrial
redevelopment of the properties. Contaminated sediment in Kaercher Creek, on the Facility
property, will be removed and the current gabion mattress liner system will be reinforced to

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further stabilize the gabion mattress liner system. Underground pipes currently containing
contaminated sediment beneath the Facility will be cleaned out and grouted closed to prevent any
additional contamination from entering Kaercher Creek. No active cleanup measures will be
taken for ground water at the Site. However, new monitoring wells will be added to the current
monitoring well network (after soil remediation is implemented), and ground water will continue
to be monitored.

The components of the Selected Remedy are:

Soil:

1.	Removal of concrete pavement, floor slabs, and foundations overlying the RAL and PTW
contaminated soils. The concrete pavement, floor slabs, and foundations will be
segregated, cleaned to remove residual contamination (based on visual observations)
pursuant to the requirements of RCRA, crushed, and stockpiled. Crushed material will be
analyzed for inorganic constituents and the results compared against the PADEP
Statewide Health Standards for non-residential soils (direct contact) prior to reuse as
backfill.

2.	Excavation of soils from the Main Parcel and the Warehouse Parcel that exceed the
lowest calculated RAL (8,669 ppm) for lead-in-soil, including PTW soils, except to the
extent that contaminated soil cannot be removed because of field conditions (i.e.,
physical constraints, proximity of building foundations, maintaining safe excavation
slopes, encountering ground water, etc.).

3.	Excavated soils shall be sampled and analyzed using the Toxicity Characteristic Leaching
Procedure (TCLP) to determine the appropriate off-site disposal facility. Soils which
exceed the TCLP criteria may be stabilized on-site to render the soil non-hazardous or
transported to an off-site RCRA-permitted facility for appropriate treatment and disposal.

If stabilization is conducted on-site, the soil shall be mixed with a reagent (i.e. trisodium
phosphate or other reagents) to render it non-hazardous. Confirmation sampling shall be
conducted on the stabilized soils to ensure the soil is non-hazardous prior to off-site
disposal.

4.	Post-excavation confirmation sampling of excavation floor mid sidewalls to ensure RAL
levels have been achieved. Recalculate the exposure point concentration (EPC) utilizing
confirmation sample results collected after excavation.

5.	Backfill of resulting excavations with reclaimed crushed concrete and clean fill material
to levels at or near existing grades except as coordinated with Site redevelopment
activities. Any crushed material used for backfilling will be overlain by imported clean
fill. Reclaimed crushed concrete must meet backfill concentrations identified in the
BHHRA for lead (<50 ppm), arsenic (< 100 ppm), and antimony (< 46 ppm). If
reclaimed concrete exceeds 50 ppm lead (but is below the PADEP Statewide Health
Standards for non-residential soils for direct contact of 1,000 ppm lead), the RAL must be

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recalculated utilizing the actual concentration for the proportion of backfilling completed
using recycled concrete and additional soil remediation performed as appropriate to
achieve the desired RBC. Clean soil must meet Pennsylvania Criteria for Management of
Fill, or the backfill concentrations identified in the BHHRA, whichever is more stringent.

6.	Restore Site surfaces using concrete, asphalt, buildings, and landscaping in a manner
consistent with plans for Site redevelopment and suitable for preventing erosion of soils
above residential remediation standards and as specified by erosion and sediment control
requirements. -

7.	Implement institutional controls (ICs) to ensure that the remedy provides an adequate
measure of protection in light of current and anticipated commercial/industrial future use
of the Site. Such additional institutional controls will include notification to future
property owners that contaminated soils remain in-place and that special handling of
these soils would be required if these soils are disturbed during redevelopment
construction activities. No residential use of the properties will be permitted. ICs will
include activity and use restrictions enacted through proprietary (e.g., easements,
covenants) and/or governmental (e.g., zoning requirements) controls to prevent use of the
property that will pose an unacceptable risk to receptors. The exact type of IC
implemented will be determined by EPA in consultation with PADEP and local
government agencies. The restrictions in the current Declaration of Use and Deed
Restriction Will be incorporated into any new institutional controls.

Sediment:

1.	Remove accumulated sediment from the gabion mattress, to the extent possible, using a
vacuum truck or equivalent. Remove sediment from underground pipes and penetrations
including, but not limited to, Pipes 1,2, and 3. Grout any underground pipes, as ' .
necessary, to further prevent contaminated sediment within any pipes from entering
Kaercher Creek.

\ ,

2.	Dispose of accumulated sediment off-site or use as backfill in on-site soil excavation
areas if coordinated with soil remediation and sediment meets the same requirements for
other soils under Alternative S-4A, above.

3.	Grout gabion mattress to ensure long-term stability of the Creek bed.

4.	Perform annual inspections to confirm that the gabion mattress and channel walls remain
stable and remove accumulated trash and debris to maintain the hydraulic capacity of the
channel.

5.	Implement institutional controls to prohibit removal of the gabion mattress or excavation
of soils within or along the Creek in conjunction with the IC requirements of Alternative
S-4A.

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Ground Water:

No active cleanup measures will be taken for ground water at the Site.

1.	Install new monitoring wells to the current monitoring well network after soil remediation
is implemented. Redevelop or replace monitoring well BW-3 to address turbidity
problems within the monitoring well.

2.	Conduct quarterly ground water sampling. After eight consecutive quarters of
monitoring, conduct at statistical evaluation to determine contaminant concentration
trends and continue statistical analysis annually. Reevaluate need for continued
monitoring at five-year intervals.

In summary, the OU-2 Selected Remedy is believed to provide the best balance of trade-offs
among all the alternatives evaluated with respect to the nine criteria above. Based on the
information available at this time, EPA believes the OU-2 Selected Remedy would protect
human health and the environment, would comply with ARARs, would be cost effective, and
Would utilize permanent solutions and alternative treatment technologies to the extent
practicable. The OU-2 Selected Remedy would also meet the statutory preference for the
selection of a remedy that includes treatment as a principal element.

3.	Cost Estimate for the OU-2 Selected Remedy

Appendix E includes details of the estimated costs to construct and implement the OU-2 Selected
Remedy. The estimated total cost to construct and implement the OU-2 Selected Remedy is
$3,222,823. The information in this cost estimate is based on the best available information
regarding the anticipated scope of the remedial action.	1

Some changes to cost are expected to occur during implementation of the remedy. Major
changes may be documented in the form of a technical memorandum in the Administrative
Record, an ESD, or a ROD amendment. This cost estimate is expected to be within +50 to -30
percent of the actual project cost.

4.	Expected Outcome of the OU-2 Selected Remedy

The OU-2 Selected Remedy is consistent with the current zoning of the Exide-owned portions of
the Site. Although no residential development would be permitted under the OU-2 Selected
Remedy, the OU-2 Selected Remedy is consistent with the Borough's BD and VC zoning which
allows future use of the properties for commercial redevelopment. The OU-2 Selected Remedy
will provide for a Site which is suitable for future commercial/industrial use. Other than the
building on the Warehouse Parcel of the Exide-owned properties, the remaining parcels are
vacant. The Parking Lot Parcel has already been acquired by Berks County with the expectation
that it will be donated to the Borough of Hamburg for use as additional public parking. It is
anticipated that the remediation of the Warehouse and Main Parcels will result in increased
property values, job creation, and increased tax revenues due to redevelopment.

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M. STATUTORY DETERMINATIONS

Under CERCLA (42 U.S.C. § 9621) and the NCP (40 C.F.R. § 300.430(f)(5)(ii)), EPA must
select remedies that are protective of human health and the environment, comply with ARARs,
are cost effective, and utilize permanent solutions and alternative treatment technologies or
resource recovery to the maximum extent possible. There is also a preference for remedies that
use treatment that permanently and significantly reduce the volume, toxicity, or mobility of
hazardous wastes as a principal element. The following sections discuss how the remedy meets
these statutory requirements.

1.	Protection of Human Health and the Environment

!

The Selected Remedy for OU-1 is No Further Action. The Remedial Action Objectives selected
in the September 30,2009, Interim ROD are protective of human health and the environment and
have been met at all eligible residential properties whose owners provided access for cleanup.
There are no known additional residential properties (for which owners provided access)
requiring cleanup.

The OU-2 Selected Remedy will provide protection of human health and the environment by
achieving the Remedial Action Objectives through conventional engineering measures. Risks
associated with lead-contaminated soils and sediment at the Site are caused by the potential for
direct contact with contaminated soils and sediment. The OU-2 Selected Remedy eliminates this
direct exposure pathway through excavation and replacement of lead-contaminated soils.
Contaminated soils will be removed from remediated areas, permanently eliminating this
identified source of exposure. Likewise, removal of contaminated sediments will significantly
reduce exposures to lead-contaminated sediment within the on-site portions of Kaercher Creek.
The implementation of the OU-2 Selected Remedy will not pose unacceptable short-term risks or
cross-media impacts.

2.	Compliance with Applicable or Relevant and Appropriate Requirements

The NCP (40 C.F.R. § 300.430(f)(5)(ii)(B) and (C)) requires that a ROD describe Federal and
State ARARs that the remedy will attain or provide a justification for any waivers. Applicable
requirements are those cleanup standards, standards of control, and other substantive
environmental protection requirements, criteria, or limitations promulgated under Federal or
State law that specifically address a hazardous substance, pollutant, or contaminant; remedial
action; location; or other circumstance at a CERCLA site. Relevant and appropriate
requirements, while not legally applicable to circumstances at a particular CERCLA site, address
problems or situations similar to those encountered at the site such that their use is considered
relevant and appropriate.

The Selected Remedy for OU-1 is No Further Action. The remedial actions selected in the
September 30,2009, Interim ROD have been completed and complied with all Federal and State
requirements, standards, criteria and limitations that were applicable or relevant and appropriate,
as required by section 121(c) of CERCLA, 42 U.S.C. § 9621(c). Such requirements, standards,
criteria and limitations were identified in the 2009 Interim ROD.

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The OU-2 Selected Remedy will comply with all Federal and State requirements, standards,
criteria and limitations that are applicable or relevant and appropriate, as required by section
121(c) of CERCLA, 42 U.S.C. § 9621(c). Such requirements, standards, criteria and limitations
are identified in Appendix D of this ROD.

3.	Cost Effectiveness

Section 300.430(f)(l)(ii)(D) of the NCP, 40 C.F.R. § 300.430(f)(l)(ii)(D), requires EPA to
evaluate cost effectiveness by comparing all of the alternatives that meet the threshold criteria
against long-term effectiveness and permanence, short-term effectiveness, and reduction of
toxicity, mobility or volume through treatment (collectively referred to as "overall
effectiveness"). The NCP further states that overall effectiveness is then compared to cost to
ensure that the remedy is cost effective and that its costs are proportional to its overall
effectiveness.

EPA concludes, following an evaluation of these criteria, that the Selected Remedy is cost
effective in providing overall protection in proportion to costs and meets all other requirements
of CERCLA. The estimated present worth cost of the OU-2 Selected Remedy is $3,222,823.

4.	Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable

The Selected Remedy for OU-1 is No Further Action. The remedial actions selected in the
September 30,2009, Interim ROD have been completed and utilized permanent solutions and
alternative treatment technologies to the maximum extent practicable.

EPA has determined that the OU-2 Selected Remedy represents the maximum extent to which
permanent solutions and treatment are practicable at the Site. When compared to the other
protective alternatives that were evaluated, EPA has determined that the OU-2 Selected Remedy
provides the best balance of trade-offs in terms of the five balancing criteria, as well as the
preference for treatment as a principal element. The remedy also has State and community
acceptance.

The OU-2 Selected Remedy will meet the statutory preference for treatment as a principal
element by addressing principal threat waste by excavating PTW and RAL lead-contaminated
soils, stabilization of these soils, and off-site disposal. Stabilization/solidification of lead-
contaminated excavated soils is a demonstrated treatment technology with the ability to reliably
provide short-term and long-term effectiveness and permanence. The OU-2 Selected Remedy
best satisfies the statutory mandates for permanence and treatment.

5.	Five-Year Review Requirements

CERCLA (42 U.S.C. § 9621 (c)) and the NCP (40 C.F.R. § 300.430(f)(4)(ii)) provide the
statutory and legal bases for conducting Five-Year Reviews. The Selected Remedy for OU-1
does not result in hazardous substances, pollutants, or contaminants remaining on residential

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properties that underwent cleanup above levels that allow for unlimited use and unrestricted
exposure. Five-Year Reviews of remediated residential properties thus are not neciessary.
However, in those cases where it was not possible to achieve the soil cleanup levels or a resident
had voluntarily determined not to participate in the cleanup, hazardous substances might remain
in-place; and therefore, a statutory review will be conducted every five years. The trigger date
for the first Five-Year Review was the on-site OU-1 interim remedial action start date of August
16,2010. EPA issued the first Five-Year Review Report for OU-1 on August 3,2015.

The Selected Remedy for OU-2 will result in hazardous substances remaining on-site (i.e., the
Exide-owned properties) above levels that allow for unlimited use and unrestricted exposure.
Therefore, a statutory review will be conducted every five years coinciding with the first Five-
Year Review Report completion date of August 3,2015 for OU-1.

6.	Documentation of Significant Changes

The Proposed Plan for the Price Battery Site was released for public comment on July 15,2015.
The public comment period for the Proposed Plan was held from July 15,2015 to August 14,
2015. EPA held a public meeting on July 30,2015, to present the proposed remedial decision for
OU-1 and the Preferred Alternative for OU-2 in the Proposed Plan. EPA has reviewed and
responded to verbal and written comments submitted during the public comment period in Part
III of this ROD, the Responsiveness Summary. There are no significant changes from the
Preferred Alternative presented in the Proposed Plan.

7.	State Role

P ADEP, on behalf of the Commonwealth of Pennsylvania, has reviewed the Remedial
Alternatives presented in this ROD arid has provided its concurrence with the Selected Remedy.

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III. THE RESPONSIVENESS SUMMARY

Overview of Responsiveness Summary

This section summarizes the questions and comments received during the Proposed Plan public
comment period for this ROD for the Price Battery Site. The Proposed Plan was released for
public comment on July 15,2015. The public comment period ran from July 15 to August 14,
2015. A public meeting was held at the Borough of Hamburg Municipal Building on the
evening of July 30,2015.

The transcript for the public meeting is provided in the Administrative Record for the Site.
COMMENT#!:

A local business representative indicated during the public meeting that his business has been
trying to purchase the Exide property; however, this has not yet been possible because of the
Superfund activities ongoing at the Site. The representative stated that Exide has filed for
Chapter 11 bankruptcy and asked what the possibility would be that Exide can pay the $3.2
million projected for cleanup costs, and if the 54 weeks is a reasonable timeframe for the Site
cleanup.

The local business representative also asked how soil would be removed underneath the
Warehouse property for the one to six foot area of soil removal.

RESPONSE TO COMMENT #1:

The Exide-owned portions of the Site are addressed in the OU2-ROD for the Site. EPA may not
begin to pursue its enforcement options until the OU2-ROD is issued. Furthermore, EPA policy
expressly forbids discussion of EPA enforcement activities until those activities are public. It
should be noted, however, that pursuant to an earlier bankruptcy settlement agreement between
EPA and Exide, approved by order of the Bankruptcy Court on May 25,2011, Exide remains
responsible for the cleanup of the Exide-owned portions of the Site.

/ ^

A remedial design needs to be completed before the start of Site cleanup. The estimated 54
weeks to implement the cleanup remedy begins at the actual initiation of the construction phase
of the cleanup (i.e., shovels in the ground) and continues to the completion of the cleanup action
but does not include the time needed to formalize agreements, design, etc.

No soil would be removed underneath the Warehouse. However, soil removal would be
performed as close to the building as structurally possible. The remedial design of the cleanup
remedy would provide the details of the excavation including the excavation limits, depths, and
other requirements associated with excavating near building foundations and/or other known
surface or subsurface obstructions or features.

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COMMENT #2:

A representative from U.S. Representative Charles Dent's Office asked what happens if Exide
does not pay for or perform the cleanup.

RESPONSE TO COMMENT #2:

If Exide does not perform the work, EPA will consider using Superfund money to fund the
design and construction of the cleanup remedy.

COMMENT #3

A local citizen asked if surfaces other than floors were sampled in a residence at OU-1 and if a
lead testing machine was utilized.

RESPONSE TO COMMENT #3:

EPA only sampled residential floor surfaces for the presence of lead dust which might be
attributable to the former smelter operation and tracked into the home by foot traffic from
contaminated yards. EPA did not test window sills, for example, due to the high potential for
lead dust to be present in these areas from lead paint. If a residence was located in the predicted
lead depositional area then any lead dust found on interior floors was remediated, regardless of
whether the residence had lead paint. However, as part of the residential interior cleanup
procedures, all walls were washed and vacuumed. Lead wipe tests were completed on floors to
ensure cleanup levels were achieved. An X-ray fluorescence (XRF) instrument was utilized to
screen for lead in residential yards and less frequently within residential interiors. Although the
cleanup did not entail lead-based paint abatement, EPA notified homeowners, as a courtesy, if
lead was suspected in residential paint.

COMMENT #4

A local citizen stated that the Parking Lot parcel was owned by Hamburg Borough and not
Exide, and asked whether there were any plans to perform remediation work at the Parking Lot
parcel. Also, this citizen asked what the timeframe would be for the remaining work at OU-2,
and whether properties would have access to Peach Alley during remediation activities at OU-2

RESPONSE TO COMMENT #4:

The Hamburg Borough Building Inspector responded that the Parking Lot parcel was purchased
by the County and then donated to Hamburg Borough. There are no cleanup activities proposed
for the Parking Lot parcel. The estimate for the remaining work would be 8 to 12 months for the
remedial design, and it would likely be 2017 before construction for the Site cleanup actually
begins. The construction schedule would be developed during the remedial design of the
cleanup remedy. Peach Alley access would be available during remediation activities for OU-2
because access to the facility would likely be from Grand Street and/or Walnut Street.

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COMMENT #5:

A local citizen asked how long the gabion mattresses in the Kaercher Creek would last, and how
long ground water would be monitored.

RESPONSE TO COMMENT #5:

The life expectancy of gabion mattresses depends on the lifespan of the wire, not on the contents
of the basket. The structure will fail when the wire fails. Galvanized steel wire is most common,
but PVC-coated and stainless steel wire are also used. The estimated life-expectancy of a gabion
system can be 50 to 60 years or more depending on the type of wire. Ground water monitoring
will be performed quarterly for two years. After eight consecutive quarters of monitoring, a
statistical evaluation will be conducted to determine contaminant concentration trends. Based on
EPA's review of the results, the statistical analysis of the ground water data will continue to be
conducted annually. The need for continued monitoring will be re-evaluated during the Five-
Year Reviews of the Site at which time the ground water monitoring program may be modified
or discontinued depending upon the results..

COMMENT #6:

A local citizen asked if excavation activities will cause lead dust to become airborne, and
whether contaminated water will be used for dust suppression.	;

RESPONSE TO COMMENT #6:

Air monitoring will be conducted during construction activities to ensure air-borne lead levels
remain at acceptable levels. Dust suppression techniques such as applying water will be utilized
during excavation. Contaminated water will not be used for dust suppression.

COMMENT #7: •	. . "

An email comment was received requesting that EPA please cleanup the property. It is a
dangerous place now. If cleaned, it can be developed into a useful place for the community.

RESPONSE TO COMMENT 7:

EPA thanks the commenter for the email. EPA notes that the remedy in the ROD, orice
implemented, will result in the property being placed back into beneficial reuse as a commercial
and/or industrial property.

COMMENT #8:

A written comment was received from a local citizen requesting that EPA consider cleaning and
reopening Kaercher Creek Park in Windsor Township, Pennsylvania. The commenter stated that

65

AR307540


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it is awful that this beautiful park has been closed due to lack of funds for battery cleanups and
that the park was used by thousands yearly and is now in disrepair and disgrace.

RESPONSE TO COMMENT #8:

Kaercher Creek Park does not fall under the EPA Price Battery Site cleanup. The Price Battery
cleanup is limited to lead deposition in residential areas from the former Price Battery smelter,
the former Price Battery facility properties, and Mill Creek, Kaercher Creek (downstream of
Kaercher Creek Park), and the Schuylkill River. PADEP is the lead environmental agency for
the Kaercher Creek Park cleanup. Correspondence may be addressed to:

Mr. David Hrobuchak
PADEP

South Central Regional Office
909 Elmerton Avenue
Harrisburg, PA 17110

EPA has made PADEP aware of this commenter's concerns.

COMMENT #9:

An email was received from a local commercial business owner requesting where information
concerning Price Battery OU-1 and OU-2 could be found, as well as a report that summarizes
historic soil sampling/XRF results and ground water results from their property, including site-
specific PADEP Act 2 standards for OU-1 and OU-2.

RESPONSE TO COMMENT #9:

All documents supporting EPA' s selection of the remedy are contained in the Price Battery
Administrative Record which is available at www.epa. eov/arweb. Click "PA", then "Price
Battery", then "Remedial OU-1 and OU-2". The Administrative Record for the Price Battery
Site may also be found at the Hamburg Borough Public Library as well as the EPA Region III
Offices in Philadelphia, PA. EPA worked directly with this commenter to supply the requested
information.

66


-------
APPENDIX A
ADMINISTRATIVE RECORD


-------
PRICE BATTERY
' QUI & 0U2 ADMINISTRATIVE RECORD FILE*
INDEX OF DOCUMENTS

II.

REMEDIAL ENFORCEMENT PLANNING

Letter to Mr. John Banks, U.S. EPA, from Mr. Martin

Siegel, Pennsylvania Department of Environmental .
Protection (PADEP), re: Response^ to September 19, 2006,
letter to Arthur Dalla Piazza regarding the Site,
10/31/04. P. 200001-200001.

Letter to Ms.- Sharon Shutler	Peter Knight,

National Oceanic and Atmospheric AdministratiS^JpSAA),
from Mr. John Banks, U.S. EPA, re:' 122 (j) notification
and NOAA participation in negotiations,,regarding
response to release or threatened relfp'ase of hazardous

substances, 9/19/06. P.
Location Map, is attach#!?



-200004. Figure 1, Site

¦p'	, ,^

Letter to Ms. Sharon|^hutlgr	Knight, NOAA,

from Mr. John Banks, i||jj|3. |fePA,	122 (j ) notification

and'NOAA part icj^ft ion ii^negotaiations regarding
response to- reljli'e or t|fr?eaJielled release of hazardous

substances, ||4M/06. P. %|®ir5-20000-9. A certified

¦ mail receipliS
attached. *

Figure 1, Site Location Map, are

4. Lette|||feg||Mr. AntB'^^f'Conte and Mr. Mike Cheznik,

Department of the Aterior (DOI), from Mr. John Banks,
U|p3. EPA, re: ,122*(j) notification and DOI participation
|H ne.gotiat^|^p^rega.rding -response..to release or
§||a:eatened iJBflase of hazardous substances, 9/19/06.
IfS^0OOlO-2iOl)O12. Figure 1, Site Location Map, is

Letter to Mr. Anthony Conte and Mr. Mike Cheznik,
Department of the Interior (DOI)., from Mr. John Banks,
U.S. EPA, re: 122(j) notification and DOI participation
in negotiations regarding response to release or

Administrative Record File available 7/14/15, updated
//.

AR307543


-------
threatened release of hazardous substances, 9/19/06.
P. 200013-200019. Certified mail receipts and Figure 1,
Site Location Map, are attached.

8.

9.

10,

Letter to Mr. Arthur Dalla Piazza, PADEP, from Mr. John
Banks, U.S. EPA, re: .Notification of RI/FS Negotiations
and PADEP participation, 9/19/06. P. 200020-200024. A
certified mail receipt and Figure 1, Site Location Map,
are attached.

Letter to Mr. Gordon Ulsh, Exi
from Mr. Abraham Ferdas, U.S.
Letter for the "Owned Propert
Waiver of Special Notice for t
portions of the Site, 9/29/06

Techncp
IPA, re: J

j|es, Inc.,,

^ji^al Notice

toortJifens	Sit|e and

SK-> Mr	. m

-owned

,00025-200(

Letter to Mr. John Banks, U.S. EPA,
Collings, Schnader Harrison Segal &
of Exide Technologies, Inc.re:
Notice -"Letter/Good ' FaiMTOf £ e'r or
portions of the Site/jjfi2VlL$05fj

Letter to Mr
from Mr. James
Faith Offer
Bafetery Sup

ip® Mr .^Robert
Lewis LLP, on behalf

spbfi»r to Special

ISF*

Owrj^ti Property"
2015068-200078.

Exidjg^technologies, Inc»,

¦Gordon 1

Ipb, U.S. tEPA,^e: Acceptance of Good
"Owned	portions of ' Price'

d site,	P. 200079-200079.

trative

for Rio%iial Invel

MatjtefSl

LLement Agreement and Order on Consent
ptotf^on/Feasibility Study, in the
Price li^^Kery Superfund Site, Docket No.
|011§Djlf 5/30/07. P. 200080-200123. A May
¦2007-,	letter to Mr. Robert Collings,

SShnader Hari»M)n Segal & Lewis LLP, from Mr. Thomas
Cinti, U.S.JEPA, is attached.

11. Letter to" Mr. John Banks, U.S. EPA, from Mr. Matthew

Love, Exide Technologies, re: Notification of Change in
Ownership - Parking Lot Parcel, Exide-Owned Properties,
3/1/13. P. 200124-200126. A Site Layout figure is
attached.

AR307544


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III. REMEDIAL RESPONSE PLANNING

Report: Final Site Management Plan for Remedial
Investigation Feasibility Study, Price Battery Site,
Hamburg, Berks County, Pennsylvania, prepared by CDM
Federal Programs Corporation (CDM), 10/13/06.
P.300001-300145. A transmittal letter to Mr. John
Banks, U.S. EPA, from Ms. Joan Knapp, CDM, is
attached.

Letter Report to Mr. John BankspT U. S. BS^^from Mr.
Daniel Gilroy, CDM, re: Addendum to tJlf%I|lai • Site
Management Plan, 2/12/07. P. Q0,014§.-#30016i|fl

w

shew

Letter to Mr. John Banks, U.S.

;ifrom Mr

Love,. Exide Technologies, re: ^j^e^lf^tion of Project
Coordinator, 7/17/07 . P. 300l1>9-300172. A r(esume for
Mr. Matthew Love is attached.

Letter to Mr.- Matthew Jpdve^
Mr. John Banks, U.S. EPA, r

ide Technologies, from
¦Ss^cejgtahce of Project

Coordinator, 7/27/07-,

*§§§

#OOl«PS0173.f

M

Letter to Mr. M^trpiew Lorn, Exipe Technologies, from
Mr. John BanJgg,|fU.S. EPAceptance of Project
Ca»sultant, -Jlil/07. P. ^^74-30017.4.

Report

jfe. John Banks, U.S. EPA, from Mr.

MattHjjjjtpve,- Exide Technologies, re: Progress. Report

Letter Rep

P ^^175-300176

John Banks, U.S. EPA,

WIS

Matthew f^e, Exide Technologies, re:
>rt No. 2f ^/7/07. P. 300177-300178.

"Fi*".., .. r'-',	..	¦

Igfeport to Mr. John Banks, U.S.

from
Progress

EPA, from Mr.

Matthew Love, Exide Technologies, re: Progress Report
No. 3, 10/8/07. P. 300179-300180.

Letter Report to Mr. John Banks, U.S. EPA, from
Mr. Matthew Love, Exide Technologies, re: Progress'
Report No. 4, 11/5/07. P. 300181-300182.

3

AR307545


-------
10. Letter to Mr. John Banks, U.S. EPA, from Mr. Matthew

Love, Exide Technologies, re: / Schedule for submittal of
RI/FS Work Plan, Exide-Owned Portion of Site, 11/13/07.
P. 300183-300183.

11.

12

13

14

15,

16,

17,

Letter Report to Mr. John Banks, U.S. EPA, from
Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 5, 12/4/07. P. 300184-300185.

Letter to Mr. John Banks, U.S. E
Stratman, Advanced GeoServices,^re: ' Si|
Work Plan, Exide-Owned Properties, 12/5/
300186.

rqtkMfc-

Paul
sion of RI/FS
300186-

EPA, from js
Advanced

Letter-Report'to Mr..John Banks
Elizabeth Sussman and Mr. Paul Stratman,
GeoServices, re: Preliminary Reuse%^sessment' for
Exide-Owned properties, 1/21/08. P.

00187#300194.

June 2006 Land Use Plan
attached.

Letter to Mr. John B

ipe and Site photographs are

' M



i|||pffrom Mr. Asuquo

Effiong, PADEP,	%fee,^al''IilfSS^igation/Feasibility

'Study • (RI/FS) Wj^c?Plan',- J^idejf)*med Properties,
1/28/08. P. ,;3Q|ll95-3,001<

John Banks, U.S. EPA, from
ide Technologies, re: Progress
P. 300197-300198.

to Mr. John Banks, U.S. EPA, from Mr. Rich

; ¦ "W

Addendum Number 2 to the Final Site
2/25/08. P. 300199-300223.

to Mr. John Banks, U.S. EPA, from Mr.

Exide Technologies, re: Progress Report
P. 300224-300225.

18. Letter to Mr. Matthew Love, Exide Technologies, from
Mr. John Banks, U.S. EPA, re: EPA comments to RI/FS
Work Plan, 3/11/08. P. 300226-300257. Related
documents are attached.

4

AR307546


-------
J

19.	Meeting Minutes, RI/FS Work Plan Meeting Review with
Exide, Operable Unit 2, 3/26/08. P. 300258-300277. An
April 8, 2008, cover letter to Mr. John Banks, U.S. EPA,
from Mr. Richard Opem, CDM, is attached.

20.	Letter to Mr. John Banks, U.S. EPA, from Mr. Matthew
Love, Exide Technologies, re: Deadline for Submittal of
Revised RI/FS Work Plan, Exide-Owned Portion of Site,
3/28/08. P.. 300278-300278.

'--M'-	

21. Letter Report to Mr. John Banks^'' U. S. EPA, yf rom
Mr. Matthew Love, Exide Technologies, re:

Report No. 9, 4/4/08. P. 3002ff§!c300,p0.

22. Letter to Mr. John. Banks, U.S. .^^fe;£roni Mr. fllilF*

Stratman, Advanced GeoServices,,^r^E%p.esponse to USEPA
March 11, 2008, comments on Rl/FS W
-------
Revised RI/FS Work Plan dated April 25, 2008, 7/14/08.
P. 300843-300844.

29

30,

31.

33

34

Letter to Mr. John Banks, U.S. EPA, from Mr. Paul
Stratman, Advanced GeoServices, re: Response to USEPA
Comments on1 Revised RI/FS Work Plan dated April 25,
2008, 8/1/08. P. 300845-300874. Replacement pages for
the RI/FS Work Plan are attached.

Letter Report to Mr. John Banks,.U.S.f
Mr. Matthew Love, Exide Technologies,
Report No. 13, 8/8/08. P. 300^75-3008

Electronic memorandum to Mr. Joh
Mr. Paul Stratman, Advanced Geolf
and addenda to RI/FS Work Plan^%
300878.

32- Letter to Mr. Matthew LqExide

Mr. John Banks, U.S.
- Exide-Owned Proper

Letter Report to
Matthew Love,
No. 14, 9/9/

rom

rogress

i^ffrom

pS'ge's
300877-

> w ¦
ogies,

from

RI/FS Work Plan Approval
8/2.8/08 . ,P. ^300879-300879 .

anksjNISfS. EPA,

Hate TechiflSloaie's, re:

from Mr.
Progress Report

H81.

R|||p|g^:	Management Plan for Remedial

;ih^i^^gation/P^fe4bilit;y Study Oversight, Operable Unit
2, PFCi^^attery^SQ^und Site, Hamburg, Berks County,
Pennsylvania, prepaid by CDM, 9/15/08. P. 300882-
30^*971. ¦' re: Progress
Report No. 15, 10/9/08. P. 300972-300973.

36. Letter Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report NO. 16, 11/7/08. P. 300974-300975.

37. Letter Report to Mr. John Banks, U.S. EPA, from Ms.

Lucinda Pype, CDM, re: Addendum Number 3 to the Final
Site Management Plan, 12/5/08. P. 300976-301015.

6

AR307548


-------
38. Letter Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 17, 12/10/08. P. 301016-301017.

39,

40

41.

42

43

44

Memorandum to Mr. Matthew Love, Exide Technologies, from
Mr. Matthew Potter, Advanced GeoServices> re: Screening
Level Exposure Evaluation, 12/11/08. P. 301018-301024.
A Kaercher Creek Sediment Analytical,. Results^ Table and
Site photographs are attached.

ion

Draft for Release Remedial

Report:

Report, Exide-Owned Propertiesj^Pric# Bat€1lfe^gupe]|£und

Site, Hamburg, Pennsylvania/ pre
GeoServices, 12/18/08. P. 3010*_i

by Adv&nced||§F
2 46 0.

Letter Report to Mr. John Banks, U, . S. EPA, f j.om Ms.
Lucinda Pype, CDM, re: Round 4A & 5 Remedial.
Investigation Data Summax^^port¦, Ope^Spffe Unit 1,
12/18/08. P. 302461-3ji

from
Progress

Development and Stileening of Alternatives,

Blighties, Price Battery. Superfund. .site,

Letter Report to Mr. Jlgfohn .BknksM-UHB. EPA,
Mr; Matthew Love^^xiSBe?-Tjehnolfijfles, re:
Report No. 18, 1/9/0-9pJI, 302406-30.2477 •

Report:

Ownedp^

^'B^iys,ouh t y,

Act! m

Lvania, (Memorandum on Remedial

ectiveSll

tii

IMf .Alter

iMemorandum on Development and

GefServiSf|
]j||tter to fel
tratman, A

tives), prepared by Advanced
1/12/09. P. 302478-302489. A transmittal
.©fin Banks, U.S. EPA, from Mr.-Paul

Igif	.	'	'

ced GeoServices, is attached.

Rgjjpll;,;	...Qc^ft for Release Revised Baseline Human Health

Risk Assessment for Exide-Owned Properties, Price
¦Battefy* Superfund Site, Hamburg, Pennsylvania, prepared
by. Gradient Corporation (Gradient), 1/21/09. ;P. 302490-
302621. A January 23, 2009, letter to Mr. John Banks,
U.S. EPA, from Mr. Paul Stratman, U.S. EPA, regarding
supplemental information and transmittal of the Draft
Remedial Investigation Report, is attached.

AR307549


-------
45. Letter to Mr. John Banks, U.S. EPA, from Ms. Lucinda
Pype, CDM, re: Comments on the Draft Remedial
Investigation Report for Exide-Owned Properties,
1/22/09. P. 302622-302624.

46. Letter to Mr. John Banks, U.S. EPA, from Mr. Paul
Stratman, Advanced GedServices, re: Supplemental
Information for Draft Remedial Investigation Report for
Exide-owned Properties, 1/23/09. P. 3Q2625-302625.

47. Meeting Minutes, Review Meeting^

48

50,

51,

52,

xide's
SIM, 1/23/09.

December 2008 Draft RI Report,JOperablet

A March 16,§§2009, .c^veHl^kter t|p

EPA, frorffp^, _.^5cinda "®

P. 302626-302630.
Mr. John Banks, U.S.
attached.

Letter-Report to Mr. John :Bank©v
Matthew Love, Exide Technologies,
No. 19, 2/9/09. P. 302631-3.02632.

CDM, is

EPA, from Mr.
* Progress Report

49. Report: . Data Evaluation Ov^^llght Report, Exide-Owned
Properties, ...Price Ba1^&ry sMpeiiflilici^Site OU 2, Hamburg,

2/23/09. P. 302633-
Mr> John Banks, U.S.
is attached.

Pennsylvania, . preparea^Dy j^dm,
30298.2. A 't'ran^fetal _ loiter
EPA, from Ms. Llplrhda Pyj

Le^Sfeer ¦ to Mr

fpe, CDM

John Banks, U.S. EPA/

302983-302989. Figures 1 and 2

from Mr. Paul

SSt-gytoan, Advanced GeoServices, re: Proposed Phase 2
fiemeMlilL Irtvest^Pfeton .Activities for -Exide-Owned

¦ ~ 3/io^wwr. ¦'	' ¦

aref

#"

Iff Mr. John Banks, U.S. EPA, from
e, Exide Technologies, re: Progress
3/16/09. P. 302990-302991.

tound 6 Remedial Investigation Data Summary AA
Report for OU-1, Price Battery Superfund Site, Berks
County, Hamburg, Pennsylvania, prepared by CDM, 3/23/09.

AA Document has been redacted to protect the privacy of
individuals. Redactions are evident from the face of
the document, and Appendix A was removed entirely from
the document, however, its content was summarized in the
main body of the report.

AR307550


-------
P. 302992-303035. A transmittal letter to Mr. John
Banks, U.S. EPA, from Ms. Lucinda Pype, CDM, is
attached.

53. Letter Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 21, 4/22/09. P. 303036-303037.

54

55

56

57,

58

Letter to Mr. Matthew Love, Exide Technologies, from
Mr. John Banks, U.S. EPA, re: Comments to*December 18,
2008, Draft Remedial Investigation Report fpr Exide-
owned Properties, 4/24/09. P.^303038-30s3|^|i4

John Banks

Letter Report to Mr. uwmi oan^|
Matthew Love, Exide Technologies
No. 22, 5/7/09. P. 303043-30 3.Qp 4

EPA, f^pML.
Progress Report

AA

Report: Round 6A Remedial InvestigatSiffiHaCa
Summary Report for OU-lr PricQ Battery Ijijperfund.

¦ Site', .Berks, County, H^Burj^^^^nsylvagafa,' prepared by
CDM> 5/8/09. - P.''303(Mi5^3'03*i#3^}l5A transmittal letter to
Mr. John Banks, U.S^jjjpBA, #rom "Ms. -Lucinda Pype, CDM, is
attached. . .	¦ * " ¦

Memorandum	John	EPA, from Ms. Lucinda

l, CDM, ialliij| Hydro Evaluation for the Proposed Phase

-2^fefcedial
6/5
John

attarcte®1l

n^eSjlqation Activities, Operable" Unit 2,

A transmittal letter to Mr.

3 0 3H$2%3 03085.

U.S. Ilg&t-lifrom Ms. Lucinda Pype, CDM, is

^emorandum^^a^#. John Banks, U.S. EPA, from Ms. Lucinda
|^pe, CDM, r^tliy Hydro Evaluation for the Proposed Phase
!||||gmedial ^Instigation Activities, Operable Unit 2,
6/5/09. P." 303086-303089. A June 19, 2009, electronic
tf'S^miUli'l memorandum to Mr. Matt Love,' Exide
Technologies, from Mr. John Banks, U.S. EPA, is
attached.

59. Letter Report to Mr. John Banks, U.S. EPA, from Mr.

Matthew Love, Exide Technologies, re: Progress Report
No. 23, 6/10/09. P. 303090-303091.

9

AR307551


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60. Letter Report to Mr. John Banks, U.S. EPA, from Mr.

Matthew Love, Exide Technologies, re: Progress Report
No. 24, 7/6/09. P. 303092-303093.

61.	Letter to Mr. John Banks, U.S. EPA, from Mr. Paul
Stratman, Advanced GeoServices, re: Response to April
24, 2009,, EPA comments on Revised Scope of Phase 2
Remedial Investigation Activities for Exide-Owned
Properties, 7/23/09. P. 30309.4-3030^99%^ Fijpires 1-3
are attached.

62.	Letter Report to, Mr. John Bank

Mr. Matthew Love, Exide Technologies^- re:
Report No. 25, 8/6/09. P. 303100-lf3l01.

63

64

65,

66

Letter Report to Mr. John Bank^gf'
Mr. Matthew Love, Exide Technolog
Report No. 26, 9/8/09. P. 303102

Matthew jpve',

jw- '
IP A,

from
Progress

|aLde • .Technologies, - from

Letter to Mr.

Mr. John Banks, .U.S..

Remedial Investigati^^ActJVities -»f©r Exide-Owned'
Portions of the. Site,-lX)/^091 • - P. 303104-303105.

Letter Repor
M^hew. ¦ Lov
No. -27, 10/

Revised Scope for Phase 2

Mr. John Banks/ U. S. EPA, from Mr..

ide Techn^S#gies,. re:
P. 303106-303107.

Progress Report

Banks, U.S.'EPA, from
e Technologies, re: Progress
P. 303108-303109. I

67. latter to -Mr^p6hn Banks, U.S. EPA, from Mr. Paul.

I^gatman, AcjS^nced GeoServices, re: Response' to USEPA
Qprafents o^hase 2 Remedial Investigation (RI) Scope,

11/19/09.. P. 303110-303121. Related documents are

¦ ' ' '

attached.	^

68. Letter Report to Mr. John Banks, U.S. EPA, from Mr.

Matthew Love, Exide Technologies, re: Progress Report
No. 29, 12/2/09. P. 303122-303123.

69. Letter to Mr. Matthew Love, Exide Technologies, from
Mr. John Banks, U.S. EPA, re: Response to USEPA

10

AR307552


-------
comments on Phase 2 RI Scope, 12/21/09. P. 303124-
303125.

70. Letter Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 30, 1/6/10. P. 303126-303127.

71.

72

73

74

75,

76,

Report: Final Revised Phase 2 Remedial Investigation
Work Plan, Exide-Owned Properties, JEriee Battery -
Super fund-. Site, Hamburg, PenrisyjigjS8f|t, ||||gg>lired' by

Advanced GeoServices, 1/28/10
letter to Mr. John Banks, U.S
Stratman, Advanced GeoService
U.S. EPA conditional approval
Final Revised Phase 2 RI Work

!P. 3031||
[EPA/ frjm

-303142. A
"r.1 Paul

i^gliwe
is attach^J^^^

Letter Report to Mr. John Banks, U.^^ggA, fgom
Mr-.. Matthew -Love, Exide Technologies .'^^^ogress
Report No. 31, 279/10. P, 30314,3-303l¥|^K'. ,

Letter .-Report, to Mr;, ^hn	ifpA, from

Mr.- Matthew Love, Exide T^hnolfecp||s, re-: Progress
Report No. 32, 3/a/1 SIP P#3031$W)3146. ' ¦

Letter Report^ to Mr. ,.JbhnS|pB<]p*, U.S. EPA, - from
MsfoLucinda_Jjto(g-. CDM, reifl!lflidendum Nuitiber .1 to the
Site jMaSlllfement Plan-for OU-2, 3/9/10.

>: *

Mj^V Mattn^lggove

:fp^irt' to MljptTohn Banks, -U.S.( EPA,
ide Technologies, re:

Sport No.'«|»||4fr12/10. P, 303164-303165.,

from
Progress

IfkS

, Rounds 6B & 6G Remedial Investigation Data AA
^i^fe^JRd^rt for. OU-1, Price 'Battery Superfund

County, Hamburg, Pennsylvania, prepared
CDM, 4/30/10. P. 303166-303204;. A May 3, 2010,
transmittal letter to Mr. John Banks, U.S. EPA, from Ms.
Lucinda Pype, CDM, is attached.

77. Letter Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 34, 5/12/10. P. 303205-303206.

11

AR307553


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78. Letter Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies; re: Progress
Report No. 35, 6/11/10. P. 303207-303208.

79,

80.

81.

82

83

84

85,

Letter to Mr. John Banks, U.S. EPA, from Mr. Paul
Stratman, Advanced GeoServices, re: Response to April
24, 2009, USEPA comments to Draft Remedial Investigation
Report for Exide-owned Properties, 6/30/10. P. 303209-
303215.

Combined Phase I and

Report:

Report, Exide-Owned Properties#! Price

jlljivestigation

Site, Hamburg, Pennsylvania,
GeoServices, 6/30/10. P.

tery Superfund
joar^jf by Advanced I

Letter Report to Mr. John Bankss^ 0SSm,EPA, from 1

•	. ,	,	r , -•ViflWs

Mr. Matthew Love, Exide Technologies, re: Prpgress

Report No. 36, 7/7/10.

Report: Phase II RI

303617-30 3^€§prft

^ '

.uation Oversight Report,

Exide-Owned Propertied Prifcefft%.J:eiy' Superfund Site
OU 2, Hamburg, PA, p^
P. -303619-303859. -t-A^^angtoittaPwtter to Mr. John
Banks,U.S. EPA, from Ms. Mfucinrfll Pype, CDM, is attached.

Risk Assessment for

Human Heal

-E^derOwnedf-B^^jties, ' Price Battery Superfund Site,

rter Re
, Matthe*

sis

Report No.

]^t€%r Rep<^#t to Mr. John Banks, U.S. EPA,
Mr. Matthew Love, Exide Technologies, re:
Report No. 37, 9/13/10. ; P. 304000-304001.

prepared by Gradient, 7/22/10.

from
Progress

from

Progress

toJohn Banks, U.S. EPA,
$jate& Exide Technologies, re:
ltl|i/10/10. P. 303998-303999.

86.	Letter Report to Mr. John Banks, U.S. EPA, from
Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 38, 10/15/10. P. 304002-304003.

87.	Letter to Mr. Matthew Love, Exide Technologies, from
Mr. John Banks, U.S. EPA, re: Comments to July 22,

12

AR307554


-------
2010, Revised Baseline Human Health Risk Assessment for
Exide-Owned Properties, 11/5/10. P. 304004-304009.

88. Letter Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 39, 11/9/10. P. 304010-304011.

89

90

92

Letter to Mr. Matthew Love, Exide Technologies, from
Mr. John Banks, U.S. EPA, re: EPA gornmentsjto Combined
Phase I and. II Remedial Investig|fg|©p WSty&t for Exide-
owned Properties,. 11/17/10. P.i|^04012-s^ft|p.6.

Letter Report to Mr. John BanlciffL U. S.-# EPA,

Mr. Matthew Love, Exide Techno§S4es. re:

Report No. 40, 12/13/10,

30401.8;

.Teresa

91. Letter to Mr. John Banks, U.S. EPA,^Hl|^m Ms,

Bowers, Gradient,- re: Proposal for Gitlffkfe^er Data to

be Evaluated in Baseline^jStfen Health Rfjsii Assessment
for Exide-Owned Properties, 1/7/11. P.#304019-304038.
Related documents aref&ttached. ®

iih

Letter Report to^M-r. ^liShnrffeanks, U.S.

Matthew Love, Ex$|fe Technologies, re:
No. 41, l/104ll?f'""p. 304#I|#|*040.

EPA, from Mr.
Progress Report

93. MSgi|ng MinSi^^^|»PRP Meeting Regarding Questions on
,|fffl|i!er if, 2mSk JSPA Response to Comments on the

:' ' w!% a

RemedllM%Investig$®p^rReport, Operable. Unit 2, 2/15/11,

P. ^Kip^.4044,
John Banks, *U,.S.
attached.

10^'April 1, 2011., cover letter to Mr.
EPA, from Ms.Lucinda Pype, CDM, is

94

95,

Letter Repo|jp. to. Mr. John Banks, U.S. EPA,
Mr. >Matthje^fcove, Exide Technologies, re:
" ¥42, -2/11/11. P. 304045-304046.

RSp«S N

from
Progress

IP

Electronic memorandum to Mr. Matthew Love, Exide
Technologies, from Mr. John Banks, U.S. EPA, re: EPA's
comment and transmittal of CDM's comments to Gradient's
Ground Water Proposal for the Price Battery Baseline
Human Health Risk Assessment, 2/15/11. P. 304047-
304048. A January 7, 201i, Comments on Gradient's
Proposal for Groundwater Data to be Evaluated in

13

AR307555


-------
Baseline Human Health Risk Assessment for Exide-Owned
Properties, is attached.	-

96. Electronic memorandum to Mr. Matthew Love, Exide

Technologies, from Mr. John Banks, U.S. EPA, re: CDM's
Screening Level Ecological Risk Assessment (SLERA)
. comments, 2/16/11. P. 304049-304049.

97,

98,

99;

Letter to Mr. John Banks, U.S. EPA, frfm Mr^. Paul
Stratman, Advanced GeoServices, re: . Riifeonse to

November 17, 2010, EPA commentsf^n Co:
II Remedial Investigation Repqfft-, 2/18
304063.

Report: Combined Phase I and

Report, Exide-Owned Properties,

eel. Phase I and
1. P. 304050-

edial Inve

at ion

Battery Superfund

100.

Site, Hamburg, Pennsylvania, prepareSpgK Advanced'
GeoServices,: revised 2/18/11. P. 3085. An
,-October 9, 2014, transmifatelfciletter to iff John Banks>
U.S. EPA, from Mr.- Pauys't^aan, Advaryged GeoServices,
is attached.

.Electronic memorj^umbro
Mr. Paul .Stratm^^

Owned Property e|s7 Cobalt
P.A304586-3

nic memG^B^MLum to Mr. Matthew Love, Exide .
ies, frSJfefeg^ohn Banks,' U.S., EPA,

's GoTfalPwater ''Proposal" - cobalt issue,

Jogh.. !B'anks, U.S. EPA, from
^Services, re:' Exide-
ifiing results, 2/22/11.

04588^04595. Related electronic memoranda

3/2/11.
awe attache1

101. .Jp||fcer Report "to Mr. John Banks-, U.S. EPA, from

tlfelpMattheyiidve. -Exide Technologies, 're: Progress
Report No. 43, 3/4/11. P. 304596-304597.

102. Letter to Mr. John Banks, U.S. EPA, from Ms. Lucinda
Pype, CDM, re? PRPs background well review, 3/11/11.
P. 304598-304604. Figures 1 through 4 are attached.

14

/¦)

AR307556


-------
103.	Report: Analytical Report, Price Battery SEM	**
Analysis, Hamburg, Pennsylvania, prepared by National
Enforcement Investigations Center, U.S. EPA, 4/11.

An April 25, 2011, transmittal memo to Mr. John Banks,
U.S. EPA, from Mr. David Parker, U.S. EPA, is attached.
P. 304605-304619.

104.	Meeting Minutes, Feasibility Study Scoping Meeting,
Operable Unit 2, 4/7/11. P. 304620-304626. A May 25,
2011, cover .letter to Mr. John Banks, U.S>Apa, from

Ms. Lucinda Pype, CDM, is attachSdH

105. Letter.Report to Mr. John Bank#^ U.S. EPA,

Mr. Matthew Love, Exide Techndl%gie#f're: Mogress
Report No. 44, 4/12/11. P. 304%|f»04628

106.	Report: Baseline Human Health'J>Riskf|it%,essment for
Exide-Owned Properties (Report Body	glares) y Price
.Battery. Superfund Site, Hamburg, Penns^ffinia, prepared
by Gradient, 4/29/il, ,P. 304629-3.04719.^' An undated
response to U.S." EPA <|omment?^^^^.te<| November' 5, 2-010)
on the Baseline Humarmflealth Risk/ Assessment for Exide-
Owned Properties, Prwi 'B^ter^^^perfund Site; Hamburg,
Pennsylvania, dailld July|2£, 2 (MO, is- -attached.

107.	Report: Bas,j^|»ifie Human	Risk Assessment for
Eig^e-Owned^ii^erties1 (Appendices) , Price Battery
g^^Sfund ^"it^ll^femburg, Pennsylvania, 'prepared by
*&ra5ient, 4/29/1^^^.^04720-305176.

' '

108.	Leflfejr-^S^Bt to -M^*' John• Banks,. U.S. EPA, from
M||'. Matthew Loygf flSxide Technologies, re: Progress
%port No. '45; 5/9/11. P. 305177-305178.

109.	Electronic./memorandum to Mr. John Banks, U.S. EPA, from
Mr.,-Paul Stratman, Advanced GeoServices, re: Remedial
InVe^i^lion - BW-3 well development question, 5/27/11.
P. 305179-305181.

110.	Letter Report to Mr. John Banks, U.S. EPA, from
Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 46, 6/10/11. P. 305182-305183.

~* Document has been marked "Enforcement Confidential,"
however, it is approved for release.

15

AR307557


-------
111. Letter to Mr. Matthew Love, Exide Technologies, from
Mr. John Banks, U.S. EPA, re: EPA comments and
conditional approval on February 18, 2011, Combined
Phase I and II Remedial Investigation Report for Exide-
Owned Portions of Site, 6/30/11. P. 305184-305187.

112. Letter to Mr. Matthew Love, Exide Technologies, from
Mr. John Banks, U.S. EPA, re: EPA ^^pr^val^f April
2011' Revised Baseline Human Heali^^sKi^s^Cssment for
Exide<-Owned Portions of the SAtff^ 6/30jptfc^k P. "305188-
305189.	,	' M

113. Report: Technical Report", Pat

ysis of Xead and **

Antimony .Concentrations in Resiqpp^l Soils, Hamburg,

orcement

305190-
aj^o-'Mr. John
. S. EPA, is

Pennsylvania, prepared by Nati^na
Investigations Center, U.S. EPA, 7/
305214. A July 15, 2011, transmittal"
Banks, O.S.'-EPA, from Mr. "David Parker
attached.

114. Report: Development

;ielf

Exide-Owned Proper

id ^rreefflli^RDf -'Alternatives,
Pjftce 'BjfPllf'ry Superfund Site,

Berks County, P^^pyl-vani;tf> ¦ (H^jiorandum ,on Remedial
Action ObjecM^s. and ,Mem§SlLf|lu'm on Development and

Screening ojj
^^--vice^p

jfllernatives nSprepared by Advanced

.P.'

ed 7/7/11,

305215-305230.

%M0.opment and Screening of
>wned Properties, Price Battery

115. Revie^^^pnents
Alternativei

Sj0erfunWfflfe£,	Countyy Pennsylvania, prepared by

.^gvanced GeoServices Corp., Revised 7/7/11. P. 305231-
|jij5236. An August 4, 2011, transmittal letter to Mr.
«Sito. Banks,. jt..'S. EPA, from Ms. Lucinda Pype, CDM, is

116.	Letter Report to Mr. John Banks, U.S. EPA, from
Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 47, 7/11/11. P. 305237-305238.

117.	Meeting Minutes, Feasibility.Study Scoping Meeting,
Operable Unit 2, 8/1/11. P. 305239-305244. An August
31, 2011, cover letter to Mr. John Banks, U.S. EPA, from
Ms. Lucinda Pype, CDM, is attached.

16

AR307558


-------
118

119

120

121

122

123

124

125

126

127

Letter Report to Mr.. John Banks, U.S. EPA, from
Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 48, 8/4/11. P. 305245-305246.

Letter,to Mr. Matthew Love, Exide Technologies, from
Mr. John Banks, U.S. EPA, re: EPA comments on July 7,
2011, Alternatives Screening Memorandum for Exide-Owned
Portions of Site, 8/5/11. P." 30524i-3#f5249#

Letter Report to Mr. John Bank^HJ.S.

Mr. Matthew Love, Exide Technologies,

Report No. 49, 9/12/11. P. 3(8^50-^251?

from

ogress



J

9#

Report: Feasibility Study RepoifllliExide-Owned-vT
Properties, Price Battery- Supe.jg^f^P^te, Hamburg, ,
Pennsylvania, prepared by Advanced ggl|§rvic§,s, 9/30/11.
P. 305252-305538.

Mr. Matthew Love, ExiJJS

Letter Report to Mr.	U.S. EP&, from

§, re: Progress

Report No. 50, 10/14|pl^

05540.



Letter Report t,<|jjpr. Johiptean-k#, U.S
Mr. Matthew LovSs, Exide l^Miffffogies
Repprt NO. 5l||l/17/U. W305541

Letter ^Report to Mr,. John Banks, U.S
Mr. $illS)a|!w Love, Exider Technologies

12/mfill. P. 305543

. EPA, from
, re: Progress
305542.

. EPA, from
, re: Progress
305544.

|^:hn Banks, U.S. EPA,
PADIp||? re
12-/13/11. #^05545-305546.

Iijetter to
Effiong,

from Mr. Asuquo
Comments on the Feasibility Study,



Let^a^^g&rt to Mr. John Banks, U..S. EPA,
Mr. fficiiTthew Love, Exide Technologies, re:
Report NO. 53, 1/13/12. P. 305547-305548;

from

Progress

Letter Report to Mr. John Banks, U.S. EPA, from
Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 54, 2/9/12. P. 305549-305550.

17

AR307559


-------
128. Letter Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report NO. 55, 3/9/12. P. 305551-305552.

129. Letter to Mr. Matthew Love, Exide Technologies, from

Mr. John Banks, U.S. EPA, re: Response to EPA comments
to the Draft Feasibility Study Report, Exide-Owned
Properties, 3/30/12. P. 305553-305572. A September 30,
2011, Review Comments on the Feasibility St^iy Report,
Exide-Owned Properties, prepar' GeoServices
Corp., is attached.

130.	Letter Report to Mr.,John Banks
Mr. Matthew Love, Exide Techno

Report No. 56, 4/16/12. P. 305

- - - - -

131.	Letter to Mr. John Banks, U.S

132,

133

Effiong, PADEP, re:
Study, 4/26/12. P.

Meeting Minutes, Eea
Operable Unit 2, 4/2
2012, cover letter-t<5

Additional ARARs

Ms; Lucinda Pype, CDM Smi

R

Segjjjglixy Source-Analysis for Lead Exposure,
¦Utf?^^^jPrice Battery Superfund Site, • Hamburg,
lvania, prepared rby;CDM, 5/10/12.

nsmittal letter td Mr. John
m Ms. Lucinda Pype, CDM, is

P. 3

Bank,
atjiache

134. |§|tter RepoxtgPBp Mr. John Banks, U.S. EPA, from-Mr.

Lthew LovefjPflxide Technologies, re: Progress Report
'J0/.12, P. 305631-305632.

135. ElecTraffic memorandum to Mr. John Banks, U.S. EPA, from
Mr. Paul Stratman, Advanced GeoServices, re: Draft
ARARs for the Exide-owned properties, 5/16/12.
P. 305633-305646. Related documents are attached.

136. Letter Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 58, 6/12/12. P. 305647-305648.

18

AR307560


-------
137. Electronic memorandum to Mr. Matthew Love, Exide

Technologies, from Mr. John Banks, U.S. EPA, re: Site
ARARs, 6/22/12. P. 305649-305658. A June, 1, 2012,
letter to Mr. John Banks, U. S. EPA, from Ms. Lucinda
Pype, CDM Smith, regarding comments on draft ARARs for
Exide-owned properties, OU-2, and ARARs tables, are
attached.

138

Letter Report to Mr. John Banks, U/i|p
Mr. Matthew Love, Exide Technologies, ip
Report No. 59, 7/18/12. P. 3Q|659-305#<

,#from
'rogress

139. Letter to Mr. John Banks, U.S.	rom. Mr

Effiong, PADEP, re: Applicable or Relevant aifS



Appropriate Requirements (ARA^s)' Bi|
property, 8/6/12. P. 305661-30566?

Exide-owned

140,

141,

143

Letter to Mr. Matthew Loj^^^^ide' -Technologies-, -from
Mr. John Banks, U.S. E^/''^^B^RAR8, Exide-owned
portions of Site, 8/M|7l2. /^^^^,56p5-305671 ' -Ah August
6, 2012, letter to Mr.-- JoW*	. S. EPA, from Mr.

Auquo Effiong, rjoarJ^Tg-.-J^EP' iPSfiuiuents • on ARARs . -for
the Exide-owned^eeperty^p.s atijjbached. • • .•

sport to Mr. John ^iWffics, U.S. EPA,,

11 he

Letter

^#11,

Exide 'Technologies, 're:.
No. 60, 8/21/12. P. 305672-305673.

from
Progress



142. Letfee?B#R'fe©mrt to Mr^pJohn Banks, U.'S. EPA,

A?-*#'- v	mm?	'	• '

Mx0- Matthew^Love, Elide Technologies, re:
^ciA-9/18/12., P. 305674-305675,

Report No



••^^er RepogI "to Mr. John Banks, U.S... EPA,
Mr. Matth^siiiOve, Exide Technologies, re:

10/16/12. P. 305676-305677,

from
Progress

from
Progress

144.	Letter Report to Mr. John Banks, U.S. EPA, from
Mr. Matthew Love, Exide,Technologies, re: Progress
Repdrt No. 63, 11/13/12. P. 305678-305679.

145.	Letter to Mr. Matthew Love, Exide Technologies, from
Mr. Arthur Dalla Piazza, PADEP, re: Underground storage
tank release, 12/7/12. P. 305680-305681.

19

AR307561


-------
146. Letter Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 64, 12/14/12. P. 305682-305683.

147. Letter Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 65, 1/18/13. P. 305684-305685..

148.	Letter Report to Mr. John Banks,
Mr. Matthew Love, Exide Technologies,
Report No. 66, 2/13/13. P. 30J|68 6-305j?§

149.	Meeting Minutes, Feasibility S
Unit 2, 3/14/13. P. 305688-305

transmittal letter to Mr. JohnJB'ahl

- ' - " ' ¦ - • '¦*$/'

Lucinda Pype, CDM, is attached^

r om

'rogress

150. Letter Report to Mr.

Mr.'Matthew Love, Exidei
Report No. 6.7, 3/15/1'fj

JohBi^S^ks, U. S

lee ting,

An April^ 4, ,„,2013/
JJ.S. EPA, from Ms,

from
Progress

151. .Letter 'Report tOjMy. ^^'hnjlBanksji'^CS.' EPA,
Mr.. 'Matthew"' Lov<^|g|lxide -T^phno^fibgies, re: -
Report No.''.6§te §"fl0/13. lllllilli695-305696 .

152.

;er to M:
$fr3lf An Banks^

Deter ^jtion fowl^fag^Qwned Portions of Site;, 4/16/13
05698."

from

Progress

ew Love, Exide Technologies, from
EPA, re: Area of Contamination

153.	letter--to	''Banks, U.S. EPA,- 'from Mr.- Paul
A^fe^ed ' GeoServices, re: Response to >

ised Feasibility Study Report, Exide-
ifrties, 5/17/13. P. 305699-305728.

154.	ReportTT" Draft for Release Feasibility Study Report,
Exide-Owned Properties, Price Battery Superfund Site,
Hamburg, Pennsylvania, prepared by Advanced GeoServices,
revised 5/17/13. P. 305729-306113.

155. Letter Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 69, 5/20/13. P. 306114-306115.

20

AR307562


-------
156.	Letter Report to Mr. John Banks, U.S. EPA,	from
Mr. Matthew Love, Exide Technologies, re:	Progress
Report No. 70, 6/12/13. P. 306116-306117.

157.	Letter Report to Mr. John Banks, U.S. EPA,	from
Mr. Matthew Love, Exide Technologies, re:	Progress
Report No. 71, 7/15/13. P. 306118-306119.

158. Letter to Mr. John Banks, U.S.	Asuquo

PttSP^ r

Effiong, PADEP, re: .Remedial ^asibila|^g^udy Report,
Exide-Owned Properties, 7/16/lJ[. P. 3.^1^3806122.,

illk

159. Letter Report to Mr; John Banks,.	EPA, £$$&&

Letter Report .to Mr; John Bank^f|fe.|5. EPA,
Mr. Matthew Love, Exide Technolcptfs, re:
.Report No. 72, -8/6/13. P. 306|#3^fco4/.

160. Letter Report to Mr. John Banks, U.S

Mr. Matthew Love, Exide Technologies, re:
Report No. 73, 9/10/13^P. 306125-3061#!.

if rom
Progress

161.

162

163

Letter to Mr. Matthe^j^pve„ Exide Technologies, from
Mr. John Banks,	'W?h,0:e: JfilPcomments' to the May

17, 2013, Revis^d^Feasibj^ty ffudy Report, Exide-Owned

Properties,



P.{306127-306134.

Repc^P||skMr. John Banks,' U..S.. EPA, from

Technologies, re: Progress
Report No. 74, 10/31/13. P. 306135-306136.

Letter to. Mr. John'Banks, U.S. EPA, from Ms. Jennifer
^Joseph	Paul' Stratman, Advanced GeoServices,

¦wk: Response to Comments on Revised Feasibility Study
Re'bort, Exidi§-f)wned Properties, 11/4/13. P. 306137-
306149. Jf

164. Repofi1: Feasibility Study Report, Exide-Owned

Properties, Price Battery Superfund Site, Hamburg,
Pennsylvania, prepared by Advanced GeoServices, revised
11/4/13. P. 306150-306529.

165. Letter Report to Mr. John Banks,.U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 75, 11/24/13. P. 306530-306531.

21

AR307563


-------
166.	Letter Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 76, 12/17/13. P. 306532-306533.

167.	Letter Report to Mr. John Banks, U.S. EPA, from
Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 77, 1/19/14. P. 306534-306535.

168

169,

172,

173,

Letter Report to Mr. John Banks,
Mr. Matthew Love, Exide Technologies,
Report No. 78, 2/3/14. P. 306f36-3065|i

,jfrom
Progress

Report: Final Comprehensive ¦Rjifedictl InvesllKIWfeijQ# ***
Report, for Operable Unit 1, Prfljj^ifettery Sit^Sj^iburq,

w

Berks County, Perinsylvania, prey CDM Federal
Programs Corporation (CDM Smitn), •	3:0653-8-

307292. A transmittal letter to Mr/'Jbhn Banks, U.S.

EPA, from Ms. Lucinda Pyp

DM Smith,

attached.

170. Letter Report to Mr. ,«|ohn Banks, U.!|. EPA, from

Mr. Matthew Love, EsjmEg Tej&n<&ogi«Jf, re: Progress'
Report'No.' 79, 3/]U3/l§j| ' M 3'07|%3|§07294 .

171. Letter Report

Joh:

U.S. EPA,
ptfiogies, re:
307295-307296.

to^MMt.J^in Banks, U.S. EPA,
Love,	Technologies, re:

P. 307297-307298.

Mr.. Matthew Jjiterfe, Exide Tig
Report No. 'J^|^/l0/14. P.

Lett
Mr. M<
Report

M

Jitter Repo
]|p1-,thew Lov

I§kfi2, 6/1

from

Progress

from

Progress

5/2^14

714

p Mr. John Banks, U.S. EPA, from Mr.
xide Technologies, re: Progress Report
P. 307299-307300.

174. Let"ei®r-Report to Mr. John Banks, U.S. EPA, from

Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 83, 7/14/14. P. 307301-307302.

*** Appendix E, EPA RAC Analytical Data, is on CD-ROM and is
available upon request in the Region 3 CERCLA Records
Center, however, its content has been summarized
elsewhere in the report.

22

AR307564


-------
175.	Letter Report to Mr. John Banks, U.S. EPA, from
Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 84, 8/14/14. P. 307303-307304.

I

176.	Letter Report to Mr. John Banks, U.S. EPA, from
Mr. Matthew Love, Exide Technologies, re: Progress
Report No. 85, 9/8/14. P. 307305-307306.

177.	Letter to Mr. John Banks, U.S. EPA, - fr<|m MrPaul
Stratman, Advanced GeoServices,

dibenzo (a, h) anthracene in groundwater, jpjtMe-owned
portions of site, 9/10/14. P. '307307-Jo'

178

179,

180,

Letter Report to Mr. John Banks, 'U.S. EPA, fi
Mr. Matthew Love, Exide Technor2f&ijS&, re:'
Report NO. 86, 10/3/14. . P. 30,^^fcl0.

Letter Report to Mr. John Bank's, U.S. Ilfewa-f'rom

Mr. Matthew Love, Exide T<
Report No. 87, 11/10/14

logies, re:' Progress

7311-3073

- -I

2.

Letter to Mr. John B^tflcs, U.S.^i'Sfglp'from Mr. Paul
Stratman, .Advance,^,G^^ervices,	.Supplement No,

November 4, 2013, RevisedjfFeasJbility Study Report,
11/20/14.
attached.

1 to

7313-307^

181.

i|jiReport "

Revised tables are

f&. John Banks, U.S. EPA,
Mr. ti|i;thew Love^j®fed§fTechnologies, re:

12/lgii'. P. 307334-307335.'

' -f§F 1
£§ ; ^ ,

182. letter Repoq|g^|^"Mr. John Banks, U.S. EPA,
|1|. '.Matthew 'gige, Exide Technologies, re:
>rt No. 89, 1/13/15. P. 307336-307337.

183. Le%|Pr»feport to Mr. John Banks, U.S. EPA,

u	T	„ • J	m	U	1

Mr. Matthew Love, Exide Technologies, re:
Report No. 90, 2/10/15. P. 307338-307339.

from
Progress

from
Progress

from
Progress

184. Statement of Qualifications for Advanced GeoServices,
undated. P. 307340-307352. A July 17, 2007, letter
from Mr. Matthew Love, Exide Technologies, to Mr.
John Banks, U.S. EPA, regarding designation of the
project consultant, is attached.

23

AR307565


-------
185. Response to Comments on the Hydro Evaluation for the
Proposed Phase 2 Remedial Investigation Activities,
Operable Unit 2, Price Battery, undated. P. 307353-
307355. A June 17> 2009 transmittal letter to Mr. John
Banks, U.S. EPA, from Ms. Lucinda Pype, CDM, is
attached.

186. Response to November 5, 2010, U.S. EPA%commgpts on the

July 22, 2010, Baseline Human Health Risk^'Assessment for



Exide^owned Properties, Price Battery ^g^gfund Site,
Hamburg, Pennsylvania, prepare|l by. Gra,

Exide Technologies, undated.

fen behalf of

187

188,

Superfund Program Proposed Plan
Site, Operable Units 1 & 2, 7/1

®6-30'l»

Batteryl^p'erfund
307363-307425.

.sk Assessment
9/3'TliP P. 2184330.

Tables, Revised Baseline Human
'for Exide-Owned Propertie# Ta|>les,

A cover,- letter to Mr.', U.S. jlPA, from Mr
Matthew Love, Exide Technologies, is attached.

189,

Letter to Mr. .MaJ^t^ew§jsbvj
from Mr. John Banks, U.S.
Feasibility gj|udy and su||
9/21/15. P.2184331

.r$*

echnologies, Inc.
EPA approval of
tal documentation,

24

AR307566


-------
V. COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/IMAGERY

1. U.S. EPA Public Notice, Price Battery Superfund Site,
re: U.S. Environmental Protection Agency (EPA) Seeks
Public Comment on the Proposed Cleanup Plan for the
Price Battery Superfund Site, 7/15/15. P. 2184329.

2 .

3 .

4 .

5.

Internet article entitled, "Meeting to Detail Proposed
Cleanup in Hamburg is Tonight," Reading Eagle, 7/30/15.
P. 2184328.

Transcript of Public Meeting Minutes,

Site-Proposed Planning, Price,Slatterm Superftind,
7/30/15. P. 2216741.	" ' —

AAA

Internet article entitled, "Pl^d^p^tt Phase in
Cleanup of Ex-Plant Site in Hamburg jlprtailed," Reading
Eagle, 7/31/15. P. 2184327.

Letter to Mr. John Banks, U.S. EPA, from. CDM Smith, AAA
re: Proposed Plan public	summary, 8/11/15.

P. 2216737.

Jf ¦

AAA Document has been redacted to protect the privacy of
individuals and/or due to confidential business
information. Redactions are evident from the face of
the document.

25

AR307567


-------
APPENDIX B

FIGURES

AR307568


-------
Hamburg. Pennsylvania

Pnce Battery Superfund Site

RRv-

2 Mies



Figure 1-1
Site Location Map

Price Battery SuperlUnd Site
Berks County, Hamburg, PA

FIGURE 1: PRICE BATTERY SITE LOCATION

B-l

AR307569


-------
Warehouse Parcel

Parking Lot

Figure 1-2
Exide-Owned Properties

Pnce Battery Superfund Site
Berks County. Hamburg, PA

FIGURE 2: PRICE BATTERY OU-2
EXIDE-OWNED PROPERTIES

B-2

AR307570


-------
Legend

Predicted High Probabiity Area

Former Price Battery Plant and Other Exide-Owned Properties
• Former Smokestack
I IOU1 Study Area

I Surface Water Bodies

Note

Preceded high probabiity area tor lead concantatona above 572 mg'ng
oetafrrened through analyse ot He COM Smn 2006 Air Dispersion Model
concentrations. dra>nage patterns, so* sample data. ana topograph*:
teatjre* fhe parlicuBte rarwpon evaluation was conducted tn 2008.

0.5 Mies
_J


-------
FIGURE 4: KAERCHER CREEK SEDIMENT SAMPLING LOCATIONS

B-4

NOTES

1 BASEMAP information obtained
r*0N THE "plot PLAN" drawing
He 22—SLI-94-D. DATED JUNE 5.
1070	Br EXIDE

TECHNOLOGIES

2. 9LILDNC NAMES OBTAINED FROM
"STORW VfcATTR fXJTFAl I " D#U*INC
NO 22-SLM0FD DATED JULY 19.
199N PROVIDED BY EXlOE
TECHNOLOGIES

SED-1

ri»*»

7

SCME N PICT

i£g£NP

PROPEFTT UNE CF EKIOE
OWNED PROPSRTttS

«v>noi*v»*TC LOCATION X
SREAM 8EI> SE3WENT
SAOPUSG LOCATION!;

8

SED-61

AR307572


-------
Structural

Support

Beams

block Vcollapse

FIGURE 5: APPROXIMATE LOCATION OF PIPES WITHIN ENCLOSED AREA OF KAERCHER CREEK

gfiSf

v 2 •-1
a 5T < c

2 I

waya
£ |5?£

d c |

|s|I

tf-g

LEgENP

PROPERTY UKE OF E*DE
CWNEC PROPERTIES

CMP = CORRUGATED WCTAL P«
PVC = POLYVINYL CHLORCE
TC = TERRACOTTA
W - (XJCflLE IRON

MOTES

1 NOTES ON THE PURPOSE OF

OBSERVED PIPES (!.«. "STORM") IS
BASED ON FCLD OBSERVATIONS
AND PROFESSIONAL JUDGEMENT

2- DUE TO HIGH WATER CONDITIONS,
PIPES 7 THROUGH 10 COUlD NOT
BE DIRECTLY ACCESSED TO ASSESS
CONDITION OR MATEWAL. BASED
ON GENERAL APPEARANCE AND
REGULAR SPACING. IT IS EXPECTED
THESE PIPES ARE SIMLAR IN
CONSTRUCTION AND PJRPOSE TO
PIPES 4 S. AND 6

3. BASEMAP INFORMATION OBTAINED
FROM THE "PLOT PLAN* DRa*ng

No.22—SU—94—D. DATED JUNE 5.
1979 PROVIDED BY EXHJE
TECHNOLOGIES

4 BUILDING NAMES OBTAINED FROM
"STORM WATER OUTFALL" DRAWING
NO 22-SLM8FD DATED JULY 19,
1999 PROVIDED BY EXffiE
TECHNOLOGIES

MAIN PARCtL AREA
FORMER BUDDING LOCATIONS

Pipe 2
4.5" Dl Sewer

Pipe 12
12" TC Sewer

U -

V-1F CMP Starr

Pipe 101
3" PVC Drain '
Pipe 9 1
PVC Drain
Pj>e B '
i 3" PVC Drain

Pipe 6 1
3" PVC Droin

Pipe 7

3" PVC Drain

Pipe 4

3' PVC Drain

I Pipe 3

\12" CVP Storm

B-5

AR307573


-------
AR307574


-------
4

Main Parcel B

Parking Lot

LEGEND
• Sample Location
] EipoMraVoa

AraaOf BBurainouB Concme Pnetw^m

mctaM M Part Of 2009

RMportM Acflon AcfMiM- Or|grany Sion*

C«\MhtdS»on«PMwd Along Orap OAs
Batweon Butftng Floor* And Sunoufxtng
A*» As Fall Protect on

Arm Urdwtun By Concrete Or Aipftat

NOTES:
i|Miin

MAP REFERENCES
1>At»mc<< OioSwvtcM, Fwmar Prloa
Battery 8m CAD Mm. 2002 97»00 IB. 2002
979-0120 2002 978-00 27



3

Gradient

Exposure Areas

i >>w»Mt9. PA

FIGURE

1

FIGURE 7: EXPOSURE AREAS

B-7

AR307575


-------
IFQFNP

propcr^ iiwr or cmoc omto

PROPERTIES

• COMPLETED PHASE i SOL SAMPl.NG
LOCATIONS

¦ SUPPlEMENTAL 901 SAMP-IMS LOCATIONS
FOR RjEL 01 INVESTIGATION

~ PROPOSFD SOIL SAMPLING LOCATIONS
COLLECED FOR FUEL OIL INSTIGATION

O BASED ON FIELD OBSERVATIONS
SOIL SAMSUNG LOCATIONS REMOVED
TO ^OXJMITY CT HISTORIC SAMPLE
A COMPLETED PHASE II SOIL SAMPLING
r LOCATIONS

APPROXIMATE SURFACE SOIL 5AMPUNG
® LOCATIONS (TETRA TECH 2002)

- APPROXIMATE SUB-SURFACE SOIL

SAMPUNC LOCATIONS (TETRA TECH 2002)

APPROXIMATE LOCATION OF 1995
A ADVANCED OEOSERvfCES CEOPROBE
LOCATIONS

	ESTIMATED UMT OF BTEX IMPACTED SOIL

PTW * DEEP EXCAVATION
12470 SQ.FT. AREA A, 0 SO FT AREA B
~~) PTYV 3* DEEP EXCAVATION

6760 SOJl. AREA A, 2010 SQ.FT. AREA 8

PTW 6* DEEP EXCAVATION
'400 SO FT ARE> A. 4900 SO FT ARE* 8

DEEP RAL REMEDIATION AREA

SOFT AREA A. '6560 SaFT. AREA 9
DEEP RAL REMEDIATION aw£A

SOFT AREA A. 0 SO FT AREA 8

DEEP RAL REMEDIATION AREA
SOFT AREA A. 2440 SOFT AREA B

1.	BASEMAP INFORMATION OBTAINED
FROM THE "PLOT PLAN" DRAWING

So 22—SU— 94-D. DATED JUNE 5. 1979
PROVIDED BY EXDE TECHNOLOGIES

2.	dJlLDING NAMES OBTAINED FROM
"STORM RATER OUTFALL" DRARF»G NO
22—SU—1ST DATED JULY 19. 1999
PROVIDED BY EXCE TECHNOLOGIES

3.	SAMPLE LOCATIONS MP-39 AND
MP—35 COULD NOT BE SAMPLED DUE
TO REFUSAL AT APPROXIMATELY 3.5
FEET AND 2 FEET BELOW GROUND
SURFACE RESPECTIVELY GEOPROBE
EQUIPMENT COULD NOT PENETRATE
THE OBSTRUCTION.

4 RAL EXCAVATIONS REFLECT REMOVAL
TO 8.669 mg/kfl.

FIGURE 8: ALTERNATIVE S-4A MAIN PARCEL

B-8

AR307576


-------
SCALE M FtET

PROPCPTr UNE CF EX1DE OWNED
PROPERTIES

• COMPLETED PHASE I SOI. SAMPLING
LOCATIONS

O PROPOSED SOIL SAMPLING LOCATIONS
REMOVED DUE TO PROXIMITY OF HISTORIC
SAMPLE

A COMPLETED PHASE U SOIL SAMPLING
t LOCATIONS

^ approximate SURFACE SOI sampunc

* LOCATIONS (TTTRA TECH 2002)

m APPROXIMATE 5U8—SURFACE SOIL

SAMPUNG LOCATIONS (TETRA TECH 2002)

r CCD' RAL REMEDIATION AREA

<18510 SQ.FT.)

3' DEEP RAL REMEDIATION AREA

(0 SOFT)

6" DEEP RAL REMEDIATION AREA
(14480 SOFT.)

NOTTS

1	BASEMAP INFORMATION OBTAINED FROM TME
"PLOT PUN* DRAWNG No.22-SU-94-D.
DATED JUNE 5. 1879 PROVBED Br EXIOE
TECHNOLOGIES

2	BULOINC NAMES OBTAINED FROM "STORM
WATER OUTFALL* 0RA*|NC NO 22-SU-18FD
DATED JULY 19. 1999 PROVIDED Br ExloE
TECHNOLOGIES

3. RAL EXCAVATIONS REFLECT REMOVAL TO
8.669 mq/kq.

APPROXIMATE PROPERTY UNE FOR WAREHOUSE PARCEL

FIGURE 9: ALTERNATIVE S-4A WAREHOUSE PARCEL

B-9

AR307577


-------
FIGURE 10: ALTERNATIVE SD-3

B-10

AR307578


-------
APPENDIX C

CONCEPTUAL SITE MODEL

AND
RISK TABLES


-------
TABLE C-l: CONCEPTUAL SITE MODEL

Medium Exposure Medium Exposure Point Receptor Receptor Ace Expoiurc Route*	Type of Analysis

Soil

Soil (0.1.25 ft)

Site Soil

Office Worker 1

Adult

Incidental Ingestion.
Dermal

Quantitative

Soil

Soil (0-10 ft)

Site Soil

Office Worker 2

Adult

Incidental Ingestion.
Dermal

Quantitative

Soil

Soil (0-5.25 ft)

She SoU

Utility Worker

Adult

Incidental Ingestion,
Dermal

Quantitative

Soil
Soil

Soil (0-1? ft)
Soil

Construction
Site Soil

Yard Soil

Construction
Worker

Resident

Adult
Adult and Child

Incidental Ingestion,
Dermal

Incidental Ingestion,
Dermal

Quantitative
Comparison to RSLs

Groundwater

Groundwater
Bedrock

Tap water
•

Indoor Air

Resident
Resident

!

Cbikf (0-6) &
Adult (7-30)
Child (0-6) &
Adult (7-30)

Ingestion & Dermal
Inhalation

Quantitative
Quantitative

Groundwater

Groundwater
Overburden

Tap water

Indoor Air

Resident
Resident

Child (0-6)&
Adult (7-30)
Child (0-6) &
Adult (7-30)

Ingestion & Dermal
Inhalation

Quantitative
Quantitative

Groundwater

Groundwater
Overburden

Shallow
Krotmd water

Ctmcreaiori
Worker

Adul!

Dermal Contact

Quantitative

c-i

AR307580


-------
Table C-2

Total Excess Lifetime Cancer and Non-Cancer Risk by Receptor and Pathway (without PAHs, BTEX and Mb)

Exide Hamburg, PA

Exposure
Area

Receptor/Exposure Pathway

j | COC Contributing Majority
Cancer! Percent j of Risks by Receptor &
Risk (Contribution Pathway (% contribution)

Non-Cancei
Risk

Percent
Contribntioi

COC Contributing Majority.

of Risks by Receptor &
Pathway (% contribution)

BW

Office Worker 1
Incidental Ingestion of Soil
Dermal Contact with Soil

2.5E-06 | 88.1% | Chromium (51.3%)
3.4E-07 | 11.9% 1 Arsenic (100 %)

2.0E-01
2.1E-03

98.9%
1.1%

Antimony (73.9 %)
Arsenic (100%)

Total Risk

3E-06 1 I

2E-01





Office Worker 2
Incidental Ingestion of Soil
Dermal Contact with Soil

1 I

2.4E-06 | 816% Chromium (53.6 %)
3.1E-07 | 11.4% J Arsenic (100 %)

UE-01
1.9E-03

98.3%
1.7%

Antimony (42.2 %)
Arsenic (100 %)

Total Risk! 3E-06 |



1E-01





Utility Worker 1 j
Incidental Ingestion of Soil 1 1.9E-07 I 76.5%
Dermal Contact with Soil | 5.9E-08 § 23.5%

Chromium (53.5 %)
Arsenic (100 %)

9.0E-03
3.7E-04

96.1%

3.9%

Antimony (42.1 %)
Arsenic (100 %)

Total Risk) 3E-07





9E-03





Construction Worker
Incidental Ingestion of Soil
Dermal Contact with Soil

2.5E-Q7
2.4E-08

91.5%
8.5%

Chromium (53.6 %)
Arsenic (100 %)

7.8E-01
9.6E-03

98.8%
1.2%

Antimony (42.2 %)
Arsenic (100 %)

TotalRisk

3E-07





8E-01





MP-A

Office Worker 1
Incidental Ingestion of Soil
Dermal Contact with Soil

3.7E-06
7.4E-07

83.4%
16 6%

Arsenic (68.5 %)
Arsenic (95.5 %)

4.7E+00
6.8E-03

99.9%

<1%

Antimony(98.6 %)
Arsenic (65.1 %)

Total Risk

4E-06





5E+00





Office Worker 2
Incidental Ingestion of Soil
Dermal Contact with Soil

2.8E-06
4.0E-07

87.7%
12.3%

Chromium (50.5 %)
Arsenic (94 %)

3.5E+00
4.0E-03

99.9%
<1%

Antimony (98.4 %)
Arsenic (58.3 %)

Total Risk

3E-06





4E+00





Utility Worker
Incidental Ingestion of Soil
Dermal Contact with Soil

2.3E-07
8.4E-08

73.4%
26.6%

Arsenic (51.9%)
Arsenic (94;6 %)

3.1E-01
8.1E-04

99.7%

<1%

Antimony (98.5 %)
Arsenic (61 %)

Total Risk

3E-07





3E-01





Construction Worker
Incidental Ingestion of Soil
Dermal Contact widi Soil
Dermal Contact with Groundwater

3.0E-07
3.0E-08
3.8E-08

81.4%
8.1%
10.5%

Chromium (51 %)
Arsenic (93.9 %)
Chromium (99.8 %)

2.4E+01
2.0E-02
8.7E-03

99.9%
<1%
<1%

Antimony (98.4 %)
Arsenic (57.7 %)
Chromium (53.5 %)

Total Risk! 4E-07

- ! ¦ •

2E+01





Construction Worker - Hot Spot |

j







C-2

AR307581


-------
Table C-2 (Continued)

Total Excess Lifetime Cancer and Non-Cancer Risk by Receptor and Pathway (without PAHs, BTEX and Mn)

Exide Hamburg, PA









COC Contributing Majority





COC Contributing Majority

Exposure



Cancer

Percent

of Risks by Receptor &

Non-Cancei

Percent

of Risks by Receptor &

Area

Receptor/Exposure Pathway

Risk

Contribution

Pathway (% contribution)

Risk

Contribution

Pathway (% contribution)



Incidental Ingestion of Soil

2.2E-08

95.3%

Chromium (75 .5 %)

2.1E-01

98.0%

lion (65.6%)



Dermal Contact with Soil

1.1E-09

4.7%

Arsenic (100 %)

4.3E-03

2.0%

Arsenic (100 %)



Dermal Contact with Groundwater

NA

NA



NA

NA





Total Risk

2E-08





2E-01







Office Worker 2 - Hot Spot















Incidental Ingestion of Soil

2.1E-07

93.9%

Chromium (71.8 %)

3.2E-03

97.4%

Iron (63.9 %)



Dermal Contact with Soil

1.4E-08

6.1% 1 Arsenic (100%)

8.6E-05

2.6%

Arsenic (100 %)



Total Risk

2E-07



3E-03





MP-B

Office Worker 1















Incidental Ingestion of Soil

3.3E-04

78.3%

Arsenic (100 %)

1.0E+01

94.8%

Antimony (80.3 %)



Dermal Contact with Soil

9.0E-05

21.7%

Arsenic (100 %)

5.6E-01

5.2%

Arsenic (100 %)



Total Risk

4E-04





1E+01







Office Worker 2















Incidental Ingestion of Soil

7.6E-05

78.3%

Arsenic (100 %)

2.5E+00

95.0%

Antimony (81.1 %)



Dermal Contact with Soil

2.IE-05

21.7%

Arsenic (100 %)

1.3E-01

5.0%

Arsenic (100 %)



Total Risk

9.6E-05



3E+00







Utility Worker















Incidental Ingestion of Soil

8.7E-06

60.2%

Arsenic (100 %)

2.9E-01

88.9%

Antimony (81.1 %)



Dermal Contact with Soil

5.8E-06

39.8%

Arsenic (100 %)

3.6E-02

11.1%

Arsenic (100 %)



Total Risk

IE-OS



3E-01







Construction Worker"















Incidental Ingestion of Soil

8.0E-06

83.3%

Arsenic (100 %)

1.7E+01

96.3%

Antimony (81.1 %)



Dermal Contact with Soil

1.6E-06

16.7%

Arsenic (100 %)

6.5E-01

3.7%

Arsenic (100 %)



Total Risk

IE-OS





2E+01





PL

Office Worker 1





'

'









Incidental Ingestion of Soil

7.9E-06

83.3%

Arsenic (72.5 %)

1.2E-01

92.5%

Iron (39.3%)



Dermal Contact with Soil

1.6E-06

16.7%

Arsenic (100%)

9.9E-03

7.5%

Aisenic (100 %)



Total Risk

1E-05





1E-01







Office Worker 2















Incidental Ingestion of Soil

7.3E-06

83.9%

Arsenic (69.2 %)

1.2E-01

93.1%

Iron (30.8%)

i Dermal Contact with Soil

1.4E-06

16.1%

Arsenic (100 %)

8.7E-03

6.9%

Arsenic (100 %)

! . Total Risk

9E-06



1E-01





(utility Worker













| Incidental Ingestion of Soil

6.7E-07

67.2% J Arsenic (73.9 %)

9.4E-03

82.3%

Iron (41%)

C-3

AR307582


-------
Table C-2 (Continued)

Total Excess Lifetime Cancer and Non-Cancer Risk by Receptor and Pathway (without PAHs, BTEX and Mi)

Exide Hamburg, PA









. COC Contributing Majority





COC Contributing Majority

Exposure



Cancer

Percent

of Risks by Receptor &

Non-Cancer

Percent

of Risks by Receptor &

Area

Receptor/Exposure Pathway

Risk

Contribution

Pathway (% contribution)

Risk

Contributioa

Pathway (% contribution)



Dermal Contact with Soil

3.3E-07

32.8%

Arsenic (100 %)

2.0E-03

17.7%

Arsenic (100 %)



Total Risk

1E-06





1E-02







Construction Worker















Incidental Digestion of Soil

7.7E-07

87.8%

Arsenic (69.2 %)

8.0E-01

94.9%

Iron (30.8 %)



Demial Contact with Soil

1.1E-07

12.2%

Arsenic (100 %)

4.3E-02

5.1%

Arsenic (100 %)



Total Risk

9E-07





8E-01





WH

Office Worker 1





'









Incidental Ingestion of Soil

3.4E-06

90.5%

Chromium (62.1 %)

2.6E-01

99.1%

Antimony (80.6 %)



Deimal Contact with Soil

3.6E-07

9.5%

Arsenic (100 %)

2.2E-03

<1%

Arsenic (100 %)



Total Risk

4E-06





3E-01







Office Worker 2















Incidental Ingestion of Soil

3.0E-06

91.3%

Chromium (65.6 %)

1.6E-01

98.9%

Antimony (58 %)



Dermal Contact with Soil

2.9E-07

8.7%

Arsenic (100 %)

1.8E-03

1.1%

Arsenic (100 %)



Total Risk

3E-06





2E-01







Utility Worker















Incidental Ingestion of Soil

2.5E-07

80.0%

Chromium (62.2 %)

1.6E-02

97.7%

Antimony (663. %)



Dermal Contact with Soil

6.3E-08

20.0%

Arsenic (100 %)

3.9E-04

2.3%

Arsenic (100 %)



Total Risk

3E-07





2E-02







Construction Worker















Incidental Ingestion of Soil

3.1E-07

67.1%

Chromium (66.3 %)

1.1E+00

97.8%

Antimony (58.4 %)



Deimal Contact with Soil

2.1E-08

4.5%

Arsenic (100 %)

8.5E-03

<1%

Arsenic (100 %)



Dermal Contact with Groundwater

1.3E-07

28.4%

Chromium (97.6. %)

1.7E-02

1.5%

Chromium (92.3 %)



Total Risk

5E-07



1 1E+00





MP-BR

Adult Resident













WellBW-3

Ingestion of Groundwater

NA

NA



NA

NA





Dermal Contact with Groundwater

NA

NA



.NA

NA





Inhalation ofVolatiles

NA

NA



. NA

NA





Total Risk

NA



I na







Child Resident















Ingestion of Groundwater

NA

NA



NA

NA





Dermal Contact with Groundwater

•NA

NA



NA

NA





Inhalation ofVolatiles

NA

NA



NA

NA





Total Risk

NA



I NA







Total Residential Risks:

NA









C-4

AR307583


-------
Table C-2 (Continued)

Total Excess Lifetime Cancer and Non-Cancer Risk by Receptor and Pathway (without PAHs, BTEX and Mn)

Exide Hamburg, PA

Exposure
Area

Receptor/Exposure Pathway-

C ancer | Percent
Risk {(Contribution

COC Contributing Majority

of Risks by Receptor &
Pathway (% contribution)

Non-Canceij Percent
Risk . Contributioi

COC Contributing Majority

of Risks by Receptor &
Pathway (% contribution)

MP-BR
Well BW-6

Adult Resident
Ingestion of Groundwater
Dermal Contact with Groundwater
Inhalation of Volatile s

1.1E-06
4_2E-08
1.9E-06

36.9%
1.4%
61.7%

1,2-Diehloroethane (100%)
1.2 -Dichloroethane (100 %)
1,2-Dichloroethane (100 %)

1.8E-03
6.8E-05
8.7E-05

92.0%
3.5%
4.5%

1,2-Dichloroethane (100 %)
1,2-Dichloroethane (100 %)
1,2-Dichloroethane (100 %)

Total Risk

3E-06





2E-03





Child Resident
Ingestion of Groundwater
Dermal Contact with Groundwater
Inhalation of Volatiles

6.5E-07
1.8E-08
4.6E-07

573%
1.6%
41.1%

1,2 -Dichloroethane (100 %)
1,2-Dicliloroethane (100 %)
1,2-Dichloroethane (100 %)

4.2E-03
1.2E-04
8.7E-05

95.3%
2.7%
2.0%

1,2-Dichloroethane (100 %)
1,2-Dichloroethane (100 %)
1,2-Dichloroethane (100 %)

Total Risk

1E-06





4E-03





Total Residential Risks:

4E-06









'

MP-O
Well MW-1

Adult Resident
Ingestion of Groundwater
Dermal Contact with Groundwater
Inhalation of Volatiles

4.0E-05
1.0E-07
3.9E-07

98.8%

<1%
<1%

Arsenic (99.4 %)
Arsenic (85.6 %)
1,1-Dichloroethane (100 %)

4.2E-01
3.1E-03
NA

99.3%
<1%
NA

Arsenic (60.8 %)
Antimony (80.1 %)

Total Risk

4E-05





4E-01





Child Resident
Ingestion of Groundwater
Dermal Contact with Groundwater
Inhalation of Volatiles

2.3E-05
4.4E-08
9.8E-08

99.4%
<1%
<1%

Arsenic (99.4 %) ,
Arsenic (83.6 %)
1,1 -Dichloroethane (100 %)

9.8E-01
5.3E-03
NA

99.5%
<1%
NA

Arsenic (60.8 %)
Antimony (80.1 %)

Total Risk

2E-05





1E+00





Total Residential Risks:

6E-05











MP-O

Well MW-2

Adult Resident
Ingestion of Groundwater
Dermal Contact with Groundwater
Inhalation of Volatiles

1.4E-07
8.6E-09
2.3E-07

37.1%
23%
60.6%

1,1-Dichloroethane (100 %)
1,1 -Dichloroethane (100 %)
1,1 -Dichloroethane (100 %)

3.6E-04
2.2E-05
NA

94.2%
5.8%
NA

1,1-Dichloroethane (100 %)
1.1 -Dichloroethane (100 %)

Total Risk

4E-07





4E-04





Child Resident |

Ingestion of Groundwater 1 8.1E-08
Dermal Contact with Groundwater j 3.7E-09
Inhalation of Volatiles | 5.7E-08

57.3%
2.6%
40.1%

1,1 -Dichloroethane (100 %)
1.1 -Dichloroethane (100 %)
1.1 -Dichloroethane (100%)

8.3E-04
3.8E-05
NA

95.7%
4.3%
NA

1,1 -Dichloroethane (100 %)
1,1 -Dichloroethane (100 %)

Total Ridc| 1E-07.

•



9E-04





Resident - Mutagenic compounds | j.
Ingestion of Groundwater j NA j NA









C-5

AR307584


-------
Table C-2 (Continued)

Total Excess Lifetime Cancer and Non-Cancer Risk by Receptor and Pathway (without PAHs, BTEX and Mn)

Ezide Hamburg, PA









COC Contributing Majority





COC Contributing Majority

Exposure



Cancer

Percent

of Risks by Receptor &

Non-Cancer

Percent

of Risks by Receptor &

Area

Receptor/Exposure Pathway

Risk

Contributioi)

Pathway (% contribution)

Risk

Contribution

Pathway (% contribution)



Dermal Contact with Groundwater

NA

NA











Total Risk

NA |











Total Residential Risks:

5E-07











MP-O

Adnit Resident







-





WellMW-6

Ingestion of Groundwater

NA

NA



NA

NA





Dennal Contact with Groundwater

NA

NA



NA

NA





Inhalation of Volatiles

NA

NA



NA

NA





Total Risk

NA J



NA "







Child Resident















Ingestion of Groundwater

NA

NA



NA

NA





Dennal Contact with Groundwater

NA

NA



NA

NA





Inhalation of Volatile®

NA

NA.



NA

NA





Total Risk

NA





NA







Total Residential Risks:

NA











WH-BR

Adnlt Resident













Well BW-7

Ingestion of Groundwater

1.3E-06

43.4%

ris(2-Ethylhexyl)phthalate (87.6 %

1.3E-02

45.2%

as(2-Ethylhexyl) phthalate (96.6 %]



Dennal Contact with Groundwater

1.5E-06

47.8%

>is(2-Ethylhexyl} phthalate (99.3 %

1.5E-02

54.8%

>is(2-Ethylhexyl) phthalate (99.8 %]



Inhalation of Volatiles

2.7E-07

8.8%

1,1 -Dichloroethane (100 %)

NA

NA





Total Risk

3E-06





3E-02







Child Resident















Ingestion of Groundwater

7.8E-07

52.7%

>is(2-Ethylhexyl) phthalate (87.6 %

2.9E-02

53.0%

«s(2-Ethylhexyl) phthalate (96.6 %'



Dermal Contact with Groundwater

6JE-07

42.7%

>is(2-Ethylhexyl) phthalate (99.3 %

2.6E-02

47.0%

>is(2-Ethylhexyl) phthalate (99.8 %]

-

Inhalation of Volatiles

6.8E-08

4.6%

1,1-Dichloroethane (100 %)

NA

NA .





Total Risk

1E-06 1



6E-02







Total Residential Risks:

' 5E-06 I









WHO

Adnlt Resident













Well MW-7

Ingestion of Groundwater

6.1E-05

99.8%

Arsenic (100 %)

4.1E-01

99.1%

Arsenic (96 %)



Dennal Contact with Groundwater

1.4E-07

<1%

Arsenic (100 %)

3.8E-03

<1%

Chromium (77 %)



Inhalation of Volatiles

NA

NA



NA

NA





Total Risk

6E-05 {



4E-01







Child Resident















Ingestion of Groundwater

3.5E-05

99.8%

Arsenic (100 %)

9.5E-01

99.3%

Arsenic (96 %)



Dennal Contact with Groundwater

5.8E-0S

<1%

Arsenic (100 %)

6.6E-03

<1%

Chromium (77 %)



Inhalation of Volatiles

NA

NA



NA

NA



C-6

AR307585


-------
Table C-2 (Continued)

Total Excess lifetime Cancer and Non-C ancer Risk by Receptor and Pathway ('without PAHs, BTEX and Mn)

Elide Hamburg, PA

Exposure
Area

Receptor/Exposure Pathway

Cancer
Risk

1 COC Contributing Majority
Percent § of Risks by Receptor &
Contribution Pathway (% contribution)

Non-Cane ei
Risk

| COC Contributing Majority
Percent | of Risks by Receptor &
Contribution^ Pathway (% contribution)



Total Risk

4E-05



1E+00 ( |

Resident - Mutagenic compounds
Ingestion of Gtouadwater
Dermal Contact with Groundwater

4.2E-0S 87.0% | Chromium (100%) ..
6.3E-06 j 13.0% | Chromium (100 %)







Total Risk

5E-05 | I | |- •



Total Residential Risks:

1 ! I ¦ 1



COC — Constituent of Concern.

NA - Toxicity reference values ¦were not available for identified COPCs. Therefore risks were not calculated.
O = Overburden
BR = Bedrock

C-7

AR307586


-------
Table C-3.1

Excess Lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEXand Mn)

Incidental Ingestion of Soil (0-1.25 ft bgs)

. Office Worker 1







(teal















Percent





,

Bioavailabilit

Daily Intake

Daily Intake

Cancer









Contribution







y

Cancer

Non-Cancer

Slope

Reference



Percent

Hazard

to Total

Esp



Soil EPC

U

Factor (SF)

Dose (Rfl>)

Cancer Risk

Contribution to

Quotient

Non-Cancer

Area

COPC

(mg/kg)

(unitless)

(mg/kg-d)

(mg/kg-d)

(kg-d/mg

(mg/kg-d)

CR=DI,x SF

Total Cancer Risk

HQ = DI^+RfD

Risk

BW

Aluminum

9.2E+03

l.OE+OO

1.6E-03

4.5E-03

NA

l.OE+OO

NA



4.5E-03

2% "

BW

Antimony 1

1.2E+02

1.0E+00

2. IE-OS

5.8E-05

NA

4.QE-04

NA



1.5E-01

73.9%

BW

Arsenic

1.6E+01

3.0E-01

8J2E-07

23E-06

1.5E+00

3.0E-04

1.2E-06

48 7%

7.6E-03

3.9%

BW

Chromium

1.5E+01

1 0E+00

2.6&06

7JE-06

5.GE-01
NA

3.0E-03

1.3E-06

51.3%

24E_03

1.2%

BW

Cobalt

8.6E+00

1.0E+00



'""TUST*1

30E-04

NA ~~1



1.4E-02

7l%

BW

Iran

3.3E+04

l.OE+OO

5.7E-03

1.6E-02

NA

7.0E-01





2.3E-02

115%	

BW

Lead(l)

-

-

-

-

-

-

-



-

BW

Caibazole

1.3E-01

l.OE+OO

2.3E-08

6.4E-08

NA

NA

NA



NA



MP-A

Ahmwmim

8.7E+03

l.OE+OO

l.SE-03

4.2E-03

NA

l.OE+OO

NA



4.2E-03

<1%

MP-A

Antimony

3.8E+03

ifoE+oo

6.6E-04

1.9E-03

NA

4.0E-04

NA



4.6E+O0

98.6%

MP-A

Aisenic

3.3E+01

3.0E-O1

1.7E-06

4.8E-06

1.5E+00

3.0E-04

2.6E-06

68.5%

1.6E-02

<1%

MP-A

Chromium

1.3E+01

1.0E+00

2.2E-06

6.1E-06

5.0E-01

3.0E-03

1.1E-06

29.2%

2.0E-03

<1%

MP-A

Cobalt

8.4E+00

l.OE+OO

1.5E-06

4.1E-06

NA

3.0E-04

NA



1.4E-02

<1%

MP-A

Iron

3.0E+04

1 OE+OO

5.2E-03

1.5E-02

NA

7.0E-01

NA !

2.1E-02

<1%

MP-A,

Eead(l)

—

-

-

-

-

. —

-

-





MP-A

Mercury

1 4F.-01



2.4E-08



NA*~'

1.6E-04

NA



4.3E04

<1%

MP-A

Thallium

6.0E-01

1.06^0

1.0E-07

2.9E-07

NA

NA

NA



NA



MP-A

Aroclor 1254

2.5E-01

1.0E+00

4.4E-08

1JE-07

2.0E+00

2.0E-05

i

2.3%

6.1E-03

<1%

MP-A

Caibazole

Z9B42



5.1E-09

1.4E-08

NA

NA

NA



NA



MP-A

Metbylcyclohfxanp

3.5E-03

l.OE+OO

6.1E-10

1.7E-09



NA

¦ NA



NA



MP-B

Antunony

6.7E+03

1.0E+00

1.2E-03

3.3E-03

NA

4.0E-04

NA



8.2E+00

80.3%

MP-8

Arsenic

4.1E+03

3.0E-01

2.2E-04

6.1E-04

1.SE+00

3.0E-04

3JE-04

100.0%

2.0E+00

T9.7%

MP-B

Lead(l)

—

—

—

—

-

-

—



-



PL

Alummum

8.3E+03

1.0E+00

1.4E-03

4.1E-03

NA-

l.OE+OO

NA



4.1E-03

33%

PL ~1

Antimony

1.0E+01

1 0E+00

1 7l£06 1

4.9E-06

NA

4.0E-04
3.0E-04

NA



1.2E-02

9~9%

PL

Aisenic

7.3E+01

3 0E-01

3.8E-06

1.IE-OS | 15E+00

5.7E-06

72.5%

3.6E-02

29.1%

PL

Chromium

r 2.5E+01

1.0E+00

4.4E-06

1.2E-05 1

r S.0E-01



2.2E-06

27.5%



33%

PL

Cobalt

|___

1.0E+00

1.6E-06

4.5E-06

NA

3 0E-04

NA



1.5E-02

r~~™12J%

PL

boo

6.9E+04



1.2E-02

3.4E-Q2

NA

7.0E-01

NA





39.3%

PL

Lead(l)

~

—

- •





-

-



-



PL

Mercury

1.1E+00

l.OE+O)

1.9E-07

5.4E-07

NA

1.6E-04

NA



3.4E-03

2.7%

PL

Caibazole

5.1E-01

l.OE+OO

8.9E-08

2.5E-07

NA

. NA

NA



NA



WH

Ahimirnim

1.2E+04

l.OE+O)

2.1E-03

6.0E-03

NA.

l.OE+OO

NA



6.0E-03

2.3%

WH

Antimony

1.7E+02

l.OE+OO

3.0E-05

8.5E-05

NA

4.0E-04

¦ NA



2.1E-01

80.6%

WH

Aisenic

1.7E+01

3.0E-01

S.m07~1

2.4E-06

1.5E+00

"~3"jolr04

1.3E-06

37.9%

8.1E-03

3.1%

C-8

AR307587


-------
Table C-3.1 (Continued)

Excess Lifetime Cancel- and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mn)

Incidental Ingestion of Soil (0-1.25 ft bgs)

Office Worker 1





i

Oral















Percent





¦|

Bioavailabilit

Daih' Intake

Daily Intake

Cancel-









Contribution





j

y

Cancer

Non-Cancer

Slope

Reference



Percent

Hazard

to Total

Exp



j Soil EPC:

(B)

(Die)

(DU

Factor (SF)

Dose (RfD)

Cancer Risk

Contribution to

Quotient

Non-Cancer

Area

COPC

| (mg/kg)

(unitless)

(mg/kg-d)

(mg/kg-d)

(kg-dmg)

(mg/kg-d)

CR=DItiSir

Total Cancer Risk

,

HQ = Dlat^-RfD

Risk

WH

Chromium

J 2.5E+01 "

r 1.0E+00

4 3E-06 1

1.2E-05



3.0E-03

2.1E-06 ^

621%

4.0E-03

1.5%

WH
WH

Cobalt

6 7E+G0

r 1.0E+00 1

I.2E-06 ~"i

3.3E-06

NA

3 OE-04

NA

1.1E-02

4.2%

Iron

| 3.1E+04

1.QE+00

5.4E-03

l.SE-02

r" NA~~~

7.0Er01

NA

2.2E-02

8.3%

WH

Lead(l)



-

j- _



WH

Carbazole

_™~~™J • 1.5E-02

1.0E+00

2:<5E-09

7.3E-09

NA

NA

KA

f NA

(I) Lead is evaluated using the Adult Lead Model

Total Cancer Risk:

BW 2.5E-06
MP-A 3.7E-06
MP-B 3.3E-04
PL 7.9E-Q6
WH 3.4E-06

Hazard Index:

BW 2.0E-O1
MP-A 4.7E+00
MP-B 1.0E+01
PL 1.2E-01
WH 2.6E-01

Notes:

Intake Factor (IF) •

IRxEFxEDxCF

BWxAT

1.7E-07
(cancer)

4.9E-07
(non-cancer)

1R	Ingestion Rate (mg'day)

FR	Fraction jrom Contaminated Source

EF	Ingestion Exposure Frequency (days/yr)

ED	Ingestion Exposure Duration (yrs)

CF	Conversion Factor (kg/mg)

BW	Body Weight (kg)

AT-C	Averaging Time - Cancer (d)

AT-NC	Averaging Time - Non-Cancer (d)

50
1

250
25
0.000001
70
25550
9125

HA - Hot available.

C-9

AR307588


-------
Table C-3.2

Excess lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mn)

Dennal Contact with Soil (0-1.25 ft bgs)

Office Worker 1

Exp
Area 1COPC

SoflEPC'
(mg/kg)

Dermal
Absorption
Fraction
(ABS)
(unitiess)

Dailv Intake |Daih' Intake

i

Cancer (Non-Cancer


-------
Table C-3.2 (Continued)

Excess lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mn)

Dermal Contact with Sofl (0-1.25 ft bgs)

Office Worker 1







Dermal





Dermal









Percent







Absorption

Daily Intake

Daily Intake

Cancer

Dermal



Percent

Hazard

Contribution







Fraction

Cancer

Non-Cancer

Slope

Reference

Cancer Risk

Contributio

Quotient

to Total

F.tp



SoilEPC

(ABS)

TO

(DU

Factor (SF)

Dose (RID)

CR = DIcx

n to Total

HQ =

Non-Cancer

Area

COPC

(mg/kg)

(unitless)

(mg/kg-d)

(mg/kg-d)

(kg-d/mg)

(mg/kg-d)

SF

Cancer Risk

DI^RfD

Risk

PL
PL

Mercury

1.1E+00

• NA

NA

NA

NA



NA



NA



Caibazole



NA.

NA

NA

NA. .

r NA

NA .







WH

Ahtmiraim

1.2E+04

NA

. NA

NA .

NA

1.0E+00

NA



NA



WH

Antimony

1.7E+02

NA

NA

NA

NA

6.0E-05

NA



NA



WH

Arsenic



3.0E-02

24E-07

6.7E-07

1.5E+00

3.0E-04

3.GE-07

100.0%

2.2E-03

* 100.0%

wh

Chromium

2.5E+01

NA

NA

NA

2.0E+01

7.5E-05
3.0E-04

NA
NA



NA



wh

Cobalt

j 6.7E+00

NA

NA

j———

NA

"na



WH

Iron

3.1E+04

NA

NA

NA

NA

7 OE-OI

NA



NA



WH

Lead(l)

-

—

—

—

—

—

—



—



WH

Caibazole



	"na	

r na

NA'

NA-^

NA ¦

NA



NA



(1) Lead is evaluated using the Adult Lead Model-

Total Cancer Risk:

Hazard Index

BW 3.4E-07

BW

2.1E-03

MP-A 7.4E-07

MP-A

6.8E-03

MP-B 9.0E-05

MP-B

S.dE-01

PL 1.6E-06

PL

9.9E-03

WH 3.6E-07

WH

2.2E-03

Notes:

Intake Factor (IF) =

SA x AFx EFxED x CF

=

4.8E-07

1.4E-06



BWxAT



(cancer)

(turn-cancer)

SA

Surface Area Exposed to SoiVSedimmt (cm2/day)

1980

AF

Skin Adherence Factor (mg/cm2/

0.07

EF

Dermal Exposure Frequency (days/yr)

250

ED

Dermal Exposure Duration fyrs)

25

CF

Conversion Factor (kg/mg)

0.000001

BW

Body Weight (kg)

70

AT-C

Averaging Time - Cancer (d)

25550

AT-NC

Averaging lime - Non-Cancer (d)

9125

NA - Not available.

C-ll

AR307590


-------
Table C-3.3

Excess lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mn)

Incidental Ingestion of Sofl (0-10 ft bgs)

Office Worker 2







Oral















Percent







Bioavailabilit

Daily Intake

Daih* Intake

Cancer





Percent



Contribution







y

Cancer

Non-Cancer

Slope

Reference



Contribution

Hazard

to Total

Exp



Soil EPC

(B)

(Dy

(DU

Facfor(SF)

Dose (RfD)

Cancer Risk

to Total

Quotient

Non-Cancer

Area

COPC

(mg/kg)

(aaitbss)

(mg/kg-d)

(mg/bg-d)

(kg-d/mg)

(mg/kg-d)

CR=DItxSF

Cancer Risk

HQ=D1k+RID

Risk

BW

Aluminum

9.2E+03

1.0E+00

1.6E-03

. 4.5E-03

NA

l.OE+OO

NA



4.5E-03

4%

BW

Antimony

3.9E+01 J l.OE+OO

6.8E-06

1.9E-05

NA

4.0E-04

NA

! 4.8E-02

42.2%

BW

Arsenic

1.4E+01 | 3.0E-01

7.5E-07

2JE-06



3.0E-04

1.1E-06

46.4%

7.0E-03

6.2%

BW

C&raminm

1.5E+01 } 1.0E+00

2 6E-06

7;2E-06

5.0E-01

3.0E-03

_

53.6% f 2.4E-03

2.1%

BW

Cobalt



1.0E+00

2.8E-06

___!

NA

3 0E-04



T 2.7E-02

23.5%

BW

Iron

3.6E+04

1.0E+00

6.2E-03

1.7E-02 -

NA

7.0E-01

NA

2.5E-02

22.0%

BW

Lead(l)

—

—

—

—

--

—

-

-



BW

Carbazole



l.OE+OO

2.8E-08





NA

NA

1 NA

MP-A

Aluminum

1.2E+04

l.OE+OO

2.2E-03

6.IE-03

NA

1.0E+00

NA



6.1E-03

<1%

MP-A

Antimony

____j

1.0E+00

4.9E-04

1.4E-03 I NA

4.0E-04

NA '



3.5E+00

98.4%

MP-A

Arsenic

1.7E+01

3.0E-01

9.0E-07

2.5E-06

1.SE+00

3.0E-04

1.4E-06

47.4%

8.4E-03

<1%

MP-A

Chromium

1.6E+01

1.0E+00

2.9E-06

8.0E-06

-5 0E-01

3.0E-03

1.4E-06

50.5% '

2.7E-03

<1%

MP-A

Cobalt

9.6E+00

I.0E+00

1.7E-06

4.7E-06

NA

3.0E-04

NA



1.6E-02

<1%

MP-A

Iron

2.8E+04

1.0E+00

4.8E-03

1.4E-02

NA

7.0E-01

NA



1.9E-02

<1%

MP-A

Lead (1)

—

—

—

—

-

-

-



--



MP-A
MP-A

Mercury

4.1E-01

1.0E+00



2.0E-07

NA

1.6E-04

NA



13£^3

<1%

Thallium

fiSR-Ol

l.OE+OO

1.1E-07

3.2E-07

NA



NA



NA



MP-A

Aroclor 1254

1.8E-01

ioe+oo

3.1E-08

8.6E-08

2.0E+00

2.0E-05

6.1E-08

2.2%

^ 4.3E-03

<1%

MP-A

Carbazole

1.4E-01

1.0E+00



|___ .

NA

NA

NA



NA



MP-A

TPH (as Diesel)

3 5E+03

l.OE+OO

6.1E-04

1.7E-03

NA

NA

NA



NA



MP-A

Metliylcyclohexane



I l.OE+OO

2.9E-07

8.2E-07

NA

NA

NA 1







MP-B

Antimony

1.6E+03

1.0E+00

2.9E-04

8.1E-04

NA

4.0E-04

NA

1 2.0E+00

81.1%

MP-B

Arsenic

9.6E+02

3 0&O1

5.0E-05

1.4E-04

1.5E+00

r 3.0E-04

7.6E-05

100.0%

4.7E-01

18.9%

MP-B

Lead(l)

—

—

—

—

-

—

-



-



PL

Aluminum

2.1E+04

1.0E+00

3.7E-03

1.0E-02

NA

l.OE+OO

NA



1.0E-02

8.8%

PL

Antimony

34E+00



6.0E-07

1.7E-06

NA

4.0E-04

NA



-C2E-03

3.6%

PL

Arsenic



3.0E-01

3.4E-06

"TS5T1

h_*oq

3.0E-04

5.0E-06

69.2%

3JEP02

26.8%

PL~~

Chromium

2.6E+01

l.OE+OO

4.5E-06

1.3E-05

5.0Er0l

3.0E-03

2.2E-06

aav
jU.O/o

4.2E-03

3.6%

PL

Cobalt



l.OE+OO

2.9E-06

8.2E-06



3.0E-04

NA



2.7E-02

23.4%

PL

lion

5.1E+04

i.OE+OO

9.0E-03

2.5E-02

~*NA~~1

7.0E-01

NA



3.6E-02

30.8%

PL

Lead(l)

—

—

—

-

¦-

-





- -



PL

Mercury

1.1E+00

l.OE+OO

1.9E-07

5.4E-07

r~NA

1.6E-04

NA



3.4E-03

2.9%

PL

Carbazole

5.1E-01

1 OE+OO

8.9E-08

2.5E^07

NA

NA

NA



NA



C-12

AR307591


-------
Table C-3.3 (Continued)

Excess Lifetime Cancel';

I Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mn)
Incidental Ingestion of Soil (0-10 ft togs)

Office Worker 2

Exp. j
Area COPC

Oral

Dai*jr IntakeDaily Intake

Cancer j Non-Cancer

(DIJ j (DU

(mg/kg-d) (mg/kg-d)

Cancer

Slope ( Reference
Factor (SF)| Dose (RfD)
(kg-d/mg) f (mg/kg-d)

*| Percent

I Contribution i Hazard
Cancer Risk to Total Quotient
CR = DItxSF Cancer Risk HQ = DI^RfD

Percent
Contribution
to Total

Noo-Caocer
Risk

(I) Lead is evaluated using theAdult Lead Model

Total Cancer Risk:
BW 2.4E-06
MP-A 2.8E-06
MP-B 7.6E-05
PL 7.3E-06
WH 3.0E-06

Notes:

Intake Factor (IF) —

JRxBFxEDxCF

BWxAT

1.7E-07
(cancer)

4.9E-07
(non-cancer}

Hazard Index:
BW 1.1E-01
MP-A 3.5E+00
MP-B 2.SE+00
PL 1.2E-01
WH 1.6E-01

IR	Ingestion Rite (mgfday)	50

FR	Fraction from Contaminated Source	J

EF	Ingestion Exposure Frequency (daysfyr)	250

ED	Ingestion Exposure Duration (yrz)	25

CF	Conversion Factor tkg/mg}	0.000001

BW	BcufyWe%ht(kg)	70

AT-C	Averaging Time - Cancer (d)	25550

AT-NC	Averaging Time - Non-Cancer (d)	9125

Nd - Not available.

C-13

AR307592


-------
Table C-3.4

Excess lifetime Cancer and Non-Cancer Risk by C hemical and Pathway (without PAHs, BTEX and Mn)

Dermal Contact with Soil (0-10 ft bp)

Office Worker 2

Dermal

Soil EPC

(ingfcg)

Fraction
(ABS)
(tmifless)

Daily Intake
I Cancer



(mg/kg-d)

I Dermal 1
Daily Intake Cancer | Dermal
Non-Cancer Slope I Reference
(DIeJ Factor (SF). Dose (SID)
(nig/kg-d) I (kg-d'ing) 1 (mg/kg-d)

Cancer Risk
CR=Dl^iSF

Percent
Contribution to
Total C ancer Risk

Hazard
Quotient
HQ=DInf-Rfl)

Percent
Contribution

to Total
Non-Cancer
Risk

C-14

AR307593


-------
Table C-3.4 (Continued)

Excess lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs. BTEX and Mn)

Dermal Contact with Soil (0-10 ft bgs)

Office Worker 2

'





| Dmaii





Dermal



1





Percent







I .Absorption

\ Daily Intake: Daily Intake

Cancel-

Dermal







Contribution







| Fraction

Cancer

Non-Cancer

Slope

Reference



Percent

Hazard

to Total

Exp



Soil EPC

(ABS)



fl>y

Factor (SI)

Dose (RfD)

Cancer Risk j

Contribution to

Quotient

Non-Cancer

Area

COPC

(mg/kg)

] (unitless)

! (mg^lcg-d)

| (mg/kg-d)

(kg-d/mg)

(mg/kg-d)

CR=Dlj x SFjTotal Cancer Risk

HQ=DIk*R1D

Risk

wh

Antimony

7.7E+01

NA

f - NA

i - NA

NA

6.0E-05



NA N



WH

Arsenic

1.3E+01

1 3.0E-02

i 1.9E-07

! 5.3E-07

1.5E+00

3.0E-04

2.9E-07f

100.0%

1.8E-03





Chromium

P 2.2E+01

1 ~NA

	 NA

j— na ¦

2.0E+01

7.5E-05

NA I .

NA



WH

Cobalt

1.9E+01

1 Sa~~""

NA -

NA

NA

3.0E-04

NA J

NA



WH

Iron

3.1E+04

1 NA

NA

[ NA

NA

7.0E-01

NA |

NA



vm

Lead(l)

- "

-

-



—



1 • '

-



WH

Thallium

8.4E-01

1 NA

NA



NA

NA

NA

NA



WH

Carbazole

1.1E-02



NA



	NA

NA

- NA |

NA



(1} Lead is evaluated using the Adult Lead Model









Total Cancer Risk:

Hazard Index:

















BW

3.1E-Q7

BW

1.9E-03

















MP-A

4.0E-07

MP-A

4.0E-03



x













MP-B

2.1E-05

MP-B

1.3E-01

















PL

1.4E-06

PL

8.7E-03

















WH

2.9E-07

WH

1.8E-03





Notes:























Intake Factor (IF) =

SAxAFxEFxEDxCF

=

4.8E-07

1.4E-06















BWxAT





(cancer)

(hen-cancer)









SA	Surface Area Exposed to Soil/Sediment (cm-/day)

AF	Skin Adherence Factor (mgfcm2)

EF	Dermal Exposure Frequency (days/yr)

ED	Dermal Exposure Duration (yrs)

CF	Conversion Factor (kgfmg)

BW	Body Weight fkgy

AT-C	Averaging Time - Cancer (d)

AT-NC	Averaging lime - Non-Cancer (d)

19S0
0.07
250
25
0.000001
TO
25550
9125

NA - Not available.

C-15

AR307594


-------
Table C-3.5

Excess lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mn)

Incidental Ingestion of Soil (0-5.25 ft bgs)

Utility Worker







Oral















Percent







BioavaOaUHt 1 Daily Intake

Baily Intake

Cancer





Percent



Contribution







y

Cancer

Non-Cancer

Slope

Reference



Contribution

Hazard

to Total

Frp



Soil EPC

(B)

0>lc)



Factor (SF)

Dose (RID)

Cancer Risk

to Total

Quotient

Non-Cancer

Area

COPC

(mg/kg)

(unitless)

(mg/kg-d)

(mg/kg-d)

(kg-d/mg)

(mg/kg-d)

CR=DIcxSF

Cancer Risk

HQ = DIBC+RfD

Risk

BW

Aluminum

9.2E+03

1.0E+00

1.3E-04

3.6E-04

NA

1.0E+00

NA



3.6E-04

4%

BW

Antimony

3 9E+01

1.0E+00

5.4E-07

1.5E-06

NA

4.0E-04

NA



3;8E-03

42.1%

BW

Arsenic

1.4E+01

3.ioP

6.0E-08

1.7E-07

1.5E+00

3.0E-04

9.0E-08

46.5%

5.6E-04

6.2%

BW

Chromium



lli+oo



5.8E-07

5.0E-01

3.0E-03

1.613)7

53.5%

1.9E-04

2.1%

BW

Cobalt

1.6E+01

1.QE+00

2.3E-07

6.4E-07

___j

3.0E-04

NA



2.1E-03

23.6%

BW

Iron

3.6E+04

1.0E+00

s.oe^m"'

1.4E-03

NA

7.0E-01

NA





22.0%

BW

Lead(l)

—

—

—

-

—

-

-



-



BW

Carbazole

1 1.6E-01

:"T6e+00

2.2E-09

6.3E-09

NA

NA

NA



NA



MP-A

Aluminum

1.2E+04

I.0E+00

1.7E-04

4.7E-04

NA

1.0E+00

NA



4.7E-04

<1%

MP-A

Antimony

3.1E+03

1.0E+Q0

4.3E-05

1.2E-04

NA

4.0E-04

NA



3.GE-01

98.5%

MP-A

Arsenic .

1.9E+01

!___

8.1E-08

2.3E-07

1.5E+00

3.0E-04



5L9%

7.5E-04

<1%

MP-A

Chromium



1.0E+00

2.1E-07 ~1

6.0E-07

5.0E-01

3.0E-03

1.1E-07

45.9%

2.0E-04 ~1

<1%

MP-A

Cobalt

9.6E+00



1.3E-07

3.8E-07

NA

^cSST*

NA



1.3E-03

<1%

MP-A

Iron

2.8E+04





1.1E-03

NA

7.0E-01

NA



1.5E-03

<1%

MP-A

Lead(l)

—

—

—

—

—

-

—



-



MP-A J

Mercury

4.1E-01



5.7E-09

1.6E-08

NA

1.6E-04

NA



1.0E-04

<1%

MP-A *1

Thallium

6.5E-01

1 0E+00



2.5E-08

NA

NA

NA (

NA



MP-A

Aroclor 1254

1.8E-01

1 0E+00

! . 2.5E-09

6.9E-09

2.0E+00

2.0E-05

4.9E-09

2.1%

3 4E-04 1

<1%

MP-A j

Carbazole

7.8E-01

1.0E+00

1.IE-08

3.1E-08

NA

NA

NA I

NA



MP-A

TPH (as Diesel)

3.5E+03

Toe+oo .

"Ikiiir"1

1.4E-04

NA

NA

NA



NA



MP-A

Methvicyclohexane

3.8E+00

1.0E+00

5.3E-08



NA

NA





NA



MP-B

Antimony

2.4E+03

1.0E+00

3.3E-05

9.3E-05

. NA

4.0E-04

NA



2.3E-01

81.1%

MP-B

Arsenic

1.4E+03

3.0E-01

5.8E-06

1.6E-05

1.5E+00 !

3.0E-04

8:7E-06

f 100.0%

5.4E-02

18.9%

MP-B

Lead(l)

—

—

—

—

' —

—

—



-



PL

Aluminum

8.3E+03

1.0E+00

1.2E-04

3.2E-04

-NA

1.0E+00

na 1

3.2E-04

3.4%

PL

Antinwny

3.6E+00



s.iSiH

1.4E-07

na~

4.0E-04

NA |

3.5E-04

3.8%

PL

Arsenic

7.8E+01

3.0E-01

r 3.3E-07

9.2E-07

1.5E+00

3.0E-04

4.9E-07

73.9%

3.1E-03

32.6%

PL

Chrominm

2.5E+01

l.OE^OO-"5



9.8E-07

5.0E-01

3;0E-03

1.7E-07 i 26.1%

3 3E-04

3.5%

PL

Cobalt

9.3E+00

1.0E+00

1.3E-07

3.6E-07

• NA

3.0E-04

NA -- j

1.2E-03

12.9%

PL

Iron

6.9E+04

1.0E+00

9.7E-04

2.7E-03

_ NA i 7.0E-0I

NA . f

3.9E-03

41.0%

PL

Lead(l)

—

—

-

— '

-

-



-



PL

Mercury

1.1E+00

1.0E+00

1.5E-08



_ H

1.6E-04

_

na ; f

2.7E-04

t 2.9%

PL

Carbazole

5.1E-01

1.0E+00 | 7.IE-09

2.0E-08

NA ¦



NA T

NA



C-16

AR307595


-------
Table C-3.5 (Continued)

Excess Lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mb)

Incidental Ingestion of Soil (0-5.25 ft bgs)

Utility' Worker





I -

Oral















Percent





I

Bioavailabilit (Daily Intake! DaOy Intake

Cancer





Percent



Contribution





1

y

Cancer

Non-Cancer

Slope

Reference



Contribution

Hazard

to Total

Exp



| SoilEPC*

(B)

(Die)

(DU

Factor (SF)

Dose(RfD)

Cancer Risk

to Total

Quotient

Non-Cancer

Area

COPC

| (mg/kg)

(unitless)

(mg/kg-d)

(ing/kg-d)

(kg-d/ing)

(mg/kg-d)

CR=DIcxSF

Cancer Risk

HQ = DI^+RfD

Risk

WH

Aluminum

1 1.3E+04

1.0E+00

1.8E-04

5.1E-04

NA

1.0E+00

NA



5.1E-04

3.1%

WH

Antimony

1.1E+02

l.OE+00f 1.6EAI6

4.3E-06

NA

4.0E-04

NA



i 1.1E-02

66.2%

WH

Arsenic

- | 1.5E+01

3.0E-01

6.3E-08

Hsr*

rrs&sr

3.0E-04

9.5E-08

37.8%

5.9E-04

3.6%

WH

Chromium



L^OO

3.1E-07~"



5.0E-01

3.0E-03



622%

2.9E-04

1.8%

WH

Cobalt

1 1.9E+01

1.0E+00

H—E-o?

7.3E-07

NA

3.0E-04

NA



2.4E-03

14.8%

WH

boa

1 3.1E+04

I.0E+00

4.3E-04

1.2E-03

NA

7.0E-01

NA



1 7E-03

10.5%

WH

Lead(l)

1 -

—

Hi"

—

-

—

-



-



WH

Thallium

1 8.4E-01

1.0E+00

3:3E-08

NA

NA

NA



NA



WH

Caibazole

™™i~nLIEii2™~

LCE+OO ~i

1.6E-10

4.4E-10

NA

NA

NA



NA



(1) head is evaluated using the Adult Lead ModeL

Total Cancer Risk:
BW 1.9E-07
MP-A 2JE-07
MP-B 8.7E-06
PL 6.7E-07
WH 2.5E-07

Hazard Index:
BW 9.0E-03
MP-A 3.1E-01
MP-B 2.9E-01
PL 9.4E-03
WH 1.6E-02

Notes:

Intake Factor (IF) =

IRxEFxEDxCF

BWxAT

1.4E-08
{cancer)

3.9E-0S
(non-cancer)

a	Ingestion Rate (mg/day)	100

FR	Fraction from Contaminated Source	1

EF	Ingestion Exposure Frequency (daps/yr)	10

ED	Ingestion Exposure Duration (yrs)	25

CF	Conversion Factor (kgiSng)	0.000001

BW	Body Weight (kg)	70

AT-C	Averaging Time - Cancer (d)	25550

AT-NC Averaging Time - Non-Cancer (d)	9125

NA - Not available.

C-17

AR307596


-------
Table C-3.6

Excess lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs. BTEX and Mil)

Dermal Contact with Soil (&-S.25 ft bgs)

Utility Worker







Dermal



J

Dermal









Percent







Absorption

Daily Intake iDailv Intake

Cancer

Dermal







Contribution







Fraction

Cancer

j Non-Cancer

Slope

Reference



Percent

Hazard

to Total

Exp



Soil EPC

(ABS)

(PU

(DU

Factor (SF)

Dose (RfD)

Cancer Risk

Contribution to

Quotient

Non-Cancer

Area

COPC

(mg/kg)

(onitkss)

(mg/kg-d)

j (mg/kg-d)

(kg-d/mg)

(mg/kg-d)

CR = DlcxSF

Total Cancer Risk

HQ = DI^+RfD

Risk

BW

Aluminum

9.2E+03

NA

NA

1 NA

NA

1.QE+00

NA



NA



BW
BW

Antimony

3.9E+01

NA

NA

I NA

NA.
1.5E+00

6.0E-05





"na



Arsenic

1.4E+01



4.0E-08

1.1E-07

3.0E-04

5.9E-08

100.0%

3.7E-04

100.0%

BW

Chromium

1.5E+01



NA

NA

2.0E+01

	7^05~

NA







BW

Cobalt

1.6E+01

NA

r __

i~NAT

NA

3.0E-04

NA



NA



BW

Iron

y6E~

NA

NA ¦

T-™NA~

NA

7.0E-01

NA



NA



BW

Lead(l)

— -

- —

—

-

-

_ .

-

" -



BW

Carbazole

L6E-01 |

NA

NA



NA-

NA

NA







MP-A

Aluminum

1.2E+04

NA

NA

| NA

NA -

1.0E+00

NA



NA



MP-A

Antimony

3.1E+03

NA

NA

NA

NA

6.0E-05

NA



NA



MP-A

Arsenic

1.9E+01

3.0E-02

5.3E-08

TTS&07

l.SE-HW

3.GE-04

8.0E-08

94.6%

5.0E-04

61.0%

MP-A

Chromium

1.5E+01

NA

NA

1 55S "

2.0E+01

7.5E-05

NA™™***"*1



NA



MP-A

Cobalt

9.6E+00

NA

NA

| NA

NA

3.0E-04

. NA



NA



MP-A

Iron

2 8E+04

NA

NA

NA

NA

7.0E-01

NA-"™1



NA



MP-A

Lead(l)



—

—

j

-

—

-



-



MP-A

Mercury

4.1E-01

NA

NA

NA

NA

1.6E-04

NA



NA



MP-A

Thallium

___!

"NA

NA

j NA

¦NA

NA

NA _1



NA



MP-A

Aroclor 1254

1.8E-01

1.4E-01

2 3E-09

I 6.4E-09

2.0E+00

2.0E-05



5.4%



39.0%

MP-A

Carbazole

7.8E-01

NA

NA

NA

NA

NA

NA -



NA



MP-A

TPH (as Diesel)

3.5E+03



NA

NA

NA

NA





NA



MP-A

Methylcyclohexane

3.8E+66

NA

NA

I NA '

NA

NA

NA



NA



MP-B

Antimony

2.4E+03

NA

NA

I na

NA

6.0E-0S

¦ NA



NA



MP-B

Arsenic

1.4E+03

3.0E-02

3.8E-06

j 1.1E-05

1.5E+00

3.0E-04

5.8E-06

100.0%

3 6E-02

100.0%
4.0%""™*

MP-B

Ead(l)

—

—

T- -

-

-

- ,



-

PI

Ahmritmm

8.3E+03

NA

NA

I NA

NA

1.QE+00

NA



NA



PL

Antimony

3 6E+00

NA

NA

| NA

NA

6.0E-05

NA



NA



PL

Arsenic

7.8E+01"



2.2E-07

6.1E-07

1.5E+00

3.0E-04

3.3E-07

100.0%

2.0E-03

100.0%

PL

Chromium

2.5E+01

_

- NA
NA

NA
1 NA

2.0E+01

7.5E-05

NA
NA



NA



PL

Cobalt

P 9.3E+00

r™NA^

NA

r^o&oi™



MA



PL

Iron

69E+04

NA

NA

| NA

NA

7.0E-01

NA







EL

Lead(l)

—

—

—

1 -



- -



PL

Mercury

l.l&HW

NA

t~~NA

NA

NA .

1.6E-04

NA



NA



PL

Carbazole

5.1E-01

NA

NA

"j NA

NA

NA

•NA

: NA



WH

Aluminum

1.3E+04

NA

NA

j NA

NA

1.0E+00

NA

[ NA



C-18

AR307597


-------
Table C-3.6 (Continued)

Excess Lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mn)

Derma] Contact with Soil (0-5.25 ft bgs)

Utility Worker

J



Dermal | I

Dermal









Percent





Absorption ( Daily Intake Daily Intake

Cancer

Dermal







Contribution





Fraction I Cancer 1 Non-Cancer

Slope

Reference



Percent

Hazard

to Total

Exp

Soil EPC

(ABS) J (PI.) J (Disc)

Factor (SF)

Dose (RfD)

Cancer Risk

Contribution to

Quotient

Non-Cancer

Area JCOPC

(mgftg)

(unitless) 1 (mg/kg-d) I (mg/kg-d)

(kg-d/mg)

(mg/kg-d)

CR=DI,x SF Total Cancer Risk

HQ = DItt+RfD

Risk

WH (Antimony

1.1E+02

NA NA NA

. NA

6.0E-05

NA



r na



WH JAivcmc

1.5E+01

3.0E-02 4.2E-08 ! 1.2B-07

1.5B+00

3.0E-04

6.3E-08

100.0%



100.0%

WH jChroimum

2.2E+01 j NA j NA I NA

2.0E+01





NA



WH j Cobalt

1.9E+01

NA | NA I NA

NA

3.0E-04

NA



r na



WH |lran

¦ 3.1E+04 1 NA. ' | 'NA 1' NA

NA

7.0E-01

NA







WH ILead(l)

-

I - I -

-

—

—

-



WH Thallium

8.4E-01

NA NA f NA

NA .

NA

NA

1 . NA ¦



WH ICarbazole

1.1E-02 H

| __ .j __h

NA

NA

NA

¦ I™ NA



(1) Lead is evaluated using the Adult Lead ModeL





Total Cancer Risk:

Hazard Index:



'







BW

5.9E-08

BW

3.7E-04

-









MP-A

8.4E-08

MP-A

8.1E-04











MP-B

5.8E-06

MP-B

3.6E-02











PL

3.3E-07

PL

2.0E-03











WH

6.3E-08

WH

3.9E-04



Notes:

Intake Factor (IF) =

SAxAFxEFxEDxCF

=

9.2E-OS

2.6E-07



BWxAT



(cancer)

(non-cancer)

SA

Surface Area Exposed to Soil/Sediment (cm'/day)

3300

AF

Skin Adherence Factor (mg/'cm2)

0.2

EF .

Dermal Exposure Frequency (days/yr)

10

ED

Dermal Exposure Duration (yrs)

25

CF

Conversion Factor (kg/mg)

0.000001

BW

Body Weight (kg)

?0

AT-C

Averaging Time - Cancer (d)

25550

AT-NC

Averaging Time - Non-Cancer (d)

9125

NA -Notavailable.

C-19

AR307598


-------
Table C-3.7

Excess Lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs, BXEX and Mn)

Incidental Ingestion of Soil (0-17 ft bgs)

Construction Worker























Percent







Oral

Daily Intake

Daih" Intake

Cancer





Percent



Contribution







Bloavailability

Cancer

Non-Cancer

Slope

Reference



Contribution

Hazard

to Total

Exp



Soil EPC

(B)

(M.)

(DI«c)

Factor (SF)

Dose (RID)

Cancer Risk

to Total

Quotient

Non-Cancer

Area

COPC

(mg/kg)

(unities?)

(ing/kg-d)

(ing/kg-d)

(kg-d/mg)

(mg/kg-d)

CR=DItxSF

Cancer Risk

HQ = Dlac+RfD

Risk

BW

Aluminum

9.2E+03

l.OE+OO

1.7E-04

3.1E4>2

NA

l.OE+OO

NA



3.1E-02

4%

BW

Antimony

3.9E+01

l.OE+OO

7.2E-07

r^___

NA

4.0E-04

NA



3.3E-01

42.2%

"iw

Arsenic

1.4E+01

3.0E-01

7.9E-08

14e5>5

1.5E+00

3.0E-04

1.2E-07

40.4% f 4.8E-02

6.2%

bw

Chromium

1.5E+01

10E+00

2.7E-07

5.0E-05

5.0E-01

3.0E-03

1.4E-07

53.6%

1.7E-02

2.1%

BW

Cobalt

1.6E+01

l.QE+OO



5.5E-05 '



3.0E-04

NA

1 1.8E-01

23.5%

BW

Iron

3.6E+04

10E+00

6.6E-04

1.2E-01

.NA 1



NA

1 7E-01 '

22.0%

BW

Lead(l)

—

¦ —

-

--

' -

»

• -

1 —



BW

Caibazole

1.6E-01

1.0E+00

3.0E-09

r™5.4E-07

!_~na . •

NA.

NA



NA



MPA

Aluminum

1.2E+04

l.OE+OO

2.3E-04

42E-02

NA . '

l.OE+OO

' NA



4.2E-02

<1%

MPA

Antimony

2.8E+03

l.OE+OO

5.2E-05

9.5E-03

NA"

4.0E-04

NA



2.4E+01

98.4%

MPA

Arsenic

1.7E+01

3.0E-01



1.7E-05

l.SE+OO

3.0E-04

1.4E-07

1 46.8%

5.7E-02

<1%

MPA

Chromium



l.OE+OO

3.0E-07





3.0E-03

1.5E-07

51.0%

1.8E-02

<1%

MPA

Cobalt

9.6E+00

l.OE+OO

l.SE-07

3.2E-05

~na

3 0E-04

NA



1.1E-01

<1%

MPA

Iron

2.8E+04

l.OE+OO

5.1E-04

9.3E-02

NA 1

1 7.0E-01

NA



L3E-01

<1%

MPA

Lead (1)

—

—

—

—

—

. -

-



-



MPA

Mercury

4 1E-01

l.OE+OO

7.6E-09

1.4E-06

NA™***"*'

1.6E-04

	NA	



86E-03

1 <1%

MPA

Thallium

6.5E-01

i.OE+OO

i.2E-08

2.2E-06

I

NA

NA



NA



MPA

Aroclor 12S4



l.OE+OO

3.2E-09

5.9E-07

2.0E+00 1

2.0E-05

6.5E-09

2J%

3.0E-02

<1%

MPA

Carbazole

¦ 1.4E-01

l.OE+OO

2.6E-09

4.7E-07



NA

NA

~

NA



MPA

TPH (as Diesel)

3.5E+03

l.OE+OO

6.5E-05

1.2E-02

NA

NA

NA



NA





Methyicyclohexane

1.5E+00

l.OE+OO

2.8E-08

5.2E-06

NA™"*'

NA

NA



NA



MP-B

Antimony

1.6E+03

l.OE+OO

3.0E-05

5:5E-03

NA

4.0E-04

NA



1.4E+01

81.1%

MP-B

Arsenic

9J5E+02

3 0E-01

5.3E-06

9.7E-04

l.5E+W~1

1 3.0E-04

8.0E-06

100.0%

3.2E+00

189%

MP-B

Lead(l)

-

—

—

-

- - .

-

-



-



PL

Aluminum

2.1E+04

l.OE+OO

3.9E-04

7.1E-02

NA

l.OE+OO

!___

NA



7.1E-02

8.8%

PL

Antimony

3.4E+O0

l.OE+OO

6.3E-08

1.2E-05





NA



2.9E-02

"" 3.6%

PL

Arsenic

6.4E+01

3.0E-01

3_5E-07

6.5E-05

———j

3.0E-04

5.3E-07



2.2E-01

26.8%

PL

Chromium

2.6E+01

l.OE+OO



8.6E-05

5.0E-01 1

3.0E-03

2.4E-07

30.8%

2.9E-02

3.6%

PL

Cobalt

!»___»«,

l.OE+OO

3.1E-07

5.6E-05

NA

3.0E-04

NA



1.9E-01

r_23.4%

PL

Iron

5.1E+04

l.OE+OO



1.7E-01

r~ NA

7.0E-01

NA



2.5E-01

30.8%

PL

Lead(l)

—

—

—

—

—

-

—



—



PL

Mercury

1.1E+00

l.OE+OO

2.0E-08

3.7E-06

NA

1.6E-04

NA



2.3E-02

19%

hTi

Caibazole

riE-oi'1"5

l.OE+OO

9.4E-09

1.7E-06

r NA

NA

- NA



NA



WH

Aluminum

1.3E+04

l.OE+OO

2.4E-04

4.4E-02

NA

l.OE+OO

NA



4.4E-02

3.9%

C-20

AR307599


-------
Table C-3.7 (Continued)

Excess Lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mn)

Incidental Ingestion of Soil (0-17 ft bgs)

Construction Worker







!



1











Percent







Oral

Daily Intake Daily Intake

Cancer





Percent



Contribution







Bioavailability

Cancer

Non-Cancer

Slope

Reference



Contribution

Hazard

to Total

Ftj



SoilEPC

(B)

(MJ

| 0>I«>

Factor (SF)

Dose (RfD)

Cancer Risk

to Total

Quotient

Non-Cancer

Area

COPC

(mg/kg)

1 (unitless)

(mg/kg-d)

| (mg/kg-d)

(kg-d/mg)

(mg/kg-d)

CR=M«xSF

Cancer Risk

HQ = DI^RfD

Risk

WH

Antimony

7 8E+01

1 0E+00

J.4E-06

t 2.6E-04

NA

4 0E-04

NA

1

6.6E-01

58.4%

WH

Arsenic

1.3E+01

3 0E-01

7.0E-08

j 1.3E-05

1.5E+00

3.0E-04

1.0E-07

33.7%

4.3E-02

3.8%

WH

Chromium

2.2E+01

1 0E+00

4.1E-07

\ 7.5E-05

S.0E-01

riijg£b3

2.1E-07

66.3%

- 2.5E-02 1

2.2%

WH

Cobalt

1.9E+01

1 OE+OO

3.4E-07

1 6.2E-05

NA

3 0E-04

NA



2.1E-01

18.5%

WH

Iron

3.1E+04

1 0E+00

5:7E-04

j 1.0E-01

NA

7.0E-01

NA



1.5E-01 I

13.2%



Lead(l)





-

1

—

—

—



WH

Thallium

8.4E-01



1.5E-08

f 2.8E-06

NA .

NA

NA

t" NA j '

WH

Caibazole

1.1E-02

1 1.0E+00

2.1E-10



NA

NA

NA



NA j



(1) Lead is evaluated using the Adult Lead Model ¦









Total Cancer Risk:

Hazard Index:

















BW

2-5E-07

BW

7.8E-01

















MP-A

3.0E-07

MP-A

2.4E+01

















MP-B

8.0E-06

MP-B

1.7E+01

















PL

7.7E-07

PL

8.0E-01

















WH

3.1E-07

WH

1.1E+O0



Notes:

Intake Factor (IF) —

ntxEFxEDxCF

BWxAT

I.SE-OS
(cancer)

3.4E-06
(non-cancer)

IR	Ingestion Rate (mg/day)

FR	Fraction from Contaminated Source

EF	Ingestion Exposure Frequency (daystyr)

ED	Ingestion Exposure Duration (yrs)

CF	Conversion Factor (kghng)

BW	Body Weight (kg)

AT-C	Averaging Time - Cancer (d)

AT-NC	Averaging Time - Non-Cancer (d)

330
1

100
1

0.000001
70
255S0
140

NA - Not available.

C-21

AR307600


-------
Table C-3.8

Excess lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mn)

Dermal Contact with Soil (0-17 ft bgs)

Construction Worker







Dermal





Dermal









Percent







Absorption

Dailv Intake

Daily Intake

Cancer

Dermal



Percent

Hazard

Contribution







Fraction

Cancer

Non-Cancer

Slope

Reference

Cancer Risk

Contribution

Quotient

to Total

Eip



SoilEPC

(ABS)

(DW

0>U

Factor (SF)

Dose (RfD)

CR=DItx

to Total

HQ =

Non-Cancer

Area

COPC

(mg/kg)

(unitless)

(mg/fcg-d)

(mg/kg-d)

(kg-d/mg)

(mg/kg-d)

SF

Cancer Risk

DI^+RfD

Risk

BW

Aluminum

9.2E+03

NA

NA

NA

NA

1.0E+00

NA



NA



BW

Antimony

3.9E+01



NA

h____

NA

6.0E-05

NA



NA



BW

Arsenic

1.4E+01 J 3.0E-02

1.6E-08

2.9E-06

1.5E+00

3.0E-04

2.4E-08 ( 100.0%

9.6E-03

100.0%

BW

Chromium

1.5E+01

NA

NA

NA

2.0E+01

7.5E-05

NA J .

NA



BW

Cobalt

1.6E+01

NA

NA

NA

NA

3.0E-04

NA "~1

NA



BW

Iron

3.6E+04

NA -

NA

NA

r na

7.0E-01

NA '

NA



BW

Lead(l)

—

-

-

-

- -

-

f

-



BW

Caibazole

1.6E-01

i~NA~™~"

NA

NA

p———

NA



NA



MP-A

Aluminum

1.2E+04

NA

NA

NA

NA

1.0E+00

NA j

NA



MP-A

Antimony

2.8E+03

NA

NA

NA



6.0E-05

NA I

NA





Arsenic

1.7E+01

3.0E-02

L9E4)8

3.4E-06



3.0E-04

2.8E-08

93.9%

1.1E-02

57.7%

MP-A

Chromium

1.6E+01

NA

NA

NA

2.0E+01

7 5E-05

NA 1

NA

MP-A
MP-A

Cobalt

9.6E+-00

NA



_»

NA

3 0E-04

NA _X-

NA



Iron



NA

NA

NA

NA

7 0E-01

NA

NA





Lead(l)

—

--

-

¦ -

-



-



MP-A

Mercury

4.1E-01

NA

NA



NA

1.6E-04

NA

NA



i_ri

Thallium

S&oi

NA

NA

NA

NA

\ na



NA

423%"'""

MP-A

Aroclor 1254

1.8E-01

1.4E-01

9.1E-10

1.7E-07

2.0E*00
NA

2.0E-05

1.8E-09

6.1%

8.3E-03

MP-A
MP-A

Carbazole

I.4E-01

NA





NA

_ j

NA



TPH (as Diesel)

3.5E+03

NA

NA

NA



NA

NA

NA





Methykyclohexane

1.5E+00



NA

. NA .



NA

___

NA



MP-B

Antimony

1.6E+03

NA

NA

NA

NA

6.0E-05

NA i

NA



MP-B

Arsenic

9-6E+02

3 0E-Q2

r~l.lR06

1 9E-04

1.5E+00

3.0E-04

1.6E-06 I 1000%

6.5E-01

r 100.0%

,_p

Lead(i)

—

—

—

-

-

- ,



-



PL

Aluminum

2.1E+04

NA

NA
NA

NA

na"

NA

1.0E+00

'NA I."

NA



PL

Antimony

3 4E+00

NA

NA

6.0E-05

NA 1 •

NA



PL

Arsenic

6 4E+01

3.0E-02

7.1E-08

rns5™<

1.5E+00

3.0E-04

1.1E-07

100.0%

4.3E-02-

100.0%



Chromium

2.6E+01

NA

NA

NA

p____

7 5E-05

NA

'

NAI





Cobalt

1.7E+01

NA

NA

NA

r NA

3 OE-04

NA ¦!

NA



PL
PL

Iron

5.1E+04

NA

NA

NA- .

1 NA__

7.0E-01

NA

NA

	



. —

—

—



PL

Mercury

1.1E+00

NA

NA

NA

. NA

1.6E-04

NA

NA



PL

Caibazole

5.IE-01

NA

NA

NA

NA

NA

NA

NA



C-22

AR307601


-------
Table C-3.8 (Continued)

Excess Lifetime Canes' and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mn)

Dermal Contact with Soil (0-17 ft bgs)

Construction WaH^r







I Dermal





Dermal









Percent







1 AbsorptioB
J Fraction

Daily Intake
Cancer

DaQj Intake
Non-Cancer

Cancer
Slope

Dermal
Reference

Cancer Risk

Percent
Contribution

Hazard
Quotient

Contiibudon
to Total

Frp



SoilEPC

CABS)

(Die)

(DU

Factor (SF) Dose (RID)

CR=DItx

to Total

HQ=

Non-Cancer

Area

COPC

(mg/kg)

1 (unidess)

(mg/kg-d)

(mg/kg-d)

(kg-d/mg)

(mg/kg-d)

SF

C ancer Risk

Dlet-HRfD

Risk

WH

Aluminum

1.3E+04

1 NA

NA

NA -

NA

1.0E+00

NA



NA



WH

Antimony



T NA

NA

NA

NA

6.0E-Q5

'NA



r na



WH

Arsenic

1.3E+01

1 3.OE-02

1.4E-08

2.6E-06

h 1.5E+00

3.0E-04

2.1E-08 "

100.0%

8.5E-03

100.0%

WH

Chromium

2.2E+01

Fi



NA

2.0E+0I 1

7.5E-05

NA

I NA



WH

Cobalt

1 9E-H) 1

s NA



NA

NA 1

3.0E-04

NA



NA



WH

Iron

3.1E+04

NA

NA

NA

NA

7.0E-01

NA _i



NA



WH

Lead(l)

-

-

-

- -

1



-



-



WH

Thallium

8.4E-01

NA

na""~1

NA I NA

nX

NA



NA



WH

Caibazole

1.1E-02

I NA

NA

NA '



NA

NA







(1) Lead is evaluated using the Adult Lead Model	Total Cancer Risk:	Hazard Index:

BW	2.4E-08	BW	9.6E-03

MP-A	3.0E-08	MP-A	2.OE-02

MP-B	1.6E-06	MP-B	6.5E-01

PL	1.1E-07	PL	43E-02

WH	2.1E-08	WH	8.5E-03

Notes:				

Intake Factor (IF) =

SAxAFxEFxEDxCF

=

3.7E-OS

6.7E-06



BWxAT



(cancer)

(non-cancer)

SJ	Sulfate Area Exposed to SoilSediment femi'dayi	3300

AF	Skin Adherence Factor (mg/cm2)	0.2

EF	Dermal Exposure Frequency (daystyrj	100

ED	Dermal Exposure Duration (yrs)	1

CF	Conversion Factor (kg/mg)	0.000001

BW	Body Weight (kg)	70

AT-C	Averaging Time - Cancer 
-------
Table C-3.9

Dermal Absorption of Groundwater
Construction Worker

Esp Area

Filter

COPC

Outside
EPD

MW
g/mole

Log Kow
unitkss

Kp
cm/br

B | Dsc
unitless 1

LagTiwJ t*
hr/erent | br

b

unitless

^ 1 Uri'

unitless |hr/ervat

TA
unitless

Cmk

mg/cm'

DA
mg/cm2-event

MP-Ovoburden

T

Antimony







1.0E-03

' 1

|



j 2.0

1.0

3.6E-06

7J2E-09

MP-Ovettarden

T

Chromium







2.0E-03

L—|—'

1





r 1.0

2.6E-06

1.0E-08

MP-Ovefburden

T

Di-n-octyl phthafete N

390.57

8.1

2.4E+00

I.8E+OIT1OE-O8

1.6E+01 7.5E+01



1.9E+01 | 2.0

1.0

2.8E-06

1.1E-04

MP-Overburden

"T™1

l,145ichloroeaiane N

99

1.79

6.7E-03

2.6E-02 1 4.4E-07

3.8E-01 9.0E-01

3.2E-01

3.5E-01 | 2.0

"To

4.5E-06

8.3E-08

MP-Overtjunien

T

Meftykryclohexane | Y

98.19

3.61

1.1E-01

4.2E-0lT4 ^07

"3.7E-01 9.0E-01

6.3E-0T

6.6E-01 2.0

To



1.2E-06

WH-Overburden

T

Arcane (





l.GE-03

• ' I

¦



	

1.0

5.8E-06

1.2E-08

WH-Overborden

T







2.0E-03

!







To

8.7E-06

3.SE-08

Notes:

Thickness of Skin (ok)	0,001 US EPA, 2004a

Exposure Duration {ED) -t^^, - Water Contact Duration (hr)	2.0

Conversion Factor (L/cm3)	0.001

MW - Molecular Weight ig/mole)

LogKaw - OctanoLivater partition coefficient limitless)

Kp- Strateum cerneum (sc) permeability constant (cm/hr)

B - Ratio ofpermeabibty of chemical in strateum corneum to permeability in viable epidermis tunidessj

Dsc - Effective diffushityfor chemical transfer through the skin (cm !/hr)

Cone = Groundwater concentrations tmg/L) * Conversion Factor O.OOlL'cm1

KA - NotAppbcable

t* - Time to reach stead)1 state (hr>

b&c- parameters used to calculate time to reach steady state
FA - Fraction absorbed {unitless)

DA - Absorbed Dose (mg/cm 2 -event)

EPD: Effective Prediction Domain

C-24

AR307603


-------
Table C-3.10

Excess Lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mn)

Dermal Contact with Groundwater
Construction Worker







] Absorbed

Dermally

Dermallv

Deiinal



Cancer I





1







1, Dose

Absorbed Dose

Absorbed Dose-

Cancer

Dermal

-Risk I

Percent

Hazard

Percent







(DA): .

I - Cancer

NonCancer

Slope

Reference Dose

CR=

Contiibution

Quotient

Contribution



Exp



(mg/cin2-

I (DADC)

(DADk)

Factor (SF)

(Rfl»

DADcX

to Total

HQ=

to Total Non-

Exp Area

Media

COPC

erorit)

I (m&T^-d)

(mgfeg-d)

(kg-d/mg)

(mg/kg-d)

SF |

Cancer Risk

DADm-!-RfD

Cancer Hazard

MP-Overburden

T

Antimony

! 7.2E-09

i 1.3E-09

2.4E-07

NA.

60E-0S

NA	1	:			

4.0E-03

S 46.3%

MP-Owert>urden

T

Chromium



1 1.9E-09

3.5E-07

2.0E+01

7.5E-05

3 8E-08 J

99.8%

4.7E-03

t 53.5%

MP-Overburden



Di-n-octyl phthalate

I l.lE-04"

r 2.0E-05

3.6E-03 I NA

NA

NA 1 .

, NA 1

MP-Overburden

rn

1,1-Diehloroethane

I 8 3E-08

|____

2.8E-06

5.7E-Q3

2.0E-01

^7E4TT

<1%

1.4E-05

1 <1%

MP-Overburden

"t"1

Methylcyclohexane

I 1.2E-06

1 2.2E-07

4:lE-05

NA

NA

naT

NA | -

WH-Overburden

T

Arsenic

j 1.2E-08

i 2.1E-09

3.9E-07

1.5EHJ0

3.0E-04

3.2E-09 |

14%

1.3E-03

I 7.7%

WH-Overburden

T

Chromium

™1 3.5E-08

I 64E-09

1.2E-06

2.0E+01

75E-05



97.6%

1.6E-02

I 92.3%

Total Cancer Risk:	Hazard Index:

MP-Overburden 3 8E-08 MP-Overburden 8.7E-03
WH-Overtourden 1.3E-C7 WH-Ovoburden 1.7E-02

Notes:

Intake Factor (IF) s

SAxEFxED

BWxAT

l.SE-Ol
{cancer)

34E+01
(non-cancer)

SA Surface Area Exposed to Groundwater (cm'}
EF Exposure Frequency (event/yr)
ED Exposure Duration fyr)

BW Body Weight (kg)

AT Averaging Time - Cancer 0}

Averaging Time - Non- Cancer Id)

Absorbed Dose calculated and presented in Appendix Table D. 79
DAD = DA x IF

NA - Kot available/Not Applicable

3300
100
1

70
25550
140

C-25

AR307604


-------
Table C-3.11

Excess Lifetime Cancer and >~on-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mb)

Ingestion of Groundwater
Adult Resident

1

1





1

1

Daily Intake

1

Daily Intake [ Cancer



-

Percent

Hazard

Percent

1

1









Cancer

Non-Cancer j Slope Factor

Reference

Cancer Risk} Contribution to

Quotient

Contribution to







Groundwater

(Die)

Pl«>

(SF)

Dose (RfD)

CR = DImg)

I (mg/kg-d)

SF

Risk

Dlnt^RfD j

Hazard

MP-Bedroct 1

D

BW-3

Thallium | 5.2E-03

4.9E-05

1.4E-04

NA

! NA

NA.



NA 1

MP-Bedrock j

T

BW-6

1 ;2-D»clsloroethanie I 1.3E-03

12E-05

3.6E-05

9.1E-02

2.0E-02

1.1E-06

100.0%

1.8E-03 1

100.0%

MP-Beirocki

T



Methyfcyclohexane

~ 7.6E-04

7.1E-06

2.1E-05

p___.

NA

NA ~1



NA |

MP-Overtrarderii

D

MW-1

Antimony

2.4E-03

23E-05

6.6E-05

NA

|- 4.0E-04

NA



1.6E-01 !

39.1%

MP-Oreibnrd«Ej

D

__1

Arsenic

2.81-03

2.6E-05

7.7E-05

1.5E+00

( 3.0E-04

3.9E-05

99.4%

2.6E-01 1

60.8%

MP-OvertjurdeOj

T

MW-1

lJ-Diehloroethane

!___

4.2E-05

1.2E-04

5.7E-03

| 2.0E-01

2 4E-07

<1%

6.2E-04 !

<1%

MP-Overtrardenj

T

MW-2

Di-n-octyl phthalate

2.8E-03

2.6E-05

7.7E-05

NA

) NA

NA



NA |

MP-Overborfedj

T

MW-2

1,1-DicMtaoethane

2.6E-03

2.4E-05

7.1E-05

p———

| 2.0E-01

1.4E-07

100.0%

3.6E-04 |

100.0%

MP-Overtrardenj

T

MW-6

Methylcyclohexane

4.5E-03

42E-05

1.2E-04

NA

| NA •

NA



NA I

WH-Bedrock 1

T

BW-7

t»is(2-EfliyHiexyl) phthalat*

8.9E-03

8.4E-05

2.4E-04

1.4E-02

| 2.0E-02

12E-06

87.6%

1.2E-02 I

96.6%

WH-Bedrock (

T

BW-7

1,1-Dichloroethane

3.1E-03



8.5E-05

5.7E-03

1 2.0E-01

1.7E-07

|



3.4%

WH-Overtmrdejj

D

MW-7

Arsenic

43E-03

4.0E-95

1.2E-04

1.5E+00

| 3.0E-04

6. IE-OS

100.0%

3.9E-01

96.0%

WH-Ovatwda(f

D

MW-7

Chromium

1.8E-03

M ~

4.9E-05

5.0E-01

j 3.0E-03

NA



1.6E-02 I

4.0%

M=hAitageniccm

npourw

1
1

|









Total Cancer Risk:
BW-3 NA BW-3

Bazard Index:

NA



















BW-6

1.1E-06

BW-6

1.8E-03



















MW-1

4.0E-05

MW-1

4.2E-01



















MW-2

1.4E-07

MW-2

3.6E-04



















MW-6

NA

MW-6

NA



















BW-7

1.3E-06

BW-7

1JE-02



















MW-7

6.1E-05

MW-7

4.1E-01



Note::

Intake Factor iJF) =

IRxEFxED

SWxAT

9.4E-03
(cancer)

2.7E-02

NA - Not available.

a

Ingestion Rate (Udayj

2

FS

Fraction from Contaminated Source

I

EF

Ingestion Exposure Frequency' (daysAr)

350

ED

btgestion Exposure Duration ()
-------
Table C-3.12

Dermal Absorption of Groundwater
Adult and Child Resident











MB'

Log Kow

Kp

B

Dst

Lag Time

«*

b

«

t«noi

FA

| Cone ]

DA

Exp Area

Filter

WeD .

COPC

Outside
the EPD

gimole

anitless

cm'hr

usiriess

em'/hr

hr/event

hr,;

nnitless

unirless

hr/event

unities?

| mgleaf mg/fm2-event

MP-Bedrock

D

BW-3

Thallium | j j

1.0E-03











0.3

1:0

I 5.2E-06 I

1.3E-09

MP-Bedrock

T

BW-6

1,2-Dichloroethane

N

9.9E+01

1.5E+00

4.2E-03

1.6E-02

4.4E-07

3.8E-01

9.0E-01

3.1E-01

3.4E-01

03

1.0

1 1.3E-06 |

5.5E-09

MP-Bedrock

T



Methykyclohexane

Y

9.SE+01



il.lE-01

U.2E-01

4.5E-07

3.7E-01

9.0E-01

6.3E-01

I6.6E-01

j.

1.0



1.0E-07

MP-OvaMea

D

MW-1

Antimony







1.OE03

¦



-







0.3

1.0

2.4E-06 |

6.0E-10

MP-Overtrorden

~D

MW-1

Arsenic



¦



10E-03

r











0.3

1.0

1 isEJWS 1

7.0E-I0

MP-Overburden

T

nsr1

1,1-Dichloroethase

N . .

9.9E+01

\ffi4001

6.7E-03

2.6E42

4.4E-07

3.8E-01

9.0E-01

3.2E-01

3:5E-01

oTl

1.0

j 4.SE-O6 j

3.1E-08

MP-Overijiuden

T

MW-2

Di-n-octyl phthalate

N

3.9E+02» 8.IE+00

mmm

mmm

1.0E-08

l.fiE+01



2.2E+02

1.9E+01

03

1.0

( 2.8E-O6 }

3.8E-05

MP-Ovefburden



MW-2

1,1 -Dichloroethane

- n

9.9E+01

1.8E+0G

6.7E-03

2.6E-0?

4.4E-07

3.8E-01

9.0E-01

3.2E-01

3.5E-0I

0.3 -

1.0

TTse-os

1.8E-08

MP-Ovoburdeo

T

MW-6



Y

9.SE+01

3.6E+00

1.1E-01

4.2E-01

4.5E-07

3.7E-01

9.0E-01

6.3E-01

6.6E-01

0.3

10

4.5E-06

6.0E-07

WH-Bedrock

T

BW-7

teP-E^ha^) phthalate

N

3.9E+02

5.1E+00

215E-02

1.9E-01

I.0E-08

1.6E+01



4.3E-01

4.7E-01

0 3

1.0

8.9E-06 i

1.2E-06

WH-Bedrock



BW-7

l,l-Dichlaroetha&e



9.9E+01

1.8E+00

I6.7E-03

2.6E-02

4.4E-07

3.8E-01

9.0E-01

3.2E-01

3:5E-01

oT**1

1.0

I 3.1E-06 1

2.1E-08

WH-Oveitmrden

D

MW-7

Arsenic







1.0E-03)

-









0.3

1.0

i 4.3E-06 j

1.IE-09

WH-Ovetbtuden

D

MW-71

Chromium



















" 0.3.

1.0

f 1.8E-06 F

9.0E-10

.¦Mates;

Thickness of San (city	0.001 VSEPA,2004a

Exposum Duration (ED) -1,^, - Water Contact Duration (hrj>	03

Conversion Factor (L'cm 3)	0.001

MW-MtOecahtrWei^(^mm
" LogKow - Octanolfwater partition coefficient (umtless)

Kp - Stmteum cameum (set permeability constant (cm/hri

B - Satio ttfpermeability of chemical in srrateum comeum to permeability m viable epidermis {unities:}

Die ¦ Effective tkffitnvityfor chemical transfer through the skin (cm' thr)

Canc=Qround*aterconceMratio,u
-------
Table C-3.13

Excess Lifetime Cancer and Non-Cancer Risk bv Chemical and Pathway (without PAHs, BTEX and Mn)

Adult Resident















Dermal i

















Absorbed

Dermallv

Derma Dv

Cancer



Cancer



Hazard











Dose

Absorbed

Absorbed Dose -

Slope

Dermal

Risk

Percent

Quotient

Percent









(DA)

Dose-Cancer

XonCancer

Factw

Reference Dose

CR =

Contribution to HQ —

Contribution to









(ntgW-

(DADt)

(DADbc)

(SI)

(RfD)

DADti

Total Cancer

DAD^R

Total Non-

Exp Area

Filter

Wen

core

erent)

(mgfcg-d)

(mgjkg-d)

(kg-d/mg)

(aigfcg-d)

SF

. Risk

ID

-

Cancer Hazard

MP-Bedroct

D

BW-3

Thatlmm

1.3E-09

1.1E-07

3.2E-07

NA

NA .

NA- S

- "NA |

MP-Bedroct

T

BW-6

1,2-Dichloroethane

5.5E-09

4.7E-07

1.4E-06

91E-02

2.0E-02

4.2E-0S

100.0%

6.8E-05

—

100.0%

MP-Bedroct

T~*

BW-6

Methylcyclaheacaae

r: 1.0E-O7



2.5E-05

na"""1

NA

: na I



'

MP-Ov«bmden

D

MW-1

Antimony

6.0E-10

5.1E-08

1.3E-07

HA

6-0E-O5

NA 1

2.5E-03

80.1%

MP-Ovotrardoij

D

MW-l'

Axseok

* 7.0E-10

59E-08

1.7E-07

1.5E+00

3.0E-04

8.9E-0S

85.6%

5.8E-04

18.7%

MP-Overtrardec

T

MW-1

1,1-Dichloroethane

3.1E-08

2.6E-06



J.7E-03

2.0E-01

1.5E-08 1 14.4%

3.8E-05

.1.2%

MP-Overburden

T

MW-2

Di-n-octvl phthalate

3.SE-05

3.2E-03

9.3E-03

NA | NA

NA I '

NA



MP-Ovatourden

t T

MW-2

^ISchloroefcajie

w___j

1.5E-06

4.4E-06

5.7E-03 1 2.0E-01

8.6E-09

100.0%

2.2E-05

100.0%

MP-Overt>orden

T

MW-6

Mefh^cyclohexase

6.0E-07

5.1E-j05

1.5E-04

NA

NA

NA J

NA



WH-Bedrock

T

BW-7

bis^-Efcyihexy!) phthalate

1.2E-06

1.0E-04

3.1E-04

1.4E-02

2.QE-02

1.5E-06

99.3% '

1.5E-02

99.8%

WH-Bedrock

|__H

BW-71 U-DkhlModhaoe

2.1E-08

rlSi™1

5-2E-06

f———.

2.0E-01

1.0E-0S

<1%

2.6E-05

p_=_iir

WH-Oveibuidec

D

MW-7 j Arsenic

l.lE-09

9.1E-08

2.7E-07

15E+00

3.0E-04

1.4E-Q7

100.0%

8.8E-04

23.0%

WH-Oveibcrdec



MW-7 fcinoimuai

9.0E-10 1

if"™

2.2E-07

2.0E+01

1 7.5E-05

NA' |

3.0E-03

77.0%

Total Cancer Risk:

BW-3

NA

BW-3

BW-6

4.2E-08

BW-6

MW-1

l.QE-07

MW-1

MW-2

8.6E-09

MW-2

MW-6

NA

MW-6

BW-7

1.5E-06

BW-7

MW-7

1.41-07

MW-7

NA

NA

Vnfaf
iVW(S.

InmisFact

or (IF) = —

SAxEFxED

8.SE+Q1

2.5E-HJ2







BWxAT

(cancer)

(non-cancer)

$4

£F
ED
BW
AT

Absorbed Dose calculated and presented m Appendix Table D. 7.12
DAD = DA x IF

NA - Not avaik&te®at Applicable

M = Mutagenic compound -cancer risks evaluated separately

Safiice Area Exposed to Ground water (cm'\>
Exposure Frequency (ewnt\r>

Exposure Duration $r)

Body Weight (igl

-	Cancer (di

-	Nan- Ctmcer idi

ism

350
24 _
70
25550
8760

C-28

AR307607


-------
Table C-3.14

Indoor Air CaacnlnMiMt Based ob McKmh Shower Model
Adult and Child Resident -

Bathroom Exposure Time
Shower Exposure Time
Shower Volume
Shower Veoi Rate
Bathroom/House Vail Rate
House Exposure Time
House Volume









i

| --Cone.

DiUu

Diffusion

| .

Henry's Lair

-|	—

1 ¦ Fratta ¦

1 ¦

1

Source j Shower

1
i

Bathroom

Honse

Time-
Weighted
Average









| in Water

in Water'11'

in.W11'

J Custat^

| Volatilized

Strength

Ave, Cone.

Ave. Cone, j

Ave. Cobc.

Air Cone.

Exp







) '

D1

Da

Kk

I F

S

Cshower

Cbathroom

Chouse



Area

Filter

Well

COPC

1 (ne/D

(mVs)

(mVs)

(atm-mVmoD

j (oddes)

((l^miMn")

CuaW

6>fM) 1



(nslnf)

MP- Overburden

T

BWrfi

1,2-Dichloroethane

J 1.30E-+00

1-10E-09

8.57E-06

1 • 1.18E-03 1 i 0 58

1.63E+00

9ME+00

4.70E+001

1.82E-02

2.18E-01

MP- Overburden

T

BW-6

Methyicyclohexane

|___

7.59E-10



T T»e-oi

0 46

7.57E-OI

4.49E+00



___|

1.01E-01

MP- Overburden

T

MWrl

1,1-Dichloroethane

j. 4.50E-K)0

1.06E-09

8.36E-06

j 5.62E-03

! 0.58

5.58E+00

3.31E+01

l.SlEfOl 1

6.24E-02

7.47E-01

MP- Overburden

T

MW-2

1,1-Dichloroethane

I 2.6QE+00

1.Q6E-09

8.36E-06

1 5.62E-03

| 0.5*

3.23E+00

1.91E+01

9J2E+00

, 3.60E-02

4.32E-01

MP- Overburden

T

MW-6

Methyteyclohexane j 4.50E+00

7.59E-I0

6.97E-06

j 1.89E-01

f ¦ 0.46

4.4SE+00

2.66E+01

lJffi+01 j

5.01E-02

6.00E-01

WH- Overburden

T

BW-7

1.1 -Dichloroethane

1 3.10E-HM)

1.06E-09

8 36E-06

j 5.62E-03

i 0.58 1 3.85E+00

2.28E+01

1.11E+0I 1

4.30E-02

5.15E-01

Notes:

Shower Model Notes.
KA-Not Applicable

11]

[2]

131
W

m
m
m
m
m

[10]

in]

Based on measn water use rate of 17 gallfms/skower (US EPA, 1997, Table 17-14) and 15 mm shower duration (IS EPA, 1997, Table 15-18)

McKone (1987)

75thpercmtile ofmmntes spent in the shower room after showering(10 mint + recommended upper default showering time (US EPA, 1997 Table 15-23)
Recommended upper default valuefor bathing/showering (US EPA, 1997- Table 15-1S)

McKone tl9S7)

Based on residence time of air m shower stall of20 mm (McKone, 19S7)

Typical value (USEPA,1997;Tabls 17-31)

16.4 hr total time indoors (US EPA, 1997, Table 15-176) - 0.4 hr (25 mini for time in shower and bathroom
Meim residential volume (US EPA, 1997; Table 17-il)

McKont (1987)

US EPA OOlOf)

C-29

AR307608


-------
Table C-3.15

Excess Lifetime Cancer and Xoa-Caacer Risk by Chemical and Pathway (without PAHs, BTEX and Ma)
Inhalation of Volatile Croat Showering
Adult Resident

...





1 - "





I Daih



















1





Exposure















'



\



Dally

| - Non-

•

Reference



Percent



Percent







\

TWA Air

Exposure

( Cancer

Unit Risk

Concentration

Cancel' Risk

Contribution

Hazard Quotient

C'ontribntior



Exp
Media





EPC

Cancer

1 (ADE^

(UR)

(RfC>

CR = ADEcx

to Total

HQ =

to Total Non

Exp Area

Well

jCOPC

(Hg/m3)



1 O'g''™3)



(fg'ao1)

UR

Cancer Risk

ADEK-RfC

Cancer Hazai

MP- Bedrock

T

BW-6

ll^-Dkhloroethane ..

2.2E-01

^ 7.2E-02
™"*3JE-02

! 2.1E-Q1
T 9-7E-02

2.6E-05

2.4E+03

1.9E-06

100.0%

8.7E-G5

100.0%

MP-Bedrock

T

BW-6

! Me&ylcycLohexane

l.OE-Ol

NA

NA

NA



NA

MP- Overburden

T

MW-1

(1.1-Dkhloroethaiie

7.5E-01

2.5E-01

I 7.2E-01

1.6E-06

NA

3.9E-07

100.0%

NA



MP- Overburden

T

MW-2

U,l-Dichloroethane

4JE-01

I.4E-0I

! 4.1E-01

1.6E-06

NA

2.3E4T7

100.0%

NA



MP- Overburden

T

MW-6

1 Metfcylcyclohestane

6.0E-01

2.0E-01

( 5.8E-01

NA

NA

NA



NA



WH- Bedrock

T

BW-7

(1 ,1-Dkfalocoethaae

; 5.1E-01

1.7E-01

1 4.9E-01

1.6E-06

¦ NA

2.7E-07

100.0%

NA



Total Cancer Risk:	Hazard Index:

BW-6 1.9E-06	BW-6	8.7E-05

MW-1 3.9E-07	MW-1	NA

MW-2 2.3E-47	MW-2	NA

MW-6 NA	MW-6	NA

BW-7 2.7E-07	BW-7	NA

Notes:

intake Factor (IF) = ¦.	

EFxEDxEP

3JE-01

9.6E-01







AT

.. (cancer)

(non-cancer)

EF Expacaan Fnqtmacyfmrmttyr}	35Q

ED Exposure Duration tyr)	24
EP Exposure Period (day/event) 1

AT Amv^agTbM-Qmar(4i	25SS0

Av&aging law - Aicw- Cmtartd)	8760

low Weighted Average Air EPC calculated and presented in Afpendix Table D. 7.14
HA - Not available/Not Applicable

C-30

AR307609


-------
Table C-3.16

Excess lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX and Mb)

Ingestion of Groundwater
Child Resident











Daily Intake j Daily Intake

Cancer





Percent

Hazard

Percent











Cancer

Non-Cancer

Slope Factor

Reference

Cancer Risk

Contribution to

Quotient

Contribution to









Groundwater

(m

1 PU

m

Dose (RfD)

CR-DItX

Total Cancer

HQ=

Total Non-

Exp Area

Filter

WeD

COPC

(mg/L)

(mg/kg-d)

1 (mgilsg-d)

(kg-d/mg)

(mg/kg-d)

SF

Risk

DIor^RfD

Cancer Hazard

MP-Bedrock

D

BW-3

Thallium

5.2E-03

2.8E-05

j- 3JE-04

NA

NA

NA



NA



MP-Bedrock

T

BW-6

1,2-Dichloroethane

1.3E-03

7.1E-06

1 8JE-05

9.1E-02

2.0E-02

6.5E-07

100.0%

4.2E-03

100.0%

MP-Bedrock

T

BW-6

Methylcyclohexane



4.2E-06



NA

NA





NA:



MP-Ovetburdea

D

MW-1

Antimony

2.4E-03

1 3E-05

I 1.5E-04 •

MA

4.0E-04

NA



3.8E-01

39:1%

MP-Overburden



MW-1

Arsenic

2.8E-03

1.5E-05

1 8E-Q4 ""

1.5E+00

3.0E-04

2.3E-05

99.4"! o"

6.0E-01™

60.8%

MP-Overburdeo

"T|



1,1 -Dichloroethane

4.5E-03

2.5E-05

j~2-9E-04 -

5.7E-03

2.0E-01

1.4E-07

. <1%

—i

<1%

MP-Overburden

T

MW-2

Di-n-octyl phthalate

2.8E-03

1.5E-05

| l.SE-04

NA

NA

NA



NA



MP-Oveiburden

T

MW-2

1,1 -Dichlaroethaiie

2.6E-03

1.4E-05

|___

; 5.7E-03

2.0E-01

8.1E-08

100.0%

8.3E44

100.0%

MP-Ovetbaides

T

MW-6

Methyiryxlohexane

4.5E-03

2.5E-05

' 2.9E-04

NA

NA

NA



. NA



WH-Bedrock

T

BW-7

bis(2-Elhyihexyl) phthalate

8.9E-03

4.9E-05

I 5.7E-04

1.4E-02

2.0E-02

6.8E-07

87.6%

2.8E-02

96.6%

WH-Bedrock

T

BW-7

1,1-Dichloroethane

3 1E-03

1.7E-05

| 2 0E-04

5.7E-03

2.0E-01

9.7E-08

12.4%

9.9E-04

3.4%

WH-Oveiburden

D

MW-7

Arsenic

4.3E-03

2.4E-05

1 2.7E-04

I.5E+00

3.0E-04

3.5E-05

100.0%

9.2E4J1

96.0%

WH-Ovestardea

D

MW-7

rhmnwHii

l.SE-03

M

1 1 2E-04

5.0E-01

3.0E-03

NA .



3.8E-02

4.0%

(I j Lead is evaiurted using the IEUBK model

Total Cancer Risk:

Hazard Index:

M=Mutagenic compound 
-------
Table C-3.17

Excess Lifetime Cancer s

I Non-Cancer Risk by Chemical and Patimay (without PAH*. BTEX •
Dermal Contact tiith Groundwater
¦ Child Reddeal

I Mn)









Absorbed

Derm.illy

DermaDy

Cancer



Cancer



Hazard











Dos«

Absorbed

Absorbed Dose -

Slope

Derma!

Risk

Percent

Quotient

Percent











Dose (RID)

DAD.x

Total Cancer

DAD„-HR

Total Non-

Exp Area

Filter

w»n

COPC

event)

(mgftg-d)

(m&%g-d)

id^ms)

(msfcgHO

SF

Risk

at

Cancer Hazard

MP-Bedrock

D

BW-3

TWatlmrw

1.3E-09

4.7E-08

5.5E-07

NA

NA

NA



NA



MP-Bedn>ck

T

BW-6

1,2-DirWoroetfiane

5.5E-09

2.0E-07

2.3E-06

9.1E-02

2.0E-02

l.SE-08

100.0%

1.2E-04

100.0%

MP-Bednck

T

BW-6

Methyicydohaxane

1.0E-07

3.7E-06

4.3E-0S

NA**™1

p__

NA







MP-Oveiburden

D

MW-1

Antimony

6.0E-10

2.2E-08

2.5E-07

NA

6.0E-05

NA



4.2E-03

so.i%

MP-OveAurden

D

j__T

Aneaic

7.0E-10

2 5E-OS

3.0E-O7



3.0E-04

3.SE-08

85.6%

9.8E-04

18.7%



T



1,1-Dictioroedmie

3.1E-0S

1.IE-06

\Wia

1 5.7E-03

2.0E-01

6.4E-09

14.4%

6.5E-05

.. 1.2%

MP-Overburden

T

MW-2

Oi-n-octyi phtiialite

3.8E-05

1.4E-03

J.6E-02

NA .

• NA

NA



NA





T

J—-,

1.1-Dkhloroeitane

l.SE-08

6.4E-07

7.5E46

5.7E-0S

2.0E-OI

3.7E-09

r™iTOi%~

3.8E-05

100.0%

MP-Overtmrian

T

MW-6

MAiMekiffle

6.0E-07

2.2E-05

2.5E-04

NA

NA ,

NA



NA



WH-Bedrock

T

BW-7

r

I

If

1.2E-06

4.5E-05

S.2E-04

I.1.4E-02

2.0E-02

6.3E-07

99.3%

2.6E-02

99.8%

WH-Bedrock

T

BW-7

l.l-DicMoroethaxje

ilEis

7.7E-07

9.0E-06

__™|

2.0E-01

4.4E-09

<1%

4.5E-05

d%

WH-Overirorden

D

MW-7

Al3€I2C

1.1E-09

3.9E-0S

4.5E-07

1JE+00

3.0E-04

S.SE-08

100.0%

1.5E-03

. 23.0% .

WH-Ovwbarden

D

MW-7

fltlBHMimi

9.0E-10

M



iToe+ov

7.5E-05

NA



rnE«r



it=Maagaat compound -ameer ruts evaluated separately

Total Cancer Risk:	Hazard Index:

BW-3 NA	BW-3	NA

BW-6	1.8E-08	BW-6	1.2E-04

MW-1	4.4E-0S	MW-1	5.3E-03

MW-2	3.7E-09	MW-2	3.8E-05

MW-6 NA	MW-6	NA

BW-7	6.3E-07	BW-7	2.6E-02

Mff-7	5.8E-08	MW-7	6.6E-03

Seas:

fritate Factor (1F> =

SAtEFxED

l.SE*0t

4.2E+02

BWxAT

(cancer)

tnon-cancerf

SA

Surface Area Exposed to Grow

water (cm1)

mo

EF

Exposure Frequency (ewnt/yrt



m

ED

Exposure Duration tyr)



6

BW

BodyWeigtofltgi



Ji

AT

Avenging Time - Cancer (4)



25550

Time - Non- Cancer t4i

2190

K7JS

DAD ~ DA x IF

XA - Not autilable'}fot Applicable

C-32


-------
Table C-3.18

Excels lifetime Cancer ad Non-Cancer Risk by Ckokd and Patlrpray (without PAH-. BTEX and Ma)
Inhalation of Volatile? from Showering
Child Resident '

'

-









Exposure









! Percent











Daily

Noa-



Reference



Percent

Contribution









TWA Air

Exposure

Cancer

Unit Risk

Concentration

Cancer Risk

Contribution

Hazard Quotient I to Total Non-





'



IPC

Canter

(AVEJ

(VR)



teg/mi)

, (ng/m3)-L

(P8f'jn3)

UR

Cancer Risk

ADE^RfC | Haiard

MP-Bedrock

T

BW-6

1,2-Dichlaroethaiie

2.2E-01

l.SE-02

2.1E-01

2.6E-05 .

2:4E+03

4.6E-07

100,0%

8.TE-05 | 100.0%

MP- Bedrock

rTl

¦BW-4 1



- 1.0E-01 <

S.3E-03



NA

NA

HA-*!

i NA 1

MP- Overburden

T

MW-1

l,l-Dichloroeiha&a

7.5E-01

6.1E-02

7.2E-01

1.6E-06

¦" NA

9.8E-08

100.0%

NA 1

MP- OraMes

T

MW-2

1,1-Dk^ancim

4JE-01

3:5E-®2

4.1E-01

1.6E-06

- NA

17E-08

100.0%

-'NA .. ¦ j

MP- Overburden

T

MW-6

Methylcycl'*'™'""'

6.0E-01

4.9E-02

5.SE-01

NA'

¦NA ¦ -

NA

1 NA 1

WH-Bedrock

T

BW-?

1,1-Dtchloroediane

5.1E-01

4.2E-02 '

4.SE-01

1.6E-Q6

NA

6.8E-08

100.0%

NA ! '

trial Cancer Risk	Hazard Index;

BW-6	4.6E-07	BW-6	8.7E-05

MW-1	9.8E-0S	MW-1 NA

MW-2	5.7E-08	MW-2 NA

MW-6 NA	MW-6 NA

BW-?	6.SE-08	BW-7 NA

Xdtm:

Intake Factor 0) =	

EFxEDxEPxCF

S.1S-02

9.6E-41



AT

(cancer)

(ma-cancer)

EF Exposure Frequent) (evem/jir/	ISO

ED Exposure Duration fyr)	6

EP Exposure Period (daytetent)	I

AT Averaging Time - Cancer (d)	23S5&

Averaging Tims-Hen- Cancer rd}	2190

Time Weighted Average Air EPC calculated and presented in Appendix Tabie D.7.14
NA - If at aiailable'Tfot Applicable

C-33

AR307612


-------
Table C-3.19

Excess Lifetime C ancer by Chemical and Pathway (witlioat PAHs, BTEX and Mb)
Ingestion of Croasdirater
Adult and CUU Resident - Mutagenic Compounds





i "

|

		

Intake

——|—¦' "".I

Intake { Intake

Intake

Adjusted

Adjusted

Adjusted



|







|

Cancer

Cancer { Cancer

Cancer

C ancer Slope

Cancer Slope

Cancer Slope



| Percent





j

Icnnhrrtw

(0-2 jrs)

(3-6 jtj) j (<-16 jtri)

(16-3® jrr») i

Factor (SF)

Factor (SF)

Factor (SF)



i Contribution





!

j EPC



W



{ Cancer Risk

WH-Ovabarda:

D

MW-7 | Chromium

I l.SE-03

3JE-06

6.6E-06 1 7.0E-06

' 9.9E-06

5.0E+00

1.5E+C0

5.0E-01

. 43E-0J

j 100.0%

Total Cancer Risk:
MW-? 4.2E-05

Mb:



0-2 ya

2-6 YTS

S-lim

14-30

Intake Factor (IF) -

IRxFRxEFxED _
BWxAT

L8E-03
(cancer)

3-7E-03
(earner)

S.9E-Q1
famcmi

5.5E-B3
(ameer)

m

Ingestion Rate (Ltdap)

I

I

2

2

FR

Fractionftvm Contaminated Scarce

I

1

I

I

MF

Ingestion tgwiw Fragment}- (Sayxyri

350

350

356

356

ED

Ingestion Exposure Duration tyrsi

2

4

10

14

BW

Body

IS

13

70

70

at-c

Averaging Time - Cancer (df

mse

25550

25550

15550

jffltdF

Age dependent o^juitment factor (tmiliesii

10

3 '

3

1

Adjusted cancer slope factor = Gmcer slope factor xABAF

0) Ctmcmriii — (D/w xSFtu) •t- (DI34 xSF 3.1®^+ x SF 3.1&J+ (Ntt-io x$F hmo^
Calculations fallowed methodology m US EPA. 2010a RSL User Guide

C-34

AR307613


-------
Table C-3.20

Excess Lifetime Csmwr Bfekby Omocal and Pathway (without PAHs, BTEXandMa)
Dermal Contact wilk Gronadwater
Ato»iCMdBiadBrt-y«topMi Cmni—iti

I



I I !



Dermaflv

DermaHv

Dermally

Adjusted

Adjusted

Cancel

|

j



: | Absorbed

| Absorbed

Absorbed

Absorbed

Absorbed

Cancer

Cancer

Slope

Cancer (

j



1 j ) Dwe

Dose - Cancer

Dose - Caucer

I

1

!

Slope Factor

Slope Factor

Factor

Risk I Percent

j



if 'I (DA>,

( (DADJ

(DADJ

(DADJ

(DADC>

(SF)

(SF)

m

CR= C ontribution to



F^p

I ¦ j ((¦gten^-

1 (0-2 yrs)

(2-6 vrs)

(Mfiyrs)

(16-30 vrs)

(tt-ljTS)

C-l«ws)

afr-30

D ADti Total Cancer

Eip Area I

Media

} Weil COPC ( went)

| imgfc®

0»g^-d)

(fflgfcM)

(mg^

(mgfljg-d)"1

(mg/kg-d)J

yrs)

SF i Risk

WH-Ovaburd«j

D

1 MW-7iC3ji«Bium I 9.0E-10

I 1.1E-GS

2.2E-08

3JE08

44E-08

2.0EHJ2 "

6.0E-KJ1

2.0E+01

63E-06 I 100.0%















-



Total Cancer Risk;



















MW-7

63E46

Xom:





0-2 ws

2-6 vr,

6-14Tts

15-30-yrs













SAxEFxED

I.2E-01

2.4E+61

jjsk *M

4.9E-01













BWxAT

iamceri

(concert

(concert

(cancer)











Si

Surface Art a Exposed to Qrotmd warn (cm V

6600

6600

1MW

18000











EF

Exposure Frequency (evenfyn

330

350

350

m











ED

Exposure Duration (yr)

2

4 -

10

14











BIT

BotfyWeisbtm

IS

IS

70

70







-



AT

Averaging Time - Cancer (d?

25550

25550

25550

25550











JDjIF Age dependent adjustmentftctor (wittiest

10

3

3

i









DAD =DAxIF

Adjusted cancer slope factor = Cancer slope factor* ADAF

(If Cancer risk— iDI&j xSF xii	(DI^;t xSF	xSF

Calculations fMmed methodology- m US EPA. 2016a SSL Vser Guide.

C-35

AR307614


-------
Table C-3.21

Excess

Cancer and NmhCmmt Risk by Cleaned and Pathway {without PAHa, BTEX a
I>cUk»ialtax*t«iM«fS«fl(e-l?ftbct)

Construction Worker, Mam Pared A Hot Spot Exposure

1Mb)

Percent

COPC

So3 EPC
(mglg)

Oral
Bioavailability

f)

(twitless)

Daily Intake
Cancer
fl>U
(mglg-J)

Daily Intake
Non-Cancer

(DU

{utg/kg-d)

Cancer 1
" Slope |
Factor (SF)|
(kg-d/mg) I

Acute
Reference

(mg'kg-d)

Cancer Bisk
CR = DIti

SF '

Percent
Contribution

to Total
Cancer Risk

Hazard r j '

Quotient I Xon-Caneer

HQ = DIKrRfD( Slsk

(1/Lead is <

i using the

Total Cancer Risk;
MP-A 2.2E-08

MP-A

2.1E-01

iaate Factor lIFt =	

IRxEFxEDxCF



l.SE-09

iAE-06







SWxJT



tcanctrt

Item-cancer)

W.	Ingestion Rats (mg/day)

FR	Fraction pom CcmammatedSource

EF	fegestios Exposure Frequency tde&sfyr)

ED	Ingestion Exposure Duration (yrs)

CF	Conversion Factor

BW	Body Weight «tg)

AT-C ' Averaging Time - Ctmcer (di
iWIC	Time-Hen-Cancer

. 330
1

10
I

o.mxmi

76

2S530
14

Xi -Notmailable.

C-36


-------
Table C-3.22

Excess Lifetime C ancer and Non-C ancer Risk by Chemical and Pathway (trithout PAHs, BTEX and Mn)

Dermal Contact with Soil (0-1? ft bgs)

Construction Worker, Main Parcel A Hot Spot Exposure







Dermal

1



Dermal

Acute







| Percent







Absorption

(Daily Intake

Daily Intake

Cancer

Dermal



Percent

Hazard

j Contribution







Fraction

J Cancer

Non-C ancer

Slope'

Reference

Caster Rid:

Contribution

Quotient

! to Total

Exp



Soil EPC

(ABS)

1 
-------
Table C-3.23

Dermal Absorption of Groundwater
Construction Worfcer. Main Parcel AHot Spot Exposure

Eip Area | Filter

W ell | COPC

OrtrfjJ MW iLogKwr

Kj» ( B

Dsc

Lag Time

t*

b J c 1 Uma FA ! -C«nc

DA

rheEFD.g/mole j vmtfess

csi/hr j unitle«

cmJ/hr

hr,'erent

hr

onitiess | unitfcss 1 hr/event J amtkn 1 mg'cm1

mg/cmz-eVHit

MP-Orabmdsi | T

MW-6 jMethyirvrloheitajifi

Y I 9.8E+011 3.6E+O0

l lE-01 I 42E-01

4.5E-07

3.7E-01

9.0E-01

63E-01 i 6.6E-01 | 2.0 | 1.0 | 4JE06

UE-06

Notts:

Thicbtess qf Skin (cm)	0.00 J VSEPA. 2004a

Exposure Duration (ED) - t^, - Water Contact Duraaan (hr)	2.0

Comersion Factor tUcm')	0.001

iSW - Moitcular Weight female)

LogKaw- OctanolMater partition confident (itmtless/

Zp - Strateism common (set permeability constant t'cmshr)

2 - Satio efpemea&lity of chemical in stratetan comevm to permeability in liable epidenm /umtless)

Dsc - $gbcthv dyfltsmtyfir chemical tnm&sr through theslanicm*/hr)

Cone = Qretmdxaler concentrations (mg
-------
Table C-3.24

Eichs lifetime Cancer and Xco-C'aBwr Risk by Chemical and Pa Air ay (without PAHa,BTEX and Mb)

Dermal Contact witk Groundwater
C ouuructiou Worker, Main Futtl A Hot Spot Exposure

-





J Absorbed

Dermally

DermaDy

Dermal



Cancer





Percent







I Do»

Absorbed

Absorbed Dose -

Cancer

Acute Dermal

Risk

Percent

Hazard

Contribution







(DA)

i Dose - Cancer

NonCancer

Slope

Reference Dose

CR =

Contribution

Qnotient

to Total Non-



Eip



j (mg cn»J-

(DAD,)

(DADb)

Factor (ST)


-------
Table C-3.25

Excess Lifetime Cancer and Non-Cancer Risk by Chemical and Pathway (without PAHs, BTEX ami Mn)

Incidental Ingestion of Soil (0-10 ft bgs)

Office Worker, Main Parte! A Hot Spot Exposure







Oral

Daily Is take! Daily Intake

Cancer

Acate



Percent



Percent
Contribution







BioaTailability

Cancer

1 Non-Canter

' Slope

Reference



Contribution

Hazard

to Total

Erp



Soil EPC

(B)

(DW

(OU

Factor (SF)

Dose (RID)

Cancer Risk

to Total

. Quotient

Non-Cancer

Area

COPC

(mgfcg)

(unities;)

(mg/kg-d)

1 (mg/kg-d)

(kg-4'mg)

(mgkg-d)

CR = Dltr SF

Cancer Risk

HQ = DI^-RfD

Risk

MP-A

Aluminum

1.3E+04

l.QE-KX)

2.2E-04

1 6.3E-04

HA

1.0E+00

NA -



6JE-04

19.7%

MP-A

Antimony

. 2.2E+00

l—ll&NSO

—

1 1.1E-07



4 0E-04

S'A ¦]



: 7E-04

¦ 8.5%

MP-A

Arsenic

Z7EWJ0

3.61-01

4.0E-08

!___

iTje+oo

5.0E-03

ijtmW1

2*5% ~1

2.3E-05

| :
A

I *—

1

MP-A

niwiwimn

i.SE-toi '

1.0E+00



!___

5.0E-01

5.0E-03

lJE-07

71.8%

1.7E-04

5.4%

MP-A

Cobalt

9-5E-KI0

1.0E+00

1.7E-07



MA

1.0E-02

• NA ™1



4.«E-05

1.5%

MP-A

Iron

2.9E+04

1.QE+0Q



1 1.4&03

NA "

7.0E-01

NA



2.GE-03

635%

MP-A

Lead (I)

¦ -

—

-

1

-

-

-







MP-A

Mercury

4.8E-02

1.QE+00

8.4E-10

1 2.3E-09

HA

1.6E-04

NA



1JE-05

r <1%

MP-A

Thallium

8.9E-01



1 6E-C8

j 4.4E-08

NA

NA

NA™~1



NA



MP-A

Carbazole

-



3 3E-09

J 9.3E-09

HA

. NA '

NA ¦ 1



"ST



MP-A

Methyicyclahexace

1.1E-HH

I.0E+0®:

2.0E-07

I S.5E-07



NA

NA



NA



(1) Lead is ffvoitofw* using the Adult Lead Model	Total Cancer Risk:	Hazard Index:

MP-A 2.1E-07	MP-A 3^E-03

Notes:

bate Factor (IF) = —



JExEFiEDxCF
BWxAT

1.7E-0S
(cancer)

4.9E-08
(non-cancer)



28

Ingestion Rate img-dey)



SO



FR

Fractionpom Contaminated Source



1



EF

Ingestion Exposure Frequeuy (dayzftrt



23



ED

Ingestion Exposure Duration fyn)



2S



CF

Conversion Factor ttg*ng>



0.600001



BIT

Body Weight (ig) s



. 70



ur-c

Averaging Time - Cancer id)



2SS30



Ar-NC

- Averaging Time - Non-Cancer (d)



9125

NA - Not mailable









iciac JUD









C-40


-------
Table C-3.26

Excess Lifetime Canter and Non-Canrer Risk by Chemical and Pathway (without PAHs, BTEX and Mil)

Dermal Contact with Soil (0-10 ft bgs)

Office Worker, Main Parcel A Hot Spot Exposure







Dermal
Absorption

| Daily Intake

Dailv Intake

Dermal
Cancer i

Acste
Dermal



Percent

Hoard

Percent
Contribution







Fraction

j Cancer

Non-Cancer

Slope

Reference

Cancer Risk

Contribution

Quotient

to Total

Fly

Area

COPC

SoflEPC
(mg/kg)

tABS)
(uniliess)

1 (DQ

j (mg/kg-d)

(DU

(mg/kg-d)

Factor (SF) Dose(RfD)
(kg-dfmg) j (mg/kg^l)

CR=DI,i
SF

to Total
Cancer Risk

HQ=
DI^-RfD

Non-Cancer
Risk

MP-A

Almniiuu«

1.3E+04

NA

I . NA

NA

NA

l.OBOO

NA

S NA



MP-A

Aiitiiiamy

1.6E+00

NA

NA

NA

NA

6.0E-05

NA

1 na |

MP-A

Arsenic

!___

3.0E-02

a:&o?

^~X6&08

h———

15E+00

3 OE-04

1.4E-08

1000%

8.6E-05



MP-A

Chromium

l.s&Hbi

NA





2.0E+01

7 5E-03





NA



mpI":



!___

NA

T '¦ NA i

NA



3.QE-04

NA

1 NA [

MP-A

Iran

2.9E+04

. NA

f—M—*



NA

7.0E-01

NA

1 NA 1

MP-A

teid(l)

-

-

-

—

~

—

—



- 1

MP-A

Macuiy

4.8E-02

NA

f ~~Ra

NA

NA

1.6E-04

NA



NA i

MP-A

HiaUntm

8^E01

NA

I- na



NA

NA

NA



m 1—

MP-A

Carbazole

1.9E-01

NA ••



NA



NA

NA ¦



NA



laEr1

ffibylryclofaesaDe





r f

w

NA









(1) Lead u nehutted using tie Adult Lead Mode!.	'	. Total Cancer Risk:	Hazard Index:

MP-A 1.4E-08	MP-A 8.6E-05

Nora:

bitate Factor (IF) -

SAxAFxEFxEDxCF

4.SE-0S

1.4E-Q7



BWxAT

(cancer)

(non-cancer)

, SA	Surface Area Exposed to SoibSediment (cm'/dcy)

AF	Stm Adheren ce Factor (mg 'cm'}

EF	Dermal Expo:ure Frequency (da^i>iT)

ED	Dermal Exposure Duration ifn'f

CF	Comvrsion Factor ftg/mgi

BW	Body Weight $%}

JT-C	Averaging Time - Cancer td)

AT-XC Averaging Time - Son-Cancer tdi

mo

0.0?
25
25
0000001
70
2S550
912}

NA - Not mailable

C-41

AR307620


-------
APPENDIX D
ARARS


-------
Table D-1

Action-Specific ARARs/TBCs are the
substantive requirements included in the following citations
Price Battery OU-2 Site, Hamburg, Pennsylvania

Standard,
Requirement,
Criterion, Or
Limitation

Citation Or Reference

Description

Status

Comments

FEDERAL*

Kill

si:-:

Manifesting and
Recordkeeping
Requirements

25 PA Code §§ 262a. 10
(incorporating by reference 40
CFR Part 262, but limited to
Subparts A - C, 262a. 11,
262a.12, 262a.21, and 262a.34).

Standards for recordkeeping of
the management actions for
hazardous wastes.

Applicable

Applicable if remedial activities
include the off-site transport of
hazardous waste. Does not apply
to transport of material within an
AOC.

Hazardous Waste
Management

25 PA Code §§ 261a.1
(incorporating by reference 40
CFR Part 261, but limited to
Subparts A - E, 261 a.2-8,
262a.32, and 262a.39)

Waste characterization

Applicable

Applicable for characterizing
contaminated soil or sediment
determined to be sent off-site for
disposal.

Land Disposal
Restrictions

25 PA Code §
268a. 1 (incorporating by
reference 40 CFR Part 268,
Subparts A- E)

Restricts disposal of hazardous
waste that could trigger land
disposal regulations

Applicable

Not triggered for materials that are
managed within an Area of
Contamination. Applicable to off-
site disposal only.

Storage Requirements

Preparedness and
Prevention

\

25 PA Code § 264a. 1
(incorporating by reference 40
CFR Part 264, but limited to
substantive parts of Subparts B -
6 and I - M)

Standards for the storage of
hazardous wastes.

Requirements for spill response
planning and control

Relevant
and

Appropriate

Includes requirements if remedial
activities include the storage of
hazardous waste greater than 90
days.

Materials on-site are not regulated
as hazardous waste when
consolidated in same Area of
Contamination

Off-Site Transport of
Hazardous Waste

EPA OSWER Directive 9834.11

Establishes technical guidelines
for the off-site transport of
hazardous wastes.

TBC

TBC if remedial activities include
the off-site transport and
management of hazardous waste.

National
Ambient Air
Quality Standards

40 CFR § 50.6

Requirements for fugitive dust
and particulate matter, lead in
air, and carbon monoxide.

Applicable

NAAQS for particulates and lead
may be applicable to earth-moving
activities as well as to treatment
processes that may include mixing
or other processes that result in
potential releases of particulates.

Standards for Owners
and Operators of TSD

25 PA Code § 264a Subpart N

Requirement for landfills,
including design and operating
requirements, monitoring and
inspection, response actions,
surveying, closure and post-
closure care.

TBC

Materials on-site are not regulated
as hazardous waste when
consolidated in same Area of
Contamination

•Pennsylvania has an authorized hazardous waste program; therefore the Pennsylvania hazardous waste regulations
are identified here as the applicable Federal hazardous waste standards.

D-1

AR307622


-------
Table D-1 (Continued)

Action-Specific ARARs/TBCs are the
substantive requirements included in the following citations
Price Battery OU-2 Site, Hamburg, Pennsylvania

Standard,
Requirement,
Criterion, Or
Limitation

Citation Or
Reference

Description

Status

Comments

PENNSYLVANIA





Hazardous Waste:









PA Hazardous
Waste Landfill

25 PA Code
264a. 1 (incorporating
by reference 40
CFR Part 264
Subpart N)

Requirements that cap systems
for hazardous waste landfills have
a lower permeability than their
bottom liner 1

TBC

Materials on-site are not regulated as hazardous
waste when consolidated in same Area of
Contamination

Soil:









Administration of
Land Recycling
Program (Act 2)

25 PA Code
§ 250.407(c)
Subpart D Site-
Specific Standard

For attainment of site-specific soil
standards in residential areas, the
point of compliance for ingestion
and inhalation exposure is up to
15 feet below the existing surface
unless bedrock or physical
structures are encountered which
prevent safe continued'
remediation.

Applicable

Applicable to soil remediation activities.

PA Resjdual Waste
and Municipal
Waste Regulations,
Chemical Analysis
ofWaste

25 PA Code
§§287.54, 271.611

Chemical Analysis Requirements

Applicable

Applicable to consider capping standards for on-
site disposal. Applicable to off-site disposal.

Administration of
Land Recycling
Program (Act 2)

25 PA Code
§ 250.308

Standards for protection of ground
water using default soil to ground
water standards or site-specific
soil to ground water modeling.

Applicable

Applicable to soil remediation and capping
requirements.

Residual Waste:









Final Cover and
Grading

25 PA Code
§ 288.234, 288.423,
288.523 and
288.623

Standards for cap design for on-
site consolidation area

Relevant
and

Appropriate

Siting and other design requirements for on-site
consolidation area. Requirements regarding the
type of waste that may be disposed in the
consolidation area."

General Provisions

25 PA Code §287

General provisions for residual
waste management

Relevant
and

Apprbpriate

Residual waste provisions are not applicable when
consolidating contaminated materials within an
Area of Contamination

Storage and
Transportation

25 PA Code §299
Subpart A

Storage and transportation of
residual waste

Relevant
and

Appropriate

Not applicable when consolidating materials within
an Area of Contamination

D-2

AR307623


-------
Table D-1 (Continued)

Action-Specific ARARs/TBCs are the
substantive requirements included in the following citations
Price Battery OU-2 Site, Hamburg, Pennsylvania

Standard,
Requirement,
Criterion, Or
Limitation

Citation Or
Reference

Description

Status

Comments





Other







\

Pennsylvania's
Land Recycling
Program Technical
Guidance Manual

253-0300-100

Establishes recommendations and
guidance for attainment of site
specific standards in soil at
voluntary state cleanup Sites for
land reuse.

TBC

TBC for remedial activities involving soil.

Department of
Environmental
Protection Bureau
of Land Recycling
and Waste
Management:
Management of Fill

258-2182-773

Establishes clean fill requirements.

TBC

TBC for soils used as clean fill at excavated areas at
the site.

Fugitive Dust
Control

25 PA Code
§§ 123.1-123.2

Requires that the remedial action
take all reasonable actions to
prevent particulate matter from
becoming airborne.

Applicable

Applicable to earth-moving activities as well as to
treatment processes that may include mixing or other
processes that result in potential rejeases of
particulates.

Air Pollution Control

25 PA Code
Chapters 121.1
-.3,127,139
(excluding
Subchapter I)

Requires prevention of air
emissions at remedial sites and that
ambient air quality will be
maintained in areas where air .
quality is better than applicable air
quality standards and improved in
areas where air quality is worse
than applicable air quality
standards.

Applicable

Applicable to earth-moving activities as well as to
treatment processes that may include mixing or other
processes that result in potential releases of
particulates.

Erosion and

Sedimentation

Control

35 PS §691.1
et. seq. Chapter
102,25 PA
Code §§ 102.4,
102.11, and
102.22

Regulates erosion and
sedimentation control measures.

Applicable

Applicable to grading and excavation activities
conducted as part of site remediation. Implemented
by Berks County.

Storm Water
Management Act of
1978, as
amended

32 P.S. §
680.13

Provides storm water runoff control
requirements during construction
activities.

Applicable

Applicable to grading and excavation activities
conducted as part of site remediation.

Dam Safety and

Waterway

Management

25 PA Code
105,

Subchapters A-
K

Applies to work performed within,
along, and across waterways.
Channel changes and dredging

Applicable

Chapter 105 implementation delegated to BCCD.

D-3

AR307624


-------
Table D-2

Location-Specific ARARs/TBCs are the
substantive requirements included in the following citations
Price Battery OU-2 Site, Hamburg, Pennsylvania

Standard,
Requirement,
Criterion, Or
Limitation

Citation Or
Reference

Description

Status

Comments

FEDERAL



National Historic
Preservation Act

Archeological
Resources
Protection Act

16 U.S.C. §
470; et. Seq.;
36 CFR Part
800

16 U.S.C.
469a-1

Minimizes impact of actions on
historic properties and
landmarks.

Provides protection from
actions that may cause
irreparable harm, loss, or
destruction of artifacts

Applicable

Applicable to actions at historic properties or
landmarks, or properties at the site that contain
historical and archeological data.

Clean Water Act
(Dredge and Fill
Requirements)

33 U.S.C. §§
1251-1376;
40 CFR Parts
230

Provides protection to waters
in and around the site.

Relevant
and

Appropriate

Relevant and appropriate to actions involving
capping, berm construction and/or onsite
disposal of contaminated soil that may impact
local water bodies.

PENNSYLVANIA



IP^

• /. "

Clean Streams
Law

i

35 P.S. §
619.1; 25 PA
Code §§
93.4, 93.7,
93.8 (b)(c),
93:9,25 PA
Code

Chapter 16
and Chapter
105

Subchapters
A-K

v !
Provides protection to waters
in and around the site.

Relevant
and

Appropriate

Requires that any remedial actions taken at
the site not contribute to pollution of state
waters.

PA Floodplain
Management Act

32 P.S.
679.101^60;
25 PA Code
§106.31

Standards for construction in
100 year floodplain, wetlands
and regulated waters.

Relevant
and

Appropriate

Applicable to remediation in Kaercher Creek
and realignment of the Creek.

D-4

AR307625


-------
Table D-3

Chemical-Specific ARARs/TBCs are the
substantive requirements included in the following citations
Price Battery OU-2 Site, Hamburg, Pennsylvania

Standard,
Requirement,
Criterion, Or
Limitation

Citation Or
Reference

Description

Status

Comments

FEDERAL ¦ i ¦. N ..

•- , 'V; '

Soil:

EPA Soil Screening
Guidance

EPA/540/R-
96/018 July 1996

Provides methodology for
calculating risk-based,
site-specific soil screening
levels.

TBC

Used to standardize and accelerate
site cleanup.

Hazardous Waste:
Identification and
Listing of Hazardous
Waste

25 PA Code §§
261a.2-261a.39
(incorporating by
reference 40
CFR §§ 261.2-
261.35)

Defines those solid
wastes which are subject
to regulations as
hazardous wastes.

Applicable

Applicable to determining whether
wastes are considered hazardous
under RCRA for off-site disposal.

Ground Water:

Federal MCLs

40 CFR §§
141.23 -.24,
141.51,141.61,
141.62

National drinking water
standards

Relevant
and

Appropriat
e

Applicable through the PADEP Act 2
requirements

Guidelines for Ground
Water Classification
under the EPA Ground
Water Protection
Strategy

EPA/813R88001
June 1988

Provides site-specific
ground water
classification guidelines,
procedures, and data
requirements

TBC

Applicable when classification has not
been determined by Pennsylvania

Other:

EPA Region III Risk-
Based Concentration
Table

wyvw.epa.gov/re
g3hwmd/risk/hu
man/rb-

concentration_ta
ble/Generic_Tabl
es/

Establishes chemical
screening guidelines for
use during risk
assessment.

TBC

May be useful in development of
cleanup goals.

National Ambient
Air Quality
Standards

40 CFR §§ 50.6,
50.12

Provides acceptable
ambient air quality levels
for particulate matter and
lead.

Applicable

Applicable to earth-moving activities as
well as to treatment processes that
may include mixing or other processes
that result in potential releases of
particulates or lead.

Risk Assessment
Guidance for
Superfund, Volume 1,
Part A

EPA/540/1-
89/002

Defines Preliminary
Remediation Goals and
Remedial Action Levels
for soil

TBC

Applicable when evaluating the
adequacy of soil remediation activities.

D-5

AR307626


-------
Table D-3 (Continued)

Chemical-Specific ARARs/TBCs are the
substantive requirements included in the following citations
Price Battery OU-2 Site, Hamburg, Pennsylvania

Standard, Requirement,
Criterion, Or Limitation

Citation Or
Reference

Description

Status

Comments











Revised Interim Soil
Lead Guidance for
CERCLA Sites and
RCRA Corrective Action
Facilities

OSWER Directive
9355.4-12
August 1994

Establishes a
streamlined approach for
determining protective
levels of lead in soil at
CERCLA sites and
RCRA facilities

TBC

Recommends screening levels for lead
in soils for residential land use of 400
ppm; describes how to develop PRGs
for residential land use; and describes
a plan for soil lead cleanup at sites that
have multiple sources of lead.

Clarification to the 1994
Revised Interim Soil
Lead Guidance for
CERCLA Sites and
RCRA Corrective Action
Facilities

OSWER Directive

99200.4-27P

August 1998

EPA/540/F-

98/030

PB98-963244

Clarifies the Revised
Interim Soil Lead
Guidance for CERCLA
Sites and RCRA
Corrective Action
Facilities

TBC

Clarifies OSWER policy on using the
IEUBK model and blood lead studies;
determines geographic area to use in
evaluating human exposure to lead
contamination; addresses multimedia
lead contamination; and determines
appropriate response actions at lead
sites.

PENNSYLVANIA





Soil and Ground Water
Remediation Levels

25 PA Code 250,
Subpart 250.401

Protocol for developing
site remediation
standards

Applicable

Allows the use of site-specific
standards

Water Quality Standards.

25 PA Code 93

Defines water quality
criteria, anti-degradation
requirements, and
designated water uses
for surface water

Applicable

Implementation of the Clean Streams
Law by PA. Applicable if on-site
treatment and discharge of surface
water occurs.

Water Quality Criteria

25 PA Code §§
16.11-16.52,
16.101-16.102,
Appendix A

Guidelines for
development of water
quality criteria for
surface water

Applicable

Implementation of the Clean Streams
Law by PA. Applicable if on-site
treatment and discharge of surface
water occurs.

Pennsylvania Guidance
Manual for Ground Water
Monitoring
December 2001

www.deD.state.us

Guidance for ground
water monitoring

TBC

Establishes guidelines for ground
water monitoring

Air Resources - Variance
and Alternate Standards

25 PA Code §
141.1

Criteria for
implementation of
alternate standards
related to ambient air
quality

Applicable

Applicable if imposed by PADEP

D-6

AR307627


-------
APPENDIX E
ESTIMATED COST TABLES


-------
TABLE E-l

ALTERNATIVE S-4A
MAIN PARCEL PTW/RAL WASTE
WITH OFF-SITE DISPOSAL







ESTIMATED





EXTENDED

ITEM NO.

ITEM

UNIT

QUANTITY



UNIT PRICE



PRICE

CONTRACT ITEMS











SITE PREPARATION











I

Mobilization

LS

i

$

50,000.00

$

50,000.00

2

Site Preparation

LS

1

$

25,000.00

$ 25,000.00

3

Off-Site Disposal of General Refuse

cy

100

S

36.00

$ 3,600.00

4

Off-Site Disposal Non-Hazardous Co-Mingled Material

ton

150

$

59 JO

$

8,895.00

5

Off-Site Disposal PTWand RAL Soils (w/Stabilization)
(1.6 ton/cy)

ton

6,859

$

92.00

$

631,028.00

6

E&S Controls

Is

1

$

2,500.00

$

2,500.00

7

Construction Entrance

Each

1

$

1,625.00

$

1,625.00

8

Concrete Pavement Demolition

Square Yard

3,030

s

11.25

$

34,087.50

9

Concrete Foundation Demolition

CY

500

$

125.00

s

62,500.00

10

Concrete Rubble Segregation and Sizing

CY

1,005

$

14.34

$

14,411.70

11

Asphalt Pavement Demolition

Square Yard

2,612

$

4.50

%

11,754.00

12

Excavation/Handling of Soil PTW/RAL

CY

4,287

$

11.00

$

47,157.00

13

Structural Soil Fill (Imported)

CY

3i033

$

22.78

$

$.091.74

14

Imported Granular Subgrade (In-Place), 8"

CY

1,254

s

19.14

$

24,001.56

15

Storm Water Management and Treatment

month

2.5

$

15,000.00

$

37,500.00

16

Geotextile

sy

5,643

$

2.70

$

15,236.10

—		Yf		-

Provide-AirMonitoring-Stations	

—Each—

	3	



	irl66:67-

-S	4|3UU.U-1-

18

Lead Analysis (Time Integrated)

Each

180

$

48.00

$

8,640.00

TOTAL:	$ 1,050,527.61

Engineering 20%	$	210,105.52

QA/QC@10%	$	105,052.76

Contingency 20%	$	210,105.52

TOTAL	$	1,575,791.42

1. Unit prices obtained from RCRA Facility Closure Project Bids Indiana Summer 2011, Prices include materials, installation, and maintenance during constriction unless noted
otherwise.

ITEM NO.

ITEM

UNIT

ESTIMATED
QUANTITY

UNIT PRICE

EXTENDED
PRICE

O&M ITEMS











1

Annual Inspections

each

1

$ 750.00

5 750.00

2

Annual Maintenance (weed control, cap maintenance)

per years

1

$ 2,000.00

5 2,000.00









Annual Subtotal

$ 2,750.00









Management 2096

$ 550.00









Contingency 15%

$ 41250









Total Annual O&M Cost

$ 3,71250

Present Worth of O&M Activities











Period

30

yrs







Discount Rate

7%



Present Worth

$46,068.57





















Construction Cost

$ 1575,79142









Total Present Worth

$ 1,621,859.98

E-l

AR307629


-------
TABLE E-2

ALTERNATIVE S-4A
WAREHOUSE RAL WASTE
WITH OFF-SITE DISPOSAL

ITEM NO.

ITEM

UNIT

QUANTITY

UNIT PRICE

PRICE

, 1

Mobilizatton

LS

NA

S

-

$

-

2

Site Preparation

LS

1

S

10,000.00

$

10,000.00

3

Off-Site Disposal of General Refuse

cy

20

$

36.00

$'

720.00

4

Off-Site Disposal Non-Hazardous Co-Mingled Material

ton

50

$

59.30

$

2,965.00

5

Stabilization and Off-Site Disposal RAL Soil (1.6 ton/cy'

ton

6,245

$~

92.00

$

574,521.60

6

E&S Controls

LS

1

$

2,500.00

$

2,500,00

7

Construction Entrance

Each

1

$

1,625.00

s

1,625.00

8

Concrete Pavement Demolition

Square Yard

0

$

11.25

$

-

9

Concrete Foundation Demolition

CY

0

$

125.00

$

10

Concrete Rubble Segregation and Sizing

CY

0

$

14.34

$

-

11

Asphalt Pavement Demolition

Square Yard

3,665

$

4.50

s

16,492.50

12

Excavation/Handling of Soil

CY

3,903

$

ll.(M>

$

42,933.00

13

Structural Soil Fill (Imported)

CY

3,088

s

22.78

$

70344.64

14

Imported Granular Subrgade (In-Place), 8"

CY

815

$

19.14

s

15,599.10

15

Storni Water Management and Treatment

month

1.0

$

15,000.00

$

15,000.00

16

Geotextile

SY

3,665

$

2.70

s

9.895.50

17

Provide Air Monitoring Stations

Each

3

$

1,166.67

s

3,500.01

18

LeadAnalysis (Time Integrated)

Each

90

$

48.00

$

4,320.00

Sub Total	$ 770,416.35

						{. 	 Engineering 20% $ 154,083.27

• '	'!	 '			'			QA/QC@10% $ 77,041.64

Contingency 20% $ 154,083.27
TOTAL	S 1,155,624.53

I. Unit prices obtained from RCRA Facility Closure Project Bids Indiana Summer 2011. Prices include materials, installation, and maintenance during construction unless noted otherwise.

E-2

AR307630


-------
TABLE E-3

ALTERNATIVE SD-3
SEDIMENT REMOVAL AND STREAM LINER

ITEM NO.

ITEM

UNIT

QUANTITY

UNIT PRICE

PRICE













SITE PREPARATION











1

Mobilization

LS

I

$

5,000.00

$

5,000.00

2

Site Preparation

LS

I

$

2.000.00

$

2,000.00

3

Off-Site Disposal of General Refuse

cy

25

$

36.00

S

900.00

4

Off-Site Disposal Non-Hazardous Co-Mingled Material

ton

0

s

59.30

$

-

5

On-Site Consolidation of remediated Soil

ton

350

s

13.00

s

5,250.00

6

Erosion Controls

LS

1

$

5,000.00

$

5,000.00

7

Construction Entrance

Each

1

$

1,625.00

$

1,625.00

8

Concrete Pavement Demolition

Square Yard

1,000

s

11.25

$

11,250.00

9

Concrete Foundation Demolition

CY

0

s

125.00

s



10

Concrete Rubble Segregation and Sizing

CY

250

$

14.34

$

3,585.00

11

Asphalt Pavement Demolition

Square Yard

0

s

4.50

s

-

12

Storm Water Management and Treatment

month

1.0

$ 15,000.00

$

15,000.00

13

Geotextile

SY

0

$

2.70

s

-

14

Stream Bypass Piping

LS

1

$

25,000.00

$

25,000.00

15

Removal of Sediment from Gabion

Daily Rate

15

$

3,000.00

s

45,000.00

15

Grouting Stream Bed

SY

1,000

s

25.00

s

25,000.00

16

Pipe Sediment Cleaning

LS

1

s

10,000.00

$

10,000.00

17

Post Cleaning Fall Protection/Fence

LF

1,400

s

12.00

$

16,800.00

18

Provide Air Monitoring Stations

Eacb

3

s

1,166.67

s

3,500.01

1Q

Ixad.Anafysis.CTimelntegrsted)	 . ... _

Each

	 45



		48.00..



	2,160.00









Sub Total

$

177,070.01









Engineering 20%

s

35,414.00









QA/QC @ 10%

s

17,707.00









Contingency 2096

$

35,414.00









TOTAL

s

265,605:02

ITEM NO.

ITEM

UNIT

QUANTITY

UNIT PRICE

PRICE

O&M ITEMS











1

Quarterly Inspections

. each

2

S

500.00

y

1,000.00

2

Annual Maintenance (weed control, debris removal)

per years

1

$

UW0.00



1,000.00









Annual Subtotal

i

2,000.00









Management 2096



400.00









Contingency 15«

$

300.00









Total Annual O&M



2,700.00

Present Worth of O&M Activities







*



Period

30

yr







discount Rate

7%



Present Worth

$33,504.41





















Construction Cost

S

265,605.02









Total Present Wortl

*

299,109.43

E-3

AR307631


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TABLE E-4

GROUND WATER
NO ACTION WITH MONITORING

ITEM HO.

ITEM

UNIT

ESTIMATED
QUANTITY

UNIT PRICE

EXTENDED
PRICE

CONTRACT ITEMS

<









1

Installation of Groundwater Monitoring Wells 2 @ 30ft

each

2

$ 2,000.00

5 4,000.00

2

Install bollards around wells

each

6

t' 306.66

J 1,800.00

Sub Total S 5,800.00
Contingency 10% $ 580.00
TOTAL S 6,380.00

ITEM NO.

ITEM

UNIT

ESTIMATED
QUANTITY

UNIT PRICE

EXTENDED
PRICE

O&M ITEMS











1

Quarterly Inspections and GW Monitoring

each

4

$ 2,000.00

9 8,00000

2

Annual Reporting

per years

1

$ 1,800.00

$ UQO.OO









Annual Subtotal

$ 9,800.00

'







Contingency 15%

$ 1,470.00









Total Annual O&M C<

$ 11,270.00

Present Worth of O&M Activities











Period

30

yrs







Discount Rate

7%



Present Worth

$139,B49.89





















Construction Cost

$ 6,380.00









Total Present Worth

$ 146,229,89

E-4

AR307632


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APPENDIX F
PADEP CONCURRENCE LETTER


-------
fS3j Pennsylvania

Wjm department of environmental
ISH9 protection

September 28,2015

!

Mr. Cecil A. Rodrigues, Director

Hazardous Site Cleanup Division

United States Environmental Protection Agency

Region III

1650 Arch Street

Philadelphia, PA 19103-2020

Re: Record of Decision

Operable Unit One-Residential Portion
Operable Unit Two-Facility Portion
Price Battery Superfund Site
Berks County, Pennsylvania

Dear Mr. Rodrigues:

The Department of Environmental Protection (DEP) has reviewed the Record of Decision (ROD)
for the Price Battery Superfiind Site, in Hamburg Borough, Berks County, received on
September 21,2015.

The selected remedy for this site consists of the following:

•	The Sielected Remedy for OU-1 is No Further Action. The remedial actions selected in
the September 30,2009, Interim ROD have been completed. EPA completed cleanup of
the Residential Portion of the Price Battery Site in October 2013. As the comprehensive
remedial investigation (RI).for OU-1 progressed, EPA identified additional residential
properties for cleanup, and EPA incorporated these properties into the residential
remedial action that was ongoing pursuant to the September 2009 Interim ROD for OU-1.
EPA has completed the residential cleanup at all eligible properties where owners have
provided access. There are no known additional residential properties (for which owners
provided access) requiring cleanup. The September 2009 Interim ROD also provided for
institutional controls and ongoing public education regarding lead exposure risks.
Therefore, because no additional cleanup measures are necessaxy, EPA's Selected ;
Remedy for OU-1 is No Further Action, and to establish the OU-1 interim remedy as the
final remedy for the Price Battery Site OU-1, Residential Portion.

•	The Selected Remedy for OU-2, Facility Portion, is a combination of Alternative S-4A,
Alternative SD-3, and No Action with Monitoring for ground water. The Selected
Remedy is excavation of Principal Threat Waste (PTW) lead-contaminated soils and soils
exceeding the Remedial Action Level (RAL) cleanup levels for lead calculated

Regional Director

Southcentral Regional Office 1 909 Elmerton Avenue | Harrlsburg, PA 17110-8200 | 717.705.4704 | F 717.705.4930

www.depweb.state.pa.us

AR307634


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Mr. Cecil A. Rodrigues, Director	- 2 -	September 28,2015

specifically for the Facility Portion of the Price Battery Site. .Contaminated soil will be
excavated to required cleanup levels, stabilized (on-site or off-site), and disposed of in an
approved off-site disposal facility. The resulting excavations will be backfilled with
reclaimed concrete and/or imported clean soils and graded for potential future
commercial/industrial redevelopment of the properties. Contaminated sediment in
Kaercher Creek, on the Facility property, will be removed and the current gabion
mattress liner system will be reinforced to further stabilize the gabion mattress liner
system. Underground pipes currently containing contaminated sediment beneath the
Facility will be cleaned out and grouted closed to prevent any additional contamination
from entering Kaercher Creek.

The Selected Remedy for OU-2 includes the following major components:

1.	Removal of concrete pavement, floor slabs, and foundations overlying the RAL and PTW
contaminated soils, f he concrete pavement, floor slabs, and foundations will be
segregated, cleaned to remove residual contamination (based on visual observations)
pursuant to the requirements of the Resource Conservation and Recovery Act (RCRA),
crushed, and stockpiled. Crushed material will be analyzed for inorganic constituents and
the results compared against the Pennsylvania Department of Environmental Protection
(PADEP) Statewide Health Standards for non-residential soils (direct contact) prior to
reuse as backfill.

2.	Excavation of soils from the Main Parcel and the Warehouse Parcel that exceed the
lowest calculated RAL (8,669 parts per million [ppm]) for lead-in-soil, including PTW
soils, except to the extent that contaminated soil cannot be removed because of field
conditions (i.e., physical constraints, proximity of building foundations, maintaining safe
excavation slopes, encountering ground water, etc.):

3.	Excavated soils shall be sampled and analyzed using the Toxicity Characteristic Leaching
Procedure (TCLP) to,determine the appropriate off-site disposal facility. Soils which
exceed the TCLP criteria may be stabilized on-site to render the soil non-hazardous or
transported to an off-site RCRA-permitted facility for appropriate treatment and disposal.

If stabilization is conducted on-site, the soil shall be mixed with a reagent (i.e. trisodium
phosphate or other reagents) to render it non-hazardous. Confirmation sampling shall be
conducted on the stabilized soils to ensure the soil is non-hazardous prior to off-site
disposal.

AR307635


-------
Mr. Cecil A. Rodrigues, Director

-3-

September 28, 2015

4.	Post-excavation confirmation sampling of excavation floor and sidewalls to ensure RAL
levels have been achieved. Recalculate the exposure point concentration (EPC) utilizing
confirmation sample results collected after excavation,

5.	Backfill of resulting excavations with reclaimed crushed concrete and.clean fill material
to levels at, or near, existing grades except as coordinated with Site redevelopment
activities. Any crushed material used for backfilling will be overlain by imported clean
fill. Reclaimed crushed concrete must meet backfill concentrations identified in the
Baseline Human Health Risk Assessment (BHHRA) for lead (<50 ppm), arsenic (< 100
ppm), and antimony (< 46 ppm). If reclaimed concrete exceeds 50 ppm lead (but is
below the PADEP Statewide Health Standards for non-residential soils for direct contact
of 1,000 ppm lead), the RAL must be recalculated utilizing the actual concentration for
the proportion of backfilling cpmpleted using recycled concrete and additional soil
remediation performed as appropriate to achieve the desired risk-based concentration
(RBC). Clean soil must meet Pennsylvania Criteria for Management of Fill, or the
backfill concentrations identified in the BHHRA, whichever is more stringent.

6.	Restore Site surfaces using concrete, asphalt, buildings, and landscaping in a mariner
consistent with plans for Site redevelopment and suitable for preventing erosion of soils
above residential remediation standards, and as specified by erosion and sediment control

' requirements.

7.	Implement institutional controls (ICs) to ensure that the remedy provides an adequate
measure of protection in light of current and anticipated commercial/industrial future use
of the Site. Such additional institutional controls will include notification to future
property owners that contaminated soils remain in-place and that special handling of
these soils would be required if these soils are disturbed during redevelopment
construction activities. No residential use of the properties will be permitted. ICs will
include activity and use restrictions enacted through proprietary (e.g., easements,
covenants) and/or governmental (e.g., zoning requirements) controls to prevent use of the
property that will pose an unacceptable risk to receptors. The exact type of IC
implemented will be determined by EPA in consultation witirPADEP and local
government agencies. The restrictions in the current Declaration of Use and Deed
Restriction will be incorporated into any new institutional controls.

Sediment

1. Remove accumulated sediment from the gabion mattress, to the extent possible, using a
vacuum truck or equivalent. Remove sediment from underground pipes and penetrations
including, but not limited to, Pipes 1,2, and 3. Grout any underground pipes, as
necessary, to further prevent contaminated sediment within any pipes from entering
Kaercher Creek.

AR307636


-------
Mr. Cecil A. Rodrigues, Director

-4-

September 28,2015

2.	Dispose of accumulated sediment off-site or use as backfill in on-site soil excavation
areas if coordinated with soil remediation and sediment meets the same requirements for
other soils under Alternative S-4A, above.

3.	Grout gabion mattress to ensure long-term stability of the Creek bed.

4.	Perform annual inspections to confirm that the gabion mattress and channel walls remain
stable, and remove accumulated trash and debris to maintain the hydraulic capacity of the

5. Implement ICs to prohibit removal of the gabion mattress or excavation of soils within or
along the Creek in conjunction with the IC requirements of Alternative S-4A.

Ground Water .

No active cleanup measures will be taken for groundwater at the Site.

1.	Install new monitoring wells to the current monitoring well network after soil remediation
is implemented. Redevelop or replace monitoring well BW-3 to address turbidity
problems within the monitoring well.

2.	Conduct quarterly ground water sampling. After eight consecutive quarters of
monitoring, conduct a statistical evaluation to determine contaminant concentration
trends and continue statistical analysis annually. Reevaluate need for continued
monitoring at five-year intervals. _

DEP hereby concurs with EPA's proposed remedy with the following conditions:

• DEP is provided an opportunity to fully participate in any negotiations with responsible

• DEP will be given the opportunity to review and comment on documents and concur with
decisions related to the design and implementation of the remedial actions to assure
compliance with ARARs.

Thank you for the opportunity to comment on this EPA ROD. If you have any questions
regarding this,matter, please call Mr. Asuquo Effiong at 717.705.4853.

channel.

parties.

Sincerely,

Lynn E. Langer
Regional Director

AR307637


-------