EARLY-INTERIM RECORD OF DECISION
OPERABLE UNIT THREE
SAFETY LIGHT CORPORATION SUPERFUND SITE
BLOOMSBURG, PENNSYLVANIA
Prepared by:
Environmental Protection Agency Region 111
1650 Arch Street
Philadelphia, PA 19103
June 2016
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TABLE OF CONTENTS
Page
1.0 DECLARATION 1-1
1.1 SITE NAME AND LOCATION 1-1
1.2 STATEMENT OF BASIS AND PURPOSE 1-1
1.3 ASSESSMENT OF THE SITE 1-1
1.4 DESCRIPTION OF THE SELECTED REMEDY 1-1
1.5 STATUTORY DETERMINATION 1-3
1.6 ROD DATA CERTIFICATION CHECKLIST 1-4
1.7 AUTHORIZING SIGNATURE 1-4
2.0 DECISION SUMMARY 2-1
2.1 SITE NAME, LOCATION, AND BRIEF DESCRIPTION 2-1
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
2.3 COMMUNITY PARTICIPATION 2-7
2.4 SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION 2-7
2.5 SITE CHARACTERISTICS..... 2-8
2.6 CURRENT & POTENTIAL FUTURE LAND & RESOURCE USES 2-18
2.7 SUMMARY OF SITE RISK 2-18
2.8 REMEDIAL ACTION OBJECTIVES 2-21
2.9 DESCRIPTION OF ALTERNATIVES 2-22
2.10 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 2-28
2.11 PRINCIPAL THREAT WASTE 2-34
2.12 SELECTED REMEDY 2-34
2.13 STATUTORY DETERMINATION. 2-36
2.14 DOCUMENTATION OF SIGNIFICANT CHANGES 2-38
3.0 RESPONSIVENESS SUMMARY 3-1
3.1 STAKEHOLDER COMMENTS AND LEAD AGENC Y RESPONSES 3-1
3.2 TECHNICAL AND LEGAL COMMENTS 3-3
LIST OF APPENDICES
APPENDIX A: GLOSSARY
APPENDIX B: ADMINSITRATIVE RECORD INDEX
APPENDIX C: FIGURES
APPENDIX D: TABLES
APPENDIX E: RISK RATIO TABLES
APPENDIX F: ARARS TABLES
APPENDIX G: PHOTOS
APPENDIX H: REMEDIAL ALTERNATIVE COSTS
APPENDIX I: PADEP CONCURRENCE LETTER
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LIST OF ACRONYMS AND ABBREVIATIONS
ARAR
Applicable or Relevant and Appropriate Requirements
AOC
Administrative Order on Consent
bgs
below ground surface
BRP
Bureau of Radiation Protection
cpm
counts per minute
ccpm
corrected counts per minute
CERCLA
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980
CFR
Code of Federal Regulations
Ci
Curie
COC
Contaminant of Concern
COPC
Contaminant of Potential Concern
CSM
Conceptual Site Model
dpm
disintegrations per minute
EPA
United States Environmental Protection Agency
ERA
Ecological Risk Assessment
FS
Feasibility Study
HAZWOPER
Hazardous Waste Operations and Emergency Response
I-IHRA
Human Health Risk Assessment
HI-IRE
Human Health Risk Evaluation
HI
Hazard Index
HQ
Hazard Quotient
MRS
Hazard Ranking Score
IC
Institutional Control
IMC
Intermodal Container
mg/kg
milligram/kilogram
MERL
Mobile Environmental Radiation Laboratory
mR/hr
mil liroentgens/hour
mrem
millirem
mrem/hr
miltirem/hour
mrem/yr
millirem/year
NCP
National Contingency Plan
NPL
National Priorities List
NRC
Nuclear Regulatory Commission
O&M
Operations and Maintenance
OSHA
Occupational Health and Safety Administration
ou
Operable Unit
PADEP
Pennsylvania Department of Environmental Protection
PCB
Polyehlorinated Biphenyl Compounds
pCi
picocurie
pCi/g
picocurie/gram
PAH
Polynuclear Aromatic Hydrocarbon
PRC
Preliminary Remediation Goal
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LIST OF ACRONYMS AND ABBREVIATIONS
PRAP
Proposed Remedial Action Plan
rem/hr
rems/hour
RI
Remedial Investigation
RI/FS
Remedial Investigation/Feasibility Study
ROD
Record of Decision
RSL
Regional Screening Level
SVOC
Semivolatile Organic Compound
SLC
Safety Light Corporation
SSL
Soil Screening Level
SU
Survey Unit
TBC
To-Be-Considered
(.ig/kg
micrograms/kilogram
LiR/hr
microroent gen/hour
USACE
U.S. Army Corps of Engineers
USRC
United States Radium Corporation
VOC
Volatile Organic Compound
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EARLY-INTERIM RECORD OF DECISION
OPERABLE UNIT THREE
SAFETY LIGHT CORPORATION SUPERFUND SITE
BLOOMSBURG, PENNSYLVANIA
1.0 DECLARATION
1.1 SITE NAME AND LOCATION
The Safety Light Corporation (SLC) Superfund Site (Site) is located at 4150-A Old Berwick
Road, South Centre Township, Columbia County, Pennsylvania, approximately six miles east of
Bloomsburg and six miles west of Berwick. The Site is approximately ten acres and formerly
contained numerous radioactively-contaminated buildings/structures. Other contaminated areas,
including lagoons, dumps, and an abandoned canal currently remain on-site. The National
Superfund Database Identification Number is PAD987295276
1.2 STATEMENT OF BASIS AND PURPOSE
In this Early-Interim Record of Decision (ROD), EPA has selected an early-interim remedy
(Selected Remedy) for the West Dump, West Lagoon, East Dump, and East Lagoon areas of
Operable Unit Three (OU-3) of the Site. The Selected Remedy for OU-3 was selected in
accordance with the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended, 42 U.S.C. § 9601 et seq., and
to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 C.F.R. Part 300, as amended.
This Early-Interim 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 is available lor 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 Bloomsburg Area Public Library in Bloomsburg. Pennsylvania. The
Administrative Record Index ( Appendix B) identifies each document contained in the
Administrative Record upon which the Selected Remedy for OU-3 is based.
The Commonwealth of Pennsylvania concurs with the Selected Remedy identified for OU-3.
1.3 ASSESSMENT OF THE SITE
The response action selected in this Early-Interim ROD is necessary to protect the public health
or welfare or the environment from actual or threatened releases of hazardous substances into the
environment.
1.4 DESCRIPTION OF THE SELECTED REMEDY
This Early-Interim ROD addresses non-radionuclide and radionuelide-contaminated soils/debris
which include radioactive discrete objects in the West Dump, West Lagoon, East Dump, and
East Lagoon areas of OU-3 only. These areas have been impacted by radionuclides and other
non-radionuclide contaminants (i.e., heavy metals and other organic compounds) as a result of
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Early-Interim Record of Decision OU-3— Safety Light Corporation Superfund Site, Bloomshurg, PA
former operations at the Site. The remainder of OU-3 will be addressed in future response
actions and documented in a Final ROD for OU-3. EPA is currently performing a Removal
Action to address the contamination located in the West Lagoon, East Dump, and East Lagoon
areas. EPA has decided to use this early-interim approach in order to expediently convert the
ongoing Removal Action to an Early-Interim Remedial Action. The current Remedial
Investigation (RI) for OU-3 will continue during and beyond the Early-Interim Remedial Action
to determine the full nature and extent of the contamination in OU-3.
The Selected Remedy for OU-3 consists of the following:
1. Site Preparation - Mobilize and setup support facilities, remove vegetation, and establish
soil erosion and sediment controls. Regularly inspect and maintain erosion and sediment
controls during vegetation clearance, soil excavation and stockpiling, waste loading,
backfilling, and regrading operations, until excavation and backfilling is complete and a
gravel protective cover is established at the West Dump, West Lagoon, East Dump, and
East Lagoon to minimize erosion.
2. Soil Excavation - Excavate all materials including soils/debris and radioactive discrete
objects from the West Dump, West Lagoon, East Dump, and East Lagoon in the
approximate area of concern depicted in Appendix C (Figures 4 to 7), Continue vertical
excavation until ground water or the native soil interface (the point at which fill material
meets the native soil surface) is encountered, whichever occurs first, or to the maximum
extent practicable based on Site or excavation conditions. Excavation depths are
expected to range from approximately 4 to 16 feet below ground surface (bgs), The total
in-situ volume of material designated for removal is approximately 5,978 cubic yards.
3. Post-Excavation Sampling - Collect post-excavation samples from the floor and side
walls of each excavation area, prior to backfilling and regrading, to determine and
document the concentration of radionuclide and non-radionuclide soil contamination that
may remain in-place. Conduct gamma walkovers of the excavated areas prior to
backfilling to assess any remaining radiological activity.
4. Package all excavated material as radioactive waste and load into intermodal containers
(IMCs) for shipment to disposal sites. Transfer excavated material by licensed vendors in
accordance with transportation regulations to an off-site facility as described in #5,
below.
5. Waste Disposal - Dispose off-site, at a Nuclear Regulatory Commission (NRC) licensed
radioactive waste facility, and in accordance with Section 121(d)(3) of CERCLA, 42
U.S.C. § 121(d)(3), and Section 300.440 of the NCP, 40 C.F.R. §300.440, all materials
excavated pursuant to item #2 above. Certain waste materials (including, but not limited
to, dials and some discrete objects) may also exhibit chemical hazardous waste
characteristics requiring treatment (e.g. stabilization) prior to permanent disposal. Such
waste materials shall be sampled and analyzed using the Toxicity Characteristic Leaching
Procedure (TCLP) pursuant to the Resource Conservation and Recovery Act (RCRA) to
determine if they exhibit hazardous waste characteristics. For those waste materials that
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fail TCLP, such treatment shall be performed at the off-site licensed radioactive waste
facility to render such materials non-hazardous prior to disposal at that licensed facility.
6. Site Restoration - Backfill excavated areas with clean material derived from an off-site
borrow source. Backfill material shall meet Pennsylvania Criteria for Management of Fill
specifications for chemical constituents, as certified through laboratory analysis. Regrade
excavated areas to approximate original contours, ensuring appropriate site drainage.
Install and place geotextile and a layer of gravel, with a minimum thickness of 12 inches,
011 disturbed surfaces of the West Dump, West Lagoon, East Dump, and East Lagoon as a
protective cover to minimize erosion.
The estimated cost to complete the Selected Remedy is $9,133,000.
1.5 STATUTORY DETERMINATION
This early-interim action is protective of human health and the environment in the short term and
is intended to provide adequate protection until a Final ROD for OU-3 is signed; complies with
(or waives) those federal and state requirements that are applicable or relevant and appropriate
for this limited-scope action; and is cost-effective. Although this early-interim action is not
intended to address fully the statutory mandate lor permanence and treatment to the maximum
extent practicable, this early-interim action may utilize treatment and, if so, would support that
statutory mandate. Because this action does not constitute the final remedy for OU-3, the
statutory preference for remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element, although partially addressed in this remedy, will be addressed by
the final response action for OU-3. Subsequent actions are planned to address fully the threats
posed by conditions at OU-3. This remedy may result in hazardous substances remaining in the
lagoon/dump areas of the Site above health-based levels. Five-year reviews will be conducted in
accordance with statutory requirements pursuant to Section 121(c) of CERCLA, 42 U.S.C. §
9621(c), the NCP, 40 C.F.R. §300.430(i)(4)(ii), and EPA guidance, as appropriate. Because this
is an early-interim action ROD, review of this Site and this early-interim remedy will be ongoing
as EPA continues to develop remedial alternatives for OU-3.
Soils contaminated with significant concentrations of radionuclides are considered principal
threat wastes (PTW). EPA has a preference to treat PTW, wherever practicable. However, there
is no feasible technology to practicably treat radionuclides that will not result in larger volumes
of waste, creating greater impracticability for disposal. The excavated material which includes
soils/debris and radioactive discrete objects will be packaged appropriately for off-site disposal
at an approved off-site NRC licensed radioactive waste disposal facility. Off-site disposal will
be conducted in accordance with Section 121(d)(3) of CERCLA, 42 U.S.C. § 121(d)(3), and
Section 300.440 of the NCP. 40 C.F.R. §300.440.
Certain waste materials (including, but not limited to, dials and some discrete objects) may also
exhibit chemical hazardous waste characteristics requiring treatment (e.g. stabilization) prior to
permanent disposal. Such waste materials shall be sampled and analyzed using the Toxicity
Characteristic Leaching Procedure (TCLP) pursuant to the Resource Conservation and Recovery
Act (RCRA ) to determine if they exhibit hazardous waste characteristics. For those waste
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materials that fail TCLP, such treatment shall be performed at the off-site licensed radioactive
waste facility to render such materials non-hazardous prior to disposal at that licensed facility.
The Selected Remedy for the West Dump, West Lagoon, East Dump, and East Lagoon areas of
OU-3 may result in hazardous substances, pollutants, or contaminants remaining in the
lagoon/dump areas of the Site above levels that would allow for unrestricted use and unlimited
exposure. Five-year reviews will be conducted in accordance with statutory requirements
pursuant to Section 121(c) of CERCLA, 42 U.S.C. § 9621(c), the NCP, 40 C.F.R.
§300.430(f)(4)(ii), and EPA guidance, as appropriate, to ensure that the remedy is, or will be.
protective of human health and the environment.
1.6 ROD DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary (Part 2,0) of this Early-Interim
ROD, while additional information can be found in the Administrative Record for the Site:
• Contaminants of concern (COCs) and their respective concentrations;
» Baseline risk represented by the COCs;
• Mow source materials constituting principal threats are addressed;
• Current and reasonably anticipated future land use assumptions used in the baseline risk
assessment and Early-Interim ROD;
• 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 early-interim remedy.
1.7 AUTHORIZING SIGNATURE
This Early-Interim ROD documents the Selected Remedy for the West Dump, West Lagoon,
East Dump, and East Lagoon areas of OU-3 at the Safety Light Corporation Site and is based on
the Administrative Record for the Site, EPA selected this early-interim remedy with the
concurrence of the Pennsylvania Department of Environmental Protection (PADEP). The
Director of the Hazardous Sites Cleanup Division for EPA Region III has approved and signed
this Early-Interim ROD.
sL
j,
Domin quef LueckenhofK/Acting Director
Hazardous'Site Cleanup Division
EPA Region III
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2.0 DECISION SUMMARY
2.1 SITE NAME, LOCATION, AND BRIEF DESCRIPTION
The Site is located at 4150-A Old Berwick Road, South Centre Township, Columbia County in
central Pennsylvania, approximately six miles east of Bloomsburg and six miles west of Berwick
(Figure 1). The Site is approximately ten acres and formerly contained numerous radioactively-
contaminated buildings/structures and other contaminated areas, including lagoons, dumps, and
an abandoned canal. A two-acre area of the ten-acre Site was utilized for manufacturing
operations from approximately 1948 until December of 2007 (Figure 2). The northern Site
boundary is Old Berwick Road and the southern Site boundary is the Susquehanna River,
Residential tracts of land are adjacent to the northern, eastern, and western boundaries of the
Site. Most of the Site is currently enclosed by fencing.
The CERCLA identification number for the Site is PAD987295276.
The EPA is the lead agency for Site activities and PADEP is the support agency. The cleanup of
the Safety Light Corporation Site is being funded from the Superfund Trust under the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended
(CERCLA).
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
Site History
The Site was most recently operated by SLC, which ceased manufacturing operations in
approximately December 2007. When operating, SLC made lighting products with radioactive
material (tritium) as the energy source under two licenses formerly administered by the NRC,
now administered by PADEP. The licenses, which expired on December 31, 2007, were License
Number 37-00030-02 for the characterization and cleanup of contaminated facilities, equipment,
and land from past activities, and License Number 37-00030-08 for the use of byproduct material
to make exit signs. Tritium (H-3) was used by SLC in the production of luminous signs and
dials, paints, gas chromatograph foils, and accelerator targets. SLC also held a license
administered by PADEP (License Number PA-0166), for the radium contamination at the Site
and for sealed calibration and/or reference radium sources up to 10 millicuries. This license
expired on March 31, 2008,
Historic activities at the Site varied over time and involved the use of a number of different
radionuclides. The Site had also been used for metal finishing and plating. Site operations
involved a variety of radionuclides, chemicals, fuel oil, solvents, and heavy metals.
In 1948, SLC's predecessor, the United Stales Radium Corporation (USRC), relocated its radium
operations from Brooklyn, New York to the Site. At that lime. USRC used mainly radium and
minor amounts of polonium-210 (Po-210) in the manufacture of self-illuminating watch and
instrument dials. During the 1950s, USRC expanded its operations to include the manufacture of
civil defense check sources and radiation sources utilizing cesium-137 (Cs-137), and the
production of deck markers for the U.S. Navy involving the use of strontium-90 (Sr-90). During
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this same time period, radium was also used primarily for clocks and watches (dials and hands)
and in the production or high level neutron and radiation therapy sources. During the production
of the various devices, the company placed radioactive wastes in two underground silos located
south of the Main Building on the Site. These two underground silos were closed in about 1960.
According to historical documents for the Site, the underground silos were closed by pouring
concrete over the existing silo lids.
During the 1950s, USRC began producing light sources using tritium (H-3), carbon-14 (C-14),
and krypton-85 (Kr-85); low level ionization sources using nickel-63 (Ni-63) and tritium; and
beta radiation sources using krypton. Waste from these operations was buried in the previously
mentioned underground silos. Operations using radium-226 (Ra-226) reportedly were
discontinued in 1968, and in 1969 USRC discontinued manufacturing with all radionuclides
except tritium.
In 1980, USRC underwent a corporate restructuring resulting in the creation of a new entity,
USR Industries, and the merger of USRC into USR Industries as a wholly owned subsidiary. In
turn, USRC changed its name to SLC. At the same time, USRC's divisions separately
incorporated into four new subsidiary corporations: USR Chemicals, Inc.; USR Lighting, Inc.;
USR Metals, Inc.; and USR Natural Resources, Inc. SLC continued manufacturing operations
(as described above) on the Site from 1980 until approximately December 2007. USR Metals
operated a metal products business at the Site, and ceased operations at the Site in approximately
2007.
Waste Disposal History
Wastes generated at the Site included solid and liquid waste streams contaminated with
radioactive materials, including radium-226, strontium-90, cesium-137, and tritium. These waste
materials were disposed of in multiple areas of the Site throughout the years.
During Site operations, an unused canal adjacent to the Susquehanna River was divided into a
series of lagoons and dump sites. The canal was used for the disposal of sewage, liquid waste
(including silver plating wastes and anodizing solutions), low-level radioactive waste, radium-
226 contaminated ductwork, radionuclide-contaminated debris (such as radium dials and
possibly strontium deck markers), and process wastewater from the radium laboratory in the
Main Building. In 1972, it is believed that the lagoons were flooded and their contents were
dispersed onto the Site property and into the Susquehanna River.
Four aboveground storage tanks in the Liquid Waste Building contained tritium-contaminated
wastewater from the Tritium (Nuclear) Building, which was diluted and released to the
Susquehanna River during Site operations. Tritium-contaminated wastewater was also contained
in two below-ground tanks in a vault in the basement of the Liquid Waste Building. In 1972, a
Hood uprooted one partially filled tank from the Liquid Waste Building. The tank vault was
subsequently filled with soil and covered with a concrete slab. Plant personnel believe that
radium waste was also placed in the vault before it was backfilled and capped.
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History of Response Actions
National Priority Listing
On December 20, 2001, following NRC attempts to require SIX to conduct cleanup efforts at the
Site, the NRC requested that EPA perform a site assessment of the Site, for purposes of scoring
the Site for inclusion on EPA's National Priorities List (NPL). As a result, an initial
investigation of the Site was conducted by EPA to determine the Hazard Ranking System (HRS)
score for further evaluation under CERCLA. A HRS preliminary score of 65.84 was calculated
for the Site, which was based on the various radionuclides detected on-site. The Site was
proposed for the NPL on September 23, 2004, and listed as final on the NPL on April 27, 2005
making it eligible for long-term cleanup under the Superfund program.
Removal Actions
EPA has issued several Removal Action Memoranda for the Safety Light Site. A summary of
the Action Memoranda, date of issuance, and estimated removal project ceiling costs is provided
in 'fable D-l. These Action Memoranda are included in the Administrative Record for the Site-
Further detailed information regarding the various EPA Removal Actions undertaken at the Site
may also be found at www.epaosc.org/safetvl i uht. Highlights of some of the Removal Actions
arc provided in the following sections below.
Radioactive Waste from Two (2) Underground Silos
Pursuant to a September 14, 1994 Settlement Agreement (Agreement) with the NRC, SLC had
engaged in certain cleanup efforts at the Site. Cleanup pursuant to the Agreement resulted in the
removal of radioactive wastes from the two above-mentioned underground silos and staging of
the waste in drums and containers on-site. By June 20, 2000, SLC had staged 176 drums (55-
gallon) and 26 B-25 containers (4ft x 4ft x 6ft) that contained various types of radioactive
wastes. The staging area was near the southern edge of the Site, approximately 200 feet from the
Susquehanna River. However, SLC did not arrange for the majority of the exhumed wastes to be
disposed of off-site. After numerous attempts by the NRC to require SLC to remove the waste
from the Site, NRC requested EPA's assistance in completing these actions at the Site. On July
3, 2002, following an EPA removal assessment of the radioactive wastes and storage area at the
Site, EPA determined that the release and threatened release of radioactive waste from the Site
into the environment presented an imminent and substantial endangerment to the public health or
welfare or to the environment. On February 3, 2003, EPA and SLC entered into an
Administrative Order on Consent (AOC) under Section 106 of CERCLA. 42 U.S.C. § 9606. to
complete the silo waste characterization/staging activities. By May 2004, SLC had not
completed the work required in the AOC. On July 12, 2004, EPA issued an Action
Memorandum for the Site, which approved Superfund funding for a time-critical Removal
Action to complete the characterization, packaging, and off-site disposal of the silo waste. The
time-critical Removal Action began on June 13, 2005.
On September 23, 2005, EPA executed an Inter-Agency Agreement with the United States Army
Corps of Engineers (USACE) to complete the characterization, packaging, and off-site disposal
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of the silo waste. The waste materials from the underground silos were disposed of off-site in a
secure licensed disposal facility for radioactive wastes.
Demolition of Seven Buildings
During the scoping activities for the OU-1 RI, EPA determined that four buildings on the Site
were deteriorating, unoccupied, and unmaintained by the Site owner/operator. The four
buildings were identified as the Old House, Radium Vault, Personnel Office Building, and a
portion of the Etching Building. Three additional deteriorating buildings were also identified
during performance of the OU-1 RI: the Lacquer Storage Building, Well House, and Pipe Shop.
Based 011 their poor physical condition, EPA did not believe that radiological characterization of
the buildings could be safely performed. Additionally, based on a records review, radioactive
contamination at levels that would qualify building materials as regulated radioactive waste were
identified in six of the seven buildings, with the exception of the Radium Vault. Therefore, EPA
prepared an Engineering Evaluation/Cost Analysis, dated October 2006, for the demolition and
disposal of these seven buildings.
EPA issued two Action Memoranda to address the seven aforementioned buildings on June 21,
2007, and July 11, 2008, which increased the budget of the demolition project. The demolition
of the seven buildings and off-site disposal of the resultant demolition debris was performed
during 2008/2009 and is complete. The completion of this work is documented in the "Final
Revised Completion Report for the Non-Time Critical Removal Action; Demolition of OU-1
Buildings" prepared by USAGE, dated May 2013.
West Dump and Six Outbuildings
In September 2011, the Susquehanna River rose to historic levels as a result of Tropical Storm
Lee, partially flooding the Site. Several outbuildings were flooded and post-flood assessments
conducted by PADEP's Bureau of Radiation Protection (BRP) revealed the presence of low
levels of Site-related contamination on an adjacent residential property immediately downstream
from the West Dump, Based on this information from PADEP BRP, the condition of the West
Dump was assessed, and EPA made the decision to temporarily cap the area following the
excavation of the impacted soils on the adjacent residential property. On June 11. 2013. EPA
issued an Action Memorandum including, but not limited to, the following activities: 1)
demolition of the Metal Silo, Liquid Waste Building, Solid Waste Building, Utility (SR-90)
Vault, the 8x8 Building, and the Multi-Metals/Carpenter Shop; 2) excavation of soil determined
to have migrated from the West Dump onto the adjacent property; 3) stabilization of the West
Dump to minimize the potential for further releases; and 4) disposal of building contents,
demolition debris, and excavated soils.
Between approximately June 2013 and February 2014, as part of the implementation of the June
2013 Action Memorandum. EPA completed the demolition of the six outbuildings and removed
radionuclide-contaminated soil from the adjacent residential property and consolidated that soil
with the radionuclide-contaminated soil and debris in the West Dump. The West Dump was
graded and covered with gravel and soil as a temporary action to limit future erosion. The West
Dump will be further addressed by the Selected Remedy in this Early-Interim ROD.
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West Lagoon, East Dump, and East Lagoon
During the performance of the OU-1 Remedial Action for the demolition of the remaining SLC
buildings, described in detail in the Remedial Actions section below, EPA identified additional
on-site areas that warranted Removal Actions. These areas were identified as the West Lagoon,
East Dump, and East Lagoon. On February 1, 2016, EPA issued an Action Memorandum to
address these areas, consisting of the following activities: (1) the assessment, excavation, and
removal of discrete, buried, high-activity, radiologically-contaminated items, soil and
miscellaneous sources, as practicable; (2) disposal of such soils and materials off-site; (3)
grading and capping, with an appropriately engineered cover, to prevent off-site migration of
soils during a flood event; (4) securing adjacent areas of exposed soil with geo-fabric, stone and
topsoil or an engineered cap to prevent off-site migration of soils during a flood event; and (5)
arranging for appropriate post-removal site controls which would include long-term maintenance
of the cap. This Removal Action is currently ongoing. These areas would continue to be
addressed pursuant to the Selected Remedy in this Early-Interim ROD.
Remedial Actions
EPA divided the Site into three operable units (OUs). OU-1 addresses the Safety Light
Buildings and Structures; OU-2 addresses Ground Water; and OU-3 addresses Soils, Sediment,
and Surface Water. These OUs and response actions taken arc further discussed below.
OU-1: Safety Light Buildings and Structures
OU-1 addressed the Safety Light buildings/structures and their contents. On September 2, 2010,
EPA issued a ROD for OU-1. The Selected Remedy for OU-1 included demolition and off-site
disposal of the remaining SLC buildings/structures (buildings, tanks, silo. etc.). The remedy was
selected to remove buildings/structures and their contents from the Site, which represented a
threat of release of hazardous substances (radionuclides) to the environment, and/or to facilitate
future response actions at the Site, including the completion of the investigation of soil and
ground water. A full description of the OU-1 Selected Remedy, threats posed by OU-1, and Site
history are included in the OU-1 ROD and Administrative Record.
While awaiting remedial funding to implement the OU-1 ROD, time-critical removal response
actions were undertaken to stabilize Site conditions to prevent the release of hazardous
substances at and from the Site. These removal response actions are documented in Action
Memoranda dated November 8, 2012, February 20, 2013, June 11, 2013, December 16, 2013,
September 26, 2014, and June 17, 2015. Implementation of the OU-1 Remedial Action activities
began in December 2013 and were substantially completed in September 2015. Demolition
activities were completed by September 17, 2015. On September 26, 2015, EPA and its
contractors performed a final inspection of the Site. Per the inspection, all buildings and
aboveground structures pertaining to OU-1 had been demolished and shipped off-site for
disposal. The removal of underground structures pertaining to OU-1 was also completed.
Several IMCs containing concrete from underground structures and drums containing tritium-
contaminated materials remained at the Site; however, these materials were shipped off-site for
disposal in October 2015.
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The following buildings/structures were demolished and disposed off-site, along with their
contents, as part of the Removal Actions and/or the OU-1 Remedial Action:
• Metal Silo (aboveground)
• 8x8 Building
• Solid Waste Building
• Utility Building
• Liquid Waste Building
• Multi-Metals Building
• Carpenter Shop
• Butler Building
• Elevated Water Tower
¦ Main Building
• Tritium Building
• Machine Shop
• Water Tank
• Underground Structures
Because the OU-1 Remedial Action required demolition and off-site disposal of the SLC
buildings/structures, the OU-1 ROD did not include "cleanup levels" (such as may be included in
a ROD for cleanup of soil or ground water contamination), institutional controls, monitoring
requirements, or operations and maintenance requirements.
The completion of the OU-1 Remedial Action is documented in the "Final Remedial Action
Completion Report; Operable Unit-1dated September 2015, and issued by EPA on November
23,2015.
OU-2: Ground Water
OU-2 addresses ground water at the Site. The OU-2 Remedial Investigation/Feasibility Study
(RI/FS) is being performed by EPA. A final response action for OU-2 will be determined by
EPA when the RI/FS is complete.
OU-3: Soils, Sediments, and Surface Water
OU-3 addresses soils, sediment, and surface water. The OU-3 RI/FS is currently ongoing and
will require additional data evaluation and field activities prior to finalizing the OU-3 RI/FS
Report. However, sufficient information has been evaluated to support the Selected Remedy in
this Early-Interim ROD for the West Dump, West Lagoon, East Dump, and East Lagoon areas of
OU-3 to mitigate potential threats to human health and the environment. The remainder of OU-3
will be addressed by future response actions when the OU-3 RI/FS is complete. The final
remedy will be documented in a Final ROD for OU-3.
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2.3 COMMUNITY PARTICIPATION
On May 27, 2016, 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 (PRAP) setting forth EPA's
early-interim preferred remedial alternative for the West Dump, West Lagoon, East Dump, and
East Lagoon areas of OU-3 of the Site. The PRAP was based on documents contained in the
Administrative Record. 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 Bloomsburg Area
Public Library located at 225 Market Street in Bloomsburg, Pennsylvania. A notice of
availability of these documents was published in the Press Enterprise on May 27, 2016. EPA
opened a 30-day public comment period on May 27, 2016, to receive comments on EPA's early-
interim preferred alternative and the other alternatives identified in the PRAP. Comments
received during this public comment period, as well as EPA's response to such comments, are
summarized in the Responsiveness Summary (Section 3.0) of this Early-Interim ROD. EPA and
PADEP also held a public meeting, on June 15, 2016, at the Central Columbia Middle School
located at 4777 Old Berwick Road, Bloomsburg, Pennsylvania. A detailed discussion of the
recent community activities is presented in Section 2.10 under the subheading Community
Acceptance.
More detailed documentation on the information contained in this Early-Interim ROD may be
found in the Administrative Record, which contains the Draft 2014 RI Report for OU-3,
"Remedial Alternatives Evaluation Technical Memorandum for the West Dump. West Lagoon,
East Dump, East Lagoon Areas" (Alternatives Memorandum), 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
Bloomsburg Area Public Library located at 225 Market Street in Bloomsburg, Pennsylvania and
is also available at the 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.aov/arweb. Copies of this Early-Interim
ROD are available for public review in these information repositories.
2.4 SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
As with many Superfund sites, the problems at the Safety Light Corporation Site are complex.
As a result, EPA has organized the work into three operable units (OUs):
• Operable Unit One (OU-1); Safety Light Buildings and Structures
¦ Operable Unit Two (OU-2): Ground Water
• Operable Unit Three (OU-3): Soils, Sediments, and Surface Water
This Early-Interim ROD sets forth the Selected Remedy for addressing non-radionuclide and
radionuclide-contaminated soils/debris and radioactive discrete objects in the West Dump, West
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Lagoon, East Dump, and East Lagoon areas of OU-3, consistent with the ongoing Removal
Action. Soils within and near these areas contain elevated levels of radionuclide and non-
radionuclide contamination and radionuclide-contaminated debris in surface and subsurface
soils, which pose a threat to human health and the environment. Because the non-radionuclide
and radionuclide-contaminated soils are comingled, all soils in these areas will be handled as
radioactive waste materials.
Although a security fence restricts access to the Site, trespassing has been observed and
documented at the Site. Trespassers could come into contact with non-radionuclide and
radionuclide-contaminated soils and other debris or radioactive discrete objects in the fenced-in
West Dump, West Lagoon, East Dump, and East Lagoon areas on the Site. These radioactive
discrete objects could easily be retrieved by unsuspecting trespassers and cause considerable
harm to trespassers or others if the radioactive discrete objects are removed from the Site. In
addition, these non-radionuclide and radionuclide-contaminated soils and radioactive discrete
objects lie within the 100-year floodplain of the Susquehanna River which is prone to flooding.
Flood waters may transport radionuclide-contaminated soils and other radionuclide-contaminated
debris/objects to adjacent downstream residential properties and other properties further
downstream depending upon the severity of the flooding event. Immediate implementation of an
early-interim remedial action would substantially reduce the threat to human health and the
environment posed from the lagoon and dump areas until a final remedy is selected for OU-3.
This Early-Interim ROD addresses only the West Dump, West Lagoon, East Dump, and East
Lagoon areas of OU-3. The remaining areas of OU-3 will be addressed in a future response
action when the OU-3 RI/FS is completed. The final remedy will be documented in a Final ROD
for OU-3.
In addition, this Early-Interim ROD does not address OU-2 Ground Water. The OU-2 RI/FS is
currently being performed by EPA, and OU-2 will be addressed when the RI/FS is complete.
2.5 SITE CHARACTERISTICS
Physical Characteristics and Land Use
The Site, at an elevation of 490 feet above mean sea level, is located on an old terrace and
floodplain on the north bank of the Susquehanna River. The topography of the Site has low
relief with the ground surface sloping gently towards the River. A fence currently surrounds the
Site. The northern portion of the Site comprises parking areas and a lawn. The central portion of
the Site, which contained SLC's former operating facilities, consisted of multiple
buildings/structures used for offices, manufacturing, shipping and receiving, and waste storage.
The buildings/structures on-site have been demolished as described in Section 2.2 of this Early-
Interim ROD. The floodplain of the Susquehanna River is immediately south of the former
operations area and includes the West Dump, West Lagoon, East Dump, and East Lagoon, as
well as an abandoned canal. The floodplain from the perimeter fence to the Susquehanna River
is heavily vegetated.
Residential areas are located adjacent to the north of the Site, across Old Berwick Road, and
adjacent to the east and west of the Site.
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Site Drainage and Surface Water
The Susquehanna River is the only natural surface water body on or adjacent to the Site, and
ground water flows south toward the Susquehanna River. The River has an estimated average
flow rate of 10,000 to 100,000 cubic feet per second. Storm drains on the Site appeared to
directly discharge surface water to the Susquehanna River; these storm drains were removed
during the EPA Removal Actions. The southern portion of the Site, from the bank of the
Susquehanna River to about 200 feet inland, is within the 100 year floodplain of the River. The
West Dump, West Lagoon, East Dump, and East Lagoon lie within the 100 year floodplain.
Site Soils
Most of the Site is underlain by the Chenango gravelly sand loam. The Chenango series consists
of deep, well-drained soils that formed in glacial outwash of gravel and sand. This outwash was
derived principally from acid grey sandstone, shale and various erratics. Field observations of
the fluvioglacial deposits uncovered gravels and sands having thickness totals of approximately
35 to 45 feet. These fluvioglacial deposits can be divided into two broad units:
* Upper unit: coarse sand and gravel with large sandstone boulders, approximately 15 to
25 feet thick;
* Lower unit: fine-grained sand and gravel, approximately 10 to 20 feet thick.
The other soil series present on the Site is the Middlebury silt loam. The Middlebury series
consists of deep, moderately well drained to somewhat poorly drained soils that formed in
relatively recent alluvium deposits of the Susquehanna River on nearly level and gently sloping
floodplains. Field observations note that the River has cut a fairly steep bank against the sand
and gravel outwash plain and has deposited a blanket of silts, fine sandy silts, clayey silts and
coaly silts on the floodplains.
Also worth noting is an abandoned canal that follows the upper edge of the gravel bank and has
been filled in over most of the Site. The canal was about 100 feet wide and 15 feet deep. The
East and West Lagoons are actually remnants of the old canal. The canal was dug primarily in
the silts and appears to have little influence on the hydrologic system. One test pit in the former
canal encountered wood and radioactive debris with a strong oily smell.
Nature and Extent of Contamination - Soils
Radioactivity and Exposure Measurements and Units
In order to facilitate an understanding of the following discussions regarding radiological
measurements and exposures at the Site, this information is offered to provide some context to
the terms and measurements that EPA uses for radionuclide-contaminated Superfund Sites.
Definitions of commonly used radiological terms and units of measurement used in the following
sections arc presented in the Glossary in Appendix A.
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How is Radioactivity Measured
Radioactivity is measured by the activity of a material. The activity is the number of
radionuclides that decay each second. When radionuclides decay, they release alpha, beta, and
gamma radiation. EPA often uses a unit called a curie (Ci) to measure activity. One curie is 37
billion decays per second. This unit is too large to use at most Superfund sites to assess radiation
risk, so EPA usually uses a unit called a picocurie (pCi). One picocurie is equal to one trillionth
of a curie, or about 2.2 radionuclide decays per minute. EPA measures radioactive
contamination by the number of picocuries measured in a specific amount of contaminated
material. Soil contamination, for example, is measured in picocuries per gram (pCi/g),
How is Dose Measured
Under most situations, radiation exposure is measured in dose. Dose is related to the amount of
radiation absorbed by a person's body. The unit for radiation dose that EPA uses is the millirem
(mrem). Millirem relates the absorbed dose of radiation to the amount of biological damage
from the radiation. According to the National Council for Radiation Protection and
Measurements, the average person in the United States receives a radiation exposure of
approximately 620 millirems per year (mrem/yr) from both natural and man-made sources.
Background sources of radiation include cosmic radiation from space, medical procedures,
radiation found naturally in the soil and water, and indoor radon. However, at Superfund sites,
EPA compares levels of radioactive contaminants against background levels of the same
radionuclides that may be naturally occurring in media such as soil and ground water.
OU-3 RI Field Investigation
OU-3 Survey Units
The Site and neighboring residential properties to the east and west of the Site were divided by
EPA into 22 survey units (SU) during the OU-3 RI, based on the unit's history and results of
previous characterization data (Figure 3). Radiological surveys were conducted in each SU with
a radiological instrument detector approximately 30 centimeters above the ground (general area
reading). A gamma walkover survey was done of all accessible areas of the unit to locate any
areas with radiation levels higher than normal background. Areas of elevated activity were
marked and a static count was taken to quantify the amount of contamination by placing the
detector directly on the ground surface (contact reading) and taking a timed (usually one minute)
count (i.e., counts per minute or cpm).
After the scan surveys were completed, grids were established in each SU and static
measurements were taken on the grids to verify the results of the scan survey and to determine if
contamination was consistent across a unit. Note, depending upon the type of radiation detector
used, common readout units are roentgens per hour (R/hr), milliroentgens per hour (mR/hr), rem
per hour (rem/hr), millirem per hour (mrem/hr), and cpm.
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Because field instrumentation can only distinguish types of radiation (i.e., alpha, beta, and
gamma), surface and subsurface soil sampling and analysis for identification of specific
radionuclides was performed in a laboratory. Dependent upon the SU, approximately five to
eleven surface soil samples were collected in each SU in known or suspected locations of
contamination and/or grid locations used for the static measurements.
OU-3 RI Soil Sampling
Soil sampling was conducted to determine the nature and extent of the radiological
contamination in soil at the Site, Because field instrumentation can only distinguish types of
radiation (i.e., alpha, beta, and gamma), analysis for identification of specific radionuclides was
performed in a laboratory. Soil samples were collected during the OU-3 RI and analyzed for
radionuclides. The results were used to characterize the relative abundance of each of the
specific radionuclides in each SU and to provide inputs to the risk assessment. In addition,
several locations in each SU were analyzed for non-radionuclides (chemical parameters)
including volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs),
pesticides and polychlorinated biphenyls (PCBs), and metals.
Results from the soil surveys and soil sampling generally indicated radiological contamination
above background throughout most areas of the Site. A comprehensive summary of the OU-3 RI
soil sampling results for all the SUs is provided in the June 2014 Draft OU-3 RI Report, which is
part of the Administrative Record.
OU-3 Data Evaluation
Sampling results were compared to calculated soil screening levels (SSLs) developed by EPA.
SSLs for non-radionuclides were calculated using EPA's Regional Screening Level calculator
and direct contact with soil exposure assumptions. More information regarding EPA's RSL
calculator may be found at https://www.epa.gov/risk/regional-screening-levels-rsls. SSLs for
radionuclides were calculated using EPA's Preliminary Remediation Goals for Radionuclides
(PRO) Calculator. The PRG calculator is a tool that allows EPA to calculate initial cleanup
levels for radiation in soil, water, and air at Superfund Sites but also may be used for generating
SSLs. The target risk for SSLs is a 1E-06 (one in one million) risk for carcinogens and a hazard
quotient (HQ) of 0.1 for non-carcinogens due to cumulative effects. These SSLs are based on
achieving acceptable risk ranges for exposure to contaminants on a specific Superfund Site.
More information regarding EPA's PRG Calculator may be found at https;//cpa-
nras.oinl.gov/radionuclides/.
The calculated SSLs were used to determine the area of concern at the West Dump, West
Lagoon, East Dump, and East Lagoon. SSLs with a target cancer risk threshold of 1E-06 from
exposure to all carcinogens were used in the determination. Calculated SSLs for the site-related
radionuclides and non-radionuclides for the Site are provided in Table D-2 of this Early-Interim
ROD. The following table is an excerpt from Table D-2 summarizing the radionuclide SSLs
calculated using EPA's PRG calculator corresponding to a 1E-06 cancer risk, and their
respective background concentrations.
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Tabic I
SLC Superfund Site
Calculated Radionuclide Soil Screening Levels IE-06 Risk
Radionuclide
SSL (pCi/g)
Background (pCi/g)
Americium-241 (Am-24l)
0.049
NA
Cesium-137 (Cs-137)
0.047
0.431
Lead-210 {Pb-210)
0.0077
1.64
Neptunium-237 (Np-237)
0.046
0.13
Niekel-63 (Ni-63)
6.7
NA
Radium-226 (Ra-226)
0.0064
1.52
Strontium-90 (Sr-90)
0.066
0.604
Thallium-204 (Tl-204)
2.1
0.356
Tritium (H3)
0.23
3.78
Mobile Environmental Radiation Laboratory (MERL) Sampling
In addition to the OU-3 RI soil sampling data, supplemental information was collected in
October 20) 5 during ongoing removal activities utilizing the EPA Mobile Environmental
Radiation Laboratory (MERL). EPA conducted additional investigation of several potential
source areas as part of the ongoing Removal Action. Elevated radiological activity and/or
radiologically impacted debris have been identified during removal activities at various areas at
the Site. The MERL team consists of EPA health physicists, nuclear scientists, and
radiochemists, all with significant experience with radionuclide analysis and interpretation. This
expertise allowed EPA to analyze on-site samples and provide the most up-to-date information
on contaminants in addition to data collected during the OU-3 RI.
OU-3 RI and MERL Soil Results
Results of the radiological and chemical analyses performed during the OU-3 RI and MERL
sampling, including field measurements and laboratory analyses, are summarized in the
following sections. The Selected Remedy in this Early-Interim ROD addresses only Survey Unit
12 - West Dump, Survey Unit 13 - West Lagoon, Survey Unit 14 - East Dump, and Survey Unit
15 — East Lagoon. Therefore, only these areas of OU-3 are discussed in the following sections.
Additional data evaluation and field activities may be necessary prior to finalizing the OU-3
RI/FS,
Background Radiation
Off-site background gamma measurements were collected in a vacant lot east of Survey Unit 22.
Soil types were similar to those from the other SUs and radioactive material had not been used or
stored in this area. A reference background level (i.e., normal background) was established by
calculating the mean of 48 static measurements collected utilizing the same sampling procedures
used for the on-site field survey. The calculated reference background value for the field survey
during the OU-3 RI was 8,796 cpm. Dose rates from the background area ranged from 9 to 10
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uR/hr. Background samples were also collected by USAGE in 2015 to provide additional results
for radium-226.
Background concentrations for specific radionuclides in soil are presented in Table 1 and Table
D-2. These results are the calculated 95% upper prediction limit for radium-226 for the USAGE
data and the 95% upper tolerance limit from the OU-3 RI data for the other radionuclides.
West Dump - Survey Unit 12
This SU is approximately 3,122 square feet and includes the West Dump. The West Dump
contained no buildings/structures and more than 50% of the West Dump was inaccessible due to
immovable debris; however, surface scans and gridded static count surveys were performed on
the accessible areas. Scan results showed high activity on all accessible areas, averaging
approximately 142,000 corrected counts per minute (i.e., cpm above background or ccpin). Only
20 of the required 23 gridded static measurements were taken due to inaccessibility and averaged
approximately 58,000 cepm, which was above background readings. Average dose rates were
between 0.1 and 0.4 mR/hr. The highest result detected (1,090,439 ccpm with a dose rate of 231
microroentgen per hour (pR/hr)) was found in a depression in the eastern portion of the West
Dump where a terracotta pipe was exposed. It should be noted that these measurements have
dropped significantly because of the removal of discrete radio nuclide-contaminated items and
placement of the temporary cover during the West Dump Removal Action.
Eleven samples were taken from five biased sample locations and analyzed for radionuclides and
non-radionuclides. Soil samples from the five biased locations were collected from various
depths (0 to 0.5 feet and 0.5 to 2.0 feet in depth at each location and 3 to 4 feet at one location).
Significant results (above the SSLs calculated by EPA's PRC calculator for radionuclides) were
reported for lead-210 (up to 163 pCi/g) and radium-226 (up to 617 pCi/g). The sample collected
from the area of highest static measurements (Biased Sample #5) showed low levels of
radionuclides which did not correlate with the high counts and dose rates recorded near that
location. It is likely that the high dose rates were associated with the terracotta pipe and not soil
in that area. Table D-3 and Figure 4 show the OU-3 RI radionuclide sampling results and
locations for the West Dump.
MERL on-site sampling was not conducted for the West Dump area soils.
Elevated concentrations of inorganic and organic contaminants were detected in surface soils and
included chromium up to 230 milligrams per kilogram (mg/kg); iron (up to 35,100 mg/kg); and
Aroclor-1254 up to 4,400 micrograms per kilogram (pg/kg).
West Lagoon - Survey Unit 13
Survey Unit 13 is approximately 8,600 square feet and includes the West Lagoon, which is south
of the former Etching Building, the Pipe Shop, Survey Unit 4, and is located north of the
Susquehanna River floodplain. The West Lagoon was the discharge point for the septic system
overflow and is suspected of receiving liquid wastes during operations. The southern half of the
West Lagoon is likely a filled portion of the abandoned canal.
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Surface scan and static count surveys could not be performed during the OU-3 RI field activities
conducted in 2007/2008 due to the presence of raw sewage. Only the perimeter of the West
Lagoon was scanned and results consistently showed elevated activity averaging approximately
17,000 ccpm. Dose rates were measured with an extendable instrument and results were not
detectable, with the exception of an area in the northwest corner which had a contact reading of
2.0 mR/hr. The highest contamination found in this unit was 68,772 ccpm and the highest dose
rate was 35 pR/hr at an area in the northeast corner of the West Lagoon.
Ten samples were taken from five biased sample locations (0 to 0.5 feet and 0.5 to 2.0 feet in
depth at each location) and analyzed for radionuclides. Significant results above SSLs were
reported for tritium, lead-210, and radium-226 in all samples, neptunium-237 at two sample
locations, and uranium-238 in one shallow surface soil sample. Contamination was distributed
from surface to a depth of 2 feet; however, due to the inaccessibility of the West Lagoon from
the sewage waste, samples below 2 feet were not obtained.
During the MERL sampling analysis event, an additional forty-one samples were taken from
twenty-two boring locations distributed throughout the West Lagoon. MERL soil results
indicated that elevated levels of radionuclides were detected at depths up to 12 feet bgs. The
radionuclides detected at concentrations above SSLs were radium-226 (up to 181 pCi/g at
thirteen boring locations), lead-210 (up to 193.6 pCi/g at fourteen boring locations), cesium-137
(up to 1.037 pCi/g at three boring locations), Americium-241 (up to 16.93 pCi/g at two boring
locations), and neptunium-237 (up to 0.7401 pCi/g at one boring location).
The OU-3 RI and MERL soil sampling results from the West Lagoon are presented in Table D-4
and Table D-7, respectively. Figure 5 shows the OU-3 RI and MERL sampling locations for the
West Lagoon.
Inorganic contaminants detected in West Lagoon surface soils at elevated concentrations
included arsenic (up to 27.7 mg/kg); antimony (up to 68.5 mg/kg); cadmium (up to 198 mg/kg);
chromium (up to 8,350 mg/kg); iron (up to 58,300 mg/kg); lead (up to 2.690 mg/kg); mercury
(up to 74.7 mg/kg); and silver (up to 224 mg/kg). The West Lagoon is believed to have received
wastewater from the Etching Building, which could account for the elevated concentrations of
metals detected in this area.
Organic contaminants detected in West Lagoon surface soils at elevated concentrations include
polynuclear aromatic hydrocarbons (PAMs) such as benzo(a)pyrenc (up to 1,200 pg/kg);
benzo(a)anthracene (up to 1,600 (.ig/kg); benzo(b)fluoranthene (up to 2,200 pg/kg);
dibenzo(a,h)anthracene (up to 330 pg/kg); and indeno(l,2,3-cd)pyrene (up to 1,400 pg/kg). In
addition, the PCBs aroclor-1254 (up to 23,000 pg/kg) and aroclor-1260 (up to 13,000 pg/kg)
were detected in this area. The pesticides alpha-BHC (up to 190 pg/kg) and heptachlor epoxide
(up to 81 pg/kg) also were present in several surface soils.
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East Dump - Survey Unit 14
Survey Unit 14 includes the East Dump. This area is believed to be an older dump that was
completely built up with soil and covered with grass to make a walkway between the West and
East Lagoons, The East Dump is located south of the former Pipe Shop and north of Survey
Unit 16 and the floodplain. EPA has documented that numerous radioactive dials found in the
West Lagoon also extend into the subsurface soils of the East Dump (see section on Radioactive
Discrete Objects/Items).
Scan results showed uniformly high activity across the East Dump averaging approximately
19.000 ccpm. All 15 gridded static counts were above background and averaged approximately
16,000 ccpm. The evidence of highest contamination in the East Dump was 30,214 ccpm and
the highest dose rate was 16 gR/hr.
Fifteen samples were taken from five biased sample locations distributed throughout the East
Dump and analyzed for radionuclides. Samples at each location were collected from depths of 0
to 0.5 feet bgs. 0.5 to 2.0 feet bgs. and at depths from 10 to 12 feet bgs (or 8 to 12 feet bgs in one
sample). All samples exceeded the SSLs established by the PRCi calculator for radium-226 and
all but one sample exceeded the screening level for lead-210. Elevated levels of tritium and
uranium-238 were also frequently detected while one subsurface sample had a level of
neptunium-237 above the SSLs. Contamination was distributed from the surface to a depth of 12
feet with the highest levels observed at depth, particularly for lead-210 and radium-226.
Boring logs indicate that a clay layer was observed at depths ranging from approximately 2 to 3
feet bgs and, in some areas of the East Dump, at depths of approximately 11 to 12 feet bgs. This
is consistent with other areas of the Site, as observed in test pits excavated during EPA Removal
Actions and in other borings installed during the OU-3 Rl. A layer of ash was also encountered
at approximately 4 feet bgs in a boring (SUM-10) in the southwest end of the East Dump. Test
pits in other areas of the Site {e.g. East Lagoon) excavated during EPA Removal Actions also
showed ash material. The source and nature of this ash remains unknown. However, data
suggest that the ash may have been used as a cover. Fill material was also noted at depths of 10
to 11 feet bgs on the eastern side of the East Dump area. The fill material showed the highest
activity in the boring when surveyed. The highest radiological activity in the borings were
typically recorded in the deepest intervals. Ground water was encountered at depths of
approximately 14 feet bgs in the East Dump.
In 2015. utilizing the MERL, EPA collected an additional fifteen samples from seven boring
locations distributed throughout the East Dump. MERL soil results indicated that elevated levels
of radionuclides were detected at depths down to 16 feet bgs, confirming that contamination is
concentrated in the subsurface soils. The radionuclides detected at concentrations above SSLs
were radium-226 (up to 889.2 pCi/g at six boring locations), lead-210 (up to 844.5 pCi/g at ail
boring locations), americium-241 (up to 7.36 pCi/g at three boring locations), and neptunium-
237 (up to 544 pCi/g at two boring locations).
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The OU-3 RI and MERL soil sampling results from the East Dump are presented in Table D-5
and Table D-8, respectively. Figure 6 shows the OU-3 RI and MERL sampling locations for the
East Dump.
Arsenic (up to 19 mg/kg) was detected in East Dump surface soils, PAHs were the only other
contaminants detected at elevated concentrations in this area and include benzo(a)pyrene (up to
5,600 pg/kg); benzo(a)anthraeene (up to 5,600 pg/kg); benzo(b)fluoranthene (up to 7,900
pg/kg); benzo(k)fluoranthene (up to 2,100 pg/kg); dibenzo(a,h)anthracene (up to 850 pg/kg);
and indeno(l ,2,3-cd)pyrene (up to 3.700 pg/kg). Subsurface soils did not show elevated
concentrations of contaminants.
East Lagoon - Survey Unit 15
Survey Unit 15 is approximately 4,295 square feet and includes the East Lagoon; it is located
east of the East Dump, south of the former Multi-Metals Waste Treatment Plant and Carpenters
Shop, north of the floodplain, and west of Survey Units 5 and 16. The southern section of the
East Lagoon appears to be a portion of the abandoned canal, which may have been filled in with
plant production debris.
Most surfaces in the East Lagoon had elevated scan activity averaging approximately 144,000
ccpm, A tree root at the end of a discharge pipe read 1,856.627 ccpm and had the highest contact
dose rate recorded in the East Lagoon (2.2 mR/hr). All 23 gridded static counts collected in the
East Lagoon averaged approximately 75,000 ccpm and were all well above background (see
Table 1 and Table D-2). Near the outfall pipe, a reading of 1,173,294 ccpm and the highest dose
rate (591pR/hr) from the East Lagoon soils was recorded.
Eleven samples were taken from five biased sample locations during the OU-3 RI and analyzed
for radionuclides. Samples were collected at depths of 0 to 0.5 feel bgs and 0.5 to 2.0 feet bgs at
each location and a sample at location SU-15-4 (near the outfall pipe) was also collected at a
depth of 9 to 11 feet bgs. The boring log from location SU-15-4 shows a thin clay layer at 4 feet
bgs with ground water encountered at 11 ieet bgs. While the soil in this location is
contaminated, the survey readings are likely due to activity associated with the outfall pipe and
not the surrounding soil. Significant results for cesium-137, lead-210, radium-226, and
strontium-90 were detected in one or more samples with the highest levels detected in the
central-western side of the East Lagoon (SU-15-11).
An additional thirty-seven MERL samples were collected from nineteen sample locations
distributed throughout the East Lagoon ranging in depth from 0-4 feet to 12-18 feet bgs. MERL
soil results indicated that elevated levels of radionuclides were detected at depths up to 16 feet
bgs; however, an overall analysis of these results indicates that much of the contamination in the
East Lagoon is concentrated in the 0-4 foot soils, which are those directly exposed to the
elements.
The radionuclides that were detected at concentrations above SSLs were radium-226 (up to 3,366
pCi/g at fifteen boring locations), lead-210 (up to 3,016 pCi/g at sixteen boring locations),
cesium-137 (up to 113 .3 pCi/g at sixteen boring locations), americium-241 (up to 32.73 pCi/g at
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ten boring locations), and neptunium-237 (up to 8.853 pCi/g at three boring locations). In
comparison, these results are significantly higher than the results obtained during the OU-3 RI
sampling. The highest radium-226 measurement in the East Lagoon detected during the OU-3
RI was 30.6 pCi/g.
The OU-3 RI and MERL soil sampling results from the East Lagoon arc presented in Table D-6
and Table D-9, respectively. Figure 7 shows the OU-3 RI and MERL sampling locations for the
East Lagoon.
Inorganics detected in the East Lagoon at significant levels include arsenic (up to 13.8 mg/kg);
cadmium (up to 155 mg/kg); chromium (up to 942 mg/kg); iron (up to 27,800 mg/kg); lead (up
to 1,010 mg/kg); and silver (up to 127 mg/kg). The highest concentrations of inorganic
compounds were detected in surface soils with the exception of iron, where the highest
concentration was detected at a depth of 9 to 11 feet bgs. Organic contaminants detected at
elevated concentrations include the PAHs benzo(a)pyrene (up to 5,000 pg/kg);
benzo(a)anthracene (up to 4,200 pg/kg); benzo(b)fluoranthene (up to 6,800 pg/kg);
benzo(k)fiuoranthene (up to 1,800 jag/kg); dibenzo(a,h)anthracene (up to 890 pg/kg); and
indeno(L2,3-cd)pyrene (up to 3,600 pg/kg). In addition, the PCB Aroclor-1254 (up to 840
pg/kg) was detected in this area. Organic contamination was limited to surface and shallow
subsurface soil samples.
Radioactive Discrete Objects/Items
Based on findings in the West Lagoon and West Dump (from previous and current EPA
Removal Actions), additional radioactive discrete objects similar in nature to those found in the
West Lagoon and West Dump are also contained in the East Dump subsurface soils. Under the
current Removal Action, EPA has documented that numerous radioactive dials found in the
West Lagoon also extend into the subsurface soils of the East Dump (see Appendix G, Photos 1
and 2). Approximately 110 cubic yards of dials and other radioactive discrete objects have been
removed from the West Lagoon/East Dump area to date under the current EPA Removal Action.
Other radioactive discrete objects and items as minute as a glass bead were found to emit
elevated levels of radiation in the West Dump. One item, in particular, had transferable
contamination of 27,000 disintegrations per minute (dpm) alpha contamination (see Appendix G,
Photo 3). Removing and disposing of additional radioactive discrete objects, if any, from the
West Dump, West Lagoon, East Dump, and East Lagoon will minimize the threat of exposure to
human health.
2.5.1 Conceptual Site Mode!
During the OU-3 RI, a conceptual site model (CSM) was established to evaluate potential routes
of exposure between Site-related contaminants and human receptors. The CSM, which depicts
anticipated exposure pathways between Site hazardous substances in soils within the West
Dump, West Lagoon, East Dump, and East Lagoon and future potential receptors, is included in
Figure 8.
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2.6 CURRENT & POTENTIAL FUTURE LAND & RESOURCE USES
The Site is in a residential community with some industrial land use. The current land use
patterns near the Site are well established. Land use at the Site is currently limited, due to Site
conditions, and is expected to be limited in the future. Although disparate potential receptors
may potentially occupy the Site in the future, quantitative risks were estimated only for the
lifetime adult/child scenario, as that represented the most conservative exposure scenario.
Residential areas are located adjacent to the north of the Safety Light Property, across Old
Berwick Road, and adjacent to the east and west of the Safety Light Property. The Susquehanna
River is located to the south of the Site.
2.7 SUMMARY OF SITE RISK
Based on the results of the OU-3 Rl, data from ongoing removal assessments, and a review of
Site conditions, two primary risks are currently associated with the West Dump, West Lagoon,
East Dump, and East Lagoon areas of the Site: 1) threat of release of hazardous substances
(radionuclides) from these areas to the environment; and 2) threat to human health in the event
that a future adult/child or industrial/construction worker may come into contact with non-
radio nuclide and radionuclide-contaminated soils and/or radioactive discrete objects or items.
Threat of Release of Hazardous Substances to the Environment
Radiation surveys performed with on-site instrumentation and off-site laboratory analysis of
samples indicate that the Site is contaminated with numerous hazardous substances listed at 40
C.F.R. §302.4, primarily radionuclides such as cesium-137, strontium-90, radium-226, lead-210,
tritium, and non-radionuclides such as PAHs, PCBs, arsenic, cadmium, and chromium, among
others. The ongoing Removal Action was initiated to address the radiologically-contaminated
items and associated radionuclide-contaminated soils within and near the West Lagoon, East
Dump, and East Lagoon, to secure this portion of the Site and significantly reduce the threat to
public health and the environment posed by the Site (this Removal Action did not include the
West Dump). Continuation of activities under the ongoing Removal Action by implementation
of the Selected Remedy in this Early-Interim ROD would ensure that these threats are addressed
until a final remedy is selected for OU-3.
In addition to non-radionuclide and radionuclide-contaminated soils, items buried on-site include
radioactively-contaminated duct work and other contaminated items that had either been returned
to the Site by their customers or were manufactured at the Site. During implementation of the
ongoing Removal Action, extremely high-activity radiologically-contaminated items have been
discovered buried within several inches of the ground surface of the flood prone lagoons. High-
activity radiologically-contaminated sources found on or near the ground surface at the Site pose
a long-term threat of release of hazardous substances if these items are uncovered by
environmental conditions, including but not limited to flooding.
The Site is located on a terrace and floodplain on the north bank of the Susquehanna River. The
Site has experienced flooding above the 100-year floodplain, during which several radioactively-
contaminated buildings, prior to demolition under OU-L were flooded. Following Tropical
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Storm Lee in 2011, EPA determined that contamination had migrated from the West Dump to an
adjoining residential property (prompting a Removal Action in the West Dump) and that further
flooding could release additional hazardous substances, primarily the above-described
radionuclides, into the environment. The assessment of the Site, including the Lagoons and
dumps, identified items, such as gamma and beta sources, radium painted dials and other
miscellaneous manufacturing waste materials, within a few inches of the current surface. The
West Dump, West Lagoon, East Dump, and East Lagoon contain high levels of soil
contamination. Soils and radioactive discrete objects may become mobile in flood conditions
and may cause unacceptable exposures to the public. Flooding may also cause the migration of
non-radionuclide and radionuclide-contaminated soil from the lagoons and dumps to other areas
of the Site and cause further impacts to Site soils.
Threat to Hum an Health
The hazardous substances present at the Site include various radionuclides and non-radionuclide
contaminants. The radionuclide-contaminated soils/debris and radioactive discrete objects/items
are of primary concern. Residential areas are located directly to the north of the Site, across Old
Berwick Road and di rectly to the east and west of the Site. The Susquehanna River is the
southern border of the Site. Trespassing has been documented several times at the Site, and both
residents and trespassers may become exposed to hazardous substances located at the Site if
further action is not taken. Some of the highest levels of radionuclide soil contamination and
concentration of radiological discrete objects/items are in the West Dump, West Lagoon, East
Dump, and East Lagoon areas of the Site.
Human Health Risk Assessment
A Site-wide human health risk assessment (HHRA) was conducted as part of the OU-3 RI/FS for
the Site, but EPA has not finalized the HHRA. The OU-3 RI/FS is currently ongoing, and the
HHRA will be finalized when the OU-3 RI/FS is complete. However, a focused risk assessment
methodology was conducted during the development of the "Remedial Alternatives Evaluation
Technical Memorandum for the West Dump, West Lagoon, East Dump. East Lagoon Areas",
dated May 2016, (Alternatives Memorandum) located in the Administrative Record. The
focused human health risk evaluation (PIHRE) was conducted to characterize the current and
potential future human health risks that would occur if no remedial action was conducted to
address contaminated media in the West Dump, West Lagoon, East Dump, and East Lagoon.
The focused FIHRE evaluates the potential for carcinogenic and non-carcinogenic effects to
occur from exposure to Site contaminants. EPA has set a target risk range of 1E-04 (1 in 10,000)
to 1E-06 (I in 1,000,000) for a lifetime excess carcinogenic risk. For non-carcinogenic risk,
EPA has set a target Hazard Index (HI) of no greater than 0.5.
The focused HHRE conducted during the development of the Alternatives Memorandum
evaluated the current and future risks posed to humans by the contamination in the West Dump.
West Lagoon, East Dump, and East Lagoon areas of the Site. All radionuclides are considered
known human carcinogens, based on their property of emitting ionizing radiation and on the
extensive weight of evidence provided by epidemiological studies of radiogenic cancers in
humans.
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The CSM, which depicts anticipated exposure pathways between Site hazardous substances in
soils within the West Dump, West Lagoon, East Dump, and East Lagoon and future potential
receptors is included in Figure 8.
Contaminants of Concern - West Dunin, West Lagoon, East Dump, and East Lagoon
For non-radionuclides, contaminants of potential concern (COPCs) were selected using the June
2015 USEPA Regional Screening Levels (RSLs) for residential exposures to soil and migration
from soil to ground water. For radionuclides, COPCs were selected using the SSLs (Table D-2)
for residential exposures to soil and migration from soil to ground water. The SSLs for
residential exposures to soil include exposures by incidental ingestion of soil, external radiation
from contaminants in soil, inhalation of fugitive dust, and consumption of home grown produce.
The SSLs for radionuclides correspond to an excess carcinogenic risk of 1E-06. Contaminants
were considered as significant contributors to risk, and therefore are included as COPCs, if their
individual carcinogenic risk contribution was greater than 1E-06 and their non-carcinogenic
target organ HQ was greater than 0.1 contributing to a target organ HI greater than 0.5. COPCs
were considered COCs if they exceeded their respective background concentrations, if available.
Table D-10 presents the Site-related COPCs above background concentrations identified in the
West Dump. West Lagoon, East Dump, and East Lagoon.
The radionuclides and non-radionuclides identified in Table D-10 are the contaminants of
concern (COCs) for the Site, These contaminants (with the exception of aluminum, iron, and
vanadium) are hazardous substances designated at 40 C.F.R. §302.4.
Summary of Human Health Risks - West Dump, West Lagoon, East Dump, and East
Lagoon
Based on the focused HHRE, unacceptable risks to human health were identified in the West
Dump, West Lagoon, East Dump, and East Lagoon areas of the Site. This focused risk
evaluation calculated risks for the following scenarios:
• Lifetime Resident (Adult/Child)
• Lead exposure modeling for the child resident and for Industrial/Construction Worker
(West Lagoon only)
Table D-l 1 summarizes the results of the focused risk evaluation. Risk ratio calculation tables
for the non-radionuclide and radionuclide contaminants of concern are presented in Appendix E
of this Early-Interim ROD. Further information concerning the HHRE is provided in the
Administrative Record.
Cancer risks exceed the EPA target risk range of 1E-04 to 1E-06 at the West Dump, West
Lagoon, East Dump, and East Lagoon. Hazard indices exceed acceptable levels at the West
Dump, West Lagoon, and East Lagoon, but hazard indices on a target organ basis arc within
acceptable levels at the East Dump.
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Ecological Risks
An Ecological Risk Assessment (ERA) and quantitative ecological risks have not been finalized
at this time. The purpose of this Early-Interim ROD is to address risks to human health and the
potential release of contaminants to the environment associated with the West Dump, West
Lagoon, East Dump, and East Lagoon areas of OU-3. EPA will complete an ERA for the Site as
part of the OU-3 RI/FS. Quantitative ecological risk, if any, will be addressed by subsequent
response actions for OU-3.
2.7,1 Basis for Taking Action
Based on the non-radionuclide and radionuclide-contaminated surface and subsurface
soils/debris and radioactive discrete objects at the West Dump, West Lagoon, East Dump, and
East Lagoon, current Site conditions, and the results of the HHRE, the early-interim response
action selected in this Early-Interim ROD is necessary to protect the public health or welfare or
the environment from actual or threatened releases of hazardous substances into the
environment.
2.8 REMEDIAL ACTION OBJECTIVES
To protect human health and the environment from potential current and future risks, the
following remedial action objectives (RAOs) have been developed to address the West Dump,
West Lagoon, East Dump, and East Lagoon:
Protection of Human Health RAO
• Prevent future potential human exposure to radionuclide and non-radionuclide
contaminants in the West Dump, West Lagoon, East Dump, and East Lagoon areas.
Protection of the Environment RAO
• Prevent future potential release of radionuclide and non-radionuclide contaminants from
the West Dump, West Lagoon, East Dump, and East Lagoon to adjacent land areas and
the Susquehanna River.
At this time, these RAOs apply only to the West Dump. West Lagoon, East Dump, and East
Lagoon. Additional RAOs may be developed for the remainder of OU-3 in future response
actions. Any additional RAOs for the final remedy will be documented in a Final ROD for OU-3.
Soil Screening Levels
Human health risk-based soil SSLs were developed for soil COCs in the West Dump. West
Lagoon, East Dump, and East Lagoon. These SSLs were used to determine the area of concern
at the West Dump, West Lagoon, East Dump, and East Lagoon. SSLs with a target cancer risk
threshold of 1E-06 from exposure to ail carcinogens were used in the determination. The human
health risk-based SSLs for non-radionuclides were calculated using EPA's Regional Screening
Level calculator and direct contact with soil exposure assumptions. The human health risk-based
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SSLs for radionuclides were calculated using EPA's PRGs for Radionuclides calculator and
default exposure assumptions.
In developing SSLs, non-carcinogenic target risk goals for each COC were assumed to be an HQ
of 0.1, SSLs for cumulative cancer risks were calculated to reflect cancer risks within EPA's
target risk range of 1E-Q4 to 1E-06. The SSLs developed for the West Dump, West Lagoon.
East Dump, and East Lagoon are shown in Table D-2.
The SSLs are not final soil cleanup numbers for the OU-3 soils. EPA will develop soil PRGs
during the OU-3 RI/FS, which is currently being performed. The PRGs will be presented in a
PRAP and become final cleanup levels in a Final ROD for OU-3 when completed.
2.9 DESCRIPTION OF ALTERNATIVES
Because this is an early-interim remedial response action, a feasibility study (FS) was not
performed for the West Dump, West Lagoon, East Dump, and East Lagoon areas. Instead, EPA
developed the "Remedial Alternatives Evaluation Technical Memorandum for the West Dump,
West Lagoon. East Dump, East Lagoon Areas'" based on the results of the OU-3 RI sampling
data, focused HHRE, and other data obtained during past and ongoing Removal Actions and
assessments. A final FS will be developed during the OU-3 Rl/FS which will address all OU-3
Site soils.
The Alternatives Memorandum developed a limited number of Early-Interim Remedial
Alternatives capable of achieving the RAOs identified above (see Section 2.8. above), A
complete description of the evaluated Early-Interim Remedial Alternatives is included in the
Alternatives Memorandum in the Administrative Record for the Site, A summary of each of
these Early-Interim Remedial Alternatives is presented below and numbered to correspond with
the numbering used in the Alternatives Memorandum.
Volume of Contaminated Soils
For the development of remedial alternatives, areas or volumes of media (i.e., soils and waste
materials) to which general response actions might be applied were determined, taking into
account not only SSLs, but also Site conditions and the nature and extent of contamination.
Volumes of non-radionuclide and radionuelide-eontaminated soils were estimated based on OU-
3 Rl and MERL soil sampling results and comparison to appropriate SSLs. Based on the results
of OU-3 Rl and MERL soil results, it is estimated that a total volume of 7,268 cubic yards of in-
place contaminated soils, including contaminated soils that may be below the ground water table,
are present in the West Dump, West Lagoon, East Dump, and East Lagoon.
Component Common to All Alternatives
The following is a common component of all the Early-Interim Remedial Alternatives evaluated
for the West Dump, West Lagoon, East Dump, and East Lagoon,
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Security Fencing
Security fencing is installed and posted in accordance with NRC requirements to deter human
and animal entry onto the Site. The fence is approximately 6 feet high and is topped with several
strands of barbed wire. There are three locked gates which allow access to the Site. The current
fence provides some protection of human health and the environment, provided no entry is made.
Although the perimeter fence does not contain the entire Site, the West Dump, West Lagoon,
East Dump, and East Lagoon areas are located within the fenced areas. The security fence limits
access to the Site by the public/trespassers and thereby reduces the potential for exposure to
radioactive constituents.
Early-Interim Preferred Remedial Alternative
EPA's Preferred Alternative is Alternative 2, Soil Excavation with Off-Site Disposal. The
following section is a summary of the Early-Interim Remedial Alternatives that were considered
in the Alternatives Memorandum and their associated costs.
Alternative I - No Action
Capital Cost: $0
Annual Operation and Maintenance (O&M) Costs: $0
Five-Year Review Costs $30,000
Total Present Worth Cost: $64,735
The No Action alternative was developed as a baseline case as required by the NCP. Under the
No Action Alternative, no additional remedial measures would be implemented to address the
West Dump, West Lagoon, East Dump, and East Lagoon.
Under this alternative, the existing security fence would remain in place at the Site. Although
the security fence restricts access to the Site, trespassing has been observed and documented at
the Site. Trespassers could come into contact with non-radionuclide and radionuelidc-
contaminated soils and other debris or radioactive discrete objects in the fenced-in West Dump,
West Lagoon, East Dump, and East Lagoon areas on the Site. These radioactive discrete objects
could easily be retrieved by unsuspecting trespassers and cause considerable harm. In addition,
these non-radionuclide and radionuclide-contaminated soils and radioactive discrete objects lie
within the 100-year floodplain of the Susquehanna River and are prone to flooding. Flood
waters may transport radionuclide-contaminated soils and other radionuclide-contaminated
debris/objects to adjacent downstream residential properties and other properties further
downstream depending upon the severity of the flooding event.
This alternative would not reduce human health risk to acceptable levels, and would not achieve
the RAOs.
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Five-Year Reviews
Five-year reviews will be conducted in accordance with statutory requirements pursuant to
Section 121(c) of CERCLA, 42 U.S.C. § 9621(c), the NCP, 40 C.F.R. §300.430(f)(4)(ii), and
EPA guidance, as appropriate.
Alternative 2 - Soil Excavation with Off-Site Disposal
Under Alternative 2, all materials including surface and subsurface soils and other debris or
radioactive discrete objects in the approximate area of concern depicted in Appendix C (Figures
4 to 7) at the West Dump, West Lagoon, East Dump, and East Lagoon would be excavated and
transported off-site as radioactive waste to a NRC licensed facility for appropriate disposal. The
vertical extent of excavation would continue until ground water or the native soil interface (the
point at which fill material meets the native soil surface) is encountered, whichever occurs first,
and would be performed to the maximum extent practicable based on Site or excavation
conditions. The West Dump, West Lagoon, East Dump, and East Lagoon areas would be
backfilled and graded with clean soil from an off-site source and a gravel protective cover would
be installed to minimize erosion. Key components of Alternative 2 are described below.
Institutional Controls (ICs) (i.e., land use restrictions) would be needed when contamination
remains at a Site above levels that allow for unrestricted use and unlimited exposure. However,
because this is an early-interim action for the West Dump, West Lagoon, East Dump, and East
Lagoon areas of the Site and might not be the final response action for these areas, ICs would not
be required at this time. Implementation of ICs will be further evaluated during the OU-3 RI/FS
for the Site, as a whole, and be documented in a Final ROD for OU-3.
Site Preparation
Site preparation would include mobilization and setup of support facilities, vegetation removal,
and establishment of soil erosion and sediment controls. During vegetation clearance, soil
excavation and stockpiling, waste loading, backfilling, and re-grading operations, erosion and
sediment controls would be regularly inspected and maintained until excavation and backfilling
is complete and the gravel protective cover to minimize erosion is established at the West Dump,
West Lagoon, East Dump, and East Lagoon.
Soil Excavation
All materials, including soils/debris and radioactive discrete objects, in the approximate area of
concern depicted in Appendix C (Figures 4 to 7), would be excavated from the West Dump,
West Lagoon, East Dump, and East Lagoon areas. The vertical extent of excavation would
continue until ground water or the native soil interface (the point at which fill material meets the
CapitaI Cost:
Annual O&M Costs:
Five- Year Review Costs
Total Present Worth Cost:
$9,068,000
$0
$30,000
$9,133,000
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native soil surface) is encountered, whichever occurs first, and would be performed to the
maximum extent practicable based on Site or excavation conditions, Based on the results of OU-
3 RI, boring logs, and MERL soil results, the excavation depths would range from 4 to 16 feet
bgs. The total in-situ volume of non-radionuclide and radionuclide contaminated soils
designated for removal would be approximately 5,978 cubic yards.
For excavation depths exceeding 4 feet bgs, measures would be taken to comply with relevant
Occupational Health and Safety Administration (OSHA) standards for excavations (i.e., step
excavation, side-wall shoring, or sloping).
Excavation operations would be performed by qualified excavation personnel with current
Hazardous Waste Operations and Emergency Response (HAZWOPER) training, as required by
OSIIA. Operators would also be subject to site-specific radiological safety training. Standard
dust control techniques would be used during removal activities to mitigate fugitive dust
emissions. Because of risk associated with worker exposure to radioactive contamination,
respirators or air monitoring would be required during excavation activities. As excavation
occurs, health physics personnel would perform surveys and air sampling to ensure the health
and safety of workers, the surrounding community, and the environment. Shipping containers
would also be surveyed prior to off-site disposal to ensure radiation levels are within acceptable
limits prior to transport.
Post-Excavation Sampling
Post-excavation samples would be collected from the floor and side walls of each excavation
area prior to backfilling and regrading. This sampling would be conducted to determine and
document the concentration of radionuclide and non-radionuclide soil contamination that may
remain in-place. Gamma walkovers of the excavated areas would also be conducted prior to
backfilling to assess any remaining radiological activity.
Waste Disposal
Based on the results of OU-3 RI and MERL soil sampling results, and because non-radionuclide
and radionuclide-contaminated soils are comingled, it is anticipated that all excavated materials
would be classified as radioactive waste. All excavated materials would be packaged as
radioactive waste and loaded into fMCs for off-site disposal. There is no feasible technology to
practicably treat radionuclides without creating larger volumes of waste and increased disposal
difficulties. However, certain waste materials (including, but not limited to, dials and some
discrete objects) may also exhibit chemical hazardous waste characteristics requiring treatment
(e.g. stabilization) prior to permanent disposal. Such waste materials shall be sampled and
analyzed using the Toxicity Characteristic Leaching Procedure (TCLP) pursuant to the Resource
Conservation and Recovery Act (RCRA) to determine if they exhibit hazardous waste
characteristics. For those waste materials that fail TCLP, such treatment shall be performed at
the off-site licensed radioactive waste facility to render such materials non-hazardous prior to
disposal at that licensed facility.
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No rail spur is located at the Site, but rail yards are nearby and would be used to facilitate
transport by rail. Excavated materials would be transferred by licensed vendors in accordance
with transportation regulations to a NRC licensed radioactive waste disposal facility. Off-site
disposal would be conducted in accordance with Section 121(d)(3) of CERCLA, 42 U.S.C. §
121(d)(3), and Section 300.440 of the NCP. 40 C.F.R. §300.440.
Site Restoration
Backfill excavated areas with clean material derived from an off-site borrow source. Backfill
material shall meet Pennsylvania Criteria for Management of Fill specifications for chemical
constituents, as certified through laboratory analysis. Regrade excavated areas to approximate
original contours, ensuring appropriate site drainage. Install and place geotexlile and a layer of
gravel, with a minimum thickness of 12 inches, on disturbed surfaces of the West Dump, West
Lagoon, East Dump, and East Lagoon as a protective cover to minimize erosion.
Five-Year Reviews
Alternative 2 may result in hazardous substances remaining in the lagoon/dump areas (e.g.,
below the water table) of the Site above health-based levels. Five-year reviews will be
conducted in accordance with statutory requirements pursuant to Section 121(c) of CERCLA, 42
U.S.C, § 9621(c), the NCP, 40 C.F.R. §300.430(f)(4)(ii), and EPA guidance, as appropriate.
Alternative 3 - Complete Contaminated Soil Removal and Off-Site Disposal
Capital Cost: $13,536,000
Annual O&M Costs: $0
Five-Year Review Costs $0
Total Present Worth Cost: $13,536,000
Alternative 3 is similar to Alternative 2 except that Alternative 3 would involve the excavation of
all materials (including soils/debris and radioactive discrete objects below the ground water tabic
or native soil interface) in the approximate area of concern depicted in Appendix C (Figures 4 to
7) in the West Dump, West Lagoon, East Dump, and East Lagoon. Ground water control
techniques including cut-off walls and pumping would be used to control ground water to allow
excavation below the water table. During excavation, ground water would be excluded from the
excavation area by steel sheet-piling installed around the perimeter of the excavation. Dewatering
also would be conducted to lower ground water levels in the vicinity of the excavation using sump
pumping, where ground water enters the excavation and is then collected in a sump and pumped
away by robust solids handling pumps for on-site temporary storage and treatment. In addition,
excavated saturated soils would either be mechanically dewatered by physical processes or
otherwise conditioned using drying agents until it could pass the "paint filter test" and remain
stable in a transport truck. A paint filter test is used to determine the presence of free liquids in a
representative sample which could affect transportation/disposal of hazardous waste. All waste
materials would be transported as radioactive waste to a NRC licensed facility for appropriate
off-site disposal. The excavated area would be backfilled with clean off-site soil, regraded with
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clean soil, and a gravel protective cover would be established to minimize erosion. Key
components of Alternative 3 are described below.
Site Preparation
Site preparation would be performed as described in Alternative 2.
Soil Excavation
All materials (including soils/debris and radioactive discrete objects below the water table or
native soil interface) in the approximate area of concern depicted in Appendix C (Figures 4 to 7)
would be excavated in the West Dump, West Lagoon, Hast Dump, and East Lagoon. The non-
radionuelide and radionuclide-contaminated soils below ground water level would be excavated
and conditioned ex-situ using drying agents mixed at the Site, Ground water control techniques,
including cut-off walls and pumping, would be used to control ground water to allow excavation
below the water table. During excavation, ground water would be excluded from the excavation
area by steel sheet-piling installed around the perimeter of the excavation. Dewatering also would
be conducted to lower ground water levels in the vicinity of the excavation using sump pumping,
where ground water enters the excavation and is then collected in a sump and pumped away by
robust solids handling pumps lor on-site temporary storage and treatment. Based on results of the
OU-3 RL EPA removal sampling boring logs and MERL soil results, the removal depths would
range from 4 to 18 feet bgs. The total in-situ volume of materials designated for removal is
approximately 7,268 cubic yards.
For excavation depths exceeding 4 feet bgs, measures must be taken to comply with relevant
OSHA standards for excavations (i.e.. step excavation, side-wall shoring, or sloping).
Excavation operations would be performed by qualified excavation personnel with current
HAZWOPER training, as required by OSHA, Operators would also be subject to site-specific
radiological safety training. Standard dust control techniques would be used during removal
activities to mitigate fugitive dust emissions. Because of risk associated with worker exposure to
radioactive contamination, respirators or air monitoring would be required during excavation
activities. As excavation occurs, health physics personnel would perform surveys and air
sampling to ensure the health and safety of workers, the surrounding community, and the
environment. Shipping containers would also be surveyed prior to departure to ensure radiation
levels are within acceptable limits prior to transport.
Confirmation Sampling
During excavation activities, confirmation samples would be collected from the floor and
sidewalls of each excavation area prior to backfilling and regrading. Confirmation sampling and
analysis would be conducted to ensure that the remaining soils do not exceed appropriate soil
SSLs, If the confirmation sampling results show exceedances of the related SSLs, additional
excavation would be conducted and new confirmatory samples would be collected.
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Saturated Soil Conditioning
1 he saturated soil would be cither mechanically dewatered by physical processes such as a belt
filter press or otherwise conditioned on-site using drying agents until it could pass the paint filter
test and remain stable in the transport truck. Saturated soils would be conditioned ex-situ using
12% drying agents by volume mixed at the Site or an equivalent process. Conditioning materials
would consist of quick lime, lime kiln dust, cement kiln dust or other similar drying agents. An
estimated 1,548 cubic yards of excavated soils would be conditioned prior to transport and off-
site disposal,
Dewatering Waste Water
Due to the variety of radionuclides, organic compounds, and metals in the ground water, the
dewatering waste water would be treated with cement solidification processes at the Site for off-
site disposal as drummed waste. Cement solidification, or equivalent processes would be used to
treat the dewatering waste water on-site prior to off-site disposal. Types of solidifying agents
include Portland cement, gypsum and pozzolanic-based materials such as fly ash, blast furnace
slag, kiln dust and pumice. After solidification processes, all waste water would be placed into
55-gallon drummed waste for off-site disposal.
Waste Disposal
Waste disposal, including dewatering waste water, would be performed as described in
Alternative 2.
Site Restoration
Site Restoration would be performed as described in Alternative 2.
Five-Year Reviews
Five-year reviews will be conducted in accordance with statutory requirements pursuant to
Section 121(c) of CERCLA, 42 U.S.C. § 9621(c), the NCP, 40 C.F.R. §300.430(0(4)(ii), and
EPA guidance, as appropriate.
2.10 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
As part of the remedy selection process, EPA evaluates each proposed remedy against the nine
criteria specified in the NCP (see 40 C.F.R. §300.430(e)(9)(iii». The alternative selected must
first satisfy the threshold criteria set out in the NCP. Next, the primary balancing criteria are
used to weigh the tradeoffs, or advantages and disadvantages, of each of the alternatives. The
modifying criteria, which are State and community acceptance, are evaluated at the end of the
public comment period. This section of the Early-Interim ROD summarizes the relative
performance of each alternative against the nine criteria, noting how it compares with the other
options under consideration.
Below is a summary of the nine criteria used to evaluate the remedial alternatives.
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THRESHOLD CRITERIA
1. Overall Protection of Human Health and the Environment
Evaluates whether an alternative provides adequate protection and how risks posed through each
pathway are eliminated, reduced or controlled through treatment, engineering controls, or
institutional controls.
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
Evaluates whether or not an alternative will meet all ARARs under Federal and State
environmental statutes and regulations, and/or justifies a waiver.
PRIMARY BALANCING CRITERIA
3. Long-Term Effectiveness and Permanence
Addresses the ability of an alternative to afford long term, effective and permanent protection to
human health and the environment over time.
4. Reduction of Toxicity, Mobility or Volume
Addresses the extent to which an alternative will reduce the toxicity, mobility, or volume of the
contaminants causing the Site risks.
5. Short Term Effectiveness
Considers the length of time until protection is achieved and the short term risk or impact to the
community, on-site workers and the environment that may be posed during the construction and
implementation of the alternative.
6. Implcmentabilitv
Considers the technical and administrative feasibility of an alternative, including the availability
of materials and services needed to implement that remedy.
7. Cost
Includes estimated capital. O&M, and net present worth costs.
MODIFYING CRITERIA
8. State Acceptance
Addresses whether the State concurs with, opposes, or has no comment on the Preferred
Alternative.
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9. Community Acceptance
Considers whether the public agrees with EPA's analyses of the Preferred Alternative described
in the PRAP.
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 summary evaluating and comparing
each alternative against the nine criteria.
DETAILED ANALYSIS OF THE REMEDIAL ALTERNATIVES
Overall Protectiveness of Human Health and the Environment
Alternative 1 would not be protective of human health since no actions would be taken to prevent
exposure to non-radionuclide and radionuclide-contaminated soils. Alternative 1 does not satisfy
any RAOs and no risk reduction is anticipated under Alternative 1. Therefore, Alternative 1 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 2 would provide for the overall protection of human health and the environment,
because all materials including soils/debris and radioactive discrete objects from the West Dump,
West Lagoon, East Dump, and East Lagoon in the approximate area of concern depicted in
Appendix C (Figures 4 to 7) would be excavated and removed. The vertical excavation would
continue until ground water or the native soil interface (the point at which fill material meets the
native soil surface) is encountered, whichever occurs first, or to the maximum extent practicable
based on Site or excavation conditions. The excavated material would be transported off-site to
a NRC licensed disposal facility for disposal. Five-year reviews will be conducted in accordance
with statutory requirements pursuant to Section 121(c) of CERCLA, 42 U.S.C. § 9621(c), the
NCP, 40 C.F.R. §300.430(f)(4)(ii), and EPA guidance, as appropriate.
Alternative 3 would provide for the overall protection of human health and the environment,
because all the materials including soils/debris and radioactive discrete objects in the
approximate area of concern (including those materials below the ground water table) depicted in
Appendix C (Figures 4 to 7), would be excavated and transported off-site to a NRC licensed
disposal facility for disposal. Unrestricted land use would be achieved at the West Dump. West
Lagoon, East Dump, and East Lagoon following implementation of Alternative 3.
RAOs would be achieved for both Alternatives 2 and 3.
Compliance with Applicable or Relevant and Appropriate Requirements
Section 121(d) of CERCLA, 42 U.S.C. § 9621(d), and Section 300.430(f)(l)(ii)(B) of the NCP,
40 C.F.R. §300.430(i)(l )(ii)(B), require that remedial actions at CERCLA sites must at least
attain legally applicable or relevant and appropriate federal and state environmental
requirements, standards, criteria and limitations, which are collectively referred to as "ARARs,"'
unless such ARARs are waived under Section 121(d)(4) of CERCLA, 42 U.S.C. § 9621(d)(4).
Applicable requirements are those substantive environmental standards, requirements, criteria, or
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limitations promulgated under federal or state environmental or facility siting laws that
specifically address a hazardous substance, pollutant, contaminant, remedial action, location or
other circumstance at the Site. However, only those state standards that arc more stringent than
federal requirements may be applicable. 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 to 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.
Alternatives 2 and 3 include soil removal and off-site disposal. Implementing these alternatives
would trigger action-specific ARARs and TBCs pertaining to earth-moving, erosion and
sediment control activities, surface run-off, and particulate emissions. Alternatives 2 and 3
would meet Federal and State ARARs and consider TBCs.
A complete listing of ARARs and TBCs for the Early-Interim Remedial Alternatives for the
West Dump, West Lagoon, East Dump, and East Lagoon is presented in Appendix F to this
Early-Interim ROD.
Long-Term Effectiveness and Permanence
This is an early-interim action remedy. Long-term effectiveness is not a criterion. EPA will
evaluate long-term effectiveness and permanence in the evaluation for the final remedy for OU-3
in a subsequent PRAP and ROD.
Reduction of Toxicity , Mobility or Volume though Treatment
Alternatives 2 and 3 would reduce the toxicity, mobility, or volume of contamination by the
excavation and off-site disposal of radionuciide-contaminated soils/debris and radioactive
discrete objects and non-radionuclide-contaminated soil from the West Dump. West Lagoon,
East Dump, and East Lagoon, but not through treatment of the contamination. There is no
feasible technology to practicably treat radionuclides that would not result in larger volumes of
waste, creating greater impracticability for disposal. Flowever, certain waste materials
(including, but not limited to, dials and some discrete objects) may also exhibit chemical
hazardous waste characteristics requiring treatment (e.g. stabilization) prior to permanent
disposal. Such waste materials shall be sampled and analyzed using the Toxicity Characteristic
Leaching Procedure (TCLP) pursuant to the Resource Conservation and Recovery Act (RCRA)
to determine if they exhibit hazardous waste characteristics. For those waste materials that fail
TCLP, such treatment shall be performed at the off-site licensed radioactive waste facility to
render such materials non-hazardous prior to disposal.
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Short Term Effectiveness
Alternatives 2 and 3 may pose minimum potential short-term threats to workers performing the
work and to the nearby community. Because Alternative 2 and Alternative 3 each involve
excavation and off-site disposal of non-radionuclide and radionuclide-contaminated soils/debris
and radioactive discrete objects, neither of the alternatives offer comparative advantage with
regard to short-term effectiveness for the nearby community. Exposure would be limited by the
use of regulatory-driven radiological controls and on-site engineering control measures such as
minimizing dust generation. Detailed work planning, air monitoring, dust suppression, and
detailed transportation planning would be performed to minimize the potential for any adverse
impacts to the community during the remedial action.
Alternative 3 would require more exposure of construction workers to non-radionuclide and
radionuclide-contaminated soils/debris and ground water because Alternative 3 would take
approximately 3 months longer to implement and requires the excavation and desaturation of an
approximate additional 1,548 cubic yards of soil compared to Alternative 2, installation of sheet-
piling, pumping and management of radionuclide-contaminated ground water from the
excavation, and management and disposal of dewatering waste water. The process of keeping
the excavation dewatered, while technically feasible, would be very challenging to implement
effectively.
The estimated construction duration for each of the alternatives is as follows:
• Alternative 1: No implementation
• Alternative 2: Six (6) Months
• Alternative 3: Nine (9) Months
The RAOs for soil in the West Dump. West Lagoon, East Dump, and East Lagoon would be met
at the completion of construction for Alternatives 2 and 3.
Imnlcmcntability
Alternatives 2 and 3 are implementable with proper planning, and design and resources are
available. However, only a limited number of companies exist with the trained personnel,
equipment, and materials to perform site preparation, conduct soil removal, soil conditioning,
and long-term periodic monitoring of radionuclide-contaminated sites.
Under Alternative 3, complete removal of all materials including soils/debris and radioactive
discrete objects below the ground water table would be difficult. Sheet-piling and dewatering of
the excavation would be necessary to effectively implement Alternative 3. In addition,
management, storage, and disposal of radionuclide-contaminated ground water would be
challenging. It is anticipated that Alternative 3 would generate approximately 18,000 gallons of
radionuclide-contaminated ground water which would require cement-solidification resulting in
approximately 600 drums of additional material for off-site disposal. Alternative 2 would be
more implementable than Alternative 3.
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No permits for on-site work would be necessary from other agencies because the Site would be
addressed under the CERCLA program. However, the substantive requirements of such permits
would be met for Alternative 2 and Alternative 3.
Cost
The capital cost for Alternative 2 is estimated to be $9,068,000. Five-year reviews would cost
$30,000 per event. O&M requirements and estimated annual O&M costs for Alternative 2 are
deferred until the selection of a final remedy for OU-3 of the Site, as a whole, and will be
documented in a Final ROD for OU-3. The present value of the total cost for Alternative 2,
based on a 30-year period and a seven percent (7%) discount rate, is estimated to be $9,133,000.
Alternative 3 is the most expensive alternative to implement. The estimated capital cost for
Alternative 3 is $13,536,000. There are no recurring costs (i.e., O&M) associated with
Alternative 3.
The cost estimates for the Alternatives arc summarized in the table below:
Table 2
Summary of Early-Interim Remedial Alternative Costs
Capital Costs
Annual O&M
Five-Year
Present Worth
Costs
Review Costs
Costs*
Alternative I
$0
$0
$30,000
$64,735
Alternative 2
$9,068,000
$0
$30,000
$9,133,000
Alternative 3
$13,536,000
$0
$0
$13,536,000
* Discount rate of 7% was used in calculation of Present Worth Costs
The detailed cost estimates of the Early-Interim Remedial Alternatives are presented in the
Alternatives Memorandum and Administrative Record.
State Acceptance
The Commonwealth of Pennsylvania concurs with the Selected Remedy identified for the West
Dump, West Lagoon, East Dump, and East Lagoon areas of OU-3 in this Early-Interim ROD.
Community Acceptance
A thirty-day public comment period on EPA's PRAP for the Site began on May 27, 2016. An
advertisement announcing the issuance of the PRAP and a public meeting to discuss the PRAP
was placed in the Press Enterprise. The public meeting was held on June 15, 2016, at the
Central Columbia Middle School located at 4777 Old Berwick Road, Bloomsburg, Pennsylvania.
The meeting was attended by approximately five members of the community,
The community appeared to support EPA's findings and EPA's proposed early-interim remedy
for OU-3. No one objected to EPA's preferred alternative, nor did anyone recommend an
alternative approach. EPA did not receive any written comments during the public comment
period.
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A copy of the transcript of the public meeting is included in the Administrative Record. EPA's
responses to questions/comments posed during the public meeting are provided in the
Responsiveness Summary (Section 3.0) of this ROD.
2.11 PRINCIPAL THREAT WASTE
PTW is defined as source materials considered to be highly toxic or highly mobile that generally
cannot be reliably contained or would present a significant risk to human health or the
environment should exposure occur. PTW includes soils containing significant concentrations of
highly toxic materials and surface or subsurface soils containing high concentrations of
contaminants that arc, or potentially are mobile due to wind entrainment, surface runoff, or
subsurface transport. The NCP states that "EPA expects to use treatment to address the principal
threats posed by a site, wherever practicable" (40 C.F.R. § 300.430(a)(l)(iii)(A)).
The Site soils contaminated with significant concentrations of radionuclides are considered
PTW. EPA has a preference to treat PTW, wherever practicable. However, there is no feasible
technology to practicably treat the radionuclides at the Site that will not result in larger volumes
of waste, creating greater impracticability for disposal. The excavated materials will be
packaged appropriately for off-site disposal at an approved off-site NRC licensed radioactive
waste disposal facility. Off-site disposal would be conducted in accordance with Section
121(d)(3) of CERCLA, 42 U.S.C. § 121(d)(3), and Section 300.440 of the NCP, 40 C.F.R.
§ 300.440.
2.12 SELECTED REMEDY
Summary of the Rationale for the Selected Remedy
The Selected Remedy for this early-interim action is Alternative 2, Soil Excavation with Off-Site
Disposal. All materials including non-radionuclide and radionuclide-contaminated soils/debris
and radioactive discrete objects will be excavated, removed, and disposed of in off-site waste
disposal facilities. Based on the information available at this time, EPA believes that the
Selected Remedy will be protective of human health and the environment, will comply with
ARARs, and will be cost-effective.
Description of Selected Remedy and Performance Standards
The Selected Remedy for OU-3 consists of the following:
1. Site Preparation - Mobilize and setup support facilities, remove vegetation, and establish
soil erosion and sediment controls. Regularly inspect and maintain erosion and sediment
controls during vegetation clearance, soil excavation and stockpiling, waste loading,
backfilling, and regrading operations, until excavation and backfilling is complete and a
gravel protective cover is established at the West Dump. West Lagoon, East Dump, and
East Lagoon to minimize erosion.
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2. Soil Excavation - Excavate ail materials including soils/debris and radioactive discrete
objects from the West Dump, West Lagoon, East Dump, and East Lagoon in the
approximate area of concern depicted in Appendix C (Figures 4 to 7). Continue vertical
excavation until ground water or the native soil interface (the point at which fill material
meets the native soil surface) is encountered, whichever occurs first, or to the maximum
extent practicable based on Site or excavation conditions. Excavation depths are
expected to range from approximately 4 to 16 feet below ground surface (bgs). The total
in-situ volume of material designated for removal is approximately 5,978 cubic yards.
3. Post-Excavation Sampling - Collect post-excavation samples from the floor and side
walls of each excavation area, prior to backfilling and regrading, to determine and
document the concentration of radionuclide and non-radionuclide soil contamination that
may remain in-placc. Conduct gamma walkovers of the excavated areas prior to
backfilling to assess any remaining radiological activity.
4. Package all excavated material as radioactive waste and load into intermodal containers
(lMCs) for shipment to disposal sites. Transfer excavated material by licensed vendors in
accordance with transportation regulations to an off-site facility as described in #5,
below.
5. Waste Disposal - Dispose off-site, at a Nuclear Regulatory Commission (NRC) licensed
radioactive waste facility, and in accordance with Section 121(d)(3) of CERCLA, 42
U.S.C. § 121(d)(3), and Section 300.440 of the NCP. 40 C.F.R. §300.440, all soils,
materials, and items excavated pursuant to item #2 above. Certain waste materials
(including, but not limited to. dials and some discrete objects) may also exhibit chemical
hazardous waste characteristics requiring treatment (e.g. stabilization) prior to permanent
disposal. Such waste materials shall be sampled and analyzed using the Toxicity
Characteristic Leaching Procedure (TCLP) pursuant to the Resource Conservation and
Recovery Act (RCRA) to determine if they exhibit hazardous waste characteristics. For
those waste materials that fail TCLP, such treatment shall be performed at the off-site
licensed radioactive waste facility to render such materials non-hazardous prior to
disposal at that licensed facility.
6. Site Restoration - Backfill excavated areas with clean material derived from an off-site
borrow source. Backfill material shall meet Pennsylvania Criteria for Management of Fill
specifications for chemical constituents, as certified through laboratory analysis. Regrade
excavated areas to approximate original contours, ensuring appropriate site drainage.
Install and place geotextile and a layer of gravel, with a minimum thickness of 12 inches,
on disturbed surfaces of the West Dump, West Lagoon, East Dump, and East Lagoon as a
protective cover to minimize erosion.
The estimated cost to complete the Early-Interim Preferred Alternative is $9,133,000.
Sum man' of the Estimated Remedy Costs
Appendix H includes details of the estimated costs to construct and implement this Selected
Remedy for the OU-3 early-interim remedy. The information in Appendix H is based on the best
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available information regarding the anticipated scope of the early-interim remedial alternative.
Changes in the cost elements are likely to occur as a result of new information and data collected
during the implementation of the early-interim remedial alternative. This is an order of
magnitude engineering cost estimate that is expected to be within +50 to -30% of the actual
project cost.
Expected Outcome of the Selected Remedy
I he expected outcome of the Selected Remedy is that all materials including soils/debris and
radioactive discrete objects from the West Dump, West Lagoon, East Dump, and Hast Lagoon in
the approximate area of concern depicted in Appendix C (Figures 4 to 7) would be excavated and
removed. The vertical excavation would continue until ground water or the native soil interface
(the point at which fill material meets the native soil surface) is encountered, whichever occurs
first, or to the maximum extent practicable based on Site or excavation conditions. The
excavated material will be disposed off-site, at a NRC licensed radioactive waste facility, and in
accordance with Section 121(d)(3) of CERCLA, 42 U.S.C. § 121(d)(3), and Section 300.440 of
the NCP, 40 C.F.R. §300.440. The threat of a release of hazardous substances (radionuclides)
from the West Dump, West Lagoon, East Dump, and East Lagoon will be addressed. Further
investigation of the soils at the Site will be completed as part of the OU-3 Remedial Investigation
and will be addressed by a future response action and documented in a Final ROD for OU-3.
2,13 STATUTORY DETERMINATION
Under Section 121 of CERCLA, 42 U.S.C. § 962!, and the NCP (40 C.F.R. § 300.430(f){5)(ii)),
the lead agency must select remedies that are protective of human health and the environment,
comply with ARARs (unless a statutory waiver is justified), are cost-effective, and utilize
permanent solutions and alternative treatment technologies or resource recovery technologies to
the maximum extent practicable. This early-interim action is protective of human health and the
environment in the short term and is intended to provide adequate protection until a Final ROD
for OU-3 is signed; complies with (or waives) those federal and state requirements that are
applicable or relevant and appropriate for this limited-scope action; and is cost-effective.
Although this early-interim action is not intended to address fully the statutory mandate for
permanence and treatment to the maximum extent practicable, this early-interim action may
utilize treatment and, if so, would support that statutory mandate. Because this action does not
constitute the final remedy for OU-3, the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a principal element, although partially addressed in
this remedy, will be addressed by the final response action for OU-3. Subsequent actions are
planned to address fully the threats posed by conditions at OU-3. This remedy may result in
hazardous substances remaining in the lagoon/dump areas of the Site above health-based levels.
Five-year reviews will be conducted in accordance with statutory requirements pursuant to
Section 121(c) of CERCLA, 42 U.S.C. § 9621(c), the NCP. 40 C.F.R. §300.430(f)(4)(ii), and
EPA guidance, as appropriate. Because this is an early-interim action ROD. review of this Site
and remedy will be ongoing as EPA continues to develop remedial alternatives for OU-3.
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Protection of Human Health and the Environment
The Selected Remedy included in this Early-Interim ROD will be protective of human health and
the environment during implementation and after completion. All materials including non-
radionuclide and radionuclide-contaminated soils/debris and radioactive discrete objects will be
excavated, removed, and disposed of off-site, which will mitigate the threat of a release of
hazardous substances to the environment from the West Dump, West Lagoon. East Dump, and
East Lagoon areas of the Site. Excavated materials will be disposed of in off-site disposal
facilities which have been designed and permitted to receive radioactive waste material.
Compliance with Applicable or Relevant and Appropriate Requirements
The selected remedy will comply with all Federal and Stale requirements, standards, criteria, and
limitations that are applicable or relevant and appropriate, as required by Section 121(d) of
CERCLA, 42 U.S.C. § 9621(d), and the NCP Sections 30O.43O(f)(5)(ii)(B) and (C). Such
requirements, standards, criteria and limitations are identified in Appendix F.
Cost Effectiveness
The NCP, at 40 C.F.R, § 300.430(f)(])(ii)(D), requires EPA to evaluate cost-effectiveness by
comparing all the alternatives meeting the threshold criteria—protection of human health and the
environment and compliance with ARARs-against long-term effectiveness and permanence;
reduction of toxicity, mobility or volume through treatment; and short-term effectiveness
(collectively referred to as overall effectiveness). The NCP further states that overall
effectiveness is then compared to cost to insure that the remedy is cost effective.
EPA concludes, following an evaluation of these criteria, that the selected remedy is eost-
effective in providing overall protection in proportion to costs and meets all other requirements
of CERCLA. The estimated present value of the selected early-interim remedial action is
$9,133,000.
Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
The hazardous substances identified within the West Dump, West Lagoon. East Dump, and East
Lagoon are a variety of non-radionuclide and radionuclide-contaminated soils, which include
radioactive discrete objects. However, there is no feasible technology to practicably treat
radionuclides that will not result in larger volumes of waste, creating greater impracticability for
disposal. The excavated material will be packaged appropriately for off-site disposal at approved
off-site NRC licensed radioactive waste disposal facility. Off-site disposal would be conducted
in accordance with Section 121(d)(3) of CERCLA, 42 U.S.C. § 121(d)(3), and Section 300.440
of the NCP. 40 C.F.R. §300.440.
However, certain waste materials (including, but not limited to, dials and some discrete objects)
may also exhibit chemical hazardous waste characteristics requiring treatment (e.g. stabilization)
prior to permanent disposal. Such waste materials shall be sampled and analyzed using the
Toxicity Characteristic Leaching Procedure (TCLP) pursuant to the Resource Conservation and
EPA Region III
2-37
AR301637
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Early-Interim Record of Decision OU-3—Safety Light Corporation Superftind Site, Bloomsburg, PA
Recovery Act (R.CRA) to determine if they exhibit hazardous waste characteristics. For those
waste materials that fail TCLP, such treatment shall be performed at the off-site licensed
radioactive waste facility to render such materials non-hazardous prior to disposal.
EPA has determined that the Selected Remedy represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in a practicable manner at the
Site. Of those alternatives that are protective of human health and the environment and comply
with ARARs, EPA has determined that the Selected Remedy provides the best balance of trade-
offs in terms of the five balancing criteria, while also considering the statutory preference for
treatment as a principal element and bias against off-site treatment and disposal, and considering
State and community acceptance.
The Selected Remedy is an early-interim action that is not designed or expected to be final, but
represents the best balance of alternatives recognizing the limited scope and early nature of the
action. It is anticipated that this Selected Remedy will be incorporated into the final remedy of
the Site. The final remedy will be documented in a Final ROD for OU-3.
Five-Year Review Requirements
The Selected Remedy in this Early-Interim ROD is for the West Dump, West Lagoon, East
Dump, and East Lagoon areas of OU-3, and includes the excavation, removal, and off-site
disposal of materials including non-radionuclide and radionuclide-contaminated soils/debris and
radioactive discrete objects. This Selected Remedy may result in hazardous substances,
pollutants, or contaminants remaining in the lagoon/dump areas of the Site above levels that
allow for unlimited use and unrestricted exposure. Five-year reviews will be conducted in
accordance with statutory requirements pursuant to Section 121(c) of CERCLA, 42 U.S.C. §
9621(c), the NCP, 40 C.F.R. §300,430(f)(4)(ii), and EPA guidance, as appropriate.
Contaminated materials and ground water will remain at the Site at the completion of the OU-3
Selected Remedy (described in this Early-Interim ROD). Following completion of the RI/FSs
for soil, sediment, and surface water (OU-3) and ground water (OU-2), EPA will select remedies
for those media in accordance with CERCLA and the NCP.
2.14 DOCUMENTATION OF SIGNIFICANT CHANGES
The PRAP for the Safety Light Corporation Site was released for public comment on May 27,
2016. The public comment period for the PRAP was held from May 27, 2016 to June 27, 2016.
EPA held a public meeting on June 15, 2016, to present the Preferred Alternative for OU-3 in the
PRAP. EPA did not receive any written comments during the public comment period. EPA has
responded to verbal comments posed during the public meeting in Part 3.0 of this Early-Interim
ROD, the Responsiveness Summary. There are no significant changes from the Preferred
Alternative presented in the PRAP.
EPA Region III
2-38
AR301638
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Early-Interim Record of Decision OlJ-3— Safety Light Corporation Superftmd Site, Blooms burg, PA
3.0 RESPONSIVENESS SUMMARY
This Responsiveness Summary documents public participation in the remedy selection process
for the Safety Light Corporation Site. The Responsiveness Summary contains a summary of the
significant comments EPA received on the PRAP for the early-interim remedial action for OU-3,
and EPA's responses to these comments. The PRAP was released for public comment on May
27. 2016 when EPA announced the comment period in the Press Enterprise newspaper. EPA's
public comment period for the PRAP began on May 27, 2016 and continued through June 27,
2016. A public meeting was held at the Centra! Columbia Middle School on the evening of June
15, 2016. EPA received questions during the public meeting, which are summarized below.
EPA did not receive any additional written or oral comments.
The transcript for the public meeting is provided in the Administrative Record for the Site.
3.1 STAKEHOLDER COMMENTS AND LEAD AGENCY RESPONSES
COMMENT #1:
A community member inquired about the depth of the ground water table at the Site, and
whether seasonal fluctuations may affect the depth of excavation during the cleanup.
RESPONSE TO COMMENT #1:
EPA's investigation of the ground water at the Site currently is ongoing, as part of OU-2. The
investigation, or RI/FS, is expected to be completed in 2017. However, ground water data has
been collected over the years from on-site monitoring wells for chemical and radionuclide
parameters, and water level measurements. Based on these ground water level measurements,
there appear to be no significant seasonal fluctuations in ground water elevations. The lowest
ground water level measured during the OU-2 ground water monitoring events was in late
summer in August 2005. Given the Site's close proximity to the Susquehanna River, it is likely
that the river's water level is the dominant factor influencing local ground water elevations. The
water table depth ranges from 2 to 25 feet bgs across the Site. The water table in the
lagoon/dump areas is approximately 16 to 18 feet bgs; therefore, this is the target depth of the
excavation for the OU-3 early-interim remedy. Based on EPA's anticipated schedule for
implementing this remedy, the excavation work should occur in the late summer months of 2016.
During this time, ground water levels are typical low; therefore, there should be minimal impact
to the depth of excavation.
COMMENT #2:
A community member requested a copy of the public presentation. The community member also
asked about the length of the public comment period, and commented that only about 15 days
remained for the public to review the document following the public meeting.
RESPONSE TO COMMENT #2:
EPA sent the community member a copy of the public presentation, on June 20. 2016. A copy of
the presentation was also placed on EPA's website at www.epa.gov/supcrfund/safetylight.
EPA Region III
3-1
AR301639
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Early-Interim Record of Decision OU-3— Safety Light Corporation Superfund Site, Bloomsburg, PA
1 he NCP, at 40 C.F.R, § 300.430(1)(3), requires EPA to implement community relation activities
when selecting a Superfund remedy, including, but not limited to, providing no less than 30
calendar days for submission of written and oral comments 011 a FRAP, and holding a public
meeting during the public comment period. The public comment period on this PRAP began on
May 27, 2016, with public notice of availability of the PRAP published in the Press Enterprise
newspaper, and continued until June 27. As mentioned above, EPA held its public meeting on
June 15, 2016. Additional information regarding public participation in this remedy selection
process is further discussed in Section 2.3 (Community Participation) of the ROD.
COMMENT #3
A community member asked about the total costs expended on the cleanup since the Site was
listed on the National Priorities List in 2005.
RESPONSE TO COMMENT #3:
EPA has expended approximately $20 million in cleanup costs at the Site, related to
implementing several removal actions and the OU-1 remedial action at the Site (see Appendix D,
Table D-l), This cost figure does not include the estimated $9 million for the Selected Remedy
in this Early-Interim ROD. or other costs associated with the investigations of the contamination
at the Site.
COMMENT #4
A community member asked what EPA's five-year review of the Site will entail.
RESPONSE TO COMMENT #4:
Generally, five-year reviews consist of a review of relevant Site information, including any
additional data generated, current performance of the selected remedy, and any other information
thai may come to light regarding the protect!veness of the remedy. Following EPA's assessment
of the remedy, EPA would issue a Five-Year Review Report which would be made available to
the public.
This Selected Remedy may result in hazardous substances, pollutants, or contaminants remaining
in the lagoon/dump areas of the Site above levels that allow for unlimited use and unrestricted
exposure. Five-year reviews will be conducted in accordance with statutory requirements
pursuant to Section 121(c) of CERCLA, 42 U.S.C. § 9621(c), the NCP. 40 C.F.R.
§300.430(f)(4)(ii), and EPA guidance, as appropriate.
EPA Region III
3-2
AR301640
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Early-Interim Record of Decision OU-3—Safety Light Corporation Superfand Site, Btoomsburg, PA
COMMENT #5:
A community member asked: Who owns the Site property?
RESPONSE TO COMMENT #5:
According to information available to EPA, the property is owned by Safety Light Corporation
and related entities.
COMMENT #6:
A community member asked whether the fence, which surrounds the former Safety Light
Corporation property, eventually will be removed.
RESPONSE TO COMMENT #6:
EPA plans to leave the fence in place as part of the Early Interim OU-3 Remedy, to prevent
trespassing and to secure the Site. During selection of the final remedy for OU-3, a final
determination regarding the fence will be made by EPA and will be documented in a Final ROD
for OU-3.
COMMENT #7:
A community member asked about the duration of the OU-3 early-interim cleanup.
RESPONSE TO COMMENT #7:
The estimated duration is 6 to 8 months for the entire action selected under this Early-Interim
ROD for OU-3.
3.2 TECHNICAL AND LEGAL COMMENTS
EPA did not receive any written technical or legal comments during the public comment period.
EPA Region Hi
3-3
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APPENDIX A
GLOSSARY
A-l
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A-2
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Glossary of Radiation Terms
absorbed dose
The amount of radiation absorbed by an object or person. The unit for absorbed dose is
the rad (U.S. unit).
alpha particle
A form of particulate ionizing radiation made up of two neutrons and two protons.
Alpha particles pose no direct or external radiation threat; however, they can pose a
serious health threat if ingested or inhaled. Alpha particles can be stopped by thin
layers of light materials, such as a sheet of paper.
ambient air
The air that surrounds us.
background
radiation
Radiation that is always in the environment. The majority of background radiation
occurs naturally and a small fraction comes from man-made elements.
beta particle
A form of particulate ionizing radiation made up of small, fast-moving particles. Some
beta particles are capable of penetrating the skin and causing damage such as skin
burns. Beta-emitters are most hazardous when they are inhaled or swallowed.
counts per
minute
The measurement of ionizing radiation expressed as being a rate of counts per unit
time registered by a radiation monitoring instrument, of which counts per minute
(cpm) is commonly used. Count rate measurements are normally associated with the
detection of particles, such as alpha particles and beta particles.
corrected
counts per
minute
The rate of counts per unit time corrected for background radiation from naturally
occurring sources.
curie
A measure of radioactivity. One curie of radioactive material will have 37 billion
transformations of atoms (disintegrations) in one second.
disintegrations
per minute
The measure of the activity of the source of radioactivity. This unit should not be
confused with cpm, which is the number of counts received by an instrument from the
source. One dpm is the number of atoms that have decayed in one minute, not the
number of atoms that have been measured as decayed.
dose
The amount of radiation delivered to an object or person. Dose may refer to absorbed
dose, the amount of energy deposited per unit mass, or to equivalent dose, the absorbed
dose adjusted for the relative biological effect of the type of radiation being measured.
dose rate
The radiation dose delivered per unit time.
effective dose
The amount of radiation absorbed by an object or person, adjusted to account for the
type of radiation received and the effect on particular organs. The unit used for
effective dose is rem (U.S. unit).
exposure
Radiation exposure, also called irradiation, occurs when radioactive material or a
radiation machine emits radiation.
gamma rays
A form of ionizing radiation that is made up of weightless packets of energy called
photons. Gamma rays can pass completely through the human body; as they pass
through, they can cause damage to tissue and DNA.
ionizing
radiation
Radiation with so much energy it can knock electrons out of atoms. Ionizing radiation
can affect the atoms in living things, so it poses a health risk by damaging tissue and
DNA in genes.
isotope
A form of an element that has the same number of protons but a different number of
neutrons in the nucleus, giving it a different atomic mass. For example, uranium has
thirty-seven different isotopes, including uranium-235 and uranium-238.
mrem
The millirem is the U.S. unit used to measure effective dose. One millirem equals
0.001 rem.
A-3
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Glossary of Radiation Terms
picocurie
The picocurie is a U.S. unit used to measure radioactivity. One picocurie is one
trillionth of a curie.
rad:
An acronym for Radiation Absorbed Dose. The rad is a basic unit of absorbed radiation
dose.
radioactivity
The emission of ionizing radiation released by a source in a given time period. The
units used to measure radioactivity is the curie (Ci).
radioisotope
Radioactive forms of the same element, with the same number of protons but different
number of neutrons. For example, Radium-228, Radium-226, and Radium-224 are
radioisotopes of radium. Radioisotopes are a subset of radionuclides.
radioactive
decay:
The process in which a radioactive nucleus emits (gives off) radiation and changes to a
different isotope or element. A number of different particles can be emitted by decay.
The most typical are alpha, beta particles, and gamma rays.
radionuclide:
Radioactive forms of elements are called radionuclides. Radium-226, Cesium-137, and
Strontium-90 are examples of radionuclides.
rem:
Roentgen Equivalent Man. A unit of absorbed dose.
roentgen
The roentgen (R) is the term used to describe radiation exposure. This term for
exposure only describes the amount of ionization in air.
A-4
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APPENDIX B
ADMINISTRATIVE RECORD INDEX
B-l
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B-2
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SAFETY LIGHT SITE
OU 3 REMEDIAL ADMINISTRATIVE RECORD FILE **
INDEX OF DOCUMENTS
III. REMEDIAL RESPONSE PLANNING
1. Report: Revised Draft Remedial Investigation
Report for Operable Unit 3 (OU-3), Soils,^Surface
Water, and Sediment, Safety Light Corporation,
Bloomsburg, Columbia County, Pennsylvania,
prepared by Tetra Tech, 6/14 .A P. 300001-300950.
2. Report: Final Technical Memorandum Remedial
Alternatives Evaluation for West Dump, West Lagoon,
East Dump, and East Lagoon Areas, Safety Light
Corporation, Operable Unit 3 Soils, Bloomsburg,
Columbia County, Pennsylvania, prepared by Tetra Tech,
5/16. P. 300951-301506.
3. Proposed Plan, Safety Light Corporation Superfund
Site, Operable Unit 3, Bloomsburg, Columbia County,
Pennsylvania, 5/16. P. 301507-30158 6.
4. Letter to Mr. John Banks, U.S. EPA, from Mr. Andrew
Frebowitz, Tetra Tech, re: Transmittal of Revised
Table 2-4 and Revised Table C-9 for the Remedial
Alternatives Evaluation for West Dump, West Lagoon,
East Dump, and East Lagoon, Operable Unit 3, 6/10/16.
P. 2231221. Tables 2-4 and C-9 are attached.
Administrative Record File available 5/23/16, updated //.
The Safety Light Site Removal Administrative Record File,.
dated 5/23/16, and Safety Light Site OU 1 Remedial
Administrative Record Filer dated 9/8/10, are incorporated
herein by reference.
Portions of the report body have been redacted to remove
draft content that was not considered or relied on by EPA
to select this Interim OU-3 Remedial Action and that EPA
expects to revise for the final report.
B-3
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V. COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/IMAGERY
1. Draft for Release U.S. EPA Public Notice, Safety Light
Corporation Superfund Site, Bloomsburg, PA, re: EPA
Seeks Public Comments on the Safety Light Corporation
Superfund Site, 5/27/16. P. 2231217.
2. U.S. EPA Fact Sheet: Safety Light Corporation Site,
Bloomsburg, Pennsylvania, entitled, "EPA Seeks Public
Comments on OU-3 Cleanup Plan," 6/1/16. P. 2217995.
3. U.S. EPA Public Presentation: Safety Light
Corporation Superfund Site, Operable Unit 3, entitled,
"Early-Interim Soil Remedy - West Dump, West Lagoon,
East Dump, & East Lagoon," 6/15/16. P. 2231220.
4. Transcript of Public Meeting Minutes, Safety Light ***
Corporation Superfund Site, 6/15/16. P. 2231219.
5. Newspaper article entitled, "Official: Cutbacks Won't
Halt Safety Light Cleanup Progress," Press Enterprise,
6/18/16. P. 2231216.
Document has been redacted to protect the privacy of
individuals. Redactions are evident from the face of the
document.
B-4
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APPENDIX C
FIGURES
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C-2
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TETRA TECH NJS, INC.
SITE LOCATION MAP
SAFETY LIGHT CORPORATION
BLOOMSBURG, COLUMBIA COUNTY.
PENNSYLVANIA
SCALE
AS NOTED
RLE
112GO'0.19CM01
DATE
04/20/10
Fl&iflE NUWSER
FIGURE 1-1
FIGURE 1: SITE LOCATION
C-3
AR301652
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WELL 15 +
WELL 14+
WELL I A
JEWELL C
500 GALLON FUEL Oil TANK
WELL 11 +
WELL 3+
WELL 17
WEST
LAGOON
FORMER
VANCE/WALT ON PROPERTY
BURIED SILO AREA
+WELL 12 + WELL 13
M1._
FLOOD Z
WELL 1,
WELL B
A A WELL H
DUMP AREA
> \*h*M ~ WELL 4
+ WELL 10
HOOP 7QNF
EAST-'
LAGOON
WELL
¦ WELL
~WELL 13
WELL F A
WELL 5.
WELL 16 +
A WELLE
WELL D
WELL 3
k WELL A
SRAINAGE DITCH
gpotr Of rMTAVC fTVWMl.
• PERSCM-EL OFFICE BUILDING (OLD NURSES STATION)
7 WACHr E HOP
3. PIPE SHOP
•t M ILTI— METALS WASTE TREATMENT FLINT
j. CAR-ENTE iHOP (ADJACENT TO MULTI—METALS WASTE TREAT MENT PLANT)
6 'ELL H E
7 LACOuER STORAGE BUILDING
a. RADIUM VA. LT
3. UT1UT" BUILDING (SR-30 SOURCE VAULT)
ia r' x a' h.ildinc
' LIQUID WASTE BUILDING (INCLUDING UNDERGROUND TANKS)
12, OLD HOL5E
13 SOU W- IE BUILDING
14- METAL - IL • (ABOVE—GROUND)
15 ETCHING BUILDING
16 MAIN ni.lLDING - INCLUDES BASEMENT, FIRST FLOOR, SECOND FLPOR, AND ATTIC
E l I: " EXCHANGE HUT (ATTACHED TO MAIN BUILDING)
L': -'.a FC.ISCATICV (WHERE 3 SUMS OF REMOVED
RADIOACTIVE WASTE WERE PREVIOUSLY STORED)
13 POLE P..ILPING
20. NUCLEAR BUILDING (TRITIUM BUILDING)
LEGEND
_ MONITORING WELL LOCATION,
• GILES DRILLING (1976)
MONITORING WELL LOCATION.
MEISER & EA3LE (1979)
MONITORING WELL LOCATION. SLC
MONITORING WELL LOCATION, CNSI ('-990)
MONITORING WELL LOCATION
MONSERCO (1S9S)
RESIDENTIAL WELL LOCATION
PA ST A TB ROUTE 1004 OLD OSflVWCK FK>AD
m tag ""
= 1 -h
o
PROPERTT CORNER
WlKE FENCE
STREAM/WATER EDGE
— 100 YEAR FLOOD ZONE
@ BUILDING NUMBER
&S&S3 SLC OPERATIONS
eh
ABANDONED CANAL
80
Mil
K ALE I
FEET
TETRATECH
~
WELL G
SITE MAP
SAFETY LIGHT CORPORATION
BLOOMSBURG, COLUMBIA COUNTY.
PENNSYLVANIA
WELL 7+
F1_E
112GQ103BOMD2
SCALE
AS VOTED
FIGURE NUMBER
FIGURE 1
kEV M1E
0 10/03/13
FORMER RESIDENTIAL WELL LOCATION USED
A5 MONITORING WELL
FIGURE 2: SITEMAP
C-4
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JET** TE H Hifik INU
PTOFERTY BOLfSHART
WIRE FENCE
STREAM
1GD YDW FLOOD ZONE
bjlding nlmger
SOIL CLASSJF1CATICN 1
SOIL CLASSIFICATION 2
SOIL CLASSIFICATION 3
SURVE* UWT NUMBER
--Uj=.LE In FEET
FILE
^2CDT03KfrtC4
FlSLtE HLMSE*
FlG^KE 1-?
SCALE
a1, note:
«£v L-JkTE
0 54/20/10
) PERSONNEL OFFICE BUILDING (CLO NURSES STAiTlON)
) MACHINE SHCP
) PIPE SHD15
) MULT1-METAL5 AASTE TKEATVEVT -»LA?n
JCAfiPENTIR 5HCP (ADjWCEWT TO MULTI-METALS SASflE
TREATMENT PLANT)
)wELL HOUSE
JLACCUE5! STOOGE BULDING
) HCIUW VAULT
) vTlUTY BUILDING (5fi-K SOvRCE VAULT)
jjs' x a' uliILeInd
D LIQUID W*STE BUILDING (INCUMNG UWJE^DUND TANKS)
SOLD HOUSE
(SOUS WASTE BUILDING
) WEIAL KILO (AlKWE-GRIXTtC)
j ETCHING SL1LDIM3
) UAIN BULniSr. - I^U.,nE5 BASEMENT, F1R57T FLCOH.
' jecunu flow. wij ATnt
J CESIUM ION EXCHANGE HUT (ATTACHED TO MAIN BUILDhC.)
SCXC EARACE FOuKCATl'JN {WHERE DKUWS OF HEUOVEU
' RADIOACTIVE W",TE WERE PhE,'K>j5LY STORED)
£ -CLE BUILDING
)n.CLEAH HUIL^NC fTHfTI-M SLlLDINO)
LEGEND
wi»rA-tiOu's ** now
SURVEY UNIT LOCATION v)i=
SAFETY UilHT CQRPOSA.T1CN
3LOOMS8URG, COLUMBIA COUNTY,
PENNSYLVANIA
@
~
nn
~
11
FIGURE 3: SURVEY UNITS
C-5
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LEGEND
O
PROPOSED LIMITS OF EXCAVATION
LAGOON BOUNDARY
Rl SOIL SAMPLE LOCATION
ABANDON ED CANAL
100 YEAR FLOOD PLAJN
SCALE IN FEET
TETRATECH
EXTENT OF SOIL REMOVAL
SURVEY UNIT 12 - '.VEST DUMP
SAFETY LIGHT CORPORATION
BLOOMSBURG, COLUMBIA COUNTY,
PENNSYLVANIA
112G01039GM02.dwg
FIGURE SUU2EF:
FIGURE 4-
-LE
TE
REV OATE
2/23»'16
FIGURE 4: WEST DUMP SOIL SAMPLE LOCATIONS/APPROXIMATE EXCAVATION LIMITS
C-6
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:
:
:
r
;
:
|
It
WL-05
o
LEGEND
O PROPOSE D LIMITS OF EXCAVATION
LAGOON BOUNDARY
• Rl SOI L SAMPLE LOCATION
O REMOVAL SAMPLE LOCATION
ABANDONED CANAL
100 YEAR FLOOD PLAIN
TETRATECH
EXTENT OF SOIL REMOVAL
SURVEY UNIT 13 - WEST LAGOON
SAFETY LIGHT CORPORATION
BLOOMSBURG, COLUMBIA COUNTY,
PENNSYLVANIA
112G01039GM02.dwg
¦:±LE
• TE :
FIGURE 4-2
PATE
2j"23,'16
FIGURE 5: WEST LAGOON SOIL SAMPLE LOCATIONS/APPROXIMATE EXCAVATION LIMITS
C-7
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WEST LAGOON
EAST LAGOON
LEGEND
O
o
o
PROPOSED LIMITS OF EXCAVATION
LAGOON BOUNDARY
Rl SOIL SAMPLE LOCATION
REMOVAL SAMPLE LOCATION
ABANDONED CANAL
1QD YEAR FLOOD PLAIN
SCALE IN FEET
TETRATECH
EXTENT OF SOIL REMOVAL
SURVEY UNIT 14 - EAST DUMP
SAFETY LIGHT CORPORATION
BLOOMSBURG, COLUMBIA COUNTY,
PENNSYLVANIA
112G01Q39GMO2.dwg
n J RE 'I ' :E
FIGURE 4-3
SOLE
AS NOTE":
DATE
2/21'16
FIGURE 6: EAST DUMP SOIL SAMPLE LOCATIONS/APPROXIMATE EXCAVATION LIMITS
C-8
AR301657
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/ SL«17
Fl-t2
o
EL-11
o
EL-00
O
EL-13
o
EL-14.
9
SS-SU15-5
V
El.*35
0
\
CL-04
o
S=ALEI>4F=ET
0 55-SU15-12
Ct,|5 35-5U15-11-0 •
o
EL-ID
O
ELMJ7
o
Fl -09
o
EL-IB O
hi -OH
o
EL-OJ
O
/
Oel-oi
/
EL.1B
O
EL«I9
o
LEGEND
o
PROPOSED LIMITS OF EXCAVATION
LAGOON BOUNDARY
9 Rl SOI L SAMPLE LOCATION
O REMOVAL SAMPLE LOCATION
ABANDONED CANAL
1QQ YEAR FLOOD PLAIN
TETRATECH
EXTENT OF SOIL REMOVAL
SURVEY UNIT 'b - EAST LA;:r:--l
SAFETY LIGHT CORPORATION
BLOOMSBURG, COLUMBIA COUNTY,
PEKNSYLVAMA
112G0t039GMQ2-dV»gi
FIGURE 4-4
-LI
AS NCTED
REV DATE
o 2/23>'i6
FIGURE 7: EAST LAGOON SOIL SAMPLE LOCATIONS/APPROXIMATE EXCAVATION LIMITS
C-9
AR301658
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CONCEPTUAL SITE MODEL FOR HUMAN HEALTH RISK EXPOSURE PATHWAYS
SAFETY LIGHT CORPORATION OU-3
POTENTIAL
RECEPTORS
PRIMARY SOURCE
RELEASE
MECHANISM
SECONDARY
SOURCE
EXPOSURE
MEDIUM
EXPOSURE
MECHANISM
Soil Contaminated by
Historical Site Activities
Overland Runoff
and Drainage
Pathways
Sediment -
River Bank
Dermal Contact
o
n
Ingestion
LJ
LJ
Susquehanna
River (dilution)
Dermal Contact
~
n
Incidental Ingestion
~
~
Leaching to
Groundwater via
Infiltration and
Migration via
Advection/Dispersion
Groundwater Plume
Tap Water From
Wells
Dermal Contact
*¦*
—*
Ingestion
*-k
Inhalation (Showering)
**
Subsurface
Volatilizalion
Groundwater
Discharge Within
Excavations
Dermal Contact
**
Incidental Ingestion
**
Inhalation
Soil Gas Vapors
KJ
Indoor Vapor Intrusion
Inhalation
~
n
Outdoor Ambient Air
Inhalation
¦
¦
~
¦
Surface Soil or
Combined Soil
Derral Contact
LJLJ
~O
LJLJ
Ingestion of soil
********
Inhalation (Particulates)
~J
nl
Biouptake to Plants
Homegrown Produce
Ingestion of Produce
~
¦ Indicates a receptor pathway considered for quantitative evaluation of risks
O Indicates a receptor pathway considered for qualitative instead of quantitative evaluation of risks
** Indicates a receptor pathway considered in the OU-2 Groundwater Rl Risk Assessment
FIGURE 8: CONCEPTUAL SITE MODEL
C-10
AR301659
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APPENDIX D
TABLES
D-l
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D-2
AR301661
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TABLE D-l
ACTION MEMORANDA SUMMARY
SAFETY LIGHT CORPORATION SITE
Action
Memorandum
Date
Action Memorandum Summary
Removal Action
Project Ceiling
(Cumulative)
July 12, 2004
Approved funding for a time-critical removal action to complete the characterization, packaging, and off-Site
disposal of the silo waste.
$1,955,972**
June 21, 2007
Approved a non-time critical removal action for the demolition of seven deteriorated, unused, and unmaintained
buildings at the Site, and off-Site disposal of the majority of the resultant demolition debris as radioactive waste.
$3,060,766
October 2007
Approval to provide Site physical security; maintain Site fire protection systems; maintain Site utility services; and
perform limited Site maintenance.
$3,156,766
July 11,2008
Approved additional funding to for the non-time-critical removal action to complete the demolition of the seven
buildings
$5,505,776
November 8, 2012
Approved a time critical removal action to repair the Main Building to stabilize Site conditions until the expected
remedial response action."
$6,105,776
February 20, 2013
Approved funding increase and changes in scope to take additional measures needed to facilitate repair of the Main
Building and to stabilize the Site. The additional measures included securing Butler Building, in which items
removed from the Main Building were to be stored.
$6,530,776
June 11,2013
Approved funding and authorized demolishing other deteriorating Site structures, including the Metal Silo, Liquid
Waste Building, and Solid Waste Building and securing the West Dump which had eroded.
$9,363,976
December 16, 2013
Authorized demolition of the Main Building and Butler Building, which were further deteriorating due to severe
weather events.
$12,255,175
September 26, 2014
Authorized excavation, removal and disposal of contaminated discrete buried objects, buried tanks, associated
piping, and contaminated soils
$13,705,175
June 17, 2015
Approval to continue the ongoing removal and off-site disposal of buried radioactively contaminated items and
certain other actions necessary to stabilize Site conditions pending long-term cleanup activities by the Remedial
Program
$15,932,375
September 30, 2015
Approval to continue excavation, removal and disposal of contaminated discrete buried objects, buried tanks,
associated piping, and contaminated soils including the West Lagoon and further assessment of the East Dump, and
East Lagoon.
$18,914,791
February 1, 2016
Approval to continue excavation, removal and disposal of contaminated discrete buried objects, buried tanks,
associated piping, and contaminated soils including the West Lagoon, East Dump, and East Lagoon.
$18,914,791
Notes:
** Removal Action Project Ceiling Costs for July 12,2004 Action Memo are not included in cumulative costs
Action Memoranda may be found in the Administrative Record
Further information regarding all the EPA removal actions may also be found at www.epaosc.org
D-3
AR301662
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TABLE D-2
SOIL SCREENING LEVELS**
SURVEY UNITS 12,13,14 AND 15
SAFETY LIGHT CORPORATION OU-3
Chemical'1'
Target Cancer Risk Level'2'
Target Hazard
Index'2'
Background'3'
Selected Soil Screening
Level '7| 8'
Comments
10"6
10"5
10"4
0.1
Semivolatile Organic Compounds (ug/kg)
Benzo(a)anthracene
160
1,600
16,000
NA
22.1
160
Survey Units 12, 13, 14 and 15
Benzo(a)pyrene
16
160
1,600
NA
NA
16
Survey Units 12, 13, 14 and 15
Benzo(b)fluoranthene
160
1,600
16,000
NA
NA
160
Survey Units 12, 13, 14 and 15
Benzo(k)fluoranthene
1,600
16,000
160,000
NA
NA
1,600
Survey Unit 15
Dibenzo(a,h)anthracene
16
160
1,600
NA
ND
16
Survey Units 12, 13, 14 and 15
lndeno(1,2,3-cd)pyrene
160
1,600
16,000
NA
ND
160
Survey Units 13, 14 and 15
Pesticides/PCBs (|jg/kg)
alpha-BHC
86
860
8,600
51,000
NA
86
Survey Unit 13
Aroclor-1254
240
2,400
24,000
120
NA
120
Survey Units 12, 13 and 15
Aroclor-1260
240
2,400
24,000
NA
NA
240
Survey Units 12, 13
Aroclor-1268
240
2,400
24,000
NA
NA
240
Survey Unit 12
Metals (mg/kg)
Aluminum
NA
NA
NA
7,700
8,770
8,770
Survey Units 14
Antimony
NA
NA
NA
3.1
NA
3.1
Survey Units 12 and 13
Arsenic
0.68
6.8
68
3.5
7.91
7.91
Survey Units 13, 14 and 15
Cadmium
2,100
21,000
210,000
7.1
0.24
7.1
Survey Units 12, 13 and 15
Chromium'4'
0.30
3
30
23
10.5
10.5
Survey Units 12, 13, 14 and 15
Cobalt
420
4,200
42,000
2.3
8.99
8.99
Survey Units 13
Copper
NA
NA
NA
310
33.4
310
Survey Units 12, 13 and 15
Iron
NA
NA
NA
5,500
16,700
16,700
Survey Units 12, 13, and 15
Lead
400 (6)
25.9
400
Survey Unit 13
Mercury
NA
NA
NA
2.3
0.039
2.3
Survey Unit 13
Silver
NA
NA
NA
39
NA
39
Survey Units 12, 13 and 15
Thallium
NA
NA
NA
0.078
0.77
0.77
Survey Unit 13, 14 and 15
Vanadium
NA
NA
NA
39
12.8
39
Survey Unit 15
D-4
AR301663
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Chemical'1'
Target Cancer Risk Level'2'
Target Hazard
Index'2'
Background'3'
Selected Soil Screening
Level '7| 8'
Comments
10-6
10"5
10"4
0.1
Miscellaneous Parameter (mg/kg)
Cyanide
NA
NA
NA
0.27
NA
0.27
Survey Unit 13
Radionuclides (pCi/g)
Americium-241 (Am-241)
0.049
0.49
4.9
NA
NA
0.049
Survey Units 12, 13, 14 and 15
Cesium-137 (Cs-137)(9)
0.047
0.47
4.7
NA
0.431
0.431
Survey Units 12, 13, 14 and 15
Lead-210 (Pb-210)
0.0077
0.077
0.77
NA
1.64
1.64
Survey Units 12, 13, 14 and 15
Neptunium-237 (Np-237)(5)
0.046
0.46
4.6
NA
0.13
0.13
Survey Units 12, 13, and 15
Nickel-63 (Ni-63)
6.7
67
670
NA
NA
6.7
Survey Units 15
Radium-226 (Ra-226)(5»
0.0064
0.064
0.64
NA
1.52
1.52
Survey Units 12, 13, 14 and 15
Strontium-90 (Sr-90)(5)
0.066
0.66
6.6
NA
0.604
0.604
Survey Units 12, 13, 14 and 15
Thallium-204 (TI-204)
2.1
21
210
NA
0.356
2.1
Survey Unit 14
Tritium (H3)
0.23
2.3
23
NA
3.78
3.78
Survey Units 12, 13, 14 and 15
" Soil Screening Levels (SSLs) were used for determining the area of concern for soil remediation in the West Dump, West Lagoon, East Dump, and East Lagoon areas of the Site.
Notes:
1 - A chemical was retained as a chemical of concern (COC) if the total ILCR for a medium exceeded 1x10 4 and the chemical specific ILCR exceeded 1x10-6 or if the total HI on a target organ basis
exceeded 0.5 and the chemical specific HI exceeded 0.1.
2 - The Soil Screening Levels (SSLs) for nonradionuclides were calculated using USEPA's Regional Screening Level calculator and default exposure assumptions. The noncarcinogenic values
correspond to a target hazard quotient of 0.1. The SSLs for radionuclides were calculated using USEPA's Preliminary Remediation Goals for Radionuclides calculator and default exposure assumptions.
3 - The 95 percent upper tolerance limit (UTL) from the risk assessment in the 2014 Rl is presented for all nonradionuclides. For all radionuclides except radium-226 the 95 percent upper prediction limit
(UPL) calculated using the data from the 2008 Rl is presented. For radium-226 the upper 95 percent UPL from the 2015 Army Corp of Engineering dataset is presented. Actinium-227, cobalt-60,
thallium-204, cesium-137, and stronium-90 concentrations were decay corrected.
4 - Values are for hexavalent chromium.
5 - Includes daughter products
6 - RSL User guide on lead for EPA Regional Screening Level (RSL)
7 - Lowest concentration of target cancer level at 1 X 10 6or hazard index of 0.1 or background if greater than most conservative risk screening level
8 - Screening level based on EPA PRG calculator for radionuclides set at a target cancer level of 1.0E-06
NA - Not applicable/not available.
ND - Not detected
D-5
AR301664
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TABLE D-3
WEST DUMP
SURVEY AND SAMPLE RESULTS
WEST DUMP
Laboratory Results
(pci/g)
Field Readings
Sample
Location
Sample ID
Pb-210
Ra-226
Sr-90
Tl-204
(ccpm)
Biased Sample
#1
SS-SU12-1-
000.5
3.19
1.71
1.7
232175
SS-SU12-1-
0.52.0
0.720
19.1
2.9
Biased Sample
#2
SS-SU12-8-
000.5
59.5
174
0.946
1
460059
SS-SU12-8-
0.52.0
163
617
3.92
isa
Biased Sample
#3
SS-SU12-17-
000.5
7.6
3.66
444
3.3
473939
SS-SU12-17-
0.52.0
12.0
4.67
2.6
Biased Sample
#4
SS-SU12-19-
000.5
20.8
292
0.521
22.9
337551
SS-SU12-19-
0.52.0
22.3
94.0
0.625
0.7
SB-SU12-19-
0304
54.4
88.9
4t36
4.5
Biased Sample
#5
SS-SU12-22-
000.5
2.52
2.07
0.156
44
1090439
SS-SU12-22-
0.52.0
0.496
0.873
0464
1.1
* Values in bold print indicate activity' above screening criteria. Values with strikethroughs indicate invalid data.
D-6
AR301665
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TABLE D-4
WEST LAGOON
SURVEY AND SAMPLE RESULTS
WEST LAGOON
Laboratory Results
(pci/g)
Field Readings
Sample
Location
Sample ID
Depth
(Ft.)
H-3
Np-237
Pb-210
Ra-226
U-238
(ccpm)
Biased Sample
#1
SS-SU13-1-
000.5
0-0.5
10.4
0.45
329
652
0.450
2 mrem/hr (a).
contact
SS-SU13-1-
0.52.0
o
I*
O
o
5.8
0.262
36.5
2,390
0.632
Biased Sample
#2
SS-SU13-2-
000.5
0-0.5
120
0.075
37.1
163
0.606
23,225
SS-SU13-2-
0.52.0
o
O
o
8.4
0.072
10.4
87.9
0.442
Biased Sample
#3
SS-SU13-3-
000.5
0-0.5
38.7
0.039
22.5
105
0.534
68,772
SS-SU13-3-
0.52.0
o
O
o
12.6
0.309
49.8
579
0.435
Biased Sample
#4
SS-SU13-4-
000.5
0-0.5
55.2
0.062
3.34
57.7
0.974
45,915
SS-SU13-4-
0.52.0
o
O
o
8.8
ND
2.05
34.4
0.505
Biased Sample
#5
SS-SU13-5-
000.5
0-0.5
141
ND
6.28
19.2
0.421
32,510
SS-SU13-5-
0.52.0
0.5 to
2.0
277
0.055
6.41
32.5
0.386
Note: Bold Values > Screening Level per EPA PRG Calculator
D-7
AR301666
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TABLE D-5
EAST DUMP
SURVEY AND SAMPLE RESULTS
EAST DUMP
Laboratory Results
(pci/g)
Field Reading
(ccpm)
Sample
Location
Sample ID
Depth (Ft.)
H-3
Np-237
Pb-210
Ra-226
U-238
Biased Sample
#1
SS-SU14-4-000.5
0-0.5
1.6
0.011
2.19
4.23
0.926
19,632
SS-SU14-4-0.52.0
0.5 to 2.0
0.469
0.016
2.33
14.2
0.469
SB-SU14-4-1012
10 to 12
0.720
0.313
203
273
0.720
Biased Sample
#2
SS-SU14-5-000.5
0-0.5
0.926
0.006
1.48
1.87
0.926
16,576
SS-SU14-5-0.52.0
0.5 to 2.0
0.635
0.006
1.44
0.571
0.635
SB-SU14-5-1012
10 to 12
0.598
0.075
169
220
0.598
Biased Sample
#3
SS-SU14-9-000.5
0-0.5
0.629
0.011
2.65
3.84
0.629
25,438
SS-SU14-9-0.52.0
0.5 to 2.0
0.939
0.015
1.23
0.914
0.939
SB-SU14-9-1012
10 to 12
ND
0.011
14.3
185
1.17
Biased Sample
#4
SS-SU14-10-000.5
0-0.5
1.8
0.011
3.08
4.63
0.570
16,395
SS-SU14-10-0.52.0
0.5 to 2.0
3.0
0.008
1.47
0.264
0.679
SB-SU14-10-0812
8 to 12
3.8
0.066
234
189
0.744
Biased Sample
#5
SS-SU14-15-000.5
0-0.5
3.9
0.012
1.39
1.55
1.04
19,472
SS-SU14-15-0.52.0
0.5 to 2.0
2.9
0.010
0.653
0.813
1.08
SB-SU14-15-1012
10 to 12
3.8
0.009
3.43
4.96
0.993
Note: Bold Values > Screening Level per EPA PRG Calculator
D-8
AR301667
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TABLE D-6
EAST LAGOON
SURVEY AND SAMPLE RESULTS
EAST LAGOON
Laboratory Results
(pCi/g)
Field
Reading
Sample
Location
Sample ID
Depth
(Ft.)
Cs-137
H-3
Np-237
Pb-210
Ra-226
U-238
(ccpm)
Biased
Sample #1
SS-SU15-4-000.5
0-0.5
0.478
ND
ND
1.79
0.623
0.699
57,890
SS-SU15-4-
0.52.0
0.5 to 2.0
1.93
6.5
ND
2.30
10.5
0.716
SB-SU15-4-0911
9.0 to 11.0
1.04
4.4
ND
1.37
2.24
0.841
Biased
Sample #2
SS-SU15-5-000.5
0-0.5
0.639
0.657
ND
7.19
3.17
0.657
48,260
SS-SU15-5-
0.52.0
0.5 to 2.0
5.22
0.621
0.011
53.9
5.88 (R)
0.621
Biased
Sample #3
SS-SU15-11-
000.5
0-0.5
18.7
0.852
0.012
28.6
30.6
0.852
92,597
SS-SU15-11-
0.52.0
0.5 to 2.0
26.6
45.1
0.171
41.2
61.1
0.737
Biased
Sample #4
SS-SU15-12-
000.5
0-0.5
0.678
6.4
0.049
2.68
6.34
0.443
40,132
SS-SU15-12-
0.52.0
0.5 to 2.0
1.01
9.2
0.064
1.93
6.23
0.587
Biased
Sample #5
SS-SU15-15-
000.5
0-0.5
0.307
3.2
0.013
2.32
1.23 (R)
0.509
24,830
SS-SU15-15-
0.52.0
0.5 to 2.0
0.148
8.1
0.013
1.82
0.502
(R)
0.574
Notes: 1. Bold Values > Screening Level per EPA PRG Calculator.
2. (R) Data rejected during validation
D-9
AR301668
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TABLE D-7
WEST LAGOON
MERL SOIL SAMPLING RESULTS
MERL Soil Results - West Lagoon
(pCi/g)
Boring
Depth
Ra-226
Np-237
Pb-210
Ac-227
Cs-137
Kr-85
Co-60
Am-241
WL-01
0-4'
-
-
-
-
-
-
-
-
8-12'
-
-
-
-
-
-
-
-
WL-02
0-4'
-
0.7401
-
-
-
-
-
-
4-8'
-
-
-
-
-
-
-
-
WL-03
0-4'
1.782
-
-
-
-
-
-
-
8-12'
-
-
-
-
-
-
-
-
WL-04
0-4'
-
-
-
-
-
-
-
-
4-8'
-
-
-
-
-
-
-
-
WL-05
0-4'
-
-
-
-
-
-
-
-
4-8'
-
-
-
-
-
-
-
-
0-4'
-
-
-
-
-
-
-
-
WL-06
8-12'
18.2
-
20.53
-
-
-
-
-
8-12'
15.3
-
-
-
-
-
-
-
WL-07
4-8'
-
-
-
-
-
-
-
-
8-12'
-
-
-
-
-
-
-
-
WL-08
4-8'
-
-
-
-
-
-
-
-
WL-09
0-4'
-
-
2.137
-
-
-
-
-
4-8'
3.43
-
-
-
-
-
-
-
WL-10
0-4'
5.797
-
-
-
-
-
-
-
4-8'
4.906
-
10.16
-
-
-
-
-
WL-11
0-4'
9.69
-
-
-
-
-
-
-
4-8'
6.069
-
5.904
0.1367
-
-
-
-
WL-12
0-4'
5.442
0.2416
-
-
-
-
-
-
4-8'
2.144
-
5.169
-
-
-
-
-
WL-13
0-4'
16.27
-
-
-
-
-
-
-
4-8'
2.431
-
9.082
-
-
-
-
-
WL-14
0-4'
14.75
-
13.47
-
0.4861
-
-
-
4-8'
-
-
-
-
-
-
-
-
WL-15
0-4'
4.216
-
-
-
0.1235
-
-
-
4-8'
-
-
-
-
-
-
-
-
WL-16
0-4'
12.03
-
10.99
-
-
-
-
-
4-8'
-
-
-
-
-
-
-
-
WL-17
0-4'
11.82
-
8.029
-
0.3212
-
-
-
4-8'
4.618
-
-
-
-
-
-
-
D-10
AR301669
-------
MERL Soil Results - West Lagoon
(pCi/g)
WL-18
0-4'
12.76
-
-
-
0.1702
-
-
-
4-8'
-
-
6.984
-
-
-
-
-
WL-19
0-4'
36.08
-
38.62
-
0.5839
-
-
-
4-8'
-
-
105.3
-
-
-
-
-
WL-20
0-4'
181
-
193.6
-
-
-
-
16.93
WL-21
0-3"
18.94
-
25.79
-
0.2832
-
-
-
WL-22
0-3"
43.22
-
63.13
-
1.037
-
-
0.777
Results not validated
— Reported result was less than the minimum detectable activity.
WL-19 0-4' and WL-20 0-4' samples sent to NAREL for analysis.
Two depth intervals were selected from each boring to be sampled based on in-situ screening levels.
Abbreviations:
WL - West Lagoon
D-ll
AR301670
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TABLE D-8
EAST DUMP
MERL SOIL SAMPLING RESULTS
MERL Soil Results - East Dump
(pCi/g)
Boring
Depth
Ra-226
Np-237
Pb-210
Ac-227
Cs-137
Kr-85
Co-60
Am-241
ED-01
i
o
7.386
~
7.494
~
--
~
~
~
8-12'
116
~
46.34
--
~
~
~
0.9776
ED-02
I
o
2.407
~
2.06
~
~
~
~
--
8-12'
285.1
--
262.2
~
~
~
--
~
ED-03
I
o
~
~
--
~
0.08105
~
~
~
8-12'
122.6
15.21
122.1
~
--
~
~
1.537
ED-04
00
i
889.2
544
844.5
--
~
~
~
7.36
8-12'
53.16
~
59.74
~
~
~
~
--
12-16'
85.57
--
68.96
~
~
~
--
~
ED-05
I
o
--
~
--
~
0.2357
--
~
~
00
1
-i-
5.848
~
8.972
~
0.1627
~
~
~
ED-06
rt"
1
o
~
~
~
--
0.2944
~
~
~
8-12'
12.96
~
14.68
~
--
~
~
--
ED-07
1
o
2.365
--
2.48
~
0.1466
~
--
~
00
1
-i-
--
~
--
~
0.3064
--
~
~
Data is not validated.
— Reported result was less than the minimum detectable activity.
ED-02 8-12' and ED-04 4-8' samples sent to NAREL for analysis.
Two depth intervals were selected from each boring to be sampled based on in-situ screening levels.
Abbreviations:
ED - East Dump
D-12
AR301671
-------
TABLE D-9
EAST LAGOON
MERL SOIL SAMPLING RESULTS
MERL Soil Results - East Lagoon
(pCi/g)
Boring
Depth
Ra-226
Np-237
Pb-210
Ac-227
Cs-137
Kr-85
Co-60
Am-241
EL-01
4-8'
29.04
-
37.1
-
7.227
-
-
-
EL-02
4-8'
124.5
-
-
-
18.35
-
-
-
8-12'
73.69
-
71.42
-
2.828
-
-
-
EL-03
8-12'
44.83
-
55.06
-
6.013
-
-
-
12-16'
60.32
-
57.49
-
12.5
-
-
-
EL-04
4-6'
13.44
-
17.2
0.1271
1.049
-
-
6.577
EL-05
0-4'
37.39
-
-
-
7.637
-
-
7.124
8-12'
-
-
5.387
-
1.464
-
-
-
EL-06
0-4'
-
-
9.818
-
1.2
-
-
32.73
4-8'
-
-
-
-
0.1182
-
-
0.498
EL-07
0-4'
257.3
-
374.6
-
8.937
-
-
5.955
4-8'
16.33
-
18.66
-
2.521
-
-
-
EL-08
0-4'
236.7
-
244.4
-
75.03
-
-
4.729
4-8'
-
-
-
-
0.1865
-
-
-
EL-09
0-4'
4.172
-
-
-
-
-
-
-
4-8'
-
-
-
-
2.261
-
-
-
EL-10
0-4'
476.4
-
561.3
-
11.29
-
-
-
4-8'
-
-
-
-
-
-
-
-
EL-11
0-4'
730.4
-
402.2
-
6.041
-
-
-
4-8'
76.05
-
77.76
-
1.645
-
-
-
EL-12
0-4'
932.8
5.48
539
-
111.2
-
-
8.071
4-8'
415.2
-
316.6
-
113.3
-
-
4.649
EL-13
0-4'
192.2
1.044
85.98
-
9.978
-
-
3.664
4-8'
35.91
-
35.34
-
1.144
-
-
-
EL-14
0-4'
3,120
3,366
8.853
5.504
3,016
2,905
-
12.59
12.57
-
-
15.54
0-4'
2253
-
1336
-
8.574
-
-
-
8-12'
31.58
-
23.84
-
0.4073
-
-
-
EL-15
0-4'
79.67
-
91.81
-
17.34
-
-
2.201
8-12'
6.265
-
5.356
-
0.882
-
-
-
EL-16
0-4'
100.2
-
72.4
-
28.1
-
-
-
8-12'
6.377
-
5.384
-
1.301
-
-
-
EL-17
8-12'
86.64
-
-
-
0.4299
-
-
0.9261
12-16'
13.79
-
11.39
-
0.1349
-
-
-
EL-18
0-4'
-
-
-
-
0.09325
-
-
-
D-13
AR301672
-------
MERL Soil Results - East Lagoon
(pCi/g)
4-8'
-
-
-
-
-
-
-
-
EL-19
0-4'
-
-
-
-
0.1214
-
-
-
4-8'
-
-
-
-
-
-
-
-
East Lagoon
325 L
-
344 L
-
39.66 L
-
-
3.895 L
Data is not validated.
— Reported result was less than the minimum detectable activity.
L Activity calculated utilizing manufacturers software to model the sample geometry coupled with a manufacturer
provided detector characterization.
EL-08 0-4', EL-11 0-4', EL-12 0-4, EL-12 4-8', EL-14 0-4', and EL-16 0-4' samples sent to NAREL for analysis.
Two sample jars were analyzed for sample EL-14 0-4'.
Two depth intervals were selected from each boring to be sampled based on in-situ screening levels.
Abbreviations:
EL - East Lagoon
D-14
AR301673
-------
TABLE D-10
SUMMARY OF CHEMICALS OF POTENTIAL CONCERN (COPCs)
ABOVE BACKGROUND
RESIDENTIAL EXPOSURES TO ALL SOIL - SURVEY UNITS 12,13,14 AND 15
COPC
West Dump
(SU-12)
West Lagoon
(SU-13)
East Dump
(SU-14)
East Lagoon
(SU-15)
Semivolatile Organic Compounds (jig/kg)
Benzo(a)anthracene
X
X
X
X
Benzo(a)pyrene
X
X
X
X
Benzo(b)fluoranthene
X
X
X
X
Benzo(k)fluoranthene
X
Dibenzo(a,h)anthracene
X
X
X
X
Indeno( 1,2,3 -cd)pyrene
X
X
X
Pesticides/PCBs (jig/kg)
alpha-BHC
X
Aroclor-1254
X
X
X
Aroclor-1260
X
X
Aroclor-1268
X
Metals (mg/kg)
Aluminum
X
Antimony
X
Arsenic
X
X
X
X
Cadmium
X
X
X
Chromium
X
X
X
X
Cobalt
X
Copper
X
X
X
Iron
X
X
X
Lead
X
Mercury
X
Silver
X
X
X
Thallium
X
X
Vanadium
X
Miscellaneous Parameter (mg/kg)
Cyanide
X
D-15
AR301674
-------
TABLE D-10 -Continued
SUMMARY OF CHEMICALS OF POTENTIAL CONCERN (COPCs)
ABOVE BACKGROUND
RESIDENTIAL EXPOSURES TO ALL SOIL - SURVEY UNITS 12,13,14 AND 15
COPC
West Dump
(SU-12)
West Lagoon
(SU-13)
East Dump
(SU-14)
East Lagoon
(SU-15)
Radionuclides (pCi/g)
Americium-241 (Am-241)
X
X
X
X
Cesium-137 (Cs-137)
X
X
X
X
Lead-210 (Pb-210)
X
X
X
X
Neptunium-23 7 (Np-237)
X
X
X
Nickel-63 (Ni-63)
X
Radium-226 (Ra-226)
X
X
X
X
Strontium-90 (Sr-90)
X
X
X
X
Thallium-204 (Tl-204)
X
Tritium (H3)
X
X
X
X
These contaminants (with the exception of aluminum, iron, and vanadium) are hazardous
substances designated at 40 C.F.R. §302.4.
D-16
AR301675
-------
TABLE D-ll
SUMMARY OF CANCER RISKS AND HAZARD INDICES
SAFETY LIGHT CORPORATION OU-3
Exposure
Unit
Estimated Risks
Surface Soil
All Soil
All COPCs
Site Related
COPCs
Site Related
COPCs Above
Background
All COPCs
Site Related
COPCs
Site Related
COPCs Above
Background
Survey Unit 12
West Dump
Cancer Risks
No subsurface samples collected
Nonradionuclides
5E-04
5E-04
5E-04
Radionuclides
8E-02
8E-02
8E-02
Total
8E-02
8E-02
8E-02
Hazard Indices
Total
7
7
6
Survey Unit 13
West Lagoon
Cancer Risks
No subsurface samples collected
Nonradionuclides
2E-02
2E-02
2E-02
Radionuclides
2E-01
2E-01
2E-01
Total
2E-01
2E-01
2E-01
Hazard Indices
Total
53
53
53
Survey Unit 14
East Dump
Cancer Risks
Nonradionuclides
6E-04
6E-04
6E-04
6E-04
6E-04
6E-04
Radionuclides
1E-03
1E-03
1E-03
6E-02
6E-02
6E-02
Total
2E-03
2E-03
2E-03
6E-02
6E-02
6E-02
Hazard Indices
Total
2
2
Id,
3
3
Id,
Survey Unit 15
East Lagoon
Cancer Risks
Nonradionuclides
3E-03
3E-03
3E-03
2E-03
2E-03
2E-03
Radionuclides
2E-02
2E-02
2E-02
2E-02
2E-02
2E-02
Total
2E-02
2E-02
2E-02
2E-02
2E-02
2E-02
Hazard Indices
Total
9
9
9
11
11
11
Notes:
1 - Target organs hazard index are less than or equal to 0.5.
D-17
AR301676
-------
APPENDIX E
RISK RATIO TABLES
E-l
AR301677
-------
This page intentionally left blank.
E-2
AR301678
-------
TABLE E-l
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR All COPCs
RESIDENTIAL EXPOSURES TO ALL SOIL - SURVEY UMHT12
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient {HQ)
Exposure Point
Concentration1"
Residential
Screening
Level421
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level®'
Estimated
HQ
Semi volatile Organic Compounds (ug'kgl
Benzfa (anthracene
367
160
2E-06
Cancer
NA
NA
8enzo(a)pyrene
279
16
2E-05
Cancer
NA
NA
Benzo(b)fluoranfriene
369
160
2E-06
Cancer
NA
NA
Dibenz(a,h)anthracene
98
16
6E-06
Cancer
NA
NA
Indenofl ,2,3-cd)pyrene
205
160
1E-06
Cancer
NA
NA
Pesticides.'PCBs (ug/kg)
Arocior-1254
4.400
240
2E-05
Immune System, Dermal, Ooukar
1,200
4
Aroctor-1260
750
240
3E-06
Cancer
MA
NA
Aroctor-1268'3:
95D
240
4E-Q6
Cancer
NA
NA
Metals (mp.'kg)
Antimony
8.6
NA
NA
Hematologic
31
0.3
Arsenic
6.55
0.68
1E-05
Cardiovascular System, Dermal
35
0.2
Cadmium
72.2
2,100
3E-08
Urinary
71
1
Chromium"-
133
0.30
4E-04
None Specified
230
0.6
Cobalt
6.83
420
2E-08
Thyroid
23
0.3
Copper
770
NA
NA
Gastrointestinal System
3,100
0.2
Iron
24,200
NA
NA
Gastrointestinal System
55.000
0.4
Manganese
650
NA
NA
Nervous System
1.80D
0.4
Stiver
64.8
NA
NA
Dermal
390
0.2
Radionuclides (pCi/g)
Actiniurn-227 (Ac-227)
0.0431
0.039
1E-06
Cancer
NA
NA
Americium-241 fAm-241)
15.7
0.049
3E-04
Cancer
NA
MA
Cesium-137 (Cs-137),;s>
1.98
0.047
4E-05
Cancer
NA
MA
Lead-210 (Pb-210)
105
0.0077
1E-02
Cancer
NA
MA
Polonium-210
425
0.0064
7E-02
Cancer
NA
NA
Strontium-90 (Sr-90)lSl
2.22
0.066
3E-05
Cancer
NA
NA
Tritium (H3)
46.5
0.23
2E-04
Cancer
NA
MA
Urantum-238 (U-238)®
1.3
0.05
3E-05
Cancer
MA
NA
Uranrum-234 (U-234)m
1.3
0.066
2E-05
Cancer
NA
NA
Thorium-234 (Th-234)l5>7:
1.3
44
3E-08
Cancer
NA
MA
Total ILCR - Chemicals
5E-04
Total HI
7
Total ILCR - Radionuclides
8E-02
Total ILCR - Chemicals + Radionuclides
8E-02
Target Organ HIs^
Total Immune System HI =
Total Dermal HI =
Total Ocular HI =
Total Hematologic HI =
Total Cardiovascular System HI =
Total Urinary HI =
Total Norte Specified HI =
Total Thyroid HI =
Total Gastrointestinal System HI =
Total Nervous System HI =
Notes:
1 - Exposure point concentration is tfie 95% upper confidence limit calculated by ProUCL Version 5.0.00.
2 - For rton-radionuclides screening levels are U5EPA RSLs for Chemical Contaminants at Superfund Sites, November 2015. The noncarcinogenic values
correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of 1x10"^
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TR=1x10^) November 2014.
3 - Screening level is for Aroclor-1260.
4 - Screening levels are for hexavalent chromium.
5 - Screening level includes daughter products.
6 - Polonium-210 is assumed to be in equilibrium with Pb-210.
7 - Uranium-234 and Thorium-234 are assumed to be in equilibrium with U-238.
NA - Not applicable. There is no can cer slope factor (CSF) or reference dose (RfD) available for this chemical.
E-3
AR301679
-------
TABLE E-2
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR SITE RELA TED COPCs
RESIDENTIAL EXPOSURES TO ALL SOIL - SURVEY UNIT 12
SAFETY LIGHT CORPORATION OU-3
Chemical
Increimentai Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration11'
Residential
Screening
Level"1
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level®
Estimated
HQ
Semivolatile Organic Compounds (ug^g)
Benz(a Anthracene
367
160
2E-06
Cancer
NA
NA
Benzo(a)pyrene
279
16
2E-05
Cancer
NA
NA.
Benzo(b)fluoranihene
369
160
2E-06
Cancer
NA
NA
Dibenz(arh)anthfacene
98
16
6E-06
Cancer
NA
NA
lndeno(1,2,3-cd)pyrene
205
160
1E-06
Cancer
NA
NA
Pesticides/PCBs (u&'kai
Arodor-1254
4,400
240
2E-05
Immune System. Dermal, Ocular
1,200
4
Aroctor-1260
750
240
3E-06
Cancer
NA
NA
Arocior-1266'3
950
240
4E-Q6
Cancer
NA
NA
Metals (mg.'kg)
Antimony
8.6
NA
NA
Hematotogic
31
0.3
Arsenic
6.55
0.68
1E-05
Cardiovascular System, Dermal
35
0.2
Cadmium
72.2
2,100
3E-08
Urinary
71
1
Chromium"1
133
0.30
4E-04
None Specified
230
0.6
Cobalt
6.83
420
2E-08
Thyroid
23
0.3
Copper
770
NA
NA
Gastrointestinal System
3.100
0.2
Iron
24,200
NA
NA
Gastrointestinal System
55,000
0.4
Manganese
650
NA
NA
Nervous System
1,800
0.4
Silver
64.8
NA
NA
Dermal
390
0.2
Radionuclides (pCii'g)
Actinium-227 (Ac-227)
0.0431
0.039
1E-06
Cancer
NA
NA
Americium-241 (Am-241)i
15.7
0.049
3E-04
Cancer
NA
NA
Cesium-137 (Cs-137) 5
1.98
0.047
4E-05
Cancer
NA
NA
Lead-210 (Pb-210)
105
0.0077
1E-02
Cancer
NA
NA
Polonium-210 (Po-210)'6'
105
0.14
8E-04
Cancer
NA
NA
Neptunium-237 (Np-237)'5
0.12
0.046
3E-06
Cancer
NA
NA
Nickel-63 (Ni-63)
6.12
6.7
9E-07
Cancer
NA
NA
Radium-226 (Fta-226)':E:
425
0.0064
7E-Q2
Cancer
NA
NA
Strontiunv90 (Sr-90)1"'
2.22
0.066
3E-05
Cancer
NA
NA
Tritium (H3)
46.5
0.23
2E-04
Cancer
NA
NA
Uranium-238 (U-23B)'5'
--
0.05
--
Cancer
NA
NA
Uranium-234 (U-234)'Tl
--
0.066
--
Cancer
NA
--
Thorium-234 {Th-234)'"'"
--
44
--
Cancer
NA
--
Total ILCI
3 - Ctemicals
5E-04
Total HI
7
Total ILCR - Radionuclides
8E-02
Total ILCR - Chemicals + Radionuclides
8E-02
Target Organ Hl^
Total Immune System HI =
Total Dermal HI =
Total Ocular HI =
Total Hematologic HI =
Total Cardiovascular System HI =
Total Urinary HI =
Total Norse Specified HI =
Total Thyroid HI =
Total Gastrointestinal System HI =
Total Nervous System HI =
Notes:
1 - Exposure point concentration is the 95% upper confidence limit calculated by ProUCL Version 5.0.00.
2 - For non-radionucfides screening levels are USEPA RSLs for Chemical Contaminants at Superfund Sites, November 2015. The noncarcinogenic values
correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of 1x10"®
For radionuclides screening levels are from the Radionuclide Preim'jnary Remediation Goals (PRG) Summary Table (TTMxIO"*) November 2014,
3 - Screening level is for Arocfor-1260.
4 - Screening levels are for hexavalent chromium.
5 - Screening level includes daughter products.
6 - Polonium-210 is assumed to be in equilibrium with Pb-210.
7 - Uranium-234 and Thortum-234 are assumed to be in equilibrium with U-238.
NA - Not applicable. There is no can cer slope factor (CSF) or reference dose (FtfD) available for this chemical.
E-4
AR301680
-------
TABLE E-3
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR SITE RELATED COPCs ABOVE BACKGROUND
RESIDENTIAL EXPOSURES TO ALL SOIL - SURVEY UNIT 12
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration121
Residential
Screening
Level**1
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level®
Estimated
HQ
Semivolatile Organic Compounds jug/kg)
Benzfaianthracene
367
160
2E-06
Career
NA
NA
Benzo(a}pyrene
279
16
2E-05
Career
NA
NA
Benzo(b)fluoranthene
369
160
2E-06
Career
NA
NA
Dibenz(a h)antftracene
98
16
6E-06
Career
NA
NA
lndeno(1,2,3-cdjpyrene
205
160
1E-06
Career
NA
NA
Pesticides.'PCBs (ug.'kg)
Aroclor-1254
4,400
240
2E-05
Immune System. Dermal, Ocular
1.200
4
Arodor-1260
750
240
3E-06
Career
NA
NA
Aroc!or-126B':i:
950
240
4E-06
Career
NA
NA
Metals (mg/kgj
Antimony
8.6
NA
NA
Hematologic
31
0.3
Arsenic
--
0.68
--
Cardiovascular System, Demial
35
--
Cadmium
72.2
2,100
3E-08
Urirary
71
1
Chromium'5*
133
0.30
4E-04
None Specified
230
0.6
Cobalt
--
420
--
Thynoid
23
--
Copper
770
NA
NA
Gastrointestinal System
3.100
0.2
Iron
24,200
NA
NA
Gastrointestinal System
55,000
0.4
Manganese
--
NA
--
Nervous System
1.800
--
Silver
64.6
NA
NA
Denial
390
0.2
Radionuclides (pCi/g)
Actinium-227 (Ac-227)
--
0.039
--
Career
NA
NA
Americium-241 (Am-241)
15.7
0.049
3E-04
Career
NA
NA
Cestum-137 (Cs-137»:s:
1.98
0.047
4E-05
Career
NA
NA
Lead-210 (Pb-210)
105
0.0077
1E-02
Career
NA
NA
Polonium-210 (Po-210)iTl
105
0.14
BE-04
Career
NA
NA
Neptunium-237 (Np-237Ts:
0.12
0.046
3E-06
Career
NA
NA
Nickel-63 (Ni-63)
6.12
6.7
9E-07
Career
NA
NA
Radium-226 iRa-226)5
425
0.0064
7E-02
Career
NA
NA
Strontium-SD (Sr-90;iISl
2.22
0.066
3E-05
Career
NA
NA
Tritium (H3>
46.5
0.23
2E-04
Career
NA
NA
Uraniunv238 (U-238)®1
0.05
__
Career
NA
NA
Uraniunv234 (U-234)'SI
-
0.066
--
Career
NA
--
Thorium-234 (Th-234)'6's
--
44
--
Career
NA
Total ILCR - Chemicals
5E-04
Total HI
6
Total ILCR - Radionuclides
8E-02
TDtal ILCR - Chemicals + Radionuclides
8E-02
Target Organ His
Total Immune System HI =
4
Total Dermal HI =
4
Total Ocular HI =
4
Total Hematologic HI =
0.3
Total Urinary HI =
1
Total None Specified HI =
0.6
Total Gastrointestinal System HI =
0.7
Notes:
1 - Background for ncn-radionuclides was determined using the background evaluation presented in the risk assessment presented in the 2008 Rl.
The 85 percent upper prediction limit (UPL) was used to determine background for radionuclides (See COPC selection tables).
2 - Exposure point concentration is the 95% upper confidence limit calculated by ProUCL Version 5.0,00.
3 - For non-radionucfides screening levels are USEPA RSLs for Chemical Contaminants at Superfund Sites, November 2015. The noncara nogenic values
correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of 1x10""
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TK=1x10^) November 2014.
4 - Screening level is for Arodor-1260.
5 - Screening levels are ;or hexavalent chromium.
6 - Screening level Includes daughter products.
7 - Polonium-210 is asstmed to be in equilibrium with Pb-210.
8 - Uranium-234 and Thorium-234 are assumed to be in equilibrium with U-238.
NA - Not applicable. There is no cancer slope factor (CSF) or reference dose (RfD) available for this chemical.
E-5
AR301681
-------
TABLE E-4
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR ALL COPCs
RESIDENTIAL EXPOSURES TO SURFACE SOIL (0 - 2 FEET) - SURVEY UNIT 13
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration*15
Residential
Screening
Level®
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level®
Estimated
HQ
Semivolatile Organic Compounds (ug.'kg)
Benzo(a)anthraoene
1,000
180
0E-O0
Cancer
NA
NA
Benzo(a)pyrene
900
10
0E-O5
Cancer
NA
NA
Benzo(b)fluoranthene
1,700
100
1E-05
Cancer
NA
NA
Di benzo(a,h)anth racene
330
10
2E-05
Cancer
NA
NA
lndeno(1,2,3-cd)pyrene
1.000
100
0E-O0
Cancer
NA
NA
Pesticides/PCBs (ug/kg)
alpha-BHC
50D
80
0E-O0
Liver
510,000
0.001
Aroclor-1254
10,000
240
7 E-05
Immune
1,200
13
Aroclor-1200
13,000
240
5E-05
Cancer
NA
NA
Heptachlor Epoxide
81
70
1E-O0
Liver
1,000
0.08
Metals (mgi'kg)
Aluminum
12,200
NA
NA
Central Nervous System
77,000
0.2
Antimony
69
NA
NA
Blood
31
2
Arsenic
20.9
0.68
3 E-05
Skin, Cardiovascular System
35
0.0
Cadmium
134
2100
0E-O8
Kidney
71
2
Chromium'3*41
5780
0.3
2E-02
None Specified
230
25
Cobalt
19.2
420
5E-08
Thyroid
23
0.8
Copper
4,660
NA
NA
Gastrointestinal System
3100
2
Iron
48,000
NA
NA
Gastrointestinal System
55,000
0.9
Lead15'
885
NA
NA
_
NA
NA
Manganese
470
NA
NA
Central Nervous System
1.800
0.3
Mercury'6'
45.7
NA
NA
Central Nervous System
23
2
Nickel
500
15000
4E-08
Body Weight
1,500
0.4
Silver
187
NA
NA
Skin
390
0.5
Thallium '
1.5
NA
NA
Skin
0.78
2
Vanadium
53.5
NA
NA
Kidney
390
0.1
Miscellaneous Parameters (img/kg)
[Cyanide
Thyroid, Central Nervous System
Radionuclides (pClg)
Americium-241 fAm-241)
27.6
0.049
0E-O4
Cancer
NA
NA
Cesium-137 (Cs-137)®
1.35
0.047
3 E-05
Cancer
NA
NA
Lead-21D(Pb-210)W'
100
0.0077
2E-02
Cancer
NA
NA
Polonium-21D |Po-21 Cj'~
100
0.14
1E-03
Cancer
NA
NA
Neptunium-237 (Np-237) 5
0.23
0.040
5E-O0
Cancer
NA
NA
Radium-226 {Ra-228)™
144D
0.0004
2E-01
Cancer
NA
NA
Strontium-80 (Sr-90)'s'
0.434
0.060
7E-O0
Cancer
NA
NA
Tritium (H3)
75.1
0.23
3E-04
Cancer
NA
NA
Uranium-238 {U-238)IB;'
0.630
0.05
1 E-05
Cancer
NA
NA
Uranium-234 (U-234)™
0.630
0.060
1 E-05
Cancer
NA
NA
Total ILCR - Chemicals
2E-02
Total HI
53
Total ILCR - Radionuclides
2E-01
Total ILCR - Chemicals + Radionuclides
2E-01
Target Organ His
Total Blood HI
Total Body Weight HI
Total Cardiovascular System HI
Total Central Nervous System HI
Total Gastrointestinal System HI
Total Immune HI
Total Kidney HI
Total Liver HI
Total Skin HI
Total Thyroid HI
Total None Specified HI
Notes:
1 - Exposure point concentration is the 95% upper confidence limit calculated by ProUCL Version 5.0.00, if applicable, or the maximum detected concentration.
2 - For non-radionuclides screening levels are USEPA Regional Screening Levels (RSLs) for Chemical Contaminants at Superfund Sites, November 2015.
The noncarcinogenic values correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of 1x10
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TR=1E-6), November 2014.
3 - Screening levels are for hexavalent chromium.
4 - Risk exceeded 1E-02; therefore, the following alternate equation was used: ILCR = 1-Jexp(-Exposure Point Concentration*1E-06.'RSL)]_
5 - Risks for exposures to lead were evaluated using the IEUBK and ALM models.
0 - Screening levels are for mercuric chloride (and other mercury salts).
7 - Uncertainty is associated with the toxicity criterion for thallium (see text).
8 - Screening level includes daughter products.
8 - Polonium-210 is assumed to be in equilibrium with Pb-210.
E-6
AR301682
-------
TABLE E-5
SUMMARY OF RECEPTOR RISKS AMD HAZARDS FOR SITE RELATED COPCs
RESIDENTIAL EXPOSURES TO SURFACE SOIL (0 - 2 FEET) - SURVEY UNIT 13
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration'1'
Residential
Screening
Level'2'
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level®
Estimated
HQ
Semivolatile Organic Compounds (ug,'kg)
Benzo(a)anthracene
1,000
160
6E-06
Cancer
NA
NA
6enzo(a)pvrene
900
16
6E-05
Cancer
NA
NA
Benzo(b)fluoranthsne
1,700
160
1E-05
Cancer
NA
NA
Dibenzo(a, h)anthracene
330
16
2E-05
Cancer
NA
NA
I ndeno(1,2,3-cd)pyrefie
1,000
160
6E-06
Cancer
NA
NA
Pesticklesi'PCBs (ug.'kg)
alpha-BHC
500
66
6E-06
Liver
510,000
0.001
Aroclor-1254
16,000
240
7E-05
Immune
1,200
13
Aroclor-1260
13,000
240
5E-05
Cancer
NA
NA
Heptachlor Epoxide
8)
70
1E-D6
Liver
1,000
0.06
Metals (rngftg)
Aluminum
12,200
NA
HA
Central Nervous System
77,000
0.2
Antimony
69
NA.
NA
Blood
31
2
Arsenic
20.9
0.68
3E-05
Skin, Cardiovascular System
35
0.6
Cadmium
134.0
2100
6E-08
Kidney
71
2
Chromium3*4'
5780
0.3
2E-D2
None Specified
230
25
Cobalt
19.2
420
5E-06
Thyroid
23
0.8
Copper
4660
NA
MA
Gastrointestinal System
3100
2
Iron
48,000
NA
NA
Gastrointestinal System
55,000
0.9
Lead5'
685
NA
NA
_
NA
NA
Manganese
479
NA
NA
Central Nervous System
1,800
0.3
Mercury5'
45.7
NA
NA
Central Nervous System
23
2
Nickel
560
15000
4E-06
Body Weight
1,500
0.4
Silver
187
NA
NA
Skin
390
0.5
Thallium"'
1.5
NA
NA
Skin
0.78
2
Vanadium
53.5
NA
NA
Kkiney
390
0.1
Miscellaneous Parameters (nng:kg)
Cyanide
4.6
NA
NA
Thyroid, Central Nervous System
2.7
2
Radionuclides (pCi'g)
Americium-241 (Am-241)
27.6
0.049
8E-Q4
Cancer
NA
NA
Cesium-137 (Cs-137)a:
1.35
0.047
3E-05
Cancer
NA
NA
Lead-210 {Pb-210f
169
0.0077
2E-02
Cancer
NA
NA
Polonium-210 (Po210)tSl
169
0.14
1E-03
Cancer
NA
NA
Neptunium-237 (Np-237)3
0.23
0.046
5E-06
Cancer
NA
NA
Radium-226 (Ra-226)lB;i
1440
0.0064
2E-01
Cancer
NA
NA
Strontium-90 (Sr-90)l:'
0.434
0.066
7E-06
Cancer
NA
NA
Tritium (H3)
75.1
0.23
3E-04
Cancer
NA
NA
Umnium-238 (U-238)':a:'
-
0.05
-
Cancer
NA
NA
Uranium-234 (U-234)':s:
-
0.066
-
Cancer
NA
NA
Total ILCR - Chemicals
2E-D2
Total HI
53
Total ILCR - Radionuclides
2E-01
Total ILCR - Chemicals + Radionuclides
2E-01
Target Organ His
Total Blood HI =
2
Total Body Weight HI =
0.4
Total Cardiovascular System HI =
0.6
Total Central Nervous System HI =
4
Total Gastrointestinal System HI =
2
Total Immune HI =
13
Total Kidney HI =
2
Total liver HI =
0.08
Totai Skin HI =
3
Total Thyroid HI =
3
Total None Specified HI =
25
Notes:
1 - Exposure potrrt concentration is the 95% upper confidence limit calculated by ProUCL Version 5.G.00, if applicable, or the maximum detected concentration.
2 - For non-radionudides screening levels are USEPA Regional Screening Levels (RSLs) for Chemical Contaminants at Superfund Sites, November 2015.
The noncarctncgenic values correspond to a target hazard quotient of 1. Carcinogenic values represent an Incremental cancer risk of 1x10"®
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TR=1E-6), November 2014.
3 - Screening levels are for hexavalerrt chromium.
4 - Risk exceeded 1E-G2; therefore, the following alternate equation 'was used: ILCR = 1-[exp{-Exposure Point Concentration*!E-O&RSL)].
5 - Risks for exposures to lead were evaluated using the IEUBK and ALM models.
6 - Screening levels are for mercuric chloride (and other mercury salts).
7 - Uncertainty is associated with the toxicity criterion for thallium (see text).
E-7
AR301683
-------
TABLE E-6
SUMMARY OF RECEPTOR RISKS AMD HAZARDS FOR SITE RELATED COPCs ABOVEBACKGROUND '
RESIDENTIAL EXPOSURES TO SURFACE SOJL (0 - 2 FEET) - SURVEY UNIT 13
SAFETY LIGHT CORPORATION OU-3
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Mon-Carcinogenic Hazard Quotient (HQ)
Chemical
Exposure Point
Concentration™
Residential
Screening
Level13'
Estimated
ILCR
Primal/ Target Organ
Residential
Screening
Level'*'
Estimated
HQ
Semivolatile Organic Compounds (ug/kci)
Benzo(a )anthracene
1,000
160
6E-06
Cancer
NA
NA
6enzo(a)pyrene
900
16
6E-05
Cancer
NA
NA
Benzo(b )fl uoranthene
1,700
160
1E-05
Cancer
NA
NA
Dibenzoia. h anthracene
330
16
2E-05
Cancer
NA
NA
i ndeno(1,2,3-cdjpyrene
1;000
160
6E-06
Cancer
NA
NA
Pesticidesi'PCBs (ug/kg)
alpha-BHC
500
86
6E-06
Liver
510.000
0.001
Aroclor-1254
16,000
240
7E-05
Immune
1,200
13
Aroclor-1260
13,000
240
5E-05
Cancer
NA
NA
Heptachtor Epoxide
81
70
1E-06
Liver
1,000
0.08
Metals (mglkg)
Aluminum
12,200
NA
NA
Central Nervous System
77,000
0.2
Antimony
69
NA
NA
Blood
31
Arsenic
20.9
0.68
3E-05
Skin, Cardiovascular System
35
0.6
Cadmium
134.0
2100
6E-08
Kkfney
71
2
Chromium-51
5780
0.3
2E-02
None Specified
230
25
Cobalt
192
420
5E-08
Thyroid
23
0.8
Copper
4660
NA
NA
Gastrointestinal System
3100
2
Iron
48.000
NA
NA
Gastrointestinal System
55,000
0.9
Lead'51
885
NA
NA
_
NA
NA
Manganese
-
NA.
NA
Central Nervous System
1,800
-
Mercury
45.7
NA
NA
Central Nervous System
23
2
Nickel
560
15000
4E-08
Body Weight
1,500
0.4
Silver
187
MA
NA
Skin
390
D.5
Thallium®'
1.5
NA
NA
Skin
0.78
2
Vanadium
53.5
MA
NA
Kidney
390
0.1
Miscellaneous Parameters (mg,'kg)
Cyanide
4.6
MA
NA
Thyroid. Central Nervous System
2.7
2
Radionuclides (pCi/g)
Americium-241 (Am-241)
27.6
0.049
6E-D4
Cancer
NA
NA
Cesium-137 (Cs-137p
1.35
0.047
3E-05
Cancer
NA
NA
Lead-210 (Pb-210)w
169
0.0077
2E-02
Cancer
NA
NA
Polonium-210 (Po210fc
169
0.14
1E-03
Cancer
NA
NA
Neptunium-237 (Np-237)' ®
0.23
0.046
5E-06
Cancer
NA
NA
Radium-226 (Ra-226)'5'
1440
0.0064
2E-01
Cancer
NA
NA
Stronfum-90 (Sr-90)'s'
0.434
0.066
7E-06
Cancer
NA
MA
Tritium (H3)
75.1
0.23
3E-D4
Cancer
NA
MA
Uranium-238 (U-238):s:
-
0.05
-
Cancer
NA
MA
Uranium-234 (U-234);,2)
-
D.066
-
Cancer
NA
NA
Total ILC
R - Chemicals
2E-02
Total HI
53
Total ILCR - Radionuclides
2E-01
Total ILCR - Chemicals + Radionuclides
2E-01
Target Organ His
Total Blood HI =
Total Body Weight HI =
Total Cardiovascular System HI =
Total Central Nervous System HI =
Total Gastrointestinal System HI =
Total Immune HI =
Total Kidney HI =
Total Liver HI =
Total Shin HI =
Total Thyroid Hl =
Total None Specified HI =
Motes:
1 - Background for non-radionuclides was determined using the background evaluation presented in the risk assessment presented in the 2008 Rl.
The 95 percent upper prediction limit flJPL) was used to determine background for radionuclides (See COPC selection tables).
2 - Exposure point concentration is the 95% upper confidence limit calculated by PnaUCL Version 5.0.00, if applicable, or the maximum detected concentration.
3 - For non-radionuclides screening levels are USEPA Regional Screening Levels (RSLs) for Chemical Contaminants at Superfund Sites, November 2015.
The nortcarcincgenic values correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of 1 x10"6
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goafs (PRG) Summary Table (TR=1 E-6), November 2014.
4 - Screening levels are for hexavalent chromium.
5 - Risk exceeded 1E-Q2; therefore, Ihe following alternate equation was used: ILCR = 1-[exp<-Exposure Point Concentration*1E-D®RSL)].
6 - Risks for exposures to lead were evaluated using the IEUBK and ALM models.
E-8
AR301684
-------
TABLE E-7
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR ALL COPCs
RESIDENTIAL EXPOSURES TO SURFACE SOIL (0 - 2 FEET} - SURVEY UNIT 14
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration11'
Residential
Screening
Level*'
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level®
Estimated
HQ
Semivolatile Organic Compounds Hig'kgj
Benzo(a)anthracene
5,600
160
4E-05
Cancer
NA
NA
8enzo(a)pyrene
5,600
16
4E-04
Cancer
NA
MA
8enzo(b)fluoran1hene
7.900
160
5E-05
Cancer
NA
NA
Benzo(k)fl uoranthene
2,100
1,600
1E-06
Cancer
NA
NA
Dibenzo(a, h)arithracene
850
16
5E-05
Cancer
NA
NA
lndeno( 1,2,3-cd)pyrene
3,700
160
2E-05
Cancer
NA
NA
Metals (mgjkg)
Aluminum
6,510
NA
NA
Central Nervous System
77,000
0.1
Arsenic
19.0
0.68
3E-05
Skin, Cardiovascular System
35
0.5
Chromium'3'
19.7
0.30
7E-05
None Specified
230
0.09
Cobalt
6.8
420
2E-08
Thyroid
23
0.4
Iron
20,200
NA
NA
Gastrointestinal System
55,ODD
0.4
Manqanese
760
NA
NA
Central Nervous System
1,800
0.4
Thallium
0.42
NA
NA
Skin
0.76
0.5
Radionuclides (pCii'g)
Actinium-227 (Ac-227)
0.031
0.039
8E-07
Cancer
NA
NA
Americium-241 (Am-241)
0.149
0.049
3E-06
Cancer
NA
MA
Cesium-137 (Cs-137)*1
0.616
0.047
1E-05
Cancer
MA
NA
Lead-210 (Pb-210)
2.22
0.0077
3E-04
Cancer
NA
NA
Potonium-210 (Po-210)15'
2.22
0.14
2E-05
Cancer
MA
NA
Nickel-63 (Ni-63)
6.20
6.7
9E-07
Cancer
NA
NA
Radium-226 (Ra-22Sf
5.67
0.0064
9E-04
Cancer
NA
NA
Strontium-90 (Sr-90)'4j
0.524
0.066
6E-06
Cancer
MA
NA
Tritium (H3)
20.1
0.23
9E-05
Cancer
MA
NA
Uranium-238 (U-238)"1'
0.893
0.05
2E-05
Cancer
NA
NA
Uranium-234 (U-234)KI
0.693
0.066
1E-05
Cancer
NA
NA
Total ILCR - Chemicals
6E-04
Total HI
2
Total ILCR - Radionuclides
1E-03
Total ILCR - Chemicals + Radionuclides
2E-03
Target Organ His
Total Cardiovascular System HI =
D.5
Total Central Nervous System HI =
0.5
Total Gastrointestinal System HI =
0.4
Total Skin HI =
1
Total Thyroid HI =
0.4
Total None Specified HI =
0.09
Notes:
1 - Exposure point concentration is the 95% upper confidence limit calculated by ProUCL Version 5.0.00.
2 - For nort-radionudides screening levels are USEPA RSLs for Chemical Contaminants at Superfund Sites. June 2015. The noncarcinogenic values
correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of IxlO"6"
For radionuclides screening levels are from the Radionucl ide Preliminary Remediation Goals (PRG) Summary Table (TR=1E-6) November 2014.
3 - Screening levels are for hexai/alent chromium.
4 - Screening level includes daughter products.
5 - Polonium-210 is assumed to be in equilibrium with Pb-210.
6 - Uranium-234 is assumed to be in equilibrium wth U-238.
NA - Not applicable. There are no cancer slope factors (CSF) or reference dose (RfD) available for this chemical.
E-9
AR301685
-------
TABLE E-8
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR SITE RELATED COPCs
RESIDENTIAL EXPOSURES TO SURFACE SOIL (0 - 2 FEET} - SURVEY UNIT 14
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration'1'
Residential
Screening
Level
-------
TABLE E-9
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR SITE RELATED COPCs ABOVE BACKGROUND '
RESIDENTIAL EXPOSURES TO SURFACE SOIL (0 - 2 FEET} - SURVEY UNIT 14
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration42'
Residential
Screening
Level"1
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level®
Estimated
HQ
Serrtivolatile Organic Compounds (ug/kg)
6enzo(a>anthna eerie
5,600
160
4E-05
Cancer
NA
NA
Benzo(a)pyrene
5,600
16
4E-04
Cancer
NA
NA
Benzo(b}fluoran1hene
7,900
160
5E-05
Cancer
NA
NA
Benzo(k)fluoranthene
2,100
1,600
1E-06
Cancer
NA
NA
Dibenzof a.hjanthracene
850
16
5E-05
Cancer
NA
NA
lndeno(1,2,3-cd)pyrene
3,700
160
2E-05
Cancer
NA
NA
Metals (mg.'kg)
Afuminum
-
NA
-
Central Nervous System
77,000
-
Arsenic
19.0
0.68
3E-05
Skin. Cardiovascular System
35
0.5
Chromium*1'
19.7
0.30
7E-05
None Specified
230
0.09
Cobalt
8.8
420
2E-08
Thyroid
23
0.4
Iron
20,200
NA
NA
Gastrointestinal System
55,000
0.4
Manganese
-
NA
-
Central Nervous System
1.800
-
Thallium
-
NA
-
Skin
0.76
-
Radionuclides (pCi/g)
Actinium-227 (Ac-227)
-
0.039
-
Cancer
NA
NA
Americium-241 (Am-241)
0.149
0.049
3E-06
Cancer
NA
NA
Cesium-137 (Cs-137)'5
0.616
0.047
1E-05
Cancer
NA
NA
Lead-210 (Pb-210)
2.22
0.0077
3E-04
Cancer
NA
NA
Poloniurn-210 (Po-210)16'
2.22
0.14
2E-05
Cancer
NA
NA
Nickel-63 (Ni-63)
6.20
6.7
9E-07
Cancer
NA
NA
Radium-226 (Ra-226)E
5.67
0.0064
9E-04
Cancer
NA
NA
Strontium-90 (Sr-90)'s)
0.524
0.066
8E-06
Cancer
NA
NA
Tritium (H3)
20.1
0.23
9E-05
Cancer
NA
NA
Uranium-238 (U-23B)
-------
TABLE E-10
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR ALL COPCs
RESIDENTIAL EXPOSURES TO ALL SOIL (0 -10 FEET) - SURVEY UNIT 14
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration®1'
Residential
Screening
Level®
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level®
Estimated
HQ
Semivolatile Organic Compounds lug''kg I
Elenzo(a>anthracene
5,600
160
4E-05
Cancer
NA
NA
Benzo(a)pyrene
5,600
16
4E-04
Cancer
NA
NA
Benzo(b}fluoran)hene
7,900
160
5E-05
Cancer
NA
NA
Benzo(k)fl uoranthene
2,100
1,600
1E-06
Cancer
NA
NA
Dibenzoia h}anthracene
582
16
4E-05
Cancer
NA
NA
lndeno(1,2,3-cd)pyrene
2.544
160
2E-05
Cancer
NA
NA
Metals (mg.'kg)
Aluminum
8,510
NA
NA
Central Nervous System
77.0DD
0.1
Arsenic
16.0
0.68
2E-05
Skin, Cardiovascular System
35
0.5
Chromium3
19.0
0.30
6E-05
None Specified
230
0.08
Cobalt
8.61
420
2E-08
Thyroid
23
0.4
Iron
19,345
NA
NA
Gastrointestinal System
55,000
0.4
Manqanese
649
NA
NA
Central Nervous System
1,800
0.4
Thallium
0.67
NA
NA
Skin
0.78
0.9
Radionuclides (pCi/g)
Actinium-227 (Ac-227)
0.031
0.039
8E-07
Cancer
NA
NA
Americium-241 (Am-241)
D.149
0.049
3E-06
Cancer
NA
NA
Cesium-137 (Cs-137)'14
0.578
0.047
1E-05
Cancer
NA
NA
Lead-210 (Pb-210)
233
0.0077
3E-02
Cancer
NA
NA
Polonium-210 (Po-210)'s:i
233
0.14
2E-03
Cancer
NA
NA
Neptunium-237 {Np-237)"'
0.038
0.046
8E-07
Cancer
NA
NA
Nickel-63 (Ni-63}
5.86
6.7
&E-07
Cancer
NA
NA
Radium-226 (Ra-226)'
189
0.0064
3E-02
Cancer
NA
NA
Strontium-90 (Sr-90)'4'
0.639
0.066
1E-05
Cancer
NA
NA
Ttiallium-204 (TI-204)
3,34
2.1
2E-06
Cancer
NA
NA
Tritium (H3)
18.6
0.23
8E-05
Cancer
NA
NA
Uraniunv238 (U-238)'41
0.678
0.05
2E-05
Cancer
NA
NA
Uranium-234 (U-234)®1
0.878
0.066
1E-05
Cancer
NA
NA
Total ILCR - Chemicals
6E-04
Total HI
3
Total ILCR - Radionuclides
6E-02
Total ILCR - Chemicals + Radionuclides
6E-02
Target Organ His
Total Cardiovascular System HI =
Total Central Nervous System HI =
Total Gastrointestinal System HI =
Total Skin HI =
Total Thyroid HI =
Total None Specified HI =
Notes:
1 - Exposure point concentration is the 95% upper confidence limit calculated by ProUCL Version 5.0.00.
2 - For non-radionuciides screening levels are US EPA RSLs for Chemical Contaminants at Superfund Sites, June 2015. The noncarcinogenic values
correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of 1x10"®"
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TR=1E-6) November 2014.
3 - Screening levels are for hexavaferrt chromium.
4 - Screening level includes daughter products.
5 - Polonium-210 is assumed to be in equilibrium with Pb-210.
6 - Uranium-234 is assumed to be in equilibrium vwth U-238.
NA - Not applicable. There are no cancer slope factors (CSF) or reference dose (RfD) available for this chemical.
0.5
0.4
1
0.4
0.08
E-12
AR301688
-------
TABLE E-11
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR SITE RELATED COPCs
RESIDENTIAL EXPOSURES TO ALL SOIL (0 -10 FEET) - SURVEY UNIT 14
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration®1'
Residential
Screening
Level®
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level®
Estimated
HQ
Semivolatile Organic Compounds lug''kg I
Elenzoia)antliracene
5,600
160
4E-05
Cancer
NA
NA
Benzo(a)pyrene
5,600
16
4E-04
Cancer
NA
NA
Benzo(b}fluoran)hene
7,900
160
5E-05
Cancer
NA
NA
Benzo(k)fl uoranthene
2,100
1,600
1E-06
Cancer
NA
NA
Dibenzoia h}anthracene
582
16
4E-05
Cancer
NA
NA
lndeno(1,2,3-cd)pyrene
2.544
160
2E-05
Cancer
NA
NA
Metals (mg.'kg)
Aluminum
8,719
NA
NA
Central Nervous System
77.0DD
0.1
Arsenic
16.0
0.68
2E-05
Skin, Cardiwascular System
35
0.5
Chromium3
19.0
0.30
6E-05
None Specified
230
0.08
Cobalt
8.61
420
2E-08
Thyroid
23
0.4
Iron
19,345
NA
NA
Gastrointestinal System
55,000
0.4
Manqanese
649
NA
NA
Central Nervous System
1,800
0.4
Thallium
0.67
NA
NA
Skin
0.78
0.9
Radionuclides (pCi/g)
Actinium-227 (Ac-227)
0.031
0.039
8E-07
Cancer
NA
NA
Americium-241 (Am-241)
D.149
0.049
3E-06
Cancer
NA
NA
Cesium-137 (Cs-137),A'
0.578
0.047
1E-05
Cancer
NA
NA
Lead-210 (Pb-210)
233
0.0077
3E-02
Cancer
NA
NA
Polonium-210 (Po-210)'s:i
233
0.14
2E-03
Cancer
NA
NA
Neptunium-237 (N0-237)"1
0.038
0.046
8E-07
Cancer
NA
NA
Nickel-63 (Ni-63}
5.86
6.7
&E-07
Cancer
NA
NA
Radium-226 (Ra-226)'
189
0.0064
3E-02
Cancer
NA
NA
Strontium-90 (Sr-90)'4'
0.639
0.066
1E-05
Cancer
NA
NA
TtiaIum-204 (TI-2D4)
3,34
2.1
2E-06
Cancer
NA
NA
Tritium (H3)
18.6
0.23
8E-05
Cancer
NA
NA
Uraniunv238 (U-238)'41
-
0.05
-
Cancer
NA
-
Uranium-234 (U-234)®1
-
0.066
-
Cancer
NA
-
Total ILCR - Chemicals
6E-04
Total HI
3
Total ILCR - Radionuclides
6E-02
Total ILCR - Chemicals + Radionuclides
6E-02
Target Organ His
Total Cardiovascular System HI =
Total Central Nervous System HI =
Total Gastrointestinal System HI =
Total Skin HI =
Total Thyroid HI =
Total None Specified HI =
Notes:
1 - Exposure point concentration is the 95% upper confidence limit calculated by ProUCL Version 5.0.00.
2 - For non-radionuciides screening levels are USERA RSLs for Chemical Contaminants at Superfund Sites, June 2015. The noncarcinogenic values
correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of 1x10"®"
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TR=1E-6) November 2014.
3 - Screening levels are for hexavalent chromium.
4 - Screening level includes daughter products.
5 - Polonium-210 is assumed to be in equilibrium with Pb-210.
6 - Uranium-234 is assumed to be in equilibrium vwth U-238.
NA - Not applicable. There are no cancer slope factors (CSF) or reference dose (RfD) available for this chemical.
0.5
0.4
1
0.4
0.08
E-13
AR301689
-------
TABLE E-12
SUMMARY OF RECEPTOR RISKS AMD HAZARDS FOR SITE RELATED COPCs ABOVE BACKGROUND '
RESIDENTIAL EXPOSURES TO ALL SOIL (0 -10 FEET) - SURVEY UNIT 14
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration*2'
Residential
Screening
Level'8'
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level®'
Estimated
HQ
Semivolatile Organic Compounds (ug/kg)
Eienzo(a)anthracene
5,600
160
4E-05
Cancer
NA
NA
Benzo(a)pyrene
5,600
16
4E-04
Cancer
NA
NA
Benzo(b}fluoranthene
7,900
160
5E-05
Cancer
NA
NA
Benzo(k)fl uoranthene
2,100
1,600
1E-06
Cancer
NA
NA
Dibenzola.h Janthracene
582
16
4E-05
Cancer
NA
NA
lndeno(1,2,3-cd)pyrene
2,544
160
2E-05
Cancer
NA
NA
Metals (mg/kg)
Aluminum
8,719
NA
NA
Central Nervous System
77.00D
0.1
Arsenic
16.0
0.68
2E-05
Skin, Cardiovascular System
35
0.5
Chnomiinv''
19.0
0.30
6E-05
None Specified
230
0.08
Cobalt
8.61
420
2E-08
Thyroid
23
0.4
lion
19,345
NA
NA
Gastrointestinal System
55,000
0.4
Manganese
-
NA
-
Central Nervous System
1,800
-
Thallium
-
NA
-
Skin
0.78
-
Radionuclides (pCii'g)
Actinium-227 (Ac-227)
-
0.039
-
Cancer
NA
NA
Americium-241 (Am-241)
0.149
0.049
3E-06
Cancer
NA
NA
Cesium-137 (Cs-137) s
0.578
0.047
1E-05
Cancer
NA
NA
Lead-210 (Pb-210)
233
0.0077
3E-02
Cancer
NA
NA
Pofonium-210 (Po-210)'6:i
233
0.14
2E-03
Cancer
NA
NA
Neptunium-237 (Np-237)'5
-
0.046
-
Cancer
NA
NA
Nickel-63 (Ni-63)
5.86
6.7
9E-07
Cancer
NA
NA
Radium-226 (R.a-226)5
189
0.0064
3E-02
Cancer
NA
NA
Strontium-90 (Sr-90)'5'
0.639
0.066
1E-05
Cancer
NA
NA
Thallium-204 (TI-204)
3.84
2.1
2E-06
Cancer
NA
NA
Tritium (H3)
18.6
0.23
6E-05
Cancer
NA
NA
Uraniuinv238 (U-238)';i
-
0.05
-
Cancer
NA
-
Uranium-234 (U-234)'7'
.
0.066
.
Cancer
NA
.
Total ILCR - Chemicals
6E-04
Total HI
1
Total ILCR - Radionuclides
6E-02
Total ILCR - Chemicals + Radionuclides
6E-02
Target Organ His
Total Cardiovascular System HI =
D.5
Total Central Nervous System HI =
0.1
Total Gastrointestinal System HI =
0.4
Total Skin HI =
0.5
Total Thyroid HI =
0.4
Total None Specified H I =
0.08
Notes:
1 - Background for non-radionuclides was determined using the background evaluation presented in the risk assessment presented in the 2008 Rl.
The 95 percent upper prediction limit (UPL) was used to determine background for radionuclides (See COPC selection tables).
2 - Exposure point concentration is the 95% upper confidence limit calculated by ProUCL Version 5.0.00.
3 - For non-radionuclides screening levels are U5EPA RSLs for Chemical Contaminants at Superfund Sites, June 2015. Tne noncarcinogenic values
correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of 1x10*
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TR=1E-6) November 2014.
4 - Screening levels are for hexavalent chromium.
5 - Screening level includes daughter products.
6 - Poloniunv210 is assumed to be in equilibrium with Pb-210.
7 - Uraniurn-234 is assumed to be in equilibrium with U-238.
NA - Not applicable. There are no cancer slope factors (CSF) or reference dose (RfD) available for this chemical.
E-14
AR301690
-------
TABLE E-13
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR All COPCs
RESIDENTIAL EXPOSURES TO SURFACE SOIL (0 - 2 FEET) - SURVEY UNIT 15
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration'"
Residential
Screening
Level111
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level*1
Estimated
HQ
Semivolatile Organic Compounds (ugi'kg)
8enzo(a)anthracene
4,200
160
3E-05
Cancer
NA
NA
Benzo(a}pyrene
5,000
16
3E-04
Cancer
NA
NA
Benzo(b)fluoranthene
6,800
160
4E-05
Cancer
NA
NA
Benzo(k)fluoranthene
1,800
1,600
1E-06
Cancer
NA
NA
Dibenzo(a: hjanthracene
890
16
6E-05
Cancer
NA
NA
lndeno(1.2,3-cd)pyrene
3,600
160
2E-05
Cancer
NA
NA
PesticidesfPCBs (ug.'kg)
IAroctor-1254
426
240
2E-06
nruxe Sysan
1.200
Metals (mg.'kg)
Aluminum
8,787
NA
IMA
Central Nervous System
77,000
0.1
Arsenic
8.92
0.68
1E-05
Skin. Cardiovascular System
35
0.3
Cadmium
15S
2,100
7E-08
Kidney, Respiratory
71
2
Chromium3
905
0.30
3E-03
None Specified
230
4
Cobalt
8.38
420
2E-08
Thyroid
23
0.4
Copper
998
NA
MA
Gastrointestinal System
3,100
0.3
Iron
18,415
NA
NA
Gastrointestinal System
55,000
0.3
Lead'4'
158
NA
NA
NA
NA
NA
Manganese
382
NA
NA
Central Nervous System
1.800
0.2
Nickel
97.6
15,000
7E-09
Body Weight, Respiratory
1,500
0.07
Silver
77.2
NA
NA
Skin
390
0.2
Thallium
1
NA
NA
Skin
0.78
1
Vanadium
87.9
NA
NA
Kidney
390
D.2
Radionuclides (pCi/g)
Actiniuni-227 (Ac-227)
0.036
0.039
9E-07
Cancer
NA
NA
Americium-241 (Am-241)
2.84
0.049
6E-05
Cancer
NA
NA
Carbon-14 (C-14)
0.066
0.15
4E-07
Cancer
NA
NA
Cestum-137 (Cs-137)',5:'
16.2
0.047
3E-04
Cancer
NA
NA
Lead-210 (Pb-210)
37.8
0.0077
5E-03
Cancer
NA
NA
Polonium-210 (Po-210)®
37.8
0.14
3E-04
Cancer
MA
NA
Neptun.ium-237 (Np-237)®
0.079
0.046
2E-06
Cancer
NA
NA
Nickel-63 (Ni-63)
22.1
6.7
3E-06
Cancer
NA
NA
Radium-226 iRa 226)5
61
0.0064
1E-02
Cancer
NA
NA
Strontiunv&O (Sr-90)15'1
0.638
0.066
1E-05
Cancer
NA
NA
Thallium-204 (Tl-204)
2.80
2.1
1E-Q6
Cancer
NA
NA
Tritium (H3)
28.4
0.23
1E-04
Cancer
NA
NA
Uranium-238 (U-238)'51
0.693
0.05
1E-05
Cancer
NA
NA
Unanium-234 (U-234)'71
0.633
0.066
1E-05
Cancer
NA
NA
Total ILCR - Chemicals
3E-03
Total HI
9
Total ILCR - Radionuclides
2E-02
Total ILCR - Chemicals + Radionuclides
2E-02
Target Organ His
Total Immune System HI =
Total Cardiovascular System HI =
Total Central Nervous System HI =
Total Gastrointestinal System HI =
Total Skin HI =
Total Ktdr>ey HI =
Total Respiratory HI =
Total Thyroid HI =
Total Body Weight HI =
Total None Specified HI =
Notes:
1 - Exposure point concentration is the 95% upper confidence limit calculated by PnoUCL Version 5.0.00.
2 - For rton-radionucfides screening levels are US EP A RSLs for Chemical Contaminants at Superfund Sites, June 2015. The noncarcinogenic values
correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of IxlO"6
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TR=1E-6) November 2014.
3 - Screening levels are for hexavalent chromium.
4 - Risks for exposures to lead were evaluated using the IEUBK and ALM models.
5 - Screening level includes daughter products.
6 - Polunium-210 is assumed to be in equilibrium with Lead-210.
7 - Uraniurn-234 is assumed to be in equilibrium wth U-238.
NA - Not applicable. There are no cancer slope factors (CSF) or reference dose (RfD) available for this chemical.
E-15
AR301691
-------
TABLE E-14
SUMMARY OF RECEPTOR RISKS AMD HAZARDS FOR SITE RELATED COPCs
RESIDENTIAL EXPOSURES TO SURFACE SOIL (0 - 2 FEET) - SURVEY UNIT 15
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration'11
Residential
Screening
Level"1
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level™
Estimated
HQ
Semivolatile Organic Compounds (ug.'kg)
Benzo(a)anthracene
4.200
160
3E-05
Cancer
NA
NA
Benzo(a)pyrene
5,000
16
3E-04
Cancer
NA
NA
Benzoiblfluoranthene
6,800
160
4E-05
Cancer
NA
NA
Eienzo(k)fl uoranthene
1,800
1,600
1E-06
Cancer
NA
NA
Dibenzo(a,h}anthracene
890
16
6E-05
Cancer
NA
NA
lndeno(1,2,3-cd )pyrene
3,600
160
2E-05
Cancer
NA
NA
Pesticides,'PCBs (ug/kg)
IAroctor-1254
426
240
2E-06
Immune System
' 20C
Metals (mg/kg)
Aluminum
8,787
NA
NA
Central Nervous System
77.000
0.1
Arsenic
8.92
0.68
1E-05
Skin, Cardiovascular System
35
0.3
Cadmium
155
2,100
7E-Q8
Kidney, Respiratory
71
2
Chromium3'
90S
0.30
3E-Q3
None Specified
230
4
Cobalt
8.38
420
2E-08
Thyroid
23
D.4
Copper
998
NA
NA
Gastrointestinal System
3,100
0.3
Iron
18,415
NA
NA
Gastrointestinal System
55,000
0.3
Lead14'
158
NA
NA
NA
NA
NA
Manganese
382
NA
NA
Central Nervous System
1.80D
0.2
Nickel
97.6
15,000
7E-09
Body Weight, Respiratory
1.500
0.07
Stiver
77.2
NA
NA
Skin
390
0.2
Thallium
1
NA
NA
Skin
0.78
1
Vanadium
87.9
NA
NA
Kidney
390
0.2
Radionuclides (pCi'g)
Actinium-227 (Ac-227)
0.036
0.039
9E-07
Cancer
NA
NA
Americium-241 (Am-241)
2.84
0.049
6E-05
Cancer
NA
NA
Carbon-14 (C-14)
0.066
0.15
4E-07
Cancer
NA
NA
Cesiunv137 (Cs-137)':s:
16.2
0.047
3E-04
Cancer
NA
NA
Lead-210 (Pb-210)
37.8
Q.0077
5E-03
Cancer
NA
NA
Polonium-210 {Po-210)IS)
37.8
0.14
3E-04
Cancer
NA
NA
Neptunium-237 (Np-237)5'
0.079
0.046
2E-06
Cancer
NA
NA
Nickel-63 (Ni-63)
22.1
6.7
3E-06
Cancer
NA
NA
Radium-228 (Ra-226) "
61
0.0064
1E-02
Cancer
NA
NA
Strontium-50 (Sr-90:r '
0.638
0.066
1E-Q5
Cancer
NA
NA
Thalliunv204 ffl-204)
2.8
2.1
1E-06
Cancer
NA
NA
Tritium (H3)
28.4
0.23
1E-04
Cancer
NA
NA
Uranium-238 (U 238V":
-
0.05
-
Cancer
NA
-
Uraniunv234 (U-234)m
-
0.066
-
Cancer
NA
-
Total ILC
R - Chemicals
3E-03
Total HI
9
Total JLCR - Radionuclides
2E-02
Total ILCR - Chemicals + Radionuclides
2E-02
Target Organ His
Total Immune System HI =
Total Cardiovascular System HI =
Total Central Nervous System HI =
Total Gastrointestinal System HI =
Total Skin HI =
Total Kidney HI =
Total Respiratory HI =
Total Thyroid HI =
Total Body Weight HI =
Total None Specified HI =
Notes:
1 - Exposure point concentration is the 95% upper confidence limit calculated by ProUCL Version 5.0.00.
2 - For non-radionucfides screening levels are USEPA RSLs for Chemical Contaminants at Superfund Sites, June 2015. The noncarcinogenic values
correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of 1x10^
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TR= 1E-6) November 2014.
3 - Screening levels are for hexavalent chromium.
4 - Risks for exposures to lead were evaluated using the IEU6K and ALM models.
5 - Screening level includes daughter products.
6 - Poluniurn-210 is assumed to be in equilibrium with Lead-210.
7 - Uranium-234 is assumed to be in equilibrium with U-238.
E-16
AR301692
-------
TABLE E-15
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR SITE RELATED COPCs ABOVE BACKGROUND|1)
RESIDENTIAL EXPOSURES TO SURFACE SOIL (0 - 2 FEET) - SURVEY UNIT 15
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk {ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration'21
Residential
Screening
Level'31
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level'31
Estimated
HQ
Semivolatile Organic Compounds (ug)kg)
Benzo(a)anthracene
4,200
160
3E-05
Cancer
NA
NA
Benzo(a)pyrene
5,000
16
3E-04
Cancer
NA
NA
B enzo< b )fluoranthene
6,800
160
4E-05
Cancer
NA
NA
Benzo(k)fluorantfiene
1,800
1.600
1E-06
Cancer
NA
NA
Dibenzol a,h)anthracene
890
16
6E-05
Cancer
NA
NA
lndeno( 1,2,3-cd)pyrene
3,600
160
2E-05
Cancer
NA
NA
Pesticides'PCBs (ug kg)
Aroclor-1254
426
240
2E-06
Immune System
1,200
0.4
Metals (mfl/ktl)
Aluminum
8,787
NA
NA
Central Nervous Svstem
77,000
0.1
Arsenic
8.92
0.68
1E-05
Skin, Cardiovascular System
35
0.3
Cadmium
155
2.100
7E-08
Kidnev, Respirator/
71
2
Chromium141
905
0.30
3E-03
None Specified
230
4
Cobalt
8.38
420
2E-08
Thyroid
23
0.4
Copper
998
NA
NA
Gastrointestinal System
3,100
0.3
Iron
18.415
NA
NA
Gastrointestinal System
55,000
0.3
Lead151
158
NA
NA
NA
NA
NA
Manganese
382
NA
NA
Central Nervous System
1.800
0.2
Nickel
97.6
15,000
7E-09
Body Weight, Respiratory
1,500
0.07
Silver
77.2
NA
NA
Skin
390
0.2
Thallium
1
NA
NA
Skin
0.78
1
Vanadium
87.9
NA
NA
Kidney
390
0.2
Radionuclides (pCi/o)
Actinium-227 (Ac-227)
0.036
0.039
9E-07
Cancer
NA
NA
Americium-241 (Am-241)
2.84
0.049
6E-05
Cancer
NA
NA
Carbon-14 (C-14)
-
0.15
-
Cancer
NA
-
Cesium-137 (Cs-137)t6!
16.2
0.047
3E-04
Cancer
NA
NA
Lead-210 (Pb-210)
37.8
0.0077
5E-03
Cancer
NA
NA
Polonium-210 (Po-210)<7)
37.8
0.14
3E-04
Cancer
NA
NA
Neptunium-237 (Np-237)'6'
0.079
0.046
2E-06
Cancer
NA
NA
Nickel-63 (Ni-63)
22.1
6.7
3E-06
Cancer
NA
NA
Radium-226 (Ra-226)(E;
61
0.0064
1E-02
Cancer
NA
NA
Strontium-90 (Sr-90)'6:'
0.638
0.066
1E-05
Cancer
NA
NA
Thallium-204 (TI-204)
2.8
2.1
1E-06
Cancer
NA
NA
Tritium (H3)
28.4
0.23
1E-04
Cancer
NA
NA
Uranium-238 (U-238)':6;i
-
0.05
-
Cancer
NA
-
Uranium-234 (U-234)'8:'
-
0.066
-
Cancer
NA
-
Total ILCR - Chemicals
3E-03
Total HI
10
Total ILCR - Radionuclides
2E-02
Total ILCR - Chemicals + Radionuclides
2E-02
Target Organ His
Total Immune System HI =
Total Cardiovascular System HI =
Total Central Nervous System HI =
Total Gastrointestinal System HI =
Total Skin HI =
Total Kidney HI =
Total Respiratory HI =
Total Thyroid HI =
Total Body Weight HI =
Total None Specified HI =
Notes:
1 - Background for non-radionuclides was determined using the background evaluation presented in the risk assessment presented in the 2008 Rl.
The 95 percent upper prediction limit (UPL) was used to determine background for radionuclides (See COPC selection tables).
2 - Exposure point concentration is the 95% upper confidence limit calculated by ProUCL Version 5.0.00.
3 - For non-radionuclides screening levels are USEPA RSLs for Chemical Contaminants atSuperfund Sites, June 2015. The noncarcinogenic values
correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of 1x10^
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TR=1E-6) November 2014.
4 - Screening levels are for hexavalent chromium.
5 - Risks for exposures to lead were evaluated using the IEUBK and ALM models.
6 - Screening level includes daughter products.
7 - Polonium-210 is assumed to be in equilibrium with Pb-210.
8 - Uranium-234 is assumed to be in equilibrium with U-238.
NA - Not applicable. There are no cancer slope factors (CSF) or reference dose (RfD) available for this chemical.
E-17
AR301693
-------
TABLE E-16
SUMMARY OF RECEPTOR RISKS AND HAZARDS FOR ALL COPCs
RESIDENTIAL EXPOSURES TO ALL SOIL |0 -10 FEET) - SURVEY UNIT 15
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration"1
Residential
Screening
Level®
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level®
Estimated
HQ
Semivolatile Organic Compounds (ug/kg)
Benzo(a)antliracene
4,200
160
3E-05
Cancer
MA
NA
Benzo(a)pyrene
5,000
16
3E-04
Cancer
NA
NA
Benzo(b)fluoranthene
6,800
160
4E-05
Cancer
NA
NA
Benzo(kJfluoranthens
1,800
1,600
1E-06
Cancer
NA
NA
Dibenzo{a, h)anthracene
890
16
6E-05
Cancer
NA
NA
lndeno(1,2,3-cdjpyrene
3,600
160
2E-05
Cancer
NA
NA
Pesticidesi'PCBs (ug/kg)
| Aroclor-1254 | 3S2 | 240 | 2E-06 | Immune System | 1,200 | D.3
Metals (mg.'kg)
Aluminum
8,572
NA
NA
Central Nervous System
77,000
0.1
Arsenic
8.84
0.68
1E-05
Skin. Cardiovascular System
35
0.3
Cadmium
196
2,100
9E-08
Kidney, Respiratory
71
3
Chromium3-
678
0.30
2E-03
None Specified
230
3
Cobalt
8.51
420
2E-08
Thyroid
23
0.4
Copper
1625
NA
NA
Gastrointestinal System
3,100
0.5
lion
20,263
NA
NA
Gastrointestinal System
55,000
0.4
Lead'4'
142
NA
NA
NA
NA
NA
Manganese
387
NA
NA
Central Nervous System
1.800
0.2
Nickel
78.9
15,000
5E-09
Body Weight, Respiratory
1,500
0.05
Silver
69.1
NA
NA
Skin
390
0.2
Thallium
1.22
NA
NA
Skin
0.78
2
Vanadium
125
NA
NA
Kidney
390
0.3
Radionuclides (pCL'g)
Actinium-227 (Ac-227)
0.035
0.039
9E-07
Cancer
NA
NA
Americium-241 (Am-241)
2.60
0.049
5E-05
Cancer
NA
NA
Carbon-14 (C-14)
0.063
0.15
4E-07
Cancer
NA
NA
Cesium-137 (Cs-137)':5:'
26.3
0.047
6E-04
Cancer
NA
NA
Lead-210 (Pb-210)
34.9
0.0077
5E-03
Cancer
NA
NA
Polonium-210 (Po-210)16'
34.9
0.14
2E-04
Cancer
NA
NA
Neptunium-237 {Np-237)'s:
0.079
0.046
2E-06
Cancer
NA
NA
Nickel-63 (Ni-63)
55
6.7
8E-06
Cancer
NA
NA
Radium-226 (Ra-226)s
61
0.0064
1E-02
Cancer
NA
NA
Sirontium-90 (Sr-90)';)
0.593
0.066
9E-06
Cancer
NA
NA
Thallium-204 (Tl-204)
2.80
2.1
1E-06
Cancer
NA
NA
Tritium (H3)
314
0.23
1E-04
Cancer
NA
NA
Uraniunv238 (U-238)'-a
0.715
0.05
1E-05
Cancer
NA
NA
Uranium-234 (U-234)'71
0.715
0.066
1E-05
Cancer
NA
NA
Total ILCR - Chemicals
2E-03
Total HI
11
Total ILCR - Radionuclides
2E-02
Total ILCR - Chemicals + Radionuclides
2E-02
Target Organ His
Total Immune System HI = 0.3
Total Cardiovascular System HI = 0.3
Total Central Nervous System HI = 0-3
Total Gastrointestinal System HI = 0,9
Total Skin H I = 3
Total Kidney HI = 3_
Total Respiratory HI = 3_
Total Thyroid HI = 0.4
Total Body Weight HI = 0.05
Total None Specified HI = 3
Notes:
1 - Exposure point concentration is the 95% upper confidence limit calculated by ProUCL Version 5.0.00.
2 - For non-radionuctides screening levels are US EPA RSLs for Chemical Contaminants at Superfund Sites, June 2D 15. The noncarcinogenic values
correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of IxlQ"6
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TR=1E-6) November 2014.
3 - Screening levels are for hexavalent chromium.
4 - Risks for exposures to lead 'were evaluated using the IEUBK and ALM models.
5 - Screening level includes daughter products.
6 - Polunium-210 is assumed to be in equilibrium with Lead-210.
7 - Uranium-234 is assumed to be in equilibrium ifctth U-238.
NA - Not applicable. There are no cancer slope factors (CSF) or reference dose (FifD) available forthis chemical.
E-18
AR301694
-------
TABLE E-17
SUMMARY OF RECEPTOR RISKS AMD HAZARDS FOR SITE RELATED COPCs
RESIDENTIAL EXPOSURES TO ALL SOIL (0-10 FEET] - SURVEY UNIT 15
SAFETY LIGHT CORPORATION OU-3
Chemical
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Exposure Point
Concentration'11
Residential
Screening
Level"1
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level™
Estimated
HQ
Semivolatile Organic Compounds (ug.'kgl
Benzo(a)anthracene
4.200
160
3E-05
Cancer
NA
NA
Benzo(a)pyrene
5,000
16
3E-04
Cancer
NA
NA
Benzoiblfluoranthene
6,800
160
4E-05
Cancer
NA
NA
Eienzo(k)fl uoranthene
1,800
1,600
1E-06
Cancer
NA
NA
Dibenzo(a,h}anthracene
890
16
6E-05
Cancer
NA
NA
lndeno(1,2,3-cd )pyrene
3,600
160
2E-05
Cancer
NA
NA
Pesticides,1PCBs (ug,'frg)
Afodor-1254 | 382 [ 240 | 2E-06 | Immune System | 1,200 | 0.3
Metals (mg/kg)
Aluminum
6,572
NA
NA
Central Nervous System
77.000
0.1
Arsenic
8.84
0.68
1E-05
Skin, Cardiovascular System
35
0.3
Cadmium
196
2,100
SE-08
Kidney, Respiratory
71
3
Chromium3'
678
0.30
2E-03
None Specified
230
3
Cobalt
8.51
420
2E-08
Thyroid
23
0.4
Copper
1,625
NA
NA
Gastrointestinal System
3,100
0.5
Iron
20,263
NA
NA
Gastrointestinal System
55,000
0.4
Lead14'
142
NA
NA
NA
NA
NA
Manganese
387
NA
NA
Central Nervous System
1.80D
0.2
Nickel
78.9
15,000
5E-09
Body Weight, Respiratory
1.500
0.05
Stiver
69.1
NA
NA
Skin
390
0.2
Thallium
1.22
NA
NA
Skin
0.78
2
Vanadium
125
NA
NA
Kidney
390
0.3
Radionuclides (pCii'g)
Actinium-227 (Ac-227)
0.035
0.039
9E-07
Cancer
NA
NA
Americium-241 (Am-241)
2.6
0.049
5E-05
Cancer
NA
NA
Carbon-14 (C-14)
0.063
0.15
4E-07
Cancer
NA
NA
Cesium-137 (Cs-137)':s:
26.3
0.047
6E-04
Cancer
NA
NA
Lead-210 (Pb-210)
34.9
Q.0077
5E-03
Cancer
NA
NA
Polonium-210 (Po-210)IS)
34.9
0.14
2E-04
Cancer
NA
NA
Neptunium-237 (Np-237)'5'
0.079
0.046
2E-06
Cancer
NA
NA
Nickel-63 (Ni-63)
55
6.7
6E-06
Cancer
NA
NA
Radium-226 (Ra-226) "
61
0.0064
1E-02
Cancer
NA
NA
Strontium-&0 (Sr-90:r '
0.533
0.066
9E-06
Cancer
NA
NA
Thallium-204 ffl-204)
2.8
2.1
1E-06
Cancer
NA
NA
Tritium (H3)
31.4
0.23
1E-04
Cancer
NA
NA
Uranhm-238 (U 238) ":
-
0.05
-
Cancer
NA
-
Uraniunv234 (U-234)m
-
0.066
-
Cancer
NA
-
Total ILC
R - Chemicals
2E-03
Total HI
11
Total JLCR - Radionuclides
2E-02
Total ILCR - Chemicals + Radionuclides
2E-02
Target Organ His
Total Immune System HI = 0.3
Total Cardiovascular System HI = 0.3
Total Central Nervous System HI = 0.3
Total Gastrointestinal System HI = 0.9
Total Skin HI = 3
Total Kidney HI =
Total Respiratory HI = 3_
Total Thyroid HI = 0.4
Total Body Weight HI = 0.05
Total Nome Specified HI = 3
Notes:
1 - Exposure point concentration is the 95% upper confidence limit calculated by ProUCL Version 5.0.00.
2 - For non-radionucfides screening levels are USEPA RSLs for Chemical Contaminants at Superfund Sites, June 2015. The noncarcinogenic values
correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of 1x10"6
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TR=1E-6> November 2014.
3 - Screening levels are for hexavalent chromium.
4 - Risks for exposures to lead were evaluated using the IEU6K and ALM models.
5 - Screening level includes daughter products.
6 - Polunium-210 is assumed to be in equilibrium with Lead-210.
7 - Uranium-234 is assumed to be in equilibrium with U-238.
E-19
AR301695
-------
TABLE E-18
SUMMARY OF RECEPTOR RISKS AMD HAZARDS FOR SITE RELATED COPCs ABOVE BACKGROUND
RESIDENTIAL EXPOSURES TO ALL SOIL (0-10 FEETl - SURVEY UNIT 15
SAFETY LIGHT CORPORATION OU-3
Incremental Lifetime Carcinogenic Risk (ILCR)
Estimated Non-Carcinogenic Hazard Quotient (HQ)
Chemical
Exposure Point
Concentration*21
Residential
Screening
Level"'
Estimated
ILCR
Primary Target Organ
Residential
Screening
Level™1
Estimated
HQ
Semivolatile Organic Compounds litg-'kgi
Benzo(a)anth racene
4,200
160
3E-05
Cancer
NA
NA
Benzolajpyrene
5,000
16
3E-04
Cancer
NA
NA
Benzo(b)fluoranthene
6,800
160
4E-05
Cancer
NA
NA
Benzoikjfl uoranthene
1,800
1,600
1E-06
Cancer
NA
NA
Dibenzofa,h tanthracene
890
16
6E-05
Cancer
NA
NA
lndeno(1,2,3-cd)pyrene
3,600
160
2E-05
Cancer
NA
NA
Pesticides.'PCBs (ug.'kg)
Aroctor-1254
382
240
2E-06
Immune System
1.200
0.3
Metals (mg.'kg)
Aluminum
8,572
NA
NA
Central Nervous System
77,000
0.1
Arsenic
6.84
0.68
1E-05
Skin. Cardiovascular System
35
0.3
Cadmium
196
2,100
9E-0S
Kidney, Respiratory
71
3
Chromium"
678
0.30
2E-03
tone Specified
230
3
Cobalt
8.51
420
2E-08
Thyroid
23
0.4
Copper
1,625
NA
NA
Gastrointestinal System
3,100
0.5
Iron
20,263
NA
NA
Gastrointestinal System
55.000
0.4
Lead'5'
142
NA
NA
NA
NA
NA
Manganese
387
NA
NA
Central Nervous System
1.800
0.2
Nickel
78.9
15,000
5E-09
Body Weight, Respiratory
1.500
0.05
Silver
69.1
NA
NA
Skin
390
0.2
Thallium
1.22
NA
NA
Skin
0.78
2
Vanadium
125
NA
NA
Kidney
390
0.3
Radionuclides (pCir'g)
Actinium-227 (Ac-227)
0.035
0.039
9E-07
Cancer
NA
NA
Americlum-241 (Am-241)
2.6
0,049
5E-Q5
Cancer
PiA
NA
Cartxsn-14 (C-14)
-
0.15
-
Cancer
NA
-
Cesiunv137 (Cs-137 >:5
26.3
0.047
6E-04
Cancer
NA
NA
Lead-210 (Pb-210)
34.9
0.0077
5E-03
Cancer
NA
NA
Polonium-210 (Po-210)17'
34.9
0.14
2E-04
Cancer
NA
NA
Neptunium-237 (Np-237)'°
0.079
0.046
2E-06
Cancer
NA
NA
Nickel-63 (Ni-63)
55
6.7
BE-06
Cancer
NA
NA
Radlum-226 (Ra-226)':s;
61
0.0064
1E-02
Cancer
NA
NA
Strontium-90 (Sr-90)ISJ
0.593
0.066
9E-06
Cancer
NA
NA
Thallium-204 (TI-204)
2.8
2.1
1E-06
Cancer
NA
NA
Tritium (H3)
31.4
0.23
1E-04
Cancer
NA
NA
Uraniun>-23S (U-238)'61
-
0.05
-
Cancer
NA
-
Uranium-234 (U-234)®
-
0.066
-
Cancer
NA
-
Total ILC
R - Chemicals
2E-03
Total HI
11
Total ILCR - Radionuclides
2E-02
Total ILCR - Chemicals + Radionuclides
2E-02
Target Organ His
Total Immune System HI =
Total Cardiovascular System HI =
Total Central Neivous System HI =
Total Gastrointestinal System HI =
Total Skin HI =
Total Kidney HI =
Total Respiratory HI =
Total Thyroid HI =
Total Body Weight HI =
Total None Specified HI =
Notes
1
Background for ncn-radjonuclides was determined using tie background evaluation presented in the risk assessment presented in the 2008 Rl
The 95 percent upper prediction limit (UPL) was used to determine background for radionuclides (See COPC selection tables).
2 - Exposure point concentration is the 95% upper confidence limit calculated by ProUCL Version 5.0.00.
3 - For non-radionuclides screening levels are US EPA RSLs for Chemical Contaminants at Superfund Sites, June 2015. The noncarcinogertic values
correspond to a target hazard quotient of 1. Carcinogenic values represent an incremental cancer risk of 1x10
For radionuclides screening levels are from the Radionuclide Preliminary Remediation Goals (PRG) Summary Table (TR= 1E-6) November 2014.
4 - Screening levels are for hexavalent chromium.
5 - Risks for exposures to lead were evaluated using the lEUBK and AIM models.
6 - Screening level includes daughter products.
7 - Polonium-21Q is assumed to be in equilibrium with Pb-210.
8 - Uranium-234 is assumed to be in equilibrium vnth U-238.
MA - Not applicable. There are no cancer slope factors {CSF) or reference cose (RfD) availabte for this chemical.
E-20
AR301696
-------
APPENDIX F
ARARS TABLES
F-l
AR301697
-------
This page intentionally left blank.
F-2
AR301698
-------
TABLE F-1
Action-Specific ARARs/TBCs
Safety Light Corporation OU-3
Standard, Requirement,
Criterion, Or Limitation
Citation Or Reference
Description
Status
Comments
FEDERAL
Pennsylvania Hazardous Waste
Management Regulations
PA Code, Title 25, Article VII
Pennsylvania has an EPA
authorized hazardous waste
program; therefore the
Pennsylvania hazardous waste
regulations are identified here as
the applicable Federal hazardous
waste standard
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)
Applicable
Waste characterization
Applicable for characterizing contaminated soil
determined to be sent off-site for disposal.
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)
Applicable
Standards for recordkeeping of the
management actions for hazardous wastes.
Applicable if remedial activities include the off-
site transport of hazardous waste.
25 PA Code §§ 264a. 1
incorporating by reference 40
CFR Part 264, but limited to
substantive parts of Subparts B -
G and I - M)
Relevant and
Appropriate
Standards for the storage of hazardous
wastes.
Requirements for spill response planning and
control
Includes requirements if remedial activities
include the storage of hazardous waste greater
than 90 days.
25 Pa. Code Chapter 266b:
Universal Waste Management
(Incorporating 40 CFR Part 273
except as expressly provided)
Applicable
Universal wastes, including lamps (if
hazardous waste under 40 CFR Part 261) and
"oil based finishes," are subject to specific
waste management and handling
requirements.
In the event that the specified universal wastes
are identified at the Site and require disposal, the
substantive requirements will apply. No
permitting requirements apply.
25 PA Code § 268a. 1
(incorporating by reference 40
CFR Part 268, Subparts A- E,
except as expressly provided)
Applicable
Restricts disposal of hazardous waste that
could trigger land disposal regulations
Includes requirements for minimum treatment
standards for hazardous waste prior to land
disposal.
Packaging and Transportation of
Radioactive Waste
10 C.F.R. Part 71,
Subpart A - General Provisions
§71.5 Transportation of licensed
material;
Subpart B - Exemptions- §71.14
- Exemption for low level
materials
Subpart E - Package Approval
Standards; §71.43-General
standards for all packages;
§71.45 - Lifting and tie-down
standards for all packages;
§71.47 - External radiation
standards for all packages:
Relevant and
Appropriate
Establishes requirements for packaging,
preparation for shipment, and transportation of
licensed material
The substantive portions of these requirements
will be complied with during response actions at
the Site.
F-3
AR301699
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TABLE F-1
Action-Specific ARARs/TBCs
Safety Light Corporation OU-3
Standard, Requirement,
Criterion, Or Limitation
Citation Or Reference
Description
Status
Comments
PENNSYLVANIA
Pennsylvania regulations
governing Residual Waste
Management
25 Pa. Code Chapter 287:
§287.1-Definitions;
§287.2 Scope
25 Pa. Code Chapter 299
§299.101 117 Scope and Gen'l
§299.121-.133 Types of
containers; tanks; storage piles
Applicable
Provides requirements for persons who
generate, manage or handle residual waste,
and specifies that certain residual wastes
(including construction/debris, waste from
grubbing and excavation and friable asbestos
containing waste) shall be regulated as
municipal waste (Article VIII) rather than as a
residual waste.
In the event that material from the OU3 activities
meets the definition of "residual waste," the
substantive requirements of these regulations
would apply. No permitting requirements apply.
Pennsylvania regulations
governing Municipal Waste
Management
(Article Vlll)-Chapter 285
Subchapter A -
Storage of Municipal Waste
25 Pa. Code Chapter 285
Applicable
Specifies requirements for persons who store
municipal waste
The substantive requirements of this regulation
will apply for material that meets the definition of
municipal waste, or is otherwise subject to Article
VIII pursuant to 25 Pa. Code Chapter 287. No
permitting requirements apply.
Pennsylvania Regulations for
Collecting and Transporting of
Residual Wastes
25 PA Code §299.211-216.
Applicable
Collection and transportation of residual waste
The substantive requirements of this regulation
will apply for collection and transportation of
residual wastes, if any. No permitting
requirements apply.
Pennsylvania Standards for
Contamination for Fugitive
Particulate Matter
25 Pa. Code §123.2
Applicable
Prohibits release of visible fugitive particulate
matter from outside the property boundary.
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. No permitting requirements apply.
Pennsylvania Regulations for
Packaging and Transport of
Radioactive Materials
PA Code, Title 25, Chapter 230
Relevant and
Appropriate
PADEP criteria for packaging and
transportation of licensed material
Pennsylvania has incorporated the requirements
of 40 CFR 71 (relating to packaging and
transport of radioactive materials) by reference.
Only the substantive requirements of this
regulation will apply.
Pennsylvania Regulations for
Erosion and Sediment Control
25 Pa. Code Chapter 102
§102.4(b)-erosion &
sedimentation control reqts,
§102.11-general reqts
§102.22-site stabilization
Applicable
Identifies erosion and sediment control
requirements and criteria for earth disturbance
activities other than agricultural plowing or
tilling or animal heavy use areas
The substantive portions of these regulations,
including use of best management practices and
design standards, apply to earth disturbance
activities at the site including clearing, grading,
and excavation. No permitting requirements
apply.
Pennsylvania Storm Water
Management Act
32 P.S. § 680.13 -Duties of
Persons Engaged in
Development of Land
Applicable
Provides storm water runoff control
requirements during construction activities.
Applicable to alteration or development of land
which may affect storm water runoff
characteristics, if any, during the OU-3 remedial
action. No permitting requirements apply.
F-4
AR301700
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TABLE F-1
Action-Specific ARARs/TBCs
Safety Light Corporation OU-3
Standard, Requirement,
Criterion, Or Limitation
Citation Or Reference
Description
Status
Comments
Department of Environmental
Protection Bureau of Land
Recycling and Waste
Management:
Management of Fill
258-2182-773
TBC
Establishes clean fill requirements
TBC for soils used as clean fill at excavated
areas at the site.
Pennsylvania's Land Recycling
Program Technical Guidance
Manual
253-0300-100
TBC
Establishes recommendations and guidance
for attainment of site specific standards in soil
at voluntary state cleanup Sites for land reuse.
TBC for remedial activities involving soil.
F-5
AR301701
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TABLE F-2
Contaminant-Specific ARARs/TBCs are the
Safety Light Corporation OU-3
Bloomsburg, Pennsylvania
Standard, Requirement, Criterion,
Or Limitation
Citation Or
Reference
Description
Status
Comments
FEDERAL
Cleanup of Radioactively
Contaminated Superfund Sites
OSWER Directive
9200.4-18
TBC
EPA Guidance to use the Superfund remedy selection
framework when addressing radionuclides.
Provides guidance that NRC rules are not
protective and that even if they are
ARARs, risk range should be achieved.
Standards for Protection Against
Radiation
10 C.F.R. Part 20,
Subpart C -
Occupational Dose
Limits;
Subpart D - Radiation
Dose Limits for the
Public:
Subpart G - Control
of Exposures from
External Sources;
Respiratory
Protection:
Subpart I - Storage
and Control;
Subpart J
Precautionary
Measures:
Subpart H -
Appendix B, Table 2
Relevant and
Appropriate
NRC regulation pertaining to radiological standards for
discharge/emissions
The substantive portions of these
requirements will be complied with during
response actions at the Site.
Termination of Byproduct, Source,
and Special Nuclear Material
Licenses
NRC Policy and
Guidance Directive
FC83-23
TBC
Nuclear Regulatory Guidance for release of
radiological contaminated materials.
This guidance will be considered for
excavation activities, and segregation
of debris as radioactively contaminated or
nonradioactively contaminated
Termination of Operating Licenses
for Nuclear Reactors
NRC Regulatory
Guide 1.86
TBC
Nuclear Regulatory Guidance describes methods and
procedures considered acceptable by NRC staff for
the termination of operating licenses for nuclear
reactors, and includes information and considerations
for decontamination for release and unrestricted reuse
This guidance will be considered during
OU-3 remedial activities
National Emission Standards for
Hazardous Air Pollutants (NESHAP),
Subpart H: National Emission
Standards for Emissions of
Radionuclides Other Than Radon
From Department of Energy
Facilities
40 CFR Part 61
§ 61.92-standard
§ 61.93-emissions
monitoring and testing
procedures
Relevant and
Appropriate
EPA regulation pertaining to limit of radiological dose
to public from air emissions at DOE facilities.
Provides 10 millirem/year standard for
protecting the public.
F-6
AR301702
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TABLE F-2
Contaminant-Specific ARARs/TBCs are the
Safety Light Corporation OU-3
Bloomsburg, Pennsylvania
Standard, Requirement, Criterion,
Or Limitation
Citation Or
Reference
Description
Status
Comments
EPA Soil Screening Guidance
EPA/540/R-96/018
July 1996
TBC
Provides methodology for calculating risk-based, site-
specific soil screening levels.
Used to standardize and accelerate site
cleanup.
EPA Region III Risk-Based
Concentration Table
www.epa.gov/reg3hw
md/risk/human/rb-
concentration_table/G
eneric_Tables/
TBC
Establishes chemical screening guidelines for use
during risk assessment.
May be useful in development of
screening levels.
Risk Assessment Guidance for
Superfund, Volume 1, Part A
EPA/540/1-89/002
TBC
Defines Preliminary Remediation Goals and Remedial
Action Levels for soil
Applicable when evaluating the adequacy
of soil remediation activities.
PENNSYLVANIA
Pennsylvania Radiological Health -
Standards for Protection Against
Radiation
PA Code, Title 25,
Chapter 219
Relevant and
Appropriate
Establishes standards of protection against ionizing
radiation.
Pennsylvania has incorporated the
requirements of 10 CFR 20 (relating to
standards for protection against radiation)
by reference. Only the substantive
requirements of this regulation will apply.
Pennsylvania Radiological Health -
Low Level Radioactive Waste
Management and Disposal
PA Code, Title 25,
Chapter 236
§236.501-524-Waste
classification,
characteristics,
labeling and
manifests
Applicable
Identifies radioactive waste classification
considerations and minimum requirements for classes
of radioactive wastes.
The substantive portions of these
requirements will be complied with during
the OU3 activities at the Site.
Pennsylvania National Emission
Standards for
Hazardous Air Pollutants (NESHAP)
25 Pa. Code Chapter
124
§124.3
Relevant and
Appropriate
Pennsylvania has adopted the federal
NESHAP (40 CFR Part 61) in its entirety
Pennsylvania Soil and Ground
Water Remediation Levels
25 PA Code 250,
§250.402 - Human
Health and
Environmental
Protection Goals
Applicable
Protocol for developing site remediation standards
Applicable for use of site-specific
standards
F-7
AR301703
-------
TABLE F-3
Location-Specific ARARs/TBCs are the
Safety Light Corporation OU-3
Bloomsburg, Pennsylvania
Standard, Requirement, Criterion,
Or Limitation
Citation Or
Reference
Description
Status
Comments
FEDERAL
National Historic Preservation Act of
1966, as amended
16 U.S.C. §470
Applicable
Requirements relating to preserving historical and
archaeological resources; requires Federal agencies
to evaluate the impact of their undertakings on
properties included on, or eligible for inclusion in, the
National Register of Historic Places.
The preferred alternative has the potential
for disturbing historically significant
resources (old canal). Further action will
be taken to identify and mitigate adverse
effects on such identified resources. The
substantive requirements will be met.
PENNSYLVANIA
Pennsylvania Floodplain
Management
25 Pa. Code Chapter
106
§106.31 - Hydraulic
capacity
§106.32-Site
Drainage Structures
Relevant and
Appropriate
Standards for construction in 100 year floodplain,
wetlands and regulated waters.
The substantive portions of these
regulations apply to activities at the site
that occur in the floodplain, if any. No
permitting requirements apply.
F-8
AR301704
-------
APPENDIX G
PHOTOS
G-l
AR301705
-------
This page intentionally left blank.
G-2
AR301706
-------
Photo 1: West Lagoon Excavation
Photo 2: Radium Dials/Items in Excavation
G-3
AR301707
-------
i U ¦ ^
4F;S ifx ;T|*T
X A ,
Ml
kJ kL v •, ,JiB
1lllli
Photo 3: Item found in West Dump with 27,000 dpm alpha contamination.
G-4
AR301708
-------
APPENDIX H
REMEDIAL ALTERNATIVE COSTS
H-l
AR301709
-------
This page intentionally left blank.
H-2
AR301710
-------
TABLE H-l
SAFETY LIGHT CORPORATION .BLOOMSBURG, PENNSYLVANIA
SURVEY UNITS 12,13,14, AND 15
REMEDIAL ALTERNATIVES SCREENING
ALTERNATIVE 2: SOIL EXCAVATION AND OFF-SITE DISPOSAL
Capital Cost
Item
Quantity
Unit
Unit Cost
Total Cost
Subtotal
Direct Cost
Subcontract
Material
Labor
Equipment
Subcontract
Material
Labor
Equipment
1 PROJECT DOCUMENTS/INSTITUTIONAL CONTROLS
1.1 Prepare Documents, Plans, and Permits
300
hr
$40.93
$0
$0
$12,279
$0
$12,279
1.2 Prepare Deed Notifications/Restrictions
1
Is
$10,000.00
$10,000
$0
$0
$0
$10,000
2 SITE PREPARATION AND FIELD SUPPORT
2.1 Office Trailer
6
mo
$488.50
$0
$0
$0
$2,931
$2,931
2.2 Field Office Support
6
mo
$200.00
$0
$1,200
$0
$0
$1,200
2.3 Storage Trailer
6
mo
$108.00
$0
$0
$0
$648
$648
2.4 Utility Connection/Disconnection (phone/electric>
1
Is
1500.00
$1,500
$0
$0
$0
$1,500
2.5 Site Utilities
6
mo
350.00
$2,100
$0
$0
$0
$2,100
2.6 Construction Survey Support
2
days
$775.00
$43.50
$0
$1,550
$87
$0
$1,637
2.7 Equipment Mobilization/Demobilization
6
ea
$375.00
$375.00
$0
$0
$2,250
$2,250
$4,500
2.8 Site Superintendent
6
mo
$8,683.84
$0
$0
$52,103
$0
$52,103
2.9 Site Health & Safety and QA/QC (2 Persons)
12
mo
$7,203.68
$0
$0
$86,444
$0
$86,444
### Materials Storage Pad, 25' X 25"
1
Is
$1,000.00
$250.00
$200.00
$0
$1,000
$250
$200
$1,450
### Spray Truck for Dust Suppression
6
mo
$4,200.00
$0
$0
$0
$25,200
$25,200
### Water for Dust Suppression. 2,000 gatfmonth
12,000
gal
$0.20
$0
$2,400
$0
$2,400
### Cut & chip trees to 6" diam, Grub Stumps
1
Is
1800.00
$1,800
$0
$0
$0
$1,800
### Clear Site, grasses & brush
1
acre
$204.00
$185.00
$0
$0
$255
$231
$486
### Erosion and Sedimentation Controls
1
Is
8000.00
$8,000
$0
$0
$0
$8,000
3 DECONTAMINATION
3.1 Equipment Decon Pad
1
Is
$2,500.00
$3,350.00
$400.00
$0
$2,500
$3,350
$400
$6,250
3.2 Radiation Decontamination Services
6
mo
$60,000.00
$360,000
$0
$0
$0
$360,000
3.3 Pre/Post Decontamination Survey
110
ea
$400.00
$0
$44,000
$0
$0
$44,000
4 EXCAVATION AND DISPOSAL
4.1 Excavator, Crawler Mounted, 1-1/2 cy
4.5
mo
$15,613.98
$18,754.40
$0
$0
$70,263
$84,395
$154,658
4.2 Front End Loader, 3 cy (145HP)
4.5
mo
$12,132.66
$9,508.90
$0
$0
$54,597
$42,790
$97,387
4.3 Dozer, Crawler, 105 H. P.
3.5
mo
$12,132.66
$11,037.80
$0
$0
$42,464
$38,632
$81,097
4.4 LLRW Waste Acceptance Certification
1
Is
$10,000.00
$10,000
$0
$0
$0
$10,000
4.5 Confirmation Sampling and Testing -PAHs, metals. 1 week TAT
50
ea
$415.00
530.00
$80.00
$30.00
$20,750
$1,500
$4,000
$1,500
$27,750
4.5 Confirmation Sampling and Testing -Radionuclides, 1 week TAT
50
ea
$800.00
$30.00
$80.00
$30.00
$40,000
$1,500
$4,000
$1,500
$47,000
4.6 Off Site Transportation & Disposal, Non-Hazardous
0
tons
$65.00
$0
$0
$0
$0
$0
4.7 Off Site Disposal as Radioactive Waste
9,683
tons
$300.00
$2,904,900
$0
$0
$0
$2,904,900
4.8 Transportation with Intermodal Container by Rail
7,173
cy
$170.00
$1,219,410
$0
$0
$0
$1,219,410
4.8 Container Liner
300
ea
S40.00
$0
$12,000
$0
$0
$12,000
4.9 Truck for Moving Container
5
mo
$4,200.00
$0
$0
$0
$21,000
$21,000
### Radiation/ Safety Monitoring Instruments & Supplies
5
mo
$5,000.00
$25,000
$0
$0
$0
$25,000
5 BACKFILL.' SITE REGRADING AND GRAVEL COVEP
5.1 Front End Loader, 3 cy (145HP)
1.5
mo
$12,132.66
$9,508.90
$0
$0
$18,199
$14,263
$32,462
5.2 Dozer, 105 H. P.
15
mo
$12,132.66
$11,037.80
$0
$0
$18,199
$16,557
534,756
5.3 Vibratory Roller (35HP)
3
week
$2,802.00
$1,197.00
$0
$0
S8.406
$3,591
511,997
5.4 Clean Backfill Soil
9,320
cy
$18.75
$0
$174,750
$0
$0
$174,750
5.4 Geotextile Soil Stabilization
1,884
sy
$0.95
$0.24
$0
$1,790
$452
$0
$2,242
5.5 Gravel Cover. 12" thickness
628
cy
$20.50
$0
$12,874
$0
$0
512,874
5.6 Site Regrading
1
Is
$2,381.00
$2,381
$0
$0
$0
$2,381
6 POST CONSTRUCTION COST
fi 1 Contractor Completion Report
?(¥)
hr
$40 93
$n
$n
SR.IRfi
sn
$fl,1fifi
Subtotal
$4,605,841
$257,064
$385,785
$256,088
$5,504,778
Local Area Adjustments
100.0%
93.2%
100.0%
100.0%
$4,605,841 $239,583 $385,785 $256r088 $5,487,297
H-3
AR301711
-------
TABLE H-l - CONTINUED
SAFETY LIGHT CORPORATION .BLOOMSBURG. PENNSYLVANIA
SURVEY UNITS 12, 13, 14, AND 15
REMEDIAL ALTERNATIVES SCREENING
ALTERNATIVE 2: SOIL EXCAVATION AND OFF-SITE DISPOSAL
Capital Cost
Item
Quantity
Unit
Unit Cost
Total Cost
Subtotal
Direct Cost
Subcontract Material Labor Equipment
Subcontract Material Labor Equipment
Overhead on Labor Cost @
30%
$115,735
$115,735
G & A on Labor Cost {§>
10%
$38,578
$38,578
G & A on Material Cost @
10%
$23,958
$23,958
G & A on Subcontract Cost @
10%
$460,584
$460,584
G & A on Equipment Cost @
10%
$25„60S
$25,609
Tax on Materials and Equipment Cost @
6%
514,375 $15,36£
$29,740
Total Direct Cost
$5,066,425 $263,542 $540,098 $281,697
56.151,763
Indirects on Total Direct Cost @
25%
(excluding transportation and disposal cost)
$506,863
Profit on Total Direct Cost @
10%
$615,176
Subtotal
$7,273,802
Health & Safety Monitoring @
2%
(includes air quality monitoring)
$145,476
Total Field Cost
57,419,278
Contingency on Total Field Costs @
20%
51,483,856
Engineering on Total Field Cost @
5%
(excluding transportation and disposal cost)
$164,748
TOTAL COST $9,067,882
H-4
AR301712
-------
TABLE H-2
SAFETY LIGHT CORPORATION .BLOOMSBURG, PENNSYLVANIA
SURVEY UNITS 12, 13, 14, AND 15
REMEDIAL ALTERNATIVES SCREENING
ALTERNATIVE 2
Item Cost
Item Cost
Item
Years 1 through 30
per 5 years
Notes
Groundwater Monitoring
SO
Groundwater monitoring will not be conducted.
Groundwater will be the focus of OU-2.
Site Review
$30,000
Review of site conditions by two engineers for Years 5,10, 15,
20, 25. and 30
TOTALS
SO
$30,000
IT-5
AR301713
-------
TABLE H-3
PRESENT WORTH ANALYSIS
ALTERNATIVE 2 - SOIL EXCAVATION AND OFF-SITE DISPOSAL,
REMEDIAL ALTERNATIVES SCREENING
SURVEY UNITS 12, 13, 14. AND 15
SAFETY LIGHT CORPORATION, BLOOMSBURG, PENNSYLVANIA
Year
Capital I Annua!
Cost | Cost
Total Year
Cost
Annual Discount
Rate at 7%
Present
Worth
0
$9,067,882
$9,067,882
1.000
$9,067,882
1
SO
$0
0.935
$0
2
so
$0
0.873
$0
3
SO
$0
0.816
$0
4
SO
$0
0.763
$0
5
SO
S30.000
0.713
$21,390
6
SO
$0
0.666
$0
7
SO
$0
0.623
$0
8
SO
$0
0.582
$0
9
SO
$0
0.544
$0
10
SO
530,000
0.508
$15,250
11
so
$0
0.475
$0
12
so
$0
0.444
$0
13
so
$0
0.415
$0
14
so
$0
0.388
$0
15
so
S30.000
0.362
$10,873
16
so
$0
0.339
$0
17
so
$0
0.317
$0
18
so
$0
0.296
$0
19
so
$0
0.277
$0
20
so
530,000
0.258
$7,753
21
so
$0
0.242
$0
22
so
$0
0.226
$0
23
so
$0
0.211
$0
24
so
$0
0.197
$0
25
so
530, OOD
0.184
$5,527
26
so
$0
0.172
$0
27
so
$0
0.161
$0
28
so
$0
0.150
$0
29
so
$0
0.141
$0
30
so
530,000
0.131
$3,941
TOTAL PRESENT WORTH $9,132,616
Discount rate of 7% per OSWER Directive No. 9355.3-20, June 1993
H-6
AR301714
-------
APPENDIX I
PADEP CONCURRENCE LETTER
1-1
AR301715
-------
Page intentionally left blank
1-2
AR301716
-------
«£!?» Pennsylvania
DEPARTMENT OF ENVIRONMENTAL
PROTECTION
June 30,2018
Dominique Lueckenhoff
Division Director
Hazardous Sites Cleanup Division
US EPA Region III
1650 Arch Street (3HS00)
Philadelphia, PA 19103-2029
Re: Early-Interim Record of Decision (ROD)
Safety Light Corporation Site
South Centre Township, Bloomsburg, PA
Dear Ms. Lueckenhoff:
The Department of Environmental Protection (DEP) lias received and reviewed the Early-Interim
Record of Decision (ROD) for the Safety Light Corporation site in South Centre Township,
Clinton County. This Early-Interim ROD presents the selected remedial action for Operable
Unit Three (OIJ3), which addresses the soils for the West Dump, West Lagoon, East Dump, and
East Lagoon portions of the 10-acre site. These areas have been impacted by radionuclides and
other non-radionuclide contaminants (i.e., heavy metals and other organic compounds) as a result
of former operations at the Site. The remainder of OU-3 will be addressed in future response
actions. EPA is currently performing a Removal Action to address the contamination located in
the West Dump, West Lagoon, East Dump, and East Lagoon areas. EPA has decided to use this
early-interim approach in order to expediently convert the ongoing Removal Action to an
Early-Interim Remedial Action. The current Remedial Investigation (RI) for OU-3 will continue
during and beyond the Early Interim Remedial Action to determine the full nature and extent of
the contamination in OU-3.
The selected remedy for the OU-3 includes the following major components:
• Mobilize and setup support facilities, remove vegetation, and establish soil erosion and
sediment controls. Regularly inspect and maintain erosion and sediment controls during
vegetation clearance, soil excavation and stockpiling, waste loading, backfilling, and
regrading operations, until excavation and backfilling is complete and a gravel protective
cover is established at the West Dump, West Lagoon, East Dump, and East Lagoon to
minimize erosion.
• Excavate all materials including soils/debris and radioactive discrete objects from the
West Dump, West Lagoon, East Dump, and East Lagoon in the approximate area of
concern depicted in Appendix C (Figures 4 to 7). Continue vertical excavation until
ground water or the native soil interface (the point at which fill material meets the native
soil surface) is encountered, whichever occurs first, or to the maximum extent practicable
Northcentral Regional Office
208 West Third Street, Suite 101 | Williamsport, PA 17701-6448 | 570.327.3695 | F 570.327,3S6S
www.dep.pa.gov
AR301717
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Dominique Lueckcnhoff
2
June 30,2018
based on Site or excavation conditions. Excavation depths are expected to range from
approximately 4 to 16 feet below ground surface (bgs). The total in-situ volume of
material designated for removal is approximately 5,978 cubic yards.
• Collect post-excavation samples from the floor and side walls of each excavation area,
prior to backfilling and regrading, to determine and document the concentration of
radionuclide and non-radionuclide soil contamination that may remain in-place. Conduct
gamma walkovers of the excavated areas prior to backfilling to assess any remaining
radiological activity.
• Package all excavated material as radioactive waste and load into intermodal containers
(IMCs) for shipment to disposal sites. Transfer excavated material by licensed vendors in
accordance with transportation regulations to an off-site facility as described in #5,
below.
• Dispose off-site, at a Nuclear Regulatory Commission (NRC) licensed radioactive waste
facility, and in accordance with Section 121(d)(3) of CERCLA, 42 U.S.C. § 121(d)(3),
and Section 300.440 of the NCP, 40 C.F.R. § 300.440, all soils, materials, and items
excavated pursuant to item #2 above. Certain waste materials (including, but not limited
to, dials and some discrete objects) may also exhibit chemical hazardous waste
characteristics requiring treatment (e.g. stabilization) prior to permanent disposal. Such
waste materials shall be sampled and analyzed using the Toxicity Characteristic Leaching
Procedure (TCLP) pursuant to the Resource Conservation and Recovery Act (RCRA) to
determine if they exhibit hazardous waste characteristics. For those waste materials that
fail TCLP, such treatment shall be performed at the off-site licensed radioactive waste
facility to render such materials non-hazardous prior to disposal at that licensed facility.
• Backfill excavated areas with clean material derived from an off-site borrow source.
Backfill material shall meet Pennsylvania Criteria for Management of Fill specifications
for chemical constituents, as certified through laboratory analysis. Rcgrade excavated
areas to approximate original contours, ensuring appropriate site drainage. Install and
place geotextile and a layer of gravel, with a minimum thickness of 12 inches, on
disturbed surfaces of the West Dump, West Lagoon, East Dump, and East Lagoon as a
protective cover to minimize erosion.
The DEP hereby concurs with EPA's proposed remedy with the following conditions:
¦ The 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 action, to assure
compliance with Pennsylvania's Applicable, Relevant and Appropriate Requirements
(ARARs) and to be considered requirements (TBCs).
AR301718
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Dominique Lueckenhoff
3
June 30,2018
¦ The DEI' will have the opportunity to review and comment before any modification to
the ROD and the issuance of an Explanation of Significant Difference (BSD).
* This concurrence with the selected remedial action is not intended to provide any
assurances pursuant to CERCLA Section 104(c)(3), 42 U.S.C. 9604(c)(3).
* EPA will assure that the DEP is provided an opportunity to fully participate in any
negotiations with responsible parties.
11 The DEP reserves the right and responsibility to take independent enforcement
actions pursuant to state law,
Thank you for the opportunity to comment and concur on this EPA Record of Decision, if you
have any questions regarding this matter, please do not hesitate to contact me at 570.327.3695.
Director
Northcentral Region
cc: John Banks, EPA Region III
Chris Weither, DEP Region
Cheryl Sinclair, DEP Region
File
Sincerely,
AR301719
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