HRS DOCUMENTATION RECORD COVER SHEET
Name of Site:
Sherwin-Williams/Hilliards Creek
EPA ID No.:
NJSFN0204181
Contact Persons
Documentation Record:
Alicia G. Shultz, Project Manager
Tetra Tech START
(518) 356-3793
Pathways. Components, or Threats Not Scored
The ground water migration, soil exposure, and air migration pathways were not evaluated because they are
not expected to add significantly to the Hazard Ranking System (HRS) site score.
Ground Water Migration Pathway:
Although ground water contamination has been documented on site, the number of drinking water wells
located within a 4-mile radius of the site is low (Reference [Ref.] 31, p. 2-13, 2-14).
Soil Exposure Pathway:
Lead-contaminated soil has been documented on one residential property. In October 2003, an interim
removal action was completed on the property: the top 6 inches of soil were excavated from the property and
disposed of (Ref. 50, pp. ES-1, 2-3). Lead-contaminated soil may remain on the property (Ref. 51, Table 4
and Appendix A) since only the top 6 inches of soil were removed from the property and the results for
samples collected from below this depth indicated concentrations of lead greater than 400 milligrams per
kilogram (Refs. 50, pp. 1-2, 2-3; 51, Appendix A). Soil samples were collected from within the 100-year
flood plain of Hilliards Creek to evaluate whether periodic flooding transported contaminated sediments from
Hilliards Creek to the banks (flood plain) of Hilliards Creek (Ref. 51, pp. 5, 8). As documented in the other
sources section of this HRS documentation record, lead was detected in the flood plain soil samples at
concentrations exceeding three times the background concentration along Hilliards Creek from Gibbsboro
Road to sample location T-14, a distance of approximately 2,800 feet (Ref. 51, Figure 4; the other source
section of this HRS documentation record). Six areas of concern were identified including the Hilliards Creek
Wildlife Preserve (Ref. 51, p. 9). Many homes are located near the 100-year flood plain of Hilliards Creek.
There is the potential for the lead-contaminated sediment in Hilliards Creek to be carried by floods onto
residential properties located within or near the 100-year flood plain of Hilliards Creek (Ref. 97). However,
current reference documentation does not indicate that contaminated soil is located on additional residential
properties.
l
-------
HRS DOCUMENTATION RECORD COVER SHEET (Continued)
Air Migration Pathway:
No air samples have been collected. Therefore, an observed release to the air migration pathway from on-site
sources can not be documented. As documented in Section 2.4.1 for Source 1, volatile organic compounds
(VOC) have been detected in free-phase product samples collected from ground water located near Buildings
55 and 67. VOCs also were detected in soil samples collected from Sources 1, 2, and 4, as documented in
Section 2.4.1 for each source. There is the potential for the VOCs in the source areas to release to air and into
occupied buildings.
li
-------
HRS DOCUMENTATION RECORD
Name of Site:
EPA Region:
Date Prepared:
Street Address of Site*
City, County, State:
Sherwin-Williams/Hilliards Creek
2
February 8, 2006; Revised March 2008 (Pages 1, 17-20, 24, 28-29, 41-42,
47, 55-56, 179, 180, 188-201, and 215-218 revised March 2008; page
179a added March 2008)
Foster Avenue and Gibbsboro Road
Gibbsboro, Camden County, New Jersey 08026
General Location in the State: Central
Topographic Map: Clementon, New Jersey
Latitude: 39.835525541° North
Longitude: 74.964976916°West
The coordinates of Sherwin-Williams/Hilliards Creek were calculated from the northwest corner of Building
67 shown on Reference 97.* The coordinates were measured using map interpolation from Clementon, New
Jersey Quadrangle, using ArcGIS 9© software. Universal Transverse Mercator (UTM) coordinates converted
to latitude and longitude NAD83 using CorpsCon software, US Army Corps of Engineers Topographic
Engineering Center (Ref. 9).
* The street address, coordinates, and contaminant locations presented in this HRS documentation record
identify the general site location. The information represents one or more locations U.S. Environmental
Protection Agency (EPA) considers part of the site based on the screening information EPA used to evaluate
the site for listing on the National Priorities List. EPA assigns national priorities from the known "releases
or threatened releases" of hazardous substances; thus, the focus is on the release, and not on precisely
delineated boundaries. A site is defined as an area where a hazardous substance has been "deposited, stored,
placed, or otherwise have come to be located." Generally, HRS scoring and the subsequent listing of a release
represent the initial determination that a certain area may need to be addressed under the Comprehensive
Environmental Response, Compensation, and Liability Act. Accordingly, EPA contemplates that the
preliminary description of site boundaries at the time of scoring will be refined as more information is
developed on the location of contamination.
Scores
Ground Water Migration Pathway
Surface Water Migration Pathway
Soil Exposure Pathway
Air Migration Pathway
HRS SITE SCORE
Not Scored
100
Not Scored
Not Scored
50.00
1
-------
WORKSHEET FOR COMPUTING HRS SITE SCORE
s s2
1. Ground Water Migration Pathway Score (Sgw) 0.00 0.00
(from Table 3-1, line 13)
2a. Surface Water Overland/Flood Migration Component 100 10.000
(from Table 4-1, line 30)
2b. Ground Water to Surface Water Migration Component _84 7.056
(from Table 4-25, line 28)
2c. Surface Water Migration Pathway Score (Ssw) 10.000 10.000
Enter the larger of lines 2a and 2b as the pathway score.
3. Soil Exposure Pathway Score (Ss) 0.00 0.00
(from Table 5-1, line 22)
4. Air Migration Pathway Score (Sa) 0.00 0.00
(from Table 6-1, line 12)
5. Total of Sg^2 + Ssw2 + Ss2 + Sa2 10.000
6. HRS Site Score Divide the value on line 5 50.00
by 4 and take the square root
2
-------
Table 4-1 -Surface Water Overland/Flood Migration Component Score sheet
Factor categories and factors Maximum Value Assigned
Value
Watershed Evaluated: Hilliards Creek
Drinking Water Threat
Likelihood of Release:
1. Observed Release
550
550
2. Potential to Release by Overland Flow:
2a. Containment
10
2b. Runoff
10
2c. Distance to Surface Water
5
2d. Potential to Release by Overland Flow [lines
2a(2b + 2c)]
35
3.Potential to Release by Flood:
3 a. Containment (Flood)
10
3b. Flood Frequency
50
3c. Potential to Release by Flood (lines 3a x 3b)
500
4. Potential to Release (lines 2d + 3c, subject to a
maximum of 500)
500
5. Likelihood of Release (higher of lines 1 and 4)
550
550
Waste Characteristics:
5. Toxicity/Persistence
(a)
10000
7. Hazardous Waste Quantity
(a)
100
8. Waste Characteristics
100
32
Targets:
9. Nearest Intake
50
10. Population:
10a. Level I Concentrations
(b)
10b. Level II Concentrations
(b)
10c. Potential Contamination
(b)
lOd. Population (lines 10a + 10b + 10c)
(b)
11. Resources
5
12. Targets (lines 9 + lOd +11)
(b)
Drinking Water Threat Score:
13. Drinking Water Threat Score [(lines 5x8xl2)/82,500,
subject to a max of 100]
100
0
Human Food Chain Threat
Likelihood of Release:
14. Likelihood of Release (same value as line 5)
550
550
3
-------
Table 4-1 -Surface Water Overland/Flood Migration Component Score sheet
Factor categories and factors
Maximum
Value
Value Assigned
Waste Characteristics:
15. Toxicity/Persistence/Bioaccumulation
(a)
500,000,000
16. Hazardous Waste Quantity
(a)
100
17. Waste Characteristics
1000
320
Targets:
18. Food Chain Individual
50
20
19. Population
19a. Level I Concentration
(b)
19b. Level II Concentration
(b)
19c. Potential Human Food Chain Contamination
(b)
19d. Population (lines 19a + 19b + 19c)
(b)
20. Targets (lines 18 + 19d)
(b)
20
Human Food Chain Threat Score:
21. Human Food Chain Threat Score [(lines 14x17x20)/82,500,
subject to max of 100]
100
42.67
Environmental Threat
Likelihood of Release:
22. Likelihood of Release (same value as line 5)
550
550
Waste Characteristics:
23. Ecosystem Toxicity/Persistence/Bioaccumulation
(a)
500,000,000
24. Hazardous Waste Quantity
(a)
100
25. Waste Characteristics
1000
320
Targets:
26. Sensitive Environments
26a. Level I Concentrations
(b)
750
26b. Level II Concentrations
(b)
25
26c. Potential Contamination
(b)
26d. Sensitive Environments (lines 26a + 26b + 26c)
(b)
775
27. Targets (value from line 26d)
(b)
775
Environmental Threat Score:
28. Environmental Threat Score [(lines 22x25x27)/82,500
subject to a max of 601
60
60
Surface Water Overland/Flood Migration Component Score for a
Watershed
29. Watershed Score0 (lines 13+21+28, subject to a max of
100)
100
100
Surface Water Overland/Flood Migration Component Score
30. Component Score (S^)0 (highest score from line 29 for all
watersheds evaluated)
100
100
' Maximum value applies to waste characteristics category
' Maximum value not applicable
: Do not round to nearest integer
4
-------
Table 4-25 -Ground Water to Surface Water Migration Component Score sheet
Factor categories and factors Maximum Value
Value Assigned
Aquifer Evaluated: Surficial
Drinking Water Threat
Likelihood of Release to an Aquifer:
1. Observed Release
550
550
2. Potential to Release:
2a. Containment
10
2b. Net Precipitation
10
2c. Depth to Aquifer
5
2d. Travel Time
35
2e. Potential to Release [lines 2a(2b + 2c + 2d)]
500
3. Likelihood of Release (higher of lines 1 and 2e)
550
550
Waste Characteristics:
%. Toxicity/Mobility
(a)
10000
5. Hazardous Waste Quantity
(a)
100
5. Waste Characteristics
100
32
Targets:
7. Nearest Well
(b)
0
8. Population:
8a. Level I Concentrations
(b)
8b. Level II Concentrations
(b)
8c. Potential Contamination
(b)
8d. Population (lines 8a + 8b + 8c)
(b)
9. Resources
5
10. Targets (lines 7 + 8d + 9)
(b)
0
Drinking Water Threat Score:
11. Drinking Water Threat Score ([lines 3 x 6 x
100
0
101/82,500, subject to max of 100)
Human Food Chain Threat
Likelihood of Release:
12. Likelihood of Release (same value as line 3)
550
550
Waste Characteristics:
13. Toxicity/Mobility/Persistence/Bioaccumulation
(a)
20000000
14. Hazardous Waste Quantity
(a)
100
15. Waste Characteristics
1000
180
5
-------
Table 4-25 -Ground Water to Surface Water M
[igration Component Score sheet
Factor categories and factors
Maximum
Value
Value Assigned
Targets:
16. Food Chain Individual
20
17.
Population
17a. Level I Concentration
(b)
17b. Level II Concentration
(b)
17c. Potential Human Food Chain Contamination
(b)
17d. Population (lines 17a + 17b + 17c)
(b)
18. Targets (lines 16 + 17d)
(b)
Human Food Chain Threat Score:
19. Human Food Chain Threat Score [(lines
12x15x18)782,500,suject to max of 100]
100
24
Environmental Threat
Likelihood of Release:
20. Likelihood of Release (same value as line 3)
550
550
Waste Characteristics:
21. Ecosystem Toxicity/Persistence/Bioaccumulation
(a)
50000000
22. Hazardous Waste Quantity
(a)
100
23. Waste Characteristics
1000
180
Targets:
24. Sensitive Environments
24a. Level I Concentrations
(b)
750
24b. Level II Concentrations
(b)
25
24c. Potential Contamination
(b)
24d. Sensitive Environments (lines 24a + 24b + 24c)
(b)
775
25. Targets (value from line 24d)
(b)
775
Environmental Threat Score:
26. Environmental Threat Score [(lines 20x23x25)/82,500
subject to a max of 601
60
60
Ground Water to Surface Water Migration Component
Score for a Watershed
2
7. Watershed Scorec (lines 11 + 19 + 28, subject to a max
f 100)
100
84
2
a
8. Component Score (Sgs)c (highest score from line 27 for
ill watersheds evaluated, subject to a max of 100)
100
84
1
Maximum value applies to waste characteristics category
Maximum value not applicable
Do not round to nearest integer
6
-------
REFERENCES
1. U.S. Environmental Protection Agency (EPA). Hazard Ranking System; Final Rule. 40
Code of Federal Register (CFR) Part 300, Federal Register, Volume 55, No. 241.
December 14, 1990. 138 pages.
2. EPA. Superfund Chemical Data Matrix. January 2004. Pages B-l through B-12, B-II-1,
BII-8, and 28 to 30. 18 pages.
3. Factory Insurance Association. The Sherwin-Williams Company, John Lucas and
Company Inc., Site Layout Map/Figure, Gibbsboro, New Jersey. 1946. 1 sheet.
4. John Lucas & Company, Inc., Site Layout Map/Figure, Gibbsboro, Camden County, New
Jersey, November 10, 1939, and November 17, 1947. 1 sheet.
5. Factory Insurance Association. The Sherwin-Williams Company, John Lucas and
Company Inc., Site Layout Map/Figure, Gibbsboro, New Jersey. April 16, 1964. 1 sheet.
6. Roy F. Weston, Inc. (Weston). Revised Work Plan for RI/FS Activities, Gibbsboro, New
Jersey. Prepared for The Sherwin-Williams Company. November 2001. 163 pages
7. EPA. Aerial Photographic Site Analysis Sherwin-Williams, Gibbsboro, New Jersey. TX-
PIC-95058/9602203S. June 1997. (Missing pages i, ii, iv, 12). 15 pages.
8. Sherwin-Williams. Letter Regarding United States Avenue Burn Site, Gibbsboro, New
Jersey, Request for Information. From Allen J. Danzig, Senior Corporate Counsel,
Environmental. To Carl Howard, ESQ. New Jersey Superfund Branch, Office of
Regional Counsel, EPA. Region II. October 30, 1995. 10 pages.
9. U.S. Geological Survey. Topographic Map 7.5-Minute Series. Quadrangle: Clementon,
New Jersey. 1967 Photo revised 1981. 1 sheet.
10. Kaselaan & D'Angelo. Subsurface Investigation at the Paint Works Facility, Gibbsboro,
New Jersey. July 28, 1987. 43 pages.
11. Lucas, John. Chinese Blue. August 1855. 1 page.
12. Large, E.W. Lucas Inter Company Mail. Regarding Lucas Dry Color History. To W.R.
Sieplein. October 6, 1937. 1 page.
13. John Lucas & Company. John Lucas & Company 1849 to 1949. Undated. 11 pages.
14. West Brothers, Inc. John Lucas & Company, Inc. Gibbsboro, NJ. Designations of
Buildings. Undated. 2 pages.
15. None Listed. Gibbsboro Equipment Schedule. Central Facilities Engineering. July 12,
1968. 8 pages.
7
-------
16
17
18
19
20
21
22
23
24
25
26
27
28
29
REFERENCES (Continued)
Lucas. Price List. 1888. 7 pages.
Not Listed. History of Gibbsboro. Undated. 23 pages.
Weston. Remedial Action Report. Police Station Area and Storm Sewer Replacement.
The Paint Works Corporate Center Site, Gibbsboro, New Jersey. June 15, 1998. 26
pages.
State of New Jersey Department of Environmental Protection (NJDEP). Solid Waste
Administration. Letter Regarding Pilot Roast Sludge Disposal. January 24, 1978. 3
pages.
NJDEP. Solid Waste Administration. Letter Regarding Paint Sludge. The author and the
recipient's names are redacted. April 24, 1978. 4 pages.
None Listed. Letter Regarding Paint Sludge. The author and the recipient's names are
redacted. March 15, 1978. 2 pages.
None Listed. Letter Regarding Spent Iron Residue. The author and the recipient's names
are redacted. June 6, 1978. 3 pages.
NJDEP. Bureau of Hazardous and Chemical Wastes. Letter Regarding Acrylic Paint
Sludge. The recipient's names are redacted. July 20, 1978. 1 page.
None Listed. Letter Regarding By-Product Paint Process. To Ronald Buchanan, Chief,
NJDEP, Bureau of Hazardous and Chemical Wastes. The author's name is redacted. June
2, 1978. 3 pages.
None Listed. Letter Regarding Sludge Analysis. To Ronald Buchanan, Chief, NJDEP,
Bureau of Hazardous and Chemical Wastes. The author's name is redacted. July 6, 1978.
2 pages.
Tetra Tech EM Inc. (Tetra Tech). Data Summary and Validation Reports for Hilliards
Creek Site, Gibbsboro, New Jersey. Undated. 9 pages.
Tetra Tech. Memorandum Regarding The Hilliards Creek Site Analytical Data, Part 2.
From Paula MacLaren, START Quality Assurance Officer. To Alicia Shultz, Tetra Tech,
START Project Manager. February 18, 1999. 12 pages.
Tetra Tech. Memorandum Regarding The Hilliards Creek Site Analytical Data, Part 1.
From Paula MacLaren, START Quality Assurance Officer. To Alicia Shultz, Tetra Tech,
START Project Manager. February 18 1999. 82 pages.
Lockheed Martin. Memorandum Regarding Hilliards Creek Site, Soil Extent of
Contamination. From John Dougherty, REAC Task Leader. To JoAnn Camacho,
EPA/ERTC Work Assignment Manager. September 29 1999. 105 pages.
8
-------
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
REFERENCES (Continued)
Weston. Letter Regarding Laboratory Analytical Reports Summary. TCLP Analysis.
Hilliards Creek Site, Gibbsboro, New Jersey. August 1, 2002. 171 pages.
Weston. Remedial Investigations Report. The Paint Works Corporate Center, Gibbsboro,
Camden County, New Jersey. Volume I. February 2001. 386 pages.
NJDEP. Division of Water Quality. Directive and Notice to Insurers. In the Matter of the
Sherwin-Williams Company Site and the Sherwin-Williams Company; The Paint Works
Corporate Associates I; and Robert K. Scarborough (Respondents). January 31, 1990. 10
pages.
Crummy, Del Deo, Dolan, Griffinger & Vecchione. Civil Action. Answers of the Sherwin-
Williams Company, Inc. to Department of Environmental Protection's Initial Interrogatories
and Request for the Production of Documents. NJDEP Petition Verses Sherwin-Williams
Company, Inc. Respondents. June 7, 1989. 35 pages.
NJDEP. Notice of Violation. Academy Paints. March 30, 1989. 1 page.
NJDEP. Report of Phone Call. Prepared by Nick Sodano. March 30, 1989. 1 page.
NJDEP. Report of Visit. Prepared by Nick Sodano. February 25, 1988. 1 page.
NJDEP. Report of Visit. Prepared by Nick Sodano. February 19, 1988. 1 page.
NJDEP. Memorandum Regarding Seep Constituents. From Rudy Zsolway, Research
Scientist. To Leslie McGeorge, Deputy Director. February 25, 1988. 3 pages.
NJDEP. Memorandum Regarding Source of Contamination. From William Mennel, Senior
Environmental Specialist. To Nick Sodano, Environmental Specialist. September 22, 1987.
2 pages.
Farer, Siegal, & Fersko. Letter Regarding Emergency Stream Encroachment Permit. From
Farer, Siegal, & Fersko, Attorneys at Law. To Mr. Narinder Ahuja, Bureau of Flood Plain
Management. April 3, 1987. 2 pages.
Alfred McClymont. Report on Subsurface Investigation. Two Disposal Facilities. July 11,
1979. 99 pages.
McClymont Associates. Letter Regarding Report on Engineering Services. From Alfred
McClaymont, Professional Engineer. To Mr. Richard D. Phillips, Corporate Director,
Engineering-Project Management, Sherwin-Williams Company. December 31, 1979. 13
pages.
Weston. Preliminary Screening Risk Assessment. Undated. 18 pages.
EPA. Region 2 Superfund. Route 561 Dump Site. Accessed on March 23, 2004. On-line
Address: http://www.epa.gov/Region2/superfund/npl/0203909c.htm. 2 pages.
9
-------
45
46
47
48
49
50
51
52
53
54
55
56
57
REFERENCES (Continued)
EPA. Region 2 Superfund. U.S. Avenue Burn Site. Accessed on March 23, 2004. On-line
Address: http://www.epa.gov/Region2/superfund/npl/02043003c.htm. 3 pages.
Geraghty & Miller, Inc. Letter Regarding Ground Water and Sludge. From Olin C. Braids,
Senior Scientist. To Mr. Hugh B. Williams, Sherwin-Williams Company. November 27,
1978. 5 pages.
Craig Testing Laboratory, Inc. Laboratory Testing Water Analysis. The Sherwin-Williams
Company. Wastewater Collected from Settling Pond #4. November 15, 1979. 3 pages.
Weston. Free-Phase Product Recovery System, Final Progress Report No. 16, the Paint
Works Corporate Center, Gibbsboro, New Jersey. October 11, 2002. 110 pages.
Weston. Removal Action Addendum Report. Kirkwood Lake. Hilliard Creek Site. Volume
I of III. March 11, 2003. Sections 1.0 to 4.0, Table 1, and Figure 2 Only. 22 pages.
Weston. Removal Action Report for 165 Kirkwood Road, Gibbsboro, New Jersey. October
2003. Sections 1.0 to 3.0 Only. 12 pages.
Weston. Removal Action Report. Hilliard Creek Site, Gibbsboro, New Jersey. May 2002.
Section 1.0 to 4.0, Tables, Figure 4, Figure 4-b, Figure 5, Only. 115 pages.
Weston. Fish Collection and Tissue Analysis Report. Kirkwood Lake, Voorhees and
Lindenwood Townships, New Jersey. February 10, 2003. Section 1.0 to 6.0 and Figure 1
Only. 14 pages.
Weston. Removal Action Work Plan for the Hilliard's Creek Site, Gibbsboro, New Jersey.
March 2002. Section 1.0 to 9.0, Figure 1, and Boring Location Map. 22 pages.
NJDEP. Memorandum Regarding Hilliard's Creek Wildlife Refuge and Attachments. From
John Doyon, Case Manager, Bureau of State Case Management. To Mark Pedersen, Section
Chief, Case Assignment. August 3, 1998. 21 pages.
U.S. Department of Health and Human Services. Public Health Service. Agency for Toxic
Substances and Disease Registry. Division of Health Assessment and Consultation. Health
Consultation. Hilliards Creek Site, Gibbsboro, Camden County, New Jersey. September 30,
1999. 12 pages.
ExxonMobil Chemical. Varsol/Naphtha. Accessed on May 24, 2005. On-line Address:
http://www.exxonmobilchemical.com/Public Products/Fluids/Aliphatics/NorthAmerica/Grad
es and Pat... 2 pages.
NJDEP. Administrative Order. In the Matter of the Sherwin-Williams Company. August
17, 1978. 4 pages.
10
-------
58
59
60
61
62
63
64
65
66
67
68
69
REFERENCES (Continued)
Sherwin-Williams Company. Letter Regarding National Pollution Discharge Elimination
System (NPDES) Permit 74-1207. From J. J. Gadwood, Plant Manager. To Permits
Administration Branch, Regional Administrator, Region II EPA. 1 page.
NJDEP. Undated. Site Investigation. Sherwin-Williams Dump Site, Gibbsboro, Camden
County. Appendix X 8 pages, page 1 missing; Appendix Z, 2 pages; Appendix CC, 4 pages;
Appendix DD, 2 pages; Appendix EE, 3 pages; Appendix FF, 7 pages; Appendix GG, 2
pages; Appendix II, 64 pages (pages 3-28 and 3-29 missing), Appendix BBB1, 6 pages. 120
pages.
Bolger, William. The John Lucas and Company Paint and Varnish Works, Gibbsboro, New
Jersey. A History and Architectural Record. August 1982. 126 pages.
EPA. Region II. Administrative Order On Consent for Remedial Investigation/Feasibility
Study. In the Matter of the United States Avenue Burn Site, Rout 561 Dump Site and
Hilliard's Creek, The Sherwin-Williams Company. Undated. 59 pages.
New Jersey Department of Health. Public Health and Environmental Laboratories.
Academy Paints. Water Analysis. March 1987. 176 pages.
U.S. Cost Guard. Oil Identification Laboratory. Oil Spill Identification Report. Laboratory
Case Number: 89-210. Requestor: NJDEP. Unit Case Number: Sherwin-Williams. 1989. 3
pages.
State of New Jersey. Department of Environmental Protection. Division of Water
Resources. Memorandum Regarding Answers to Scarborough/Paint Works Interrogatories,
OAL Docket No. EWR07931-88. From Edward H. Post, Chief, Southern Bureau of Regional
Enforcement. To Colleen Malloy, Deputy Attorney General Division of Law. April 26,
1989. 12 pages.
NJDEP. Memorandum Regarding Scarborough Property. From Charles Elmendorf,
Environmental Specialist. To Vince Krisak. July 13, 1983. 3 pages.
NJDEP. Memorandum Regarding Sherwin-Williams, Gibbsboro, Camden County, New
Jersey. From Joseph Marchesani, Hydrogeologist. To Maria Franco Spera, Case Manager.
May 3, 1994. 2 pages.
NJDEP. Site Evaluation Submission. Academy Paint Company, Inc. December 1989. 9
pages.
Weston. Work Plan for the Hilliard's Creek Site, Gibbsboro, New Jersey. November 1999.
Volume I (37 pages) and Volume III (291 pages).
Weston. Work Plan Addendum. Hilliard's Creek Site, Gibbsboro, New Jersey. December
16, 1999. 30 pages.
11
-------
70
71
72
73
74
75
76
77
78
79
80
81
REFERENCES (Continued)
Crummy, Del Deo, Dolan, Griffinger & Vecchione. Letter Regarding Route 561 Dump Site,
Response to Request for Information. From Susanne Peticolas. To Carl R. Howard, Esq.,
Assistant Regional Counsel, EPA. October 10, 1996. 14 pages.
Crummy, Del Deo, Dolan, Griffinger & Vecchione. Letter Regarding United States Avenue
Burn Site, Response to Request for Information. From Susanne Peticolas. To Carl R.
Howard, Esq., Assistant Regional Counsel, EPA. December 31, 1996. 6 pages.
Sherwin-Williams Company. Letter Regarding Response to CERCLA Notice Regarding
Seep Area Release. From Mary Lou Capichioni, Director, Remediation Services. To Bonnie
L. Green, On-Scene Coordinator, EPA. May 2, 2002. 4 pages.
Weston. Letter Regarding Ground Water Seep Area, NRC Continuous Release Case No.
599887. From Sally Jones, Project Director. To Mr. Bruce Sprague, Chief, Response and
Prevention Branch, Emergency and Remedial Response Division, EPA. June 16,2003. 5
pages.
NJDEP. Letter Regarding Fish Collection and Tissue Analysis Report, Kirkwood Lake,
Voorhees and Lindenwood Townships, Camden County. From John Doyon, Case Manager.
To Mary Lou Capichioni, P.G., Senior Environmental Project Manager, The Sherwin-
Williams Company. April 2, 2003. 3 pages.
Weston. Letter Regarding Progress Report No. 64, Administrative Order on Consent for
Removal Action. From Daniel Kopcow, P.E., Project Manager. To Bonnie L. Green, On-
Scene Coordinator, EPA. May 10, 2002. 15 pages.
Tetra Tech. Letter Regarding Hilliard's Creek Site - Data Quality Report. From Marian
Murphy, Senior Chemist. To Bonita Green, On-Scene Coordinator, EPA. April 25, 2003.
23 pages.
ChemTech. Analytical Data Package. Project ID: SE03 0303 102. Order R1944. April 30,
2003. 87 pages.
Tetra Tech. Letter Regarding Hilliard's Creek Site - Data Quality Report. From Marian
Murphy, Senior Chemist. To Bonita Green, On-Scene Coordinator, EPA. May 30, 2002.
(Reference 78 cites the year 2002 as an error, the actual year is 2003.) 17 pages.
ChemTech. Analytical Results Summary. Project Name: SE03 0303L02. Undated. 45
pages.
Tetra Tech. Record of Telephone Conversation Regarding Surface Water Flow in Hilliards
Creek. Between Alicia Shultz, Project Manager, and Michael Wilson, Project Manager, Tetra
Tech. May 18, 2005. 1 page.
EPA. Using Qualified Data to Document an Observed Release and Observed Contamination,
EPA 540-F94-028, OSWER 9285.7-14FS, PB94-963311. Accessed on November 1996.
On-line Address: http://www.epa.gov/superfund/sites/npl/hrsres/fact/docor.pdf. 18 pages.
12
-------
82
83
84
85
86
87
88
89
90
91
92
93
94
REFERENCES (Continued)
EPA. Revisions to Office of Solid Waste and Emergency Response (OSWER) National
Priorities List (NPL) Policy, The Revised Hazard Ranking System: Evaluating Sites After
Waste Removals. Publication No. 9345.1-03FS, October 1991. Memorandum Regarding
OSWER Directive February 28, 2006. From Stephen D. Luftig, Director, Office of
Emergency and Remedial Response. To EPA Regional Offices. April 4, 1997. 4 pages.
EPA. Office of Solid Waste and Emergency Response. The Revised Hazard Ranking
System: Evaluating Sites After Waste Removals. Publication 9345.1-03FS. October 1991.
On-line Address: http://www.epa.gov/superfund/sites/npl/hrsres/fact/hrswaste.pdf. 10
pages.
Tetra Tech. Trip Report for the Hilliards Creek Site, Gibbsborro, Camden County, New
Jersey. June 13, 2005. 167 pages.
Tetra Tech. Final Sampling and Analysis Plan, Hilliards Creek Site, Gibbsboro, Camden
County, New Jersey. December 3, 2004. 24 pages.
EPA. Evaluation of Metals Data for the Contract Laboratory Program Based on SOW -
ILM05.2. Case No. 33650. Sample Delivery Group: MB5730, MB5744, MB5757,
MB5772, MB57A5. January 18, 2005. 173 pages.
EPA, Contract Laboratory Program (CLP). Inorganic and Organic Traffic Report and Chain
of Custody Record. Case No. 33650. Sample Deliver Group: MB5730, MB5744, MB5757,
MB5772, MB57A5. 2004. 20 pages.
Tetra Tech. Project Note: Sample Quantitation Limits. Prepared by Alicia Shultz, Project
Manager, Tetra Tech. June 8, 2005. 3 pages.
EPA. Superfund Analytical Services, CLP. Target Analyte and Compound List. Accessed
on December 6, 2004. On-line Address:
http://www.epa.gov/oerrpage/superfund/programs/clp/mtarget.htm. 4 pages.
EPA. Evaluation of Organic Data for the CLP. Based on Statement of Work (SOW) -
OLM04.3. Case No.: 33650. Sample Delivery Group B5755. March 1,2005. 210 pages.
EPA. CLP Data Assessment. Based on SOW - OLM04.3. Case No.: 33650. Sample
Delivery Group B5755. March 1,2005. 2002. 227 pages.
EPA. Evaluation of Metals Data for the CLP Based on SOW - OLM04.3. Case No.: 33650.
Sample Delivery Group: B5730. March 2003. 232 pages.
U.S. Department of Interior, Fish and Wildlife Service, National Wetland Inventory Map,
Clementon, New Jersey, Scale: 1:80:000, November 5, 1975. 1 sheet.
Tetra Tech. Letter Regarding Hilliards Creek Site - Data Quality Report. April 25, 2005.
103 pages.
13
-------
REFERENCES (Continued)
95. TetraTech. Project Note: Sherwin-Williams - Hilliards Creek Benchmark Concentrations.
June 14, 2005. 3 pages.
96. Priority Pollutants. Accessed on June 22, 2005. On-line Address:
http://geoweb.tamu.edu/courses/geol641/docs/02PrioritvPollutantList.pdf. 2 pages.
97. TetraTech. Sampling Location and Lucas Plant Area Map. 2005.
98. TetraTech. 15-Mile Target Distance Limit Map. 2005.
99. National Environmental Health Form 1998. "Paint Film Components." On-line Address:
http://enhealth.nphp.gov.au/council/pubs/pdf/paint.pdf. 6 pages.
100. Oregon Department of Human Services. "Technical Bulletin - Health Effects Information -
Arsenic." Accessed on December 5, 2005. On-line address:
http://www.oregon.gov/DHS/ph/dwp/docs/fact/arsenic.pdf. 2 pages.
101. Not Listed. 2005. "Arsenic Compounds, Inorganic." Accessed on December 5, 2005. On-
line Address: http: //ntp .niehs .nih. gov/ntp/roc/ele venth/profile s/sO 15 arse .pdf. 2 pages.
102. EPA. "Method 6010B - Inductively Coupled Plasma-Atomic Emission Spectrometry."
December 1996. On-line Address:
http://www.epa.gov/epaoswer/hazwaste/test/pdfs/6010b.pdf. 1 page.
103. TetraTech. E-Mail Message Regarding Detection Limits for EPA Method 601 OB. From
Marian Murphy, Chemist. To Alicia Shultz, Project Manager, Tetra Tech. December 7,
2005. 1 page.
104. Pace Analytical Services. Data Package. 1998 and 1999. 993 pages.
105. U.S. Department of Health and Human Services. Public Health Service. Agency for Toxic
Substances and Disease Registry. 1995. Toxicological Profile for Polycyclic Aromatic
Hydrocarbons. August. Pages 1 to 4 only. On-line Address:
http://www.atsdr.cdc.gov/toxprofiles/tp69-p.pdf. 6 pages.
106. The Paint Industry Voluntarily Phased Out Lead Use Decades Ago. Accessed on February
24, 2004. On-line Address http://www.paint.org/con info/leadpaint/kevpoints.cfm. 1 page.
107. ATSDR. Toxicological Profile for Cresols. July 1992. 2 pages.
108. ATSDR. Toxicological Profile for 1,1-Dichloroethane. December 1990. 2 pages.
109. Farlekas, George M.; Bronius Nemickas; and Harold E. Gill. U.S. Geological Survey, Water
Resources Investigations 83-4029. Geology and Ground-Water Resources of Camden
County, New Jersey. June 1976. 97 pages.
14
-------
REFERENCES (Continued)
110. Tetra Tech. 1998 Lead Analysis by EPA Method 6010B - Sample Quantitation Limits.
December 5, 2005. 3 pages.
111. Weston. Quality Assurance Project Plan for the Hilliards's Creek Site, Gibbsboro, New
Jersey, Volume 3 of 3. November 1999. (AOC No. 02.99-2307, Work Order No.:
20076.046.0001.) 225 pages.
112. Kealy, Jim, Technical Coordinator/NJDEP/BEERA. New Jersey Department of
Environmental Protection, Division of Remediation Management and Response, Hazardous
Site Science Element, Bureau of Environmental Evaluation and Risk Assessment. Fax to Ray
Kilmosak, Remedial Project Manager, USEPA, ERRD, NJ Projects. Subject: Sherwin
Williams QAAP MDLs. March 7, 2006. 9 pages.
15
-------
SITE SUMMARY
The Sherwin-Williams/Hilliards Creek site is located in Gibbsboro, Camden County, New Jersey. The
Sherwin-Williams/Hilliards Creek site includes, but is not limited to, contaminated soil on and ground
water underlying the former Lucas Paint Works Plant (Lucas plant) and contaminated soil and sediment
associated with Hilliards Creek. The former Lucas plant encompassed 60 acres of land and was bounded
to the north by Silver Lake and Route 561; to the east by United States (US) Avenue; to the south by
vacant land, a cemetery, and Bridgewood Lake; and to the west by Clementon-Gibbsboro Road (Refs. 6, p.
2-1 and Figure 2-4; 9; 68, p. 2-1). Hilliards Creek, also known as Millard Creek, flows southwesterly
through the former Lucas plant, under Foster Avenue, then turns west under W. Clementon Road, receives
the outflow of Bridgewood Lake, and continues west to Kirkwood Lake. Approximately 1,000 feet
upstream from Kirkwood Lake, Hilliards Creek receives surface water flow from Nichols Creek. Hilliards
Creek merges with the Cooper River just before it enters Kirkwood Lake (Refs. 6, p. 2-11 and Figure 2-2;
9; see Reference 97, Sampling Location and Lucas Plant Area Map).
Hilliards Creek received surface water runoff and discharges from the Lucas plant (see Figure 2-4 in
Reference 6). The Lucas plant began operation in 1851 and it manufactured varnishes, lacquers, and lead-
based-paints, including dry colors, paste paints, and linseed oil liquid paints. Wastes generated from the
plant were disposed of in Hilliards Creek, on-site wastewater lagoons, the Route 561 Dump Site, and the
US Avenue Burn Site (Refs. 31, p. 2-5; 61, pp. 3, 4, 5). The Route 561 Dump Site and US Avenue Burn
Site have been evaluated as separate sites and are therefore not included in this Hazard Ranking System
(HRS) documentation record (Ref. 61, p. 5).
Ground water at the Lucas plant occurs in two distinct zones: the shallow zone (30 to 40 feet thick) and a
deeper zone (total thickness unknown). The two zones are separated by a silt unit that acts as a confining
layer (Ref. 31, p. 4-2). The saturated thickness of the shallow zone is approximately 30 to 40 feet. Depth
to ground water is between 1 to 15 feet below ground surface (bgs). The horizontal direction of ground
flow is generally to the south-southwest. Locally, Hilliards Creek, White Sand Branch, and Bridgewood
Lake act as discharge zones for shallow ground water (Ref. 31, p. 4-2).
Sherwin-Williams terminated production at the Lucas plant in late 1976. The entire operation and facility
were permanently closed on September 1, 1978 (Ref. 31, pp. 2-2, 2-6). Robert K. Scarborough purchased
a portion of the facility from Sherwin-Williams sometime between June 26, 1981, and September 7, 1983.
In 1983, Scarborough demolished most of the Sherwin-Williams facility and undertook various
construction projects (Refs. 31, p. 2-2; 32, p. 5). The Paints Works Corporate Associates I (the Paint
Works), a New Jersey-based corporation, purchased a portion of the plant from Sherwin-Williams
sometime between June 26, 1981, and September 7, 1983. The Paint Works re-graded the plant (Ref. 32,
p. 5). The Lucas plant is currently used as an office and light industrial park and is called the Paint Works
Corporate Center (the Paint Works) (Ref. 6, p. 2-1).
Current Conditions
In 1981, a majority of the land encompassing the former Lucas plant or Sherwin-Williams plant was sold
to Robert K. Scarborough and developed as a light industrial park known as "The Paint Works Corporate
Center" (Refs. 6, p. 2-1; 31, p. 1-1). Development of the property included demolition or renovation of
existing structures and construction of new office, manufacturing, and warehouse space (Ref. 31, p. 2-1).
The current layout is presented in Reference 31, Figure 2-2. The center is made up of nine buildings. As
of November 2001 when the RI/FS Work Plan was revised, 20 tenant companies occupied office,
16
-------
SITE SUMMARY (Continued)
warehouse, and manufacturing space at the park (Ref. 6, p.2-2). Two of the tenants used hazardous
materials including Academy Paints and Scotko Sign & Display Company. Both Academy Paints and
Scotko Sign & Display, Inc., were listed by EPA as large-quantity generators. Scotko was listed as
generating D001, F003, and F005 wastes. Both have terminated their lease and left the park (Ref. 6, p. 2-
6). According to Sherwin-Williams, as of July 2006 there are 53 tenants with approximately 720
employees occupying office and warehouse space, and there is no manufacturing activity at the facility.
The north boundary of the corporate center is bounded by Silver Lake, which discharges into Hilliards
Creek. Hilliards Creek transverses the corporate center in a northeast-southwest direction. The corporate
center is bisected by Foster Avenue. The portion of the corporate center north of Foster Avenue is
occupied by numerous buildings including former Buildings 14, 33, 55, 57, 58, and 82, a new building
paralleling Foster Avenue, and a shed. The grounds surrounding the buildings are paved parking lots. The
northernmost part of the corporate center along US Avenue, north of all the buildings, is a gravel parking
lot. The area immediately south of Foster Avenue is occupied by buildings and is surrounded by paved
parking lots (Ref. 31, p. 2-1 and Figure 3-2).
The corporate center is surrounded by residential properties (Ref. 31, p. 2-15). A public school, library,
and municipal offices are located approximately 0.2 mile west of the corporate center, along Kirkwood
Road. Silver Lake is located on the corporate center. A pedestrian walk surrounds Silver Lake, and a
shooting range is located on the southern shore of Bridgewood Lake. Bridgewood Lake is located south of
the corporate center along the south border of the Sherwin-Williams facility. Silver Lake discharges into
Hilliard Creek through an underground culvert system that crosses under the parking lot between the lake
and Foster Avenue. The creek returns to open flow 200 feet south of Foster Avenue (Ref. 31, p. 2-17).
Generally, the topographic gradient is from northeast to southeast. The corporate center is flat and graded
toward storm water collection points. Near Hilliards Creek and Bridgewood Lake, the topographic
gradient slopes gently toward these water bodies (Ref. 31, p. 2-8). Surface water runoff from the
northernmost portion of the corporate center discharges directly into Silver Lake. The north-central
portion of the corporate center is occupied by buildings and paved areas. Runoff generated in the area
between Silver Lake and Foster Avenue enters a network of catch basins and storm sewers, which
discharge into Hilliards Creek, immediately south of Foster Avenue (Ref. 31, p. 2-9).
Operational History: John Lucas and Company
The Lucas business was first established in March 1849 to import white lead, paints, and colors (Ref. 13,
p. 3). The company was called "Gibbsboro White Lead, Zinc, and Color Works" (Ref. 17, p. D-10). From
1851 to 1930, John Lucas and Company owned and operated a paint and varnish manufacturing facility at
the Lucas plant (Refs. 31, p. 2-2; 32, p. 2; 60, p. 6). The Lucas plant was constructed at the former
location of a sawmill and, subsequently, a grain mill (Refs. 13, p. 4; 31, p. 2-2; 60, p. 15). John Lucas and
Company developed and manufactured oil-based paints, varnishes, and lacquer (Ref. 31, p. 2-2).
The plant was expanded at various stages to accommodate new operations such as grinding white lead and
colors in oils (Ref. 60, pp. 19, 26, 30). A historical map that shows locations of old buildings and
structures is presented in Reference 6, Figure 2-4 and Refs. 3, 4, and 5. The expansions included more
than 53 buildings and occupied only a portion of the current 60-acre property (Refs. 14; 15; 31, p. 2-3). In
the early 1880s, the plant operations included dry color production, color grinding in oil, varnish
production, and production of ready-mixed oil paint (Ref. 60, p. 30). During World War II, John Lucas
17
-------
SITE SUMMARY (Continued)
and Company supplied protective finishes for many types of equipment, such as trucks, tanks, gun
carriages, and barracks. The company also supplied marine finishes to the Maritime Fleet (Ref. 13, p. 10).
Information on the constituents of marine finishes was not identified in the reference documentation.
The primary products manufactured by the John Lucas and company were white lead paint, varnish, and
lacquer. Other products included dry colors produced from chemical reactions, blending, filtering, and
drying; oil-based paints produced from grinding pigments in oil and adding thinners, oils, and hardeners;
and ready-mixed linseed oil paints produced from blending linseed oil with pigments and thinners (Refs.
31, p. 2-3; 60, pp. 6, 8, 12, 22, 26). A memorandum prepared by John Lucas lists the following as
components for Chinese blue paint manufactured by Lucas Paints: prussiate potash, copper sulphate,
sulphate of iron, clear nitric acid, and sulphuric acid (Ref. 11).
The manufacturing history of John Lucas and Company began in 1849, and dry colors were among the
first products manufactured (Refs. 12; 13, p. 1). Dry color was the largest operation at the Lucas plant
through the end of the 19th century (Ref. 60, p. 33). Chrome yellow and Prussian blue were the two major
pigments produced at the Lucas plant (Ref. 60, p. 37). John Lucas made the first chrome greens and
chrome yellows produced in America. Mr. Lucas also introduced the use of brightening agents. Paints
produced included white lead, white zinc, iron blues, Paris green, chrome orange, zinc yellow, lithol, para
and toluidine reds, scarlet and maroon lakes, and alizarine colors (Refs. 12; 13, p. 1; 60, pp. 11, 17, 19, 22,
23). Prussian blue, paste paints, pure linseed oil liquid paints, French greens, Swiss green, Chinese blue,
and laundry blue also were manufactured (Refs. 13, pp. 3, 6, 7; 17, p. D-ll; 60, pp. 17, 19, 22, 24).
Reference 16 provides a comprehensive list of paints and products manufactured by Lucas. The basic
pigments used by Lucas were lead and zinc oxides, white lead, non-lead chrome green, and chrome
yellow. White lead was ground at the plant (Refs. 8, p. 3; 60, pp. 1, 19 20, 21, 42). Lucas produced 24
different varieties of varnish (Ref. 60, pp. 22, 73).
Many of the buildings on the Lucas plant were used to store paint and drums. Materials stored included
varnish, colors, oil, lacquer, paint, dry colors, coal, and sludge (Refs. 4; 5; 14; 15, pp. 1 through 6; 60, p.
29) (see Figure 2-4 in Reference 6). Raw materials Lucas used included calcined acetate of lead, lead
oxide, zinc oxide, lead chromate, ferrous sulfate, sulfuric acid, linseed oil, and various paint solvents
(Refs. 31, p. 2-3; 60, pp. 10, 26). The operations south and southwest of Silver Lake involved
manufacturing, refining, storage, handling, and transporting hazardous substances above ground and
below ground. These areas contained drums of oils and varnishes and tank farms and railroad tankers of
lacquers, solvents, caustic solutions, and petroleum-based products. All the products were used in the
paint manufacturing industry (Ref. 10, p. 9).
During the 1880s, storage tanks for oils and oil-based paints were installed in the area of Tank Farm A. In
1887, a rail spur was installed at the facility to improve transportation and handling of raw materials and
finished goods (Ref. 31, pp. 2-3, 2-4).
Several disasters occurred at the Lucas plant, including a flood in 1940 and two fires between 1905 and
1949 (Refs. 13, p. 11; 31, p. 2-5; 32, p. 3). In 1905, a fire occurred in Building 32, the Varnish Filter
House, where varnish was thinned and filtered. The second fire occurred on September 18, 1915, inside
Building 39, which was used as a dry color paint mill at the time (Refs. 31, pp. 2-5, 2-6; 60, pp. 33, 66).
Operational History: Sherwin-Williams Company
18
-------
SITE SUMMARY (Continued)
In approximately 1930, Sherwin-Williams acquired control of Lucas plant; however, Mr. Lucas continued
to operate the plant until 1967 (Refs. 8, p. 1; 17, p. D-12; 31, p. 2-2; 32, p. 2). Sherwin-Williams operated
the Lucas plant from 1967 until production ended at the plant in late 1976 or early 1977 (Refs. 8, p. 1; 31,
p. 2-2; 32, p. 2). Sherwin-Williams closed the plant permanently on September 1, 1978 (Ref. 31, p. 2-2).
When it was owned and operated by Sherwin-Williams, the plant included an area for unloading raw
materials from railroad cars; tank farms for raw materials including storage tanks constructed prior to
1908; storage areas for drummed raw materials; an industrial and domestic wastewater treatment and
disposal system consisting of unlined percolation/settling lagoons; a solid waste disposal area for paint
sludges; an extensive system of pipes to transport raw materials; and a drum cleaning area. Raw materials
were mixed and processed in a number of specialized buildings in the plant (Refs. 4; 5; 32, p. 2) (see
Figure 2-4 in Reference 6). Raw materials stored on the plant included V.M.&P. naphtha (8,000 gallons),
xylene (26,000 gallons), mineral spirits (100,000 gallons), toluene and solvent blends (65,000 gallons),
and aromatic naphtha (1,500 gallons) (Refs. 4; 5; 31, Table 2-2; 32, pp. 2, 3).
From 1967, the plant manufactured interior and exterior house paint, latex, and oil-based interior and
exterior house paint until 1975, lacquer finishes until 1975, and polymerized oils and formulated dyes until
1972 (Ref. 8, p. 1).
Sherwin-Williams expanded the operations at the plant. Office and manufacturing facilities occupied one-
third of the property, with the center of the plant located around Foster Avenue. During the 1930s,
Sherwin-Williams terminated dry color production, but the plant continued to produce oil-based paints,
varnishes, lacquers, and emulsion paints until December 1975. In 1956, Sherwin-Williams began
production of alkyd or synthetic varnish, but this operation terminated in December 1975. The plant
produced emulsion paints only between December 1975 and early 1977 (Ref. 31, p. 2-4).
Raw products used from approximately the late 1950s included titanium dioxide, a major component for
products. The following products were used in resin production: polymers, pigments, linseed oil, soya oil,
ray linseed oil, mineral spirits, refined linseed soil, glycerine, V.M.&P. naphtha, and xylene (used in resin
production). The following materials were used in lacquer production: isobutyl alcohol; c.p. acetone;
methyl amyl acetate; isopropyl acetate; xylene; lacquer solvent; toluene; toluene-based solvent blend;
methyl ethyl ketone; ethyl acetate; methyl butyl ketone; and aromatic naptha. Pulp pigments, liquid
mixers, and solvents were used in production of Sher-dye (Ref. 8, p. 2).
Raw materials were stored in aboveground storage tanks (ASTs) and underground storage tanks (USTs) in
two areas on the plant: Tank Farm Areas A and B. Raw materials (paint pigments) were also stored in 55-
gallon drums. Raw materials and finished goods were typically stored in former Buildings 55, 56, 57, 58,
62, and 67 (Ref. 31, p. 2-4 and Figure 2-2; 4; 5 ; 60, p. 68) (see Reference 6, Figure 2-4 and Reference 31,
Figure 3-2). Between 1950 and 1977, wastewater generated from the manufacturing process was treated
and disposed of in four unlined lagoons on the southern portion of the property (Ref. 31, p. 2-5) (see
Reference 6, Figure 2-4 and Reference 31, Figure 3-2).
Several fires occurred at the plant; according to Sherwin-Williams, fires occurred in 1905, 1915, 1930, and
1949. The fire on February 21, 1930 destroyed Building 36, a warehouse used to store raw materials.
After the fire in the former Building 36, a concrete foundation pad was used for exterior storage of
drummed materials. Subsequently, on July 30, 1949, a fire destroyed 1,000 drums of nitrocellulose and
lacquer stored on the concrete pad at Building 36 (Refs. 31, pp. 2-5, 2-6; 60, pp. 33, 66).
19
-------
SITE SUMMARY (Continued)
Operational History: Robert K. Scarborough
In June 1981, a majority of the Lucas plant was sold to developer Robert K. Scarborough. Scarborough
developed the former plant into a light industrial complex named The Paint Works Corporate Center. The
center is made up of nine buildings (Ref. 31, p. 2-16). At present, 20 tenant companies occupy office,
warehouse, and manufacturing space on the former plant property. In December 1997, a portion of the
former plant property was sold to Brandywine Reality Trust (Refs. 18, p. 1-1; 31, p. 2-2).
History of Investigations:
In January 1990, the New Jersey Department of Environmental Protection (NJDEP) issued a Spill Act
Directive to Scarborough (the owner of the Lucas plant property) and Sherwin-Williams Corporation (the
former owner of the Lucas plant property) requiring that a remedial investigation and feasibility study
(RI/FS) be conducted at the former Lucas plant and immediately adjacent lands. Sherwin-Williams
subsequently entered into an Administrative Consent Order (ACO) with NJDEP to conduct the RI/FS
(Ref. 31, p. 1-1).
The RI report covers activities conducted at the Lucas plant from August 1991 through January 2000
(Refs. 31, pp. 1-1, 1-2; 59, Appendix II, p. 1117). Seeps located on the facility were identified as an area of
Immediate Environmental Concern (IEC). Sherwin-Williams entered into an ACO with NJDEP to address
this IEC. A soil vapor extraction (SVE) system and a free-phase product removal system were installed in
the area of the seeps, and a free-product removal system was installed in the area of former Tank Farm A
(Ref. 31, p. 1-5). According to Sherwin-Williams, it has conducted "significant investigations at The Paint
Works and Hilliards Creek under EPA since 2000." Sherwin-Williams submitted Attachment 1 to its
comments listing a series of past and ongoing activities conducted by Sherwin Williams (EPA-HQ-
SFUND-2006-0242-0014).
20
-------
SD - Characterization and Containment
Source No. 1
2.2 SOURCE CHARACTERIZATION
2.2.1 SOURCE IDENTIFICATION
Name of source: Free-Phase Product
Number of source: 1
Source Type: Other
This source includes free-phase product present in ground water underlying the former Lucas plant in the
areas of Building 50, Building 67, and Tank Farm A (Ref. 31, pp. ES-6, 3-30, 4-18, 4-19, 4-20). The three
locations where free-phase product have been identified are referred to as seeps in reference
documentation and are shown on Figure 2-2 in Reference 31 as seep areas. The free-phase product is
composed of benzene, ethylbenzene, xylene, naphthalene, and 2-methylnaphthalene (Ref. 31, p. 4-25 and
Table 4-20). Analysis of the product indicates that it is paint thinner (Ref. 31, p. 4-26) because there was
no evidence of any organolead or organomanganese in the samples of the product (Ref. 31, p. 4-27). A
free-phase product recovery (FPR) and soil vapor extraction (SVE) system have been installed in the area
of Buildings 50 and 67 to recover the free-phase product (Refs. 31, pp. 3-24, 3-25; 48, Figure 2-1). (A
separate gasoline ground water plume is located west of Building 67 and is not evaluated in this HRS
documentation record [Ref. 31, Figure 3-2 and Appendix K, Figures 4-11 and 4-12].)
The potential sources of the free-phase product plume are Tank Farm A (Ref. 31, pp. 2-3, 2-4, and Table
2-2); operations in Lucas plant Buildings 50, 55, and 67 (formerly Building 36) including the transfer and
temporary storage of process chemicals (Refs. 6, Figure 2-4; 31, Figure 3-2; 59, Appendix II, p. 11-57; 60,
p. 68) and storage of product in Building 36 or platform 36 (Ref. 6, Figure 2-4); a 6-inch terra-cotta pipe
leading from Building 50 (Paint Works Maintenance Shop) (Ref. 18, pp. 3-4, 3-5); two 6,000-gallon
vertical steel AST formerly containing mineral spirits 66-2 and 802-15 alkyd resin adjacent to Building 50
(Ref. 18, pp. 3-5, 4-1); hazardous material and hazardous waste storage adjacent to Building 50 (Ref. 31,
p. 6-3); the Lucas plant solvent railroad and truck tank unloading station on the north side of Building 67
(Refs. 7, pp. 4 through 11, 17; 6, Figure 2-4); storage areas for empty and dirty drums east of Building 67
(Ref. 5); contamination in the Building 67 parking lot (Ref. 31, p. 3-3); leakage of storage lagoons or
drums that were once stored behind Building 67 (between Building 67 and 50); spillage from tank cars
(Ref. 10, pp. 18, 19); and two USTs, one for oil and another for solvent, located in the parking lot located
east of Building 67 (Ref. 65, p. 1). Storage lagoons are identified as a source in Reference 10, pages 18
and 19; however, no storage lagoons in the area of Buildings 50 and 67 are observed in aerial photographs
or discussed in the reports for any other investigations at the plant.
The free-phase product plume present in the ground water underlying Buildings 50 and 67 and former
Tank Farm A, has been characterized by the collection of product samples and soil samples as documented
in the sections below. Numerous investigations have been conducted in the area of the free-phase product
plume associated with Buildings 50 and 67. A summary of those investigations is provided in the section
below.
21
-------
SD - Characterization and Containment
Source No.: 1
Free-Phase Product - Buildings 50 and 67
The reference documentation for the free-phase product identified product on west side of Building 50 and
on the north and east sides of Building 67. The narrative discussion in the reference documentation
describes the two free-phase product locations together. It is therefore, difficult to separate the discussion
of the free-phase product in area of Building 50 from the free-phase product in area of Building 67 (Ref.
31, Figure 2-2 [shown as seep areas], pp. 3-2 through 3-7, 3-8 through 3-12, 3-22, 3-23 through 3-25, 4-18
through 4-24, 5-5, 5-6). The two locations of free-phase product have a similar migration pathway. Free-
phase product released to Hilliards Creek at the location where the creek emerges from underground, south
of Foster Avenue, resulted from the migration of free-phase product into the storm sewer system from
free-phase product located on the west side of Building 50 and east side of Building 67 (Ref. 31, p 3-6)
(shown as seep areas on Figure 2-2 of Reference 31).
The free-phase product plume in ground water near Buildings 50 and 67 was initially identified in 1983
when an oily substance was observed in the parking lot between former Buildings 50 (currently police
station) and 67 (also known as the Academy Paints Building). The oily substance flowed overland to a
storm water catch basin in the parking lot then into a storm sewer that discharged into Hilliards Creek
(Refs. 32, p. 5; 65, pp. 1, 2, 3). The product was observed on many occasions during construction of the
corporate center that now occupies the former Lucas plant (Ref. 65, p. 1).
In February 1985 and 1987, product was observed in the parking lot between Buildings 50 and 67 and
flowing from the eastern bank of Hilliards Creek (Refs. 6, Figure 2-4; 10, pp. 1, 2; 31, p. 3-3 and Figures
2-2 and 3-2; 32, pp. 5, 6).
Note: Numerous reports describing investigations conducted in this area refer to Building 67 as the former
Academy Paints Building (former occupants of the building) and Building 50 as the Gibbsboro Police
Station Building (current occupants of the building). Building 67 is the former location of Lucas plant
Building 36 (Refs. 6, Figure 2-4; 31, Figure 3-2). On February 21, 1930, a fire destroyed Building 36,
which was a warehouse used to store raw materials. After the fire, the concrete foundation pad for the
former Building 36 was used for exterior storage of drummed materials (Refs. 31, pp. 2-5, 2-6; 60, pp. 33,
66; 7, p. 5). Lucas used Building 50 as a garage (Ref. 60, p. 99). Hazardous material and hazardous waste
were stored adjacent to Building 50 (Ref. 31, p. 6-3).
In 1987, after free-phase product was observed flowing into Hilliards Creek, the New Jersey Department
of Water Resources (DWR) issued a directive to Sherwin-Williams requesting that actions be taken to
mitigate the release to Hilliards Creek (Ref. 10, p. 1). Sherwin-Williams refused to comply with the DWR
directive. However, the owner of the property at the time, Scarborough, procured an environmental
contractor to mitigate the release. An enclosure was constructed to prevent product from flowing through
the parking lot into a storm water inlet and finally into Hilliards Creek. The product in the enclosure was
pumped out and disposed of off the property. As of July 1987, 4,200 gallons of product were collected
and disposed of off the property (Refs. 10, p. 2; 32, pp. 6, 7).
Observations during the 1987 investigations included product flowing from the bank of Hilliards Creek,
product flowing from cracks in the pavement in the parking lot between Buildings 50 and 67 and other
areas in the parking lot, and severe contamination in soil (Ref. 10, pp. 9, 18). Oil-absorbent booms and
filter fences were installed in the area surrounding the seep and at the rip-rap channel and storm water
22
-------
SD - Characterization and Containment
Source No.: 1
conveyance to collect free-phase product. The rip-rap channel collected surface water runoff from the
parking lot and directed the water to Hilliards Creek. A berm was constructed around the seep in the
parking lot, and a temporary bypass was constructed in Hilliards Creek, conveying Hilliards Creek around
the product that emanated from the creek. A bulkhead was constructed around the perimeter of the
product that emanated into the creek (Ref. 10, pp. 2, 3).
Free-phase product entered the storm sewer system when the water table was high, indicating the product
is associated with a ground water plume underlying the Lucas plant and extending to Hilliards Creek
(Refs. 6, p. 3-47; 18, p. 2-3). On February 19, 1988, and again on February 25, 1988, NJDEP observed
product discharging into Hilliards Creek (Refs. 36; 37).
In 1989, NJDEP submitted a sample of the product to an analytical laboratory for comparison to known
petroleum and solvent products. The comparison indicated that constituents in the product sample were
most similar to a mixture of solvents and to 627 solvent (a solvent), Varsol 18 (an oil), and mineral spirits
(a solvent) (Refs. 63, pp. 1, 2; 56).
In 1994, free-phase product began to enter a storm sewer north of Building 67. The free-phase product
was removed (Ref. 31, p. 3-22). Based on the potential for repeated seepage of product into a leaky storm
water system, NJDEP identified this area as an area of IEC. NJDEP issued a directive to Sherwin-
Williams to address this IEC. A FPR and SVE system were installed after a focused feasibility study
(FFS) and a remedial action work plan (RAW) had been completed for the area of free-phase product.
Passive skimmers were installed in the thickest free-phase product to recover mobile product. The leaky
portion of the storm sewer was excavated and replaced with a sealed system to prevent infiltration of free-
phase product. Free-phase product removal equipment was also installed in the area of former Tank Farm
A (Ref. 31, pp. 1-5, 3-22, 3-23).
In 1995, Sherwin-Williams entered into an ACO with NJDEP to conduct an RI/FS in the area os Source 1
and to remove free-phase product (Refs. 18, p. 1-1; 61).
Sherwin-Williams conducted the following remedial actions in the area of Source 1:
Removal and disposal of the former wooden containment structure installed by the owner of the
property when the contamination was discovered.
Removal and disposal of contaminated soils and ground water from the area east of Hilliards
Creek and west of the police station (Building 50) (Ref. 18, p. 1-1).
Excavation of exploratory trenches in the area immediately west of the police station building
(Building 50).
Replacement of storm sewer immediately north of the Building 67.
Installation of a FPR and SVE system on the east side of Building 67 (Refs. 6, pp. 3-47 through 3-
52; 18, p. 1-2; 31, pp. 3-22, 3-23, 3-24; 48, Figure 2-1).
The aboveground treatment system consisted of a free-phase product collection and holding tank and the
SVE/Thermal Oxidizer skid (Ref. 31, p. 3-25).
23
-------
SD - Characterization and Containment
Source No.: 1
In 1996, while investigating the free-phase product plume at Buildings 50 and 67, a 6-inch terra-cotta pipe
leading from Building 50 to Hilliards Creek was uncovered. The pipe end was encountered 3 feet bgs, and
the pipe extended 10 feet to the west from Building 50 toward Hilliards Creek. The end of the pipe was
exposed. The pipe terminated abruptly, and no french drain or sump was found at its terminus. Free-
phase product was present in the interior of the pipe. The pipe was traced to a floor drain in Building 50.
The pipe was above the water table; therefore, the product found in the pipe was not introduced by
contaminated ground water. The seep on the west side of Building 50 was attributed to the pipe (Ref. 18,
pp. 3-4, 3-5, 4-1). Since John Lucas and Company used Building 50 as a garage, the free-phase product
may have resulted from the discharge of petroleum-type wastes (Refs. 6, Figure 2-4; 60, p. 99).
Also while investigating the free-phase product plume at Buildings 50 and 67, additional product was
identified in the former location of two ASTs used by Academy Paint, a tenant of Building 67, to store
mineral spirits 66-2 and 802-15 alkyd resin (Ref. 18, pp. 3-4, 3-5, 4-1, Figure 3-1). The AST were located
on the south side of Building 50 (Ref. 18, Figure 3-1).
During the removal action in 1996, Sherwin-Williams recovered 13,910 gallons of the mixture of
nonhazardous liquid, water, and oil from Buildings 50 and 67 free-phase product plume and disposed of
the material off the property (Refs. 18, pp. ES-1, 3-5; 31, p. 3-24). After remedial action was completed,
residual contamination remained in the area of the Lucas plant property and Hilliards Creek (Refs. 18, pp.
ES-1, 4-1; 31, Figure 3-2).
In November 1997, the installation of the FPR and SVE system was completed east and north of Building
67 and south of Building 50 (Ref. 48, pp. 1-1, 2-2, 3-1, Figure 2-1). As of June 20, 2002, a total of 44,785
gallons of product/water mixture have been recovered and removed off site for disposal since startup of the
system in November 1997. Approximately 8,275 gallons of this total volume collected was primarily
product from the product recovery tank. The remaining 36,510 gallons of product/water mixture were
collected during the ground water seep response and recovery efforts associated with the FPR and SVE
system (Ref. 48, p. 2-1).
On April 9, 2002, free-phase product from the free-phase product recovery system was observed in the
storm water drain north of Building 67 and in Hilliards Creek. Product was pumped out of the storm water
drain, and additional measures were taken to prevent further releases to the drain and Hilliards Creek
(Refs. 48, p. 2-3; 72, pp. 2, 4; 73, pp. 2, 4).
Location of the source, with reference to a map of the site: Source 1 is located on the west side of
Building 50, on the east and southeast sides of Building 67, the storm sewer system north of Building 67,
and in the area of Tank Farm A. Figure 2-2 of Reference 31 shows the three seep areas: one on the west
side of Building 50, one on the east side of Building 67, and one in the area of Tank Farm A and the
location of the sewer. The seep areas are the locations where free-phase product was observed at the
ground surface or in on-site monitoring wells.
24
-------
SD - Characterization and Containment
Source No.: 1
Containment:
Release to ground water: Migration of hazardous substances from the source area has been documented;
therefore, a containment factor value of 10 is assigned to this source. Additionally, as documented in the
section above, the source does not have a liner or containment system (Ref. 1, Table 3-2).
Release via overland migration and/or flood: Migration of hazardous substances from the source area
has been documented; therefore, a containment factor value of 10 is assigned to this source. Additionally,
as documented in the section above, a maintained engineered cover, or functioning and maintained run-on
control system and runoff management system, is not associated with Source 1 (Ref. 1, Table 4-2).
Gas release to air: The air migration pathway was not scored.
Particulate release to air: The air migration pathway was not scored.
25
-------
SD - Characterization and Containment
Source No.: 1
2.4 WASTE CHARACTERISTICS
2.4.1 Hazardous Substances:
Samples of free-phase product and soil are used to characterize the hazardous substances associated with
Source 1. The soil samples were collected from locations where free-phase product was observed. The
sections below provide a description and documentation of the free-phase product and soil samples
collected to characterize Source 1.
Free-Phase Product
On February 7, 1985, NJDEP personnel collected an aqueous sample of product while it was discharging
into Hilliards Creek (Ref. 32, pp. 5, 6). The following hazardous substances were detected in product
sample: 1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene, naphthalene, xylenes, ethylbenzene, cumene,
and tetrachloroethene (Ref. 32, pp. 6, 7).
In February 1987, product was observed in the parking lot between Buildings 50 and 67 and flowing from
the eastern bank of Hilliards Creek. An aqueous sample was collected from the product flowing into
Hilliards Creek, and a sediment sample was collected below the bituminous layer of the parking lot where
the product was observed (Refs. 6, Figure 2-4; 10, pp. 1, 2; 31, p. 3-3 and Figures 2-2 and 3-2).
The free-phase product ground water plume was investigated during five phases of the RI for the Lucas
plant (Ref. 31, p. 3-3). The RI identifies five areas of environmental concern (AEC). The seep areas or
areas where free-phase product was observed at the surface in the areas of Buildings 50 and 67, were
identified as AEC III. AEC III was combined with AEC I, Tank Farm A, because of similarities in the
nature of contaminants (Ref. 31, p. 3-1). Figure 3-1 of Reference 31 shows the AECs, and Figure 2-2 of
Reference 31 shows the location of three seeps one on the west side of Building 50, one on the east side of
Building 67, and one in the southern section of the former location of Tank Farm A.
The RI report for the five phases of the investigation refers to AEC I/III when presenting analytical data
collected for the free-phase product ground water plume. Figure 3-2 of Reference 31 was used to identify
sampling locations specifically associated with the free-phase product.
During Phase II activities, from June 1993 through October 1993, three well points (WP-1, WP-2, and
WP-3) were installed to delineate the free-phase product ground water plume detected in MW-13 (Ref. 31,
pp. 3-3, 3-15). Samples of free-phase product were collected from the MW-11 (located on the southern
end of Tank Farm A) and MW-13 (located east of Building 67) (Ref. 31, p. 3-17, Figure 3-2). Analytical
results for the product sample collected from MW-11 on August 6, 1993 indicated the presence of 2-
methylnaphthalene (360 milligrams per liter [mg/L]), 4-chloroaniline (320 mg/L), naphthalene (930
mg/L), chlorobenzene (100 mg/L), ethylbenzene (at an estimated concentration of 520 mg/L), and xylene
(at 4,600 mg/L) (Ref. 31, Table 4-20). The product sample collected from MW-13 on August 6, 1993
contained 2-methylnaphthalene (1,800 mg/L), naphthalene (6,200 mg/L), benzene (at 110 mg/L),
ethylbenzene (1,200 mg/L), and xylene (2,100 mg/L) (Ref. 31, Table 4-20).
During Phase III activities, from July 1995 through August 1995, 45 hand-augered borings were located
throughout the seep area to attempt to delineate the extent of free-phase product through photoionization
26
-------
SD - Characterization and Containment
Source No.: 1
detector (PID) field screening and visual observation. No samples were collected from these locations
(Ref. 31, pp. 3-3, 3-18). Additional monitoring wells were installed, and two rounds of ground water
samples were collected (Ref. 31, p. 3-19). On July 14, 1995, samples of the free-phase product were
collected from the MW-11 (located on the southern end of Tank Farm A), MW-13 (located east of
Building 67), and MW-21 (southeast of Building 67) (Ref. 31, p. 3-17, Figure 3-2). Anaytical results for
the product sample collected from MW-11 indicated the presence of naphthalene (at an estimated
concentration of 600 mg/L), ethylbenzene (66 mg/L), and xylene (2,500 mg/L). The product sample
collected from MW-13 contained naphthalene (at 3,200 mg/L), benzene (at 570 mg/L), ethylbenzene (at
1,400 mg/L), and xylene (at 7,500 mg/L). Analytical results for the product sample collected from MW-
26 indicated 2-methylnaphthalene (at an estimated concentration of 460 mg/L), naphthalene (1,600 mg/L),
and xylene (420 mg/L) (Ref. 31, Table 4-20).
Also during the Phase III activities, free-phase product was measured for the mobile thickness of the
product, the volume of recoverable product, and the recharge rates of the product (Ref. 31, p. 3-20). A
bail-down test was conducted to identify the thickness of the product (Ref. 31, Appendix K, Tables El
through E4).
The bail-down test completed in WP-3 in the area of the Building 50 indicated that the thickness of the
product in July 1995 as 0.33 foot and in August 1995 as 0.48 foot (Ref. 31, Figures 4-11 and 4-12). The
bail-down test completed in the area of the Building 67 indicated that the thickness of the product in July
1995 at MW-21 as 2.21 feet, atMW-13Ras 0.98 foot, and atWP-1 as 1.33 feet (Ref. 31, Figure 4-11). In
August 1995 the thickness of product was recorded at MW-21 as 0.66 foot, at MW-13R as 1.28 feet, and
at WP-1 as 1.33 feet (Ref. 31, Figure 4-12). The bail-down test completed in MW-11 in the area of the
Tank Farm A identified the thickness of product as 1.47 feet in July 1995 and 0.45 foot in August 1995
(Ref. 31, Appendix K, Table E2, and Figures 4-11 and 4-12). The lateral extent of three separate product
plumes in ground water are shown on Figures 4-11 and 4-12, Appendix K, Reference 31. The plumes are
considered separate because of the absence of product in the monitoring wells located between the plumes
(Ref. 31, p. 4-20).
The hazardous substance and concentrations detected in product samples collected from MW-11, in the
area of Tank Farm A, and from MW-13, in the area of Building 67 are similar (Ref. 31, Table 4-20, Figure
3-2). The fingerprint analysis of a sample of free-phase product from the storm sewer indicated that the
product most closely resembled degraded mineral spirits (Ref. 75, p. 15). Therefore, the product in ground
water in the areas of Tank Farm A and Building 67 may be from the release of mineral spirits from Tank
Farm A and Building 67. Both areas were used for the storage of mineral spirits (Refs. 4; 5; 6; 31, 2-4,
Table 2-2, Figure 2-2; 60, pp. 68 and 99).
According to the RI report, the source of free-phase product on the west side of Building 50 may be from
the discharge of waste oils to soils over time, migration of free-phase product from the former Academy
Paints hazardous materials storage area, or the Lucas maintenance shop formerly located in Building 50
(Ref. 31, pp. 4-23 and 4-24).
The RI report provides a discussion of the composition of the free-phase product. Much of the analytical
data supporting the discussion are not in the RI report. Analytical data are presented for product samples
collected from MW-11, MW-13, MW-21, and MW-26 in Table 4-20 of the RI report. The report stated
that xylene was the VOC detected at the highest concentration, and of the base/neutral acids, naphthalene
27
-------
SD - Characterization and Containment
Source No.: 1
was detected at the highest concentration. The majority of the product constituents are tentatively
identified compounds (TIC). VOC TICs consist primarily of unknown substituted benzenes. Semivolatile
organic compound (SVOC) TICs include cycloalkanes, alkanes, benzenes, and unknown polycyclic
aromatic hydrocarbons (PAH) (Ref. 31, p. 4-25). Two free-phase product samples collected from MW-11
and SVE Vent No. 6 located west of Building 67 were analyzed by American Society for Testing and
Materials (ASTM) D5134 (Component Analysis) (Refs. 31, p. 4-26, Figure 3-2; 48, Figure 2-1). The
ASTM D5134 analysis provided identification of an exhaustive list (the list was not provided in the RI
report) of hydrocarbon compounds, that are not typically analyzed for and quantified by routine SW846
methods. The result of the free-phase product analyses were compared to the results of analyses of fresh
samples of gasoline and paint-thinner. The comparison was done by principal component analysis (PCA).
The PCA suggested that the samples were more related to paint-thinner rather than gasoline. However,
because the comparison was of unweathered and degraded standard against weathered and biodegraded
environmental samples, the correlation was regarded with limited confidence (Ref. 31, p. 4-26).
One ground water sample (MW-36 located 150 feet south of Building 67) was collected and analyzed by
Modified EPA Method 8015 (capillary gas chromatography). No free-phase hydrocarbons could be
recovered from the ground water sample (Ref. 31, p. 4-26, Figure 3-2).
The RI report states that 14 free-phase product samples were analyzed for petroleum hydrocarbon
products. Analytical data for the analysis of the product samples are not presented in the RI report. No
evidence of the presence of any organolead or organomanganese compounds were found in any of the
free-phase product samples. Two free-phase product samples collected from SVE-3 and MW-36, located
east and south of Building 67, respectively, contained no petroleum product (Refs. 31, p. 4-27, Figure 3-2;
48, Figure 2-1). (Note: The location and definition of SVE-3 is not in the RI report. SVE probably
indicates soil vapor extraction and the number represents the vent number as shown on Figure 2-1 of
Reference 48). The report indicates that analytical results for product samples revealed the presence of a
biodegraded, low boiling point petroleum hydrocarbon (Ref. 31, p. 4-27). From the report is not clear
where these product samples were collected. However, the report does indicate that the product in the area
of Source 1 may be a mixture of solvents and waste petroleum product.
On April 9, 2002, free-phase product from the FPR and SVE system was observed in the storm water
system (catch basin A and inlet C) and rip-rap north of Building 67 and in Hilliards Creek. The product
was pumped out of the storm water drain, and additional measures were taken to prevent further releases to
the drain and Hilliards Creek (Refs. 48, p. 2-3; 72, pp. 2, 4; 73, pp. 2, 4). As shown on Figure 2-4 of
Reference 48, inlet A is the catch basin in the parking lot north of Building 67 that drains to the storm
sewer that runs from east to west to rip-rap and finally to Hilliards Creek. Inlet C is located on the western
end to the storm sewer system just east of the discharge point of the storm water system to the rip-rap (Ref.
48, Figure 2-4). Figure 2-1 of Reference 48 shows the location of the vertical vents and the layout of the
FPR and SVE system.
On April 10, 2002, samples of the free-phase product were collected and analyzed for VOCs, petroleum
products, and fingerprinted (Ref. 75, pp. 2, 4, 5). The concentrations of hazardous substances detected in
the product sample are in the units of micrograms per kilogram (j^ig/kg) indicating that the sample was
analyzed as a solid. Analytical results for the samples indicated the presence of benzene (up to 240,000
(ig/kg), ethylbenzene (up to 4,600,000 |_ig/kg). xylene (up to 26,000,000 |_ig/kg). naphthalene (up to
1,800,000 |ag/kg). 2-methylnaphthalene (up to an estimated concentration of 400,000 |_ig/kg). and
28
-------
SD - Characterization and Containment
Source No.: 1
numerous TICs (Ref. 75, pp. 6, 7, 8). The fingerprint analysis indicated that the product samples most
closely resembled degraded mineral spirits (Ref. 75, p. 15).
Analytical results for the wastewater sample from the product tank indicated an estimated concentration of
benzene and ethylbenzene and the presence of m/p xylenes, naphthalene, and 2-methylnaphthalene (Refs.
76, pp. 8, 9; 77, p. 35). Metals detected in the product tank include aluminum, arsenic, chromium, copper,
iron, lead, magnesium, manganese, selenium, and zinc (Ref. 77, p. 75). The toxicity characteristic
leaching procedure (TCLP) analysis revealed benzene (230 micrograms per liter [jj.g/L]) (Ref. 77, p. 31).
The inlet C sample analysis revealed an estimated concentration of benzene and the presence of
ethylbenzene, m/p- xylenes, naphthalene, and 2-methylnaphthalene (Refs. 76, pp. 10, 11; 77, p. 39). The
only TCLP metal detected in the inlet C sample was lead (455 j^ig/L) (Ref. 77, p. 82). The inlet C water
sample analysis revealed an estimated concentration of benzene, the presence of ethylbenzene and m/p-
xylenes, and estimated concentrations of naphthalene, 2-methylnaphthalene, and fluoranthene (Ref. 76, pp.
12, 13, 19, 20). Metals were also detected in the inlet C water sample, including aluminum, arsenic,
barium, chromium, copper, iron, lead, magnesium, manganese, and zinc (Ref. 77, p. 76).
As of June 30, 2002, the FPR system recovered approximately 44,785 gallons of product and /or water
since startup of the recovery system in November 1997. Approximately 8,275 gallons of this total volume
collected is primarily product from the product recovery tank. The remaining 36,510 gallons or
product/water mix were collected during the ground water seep response and recovery efforts associated
with inlets A and C (Ref. 48, p. 2-1).
In May 2003, EPA's environmental consultant collected samples of the free-phase product mixed with
water from basin A, inlet C, and the rip-rap. The samples were analyzed for target compound list (TCL)
VOCs, SVOC, pesticides and polychlorinated biphenyls (PCB), target analyte list (TAL) metals and
cyanide, gasoline range organics (GRO), diesel range organics (DRO), percent sulfur, percent ash,
Kjeldahl nitrogen, pH, and flashpoint. The analytical results confirmed the presence of benzene,
ethylbenzene, xylene, naphthalene, and 2-methylnaphthalene (Ref. 78, pp. 16, 11). Other constituents of
the product sample included the following metals: aluminum (up to 9,150 (ig/L). arsenic (up to 51.2
(ig/L), barium (up to 408 (ig/L). chromium (up to 33.3 (ig/L). copper (up to 79.0 (ig/L). iron (up to 95,200
(ig/L), lead (up to 139 (ig/L). magnesium (up to 23,000 (ig/L). manganese (up to 1,380 (ig/L). and zinc (up
to 413 jig/L) (Ref. 78, pp. 15, 16).
29
-------
SD - Characterization and Containment
Source No.: 1
Hazardous substances associated with the analytical results from product samples collected from Source 1
and discussed above are summarized in Table 1 (Ref. 31, pp. 4-18 through 4-24). As documented in Table
1, free-phase product samples were collected from seeps (product) emanating from the ground surface,
monitoring wells, and the FPR and SVE system. The analytical data presented in Table 1 from Reference
31 are from the analysis of free-phase product samples collected from on-site monitoring wells. Reference
32 provides analytical data for the analysis of a discharge to a creek. The seep (free-phase product) was
continuously discharging into the creek (Ref. 32, pp. 5, 6). The analytical data presented in References. 76
and 77 are for a product sample collected from the product tank associated with the FPR system, inlet C,
and rip-rap area where the storm sewer discharges (Refs. 77, p. 2; 48, Figure 2-4). The analytical data
presented in Reference 78 are from basin A (the storm sewer basin in the parking lot adjacent to Building
67), inlet C, and the rip-rap area (Refs. 78, p. 1; 79). The analytical data presented in Reference 79 are
from a sample collected from the product tank associated with the FPR system and a bi-phase sample
collected from inlet C (an inlet in the storm sewer) (Refs. 48, Figure 2-4; 76, p. 1).
30
-------
SD - Characterization and Containment
Source No.: 1
TABLE 1
HAZARDOUS SUBSTANCES ASSOCIATED WITH SOURCE 1
Hazardous
Substance
Evidence
Reference
Metals
Aluminum
Product sample
77, pp. 1,2, 75,76; 78, pp. 1,5, 16
Arsenic
Product sample
77, pp. 1,2, 75,76; 78, pp. 1, 15, 16
Barium
Product sample
77, pp. 1,2, 76; 78, pp. 1, 15, 16
Chromium
Product sample
77, pp. 1,2, 75,76; 78, pp. 1, 15, 16
Copper
Product sample
77, pp. 1,2, 75,76; 78, pp. 1, 15, 16
Iron
Product sample
77, pp. 1,2, 75, 76; 78, pp. 1, 15, 16
Lead
Product sample
77, pp. 1,2, 75, 76; 78, pp. 1, 15, 16
Magnesium
Product sample
77, pp. 1,2, 75,76; 78, pp. 1, 15, 16
Manganese
Product sample
77, pp. 1,2, 75,76; 78, pp. 1, 15, 16
Zinc
Product sample
77, pp. 1,2, 75, 76; 78, pp. 1, 15, 16
Volatile Organic Compounds
Benzene
Product sample
31, pp. 4-25, 6-9, Table 4-20, Figure 3-2; 32, pp. 5, 6;
75, pp. 2, 6, 12; 76, pp. 1 through 4, 12; 77, pp. 10, 19,
31; 78, p. 1; 79, pp. 2, 4
Cumene
Product (seep)
sample
32, pp. 6, 7
Ethylbenzene
Product (seep)
sample
31, pp. 4-25, 6-9, Table 5-20, Figure 3-2; 32, pp. 6, 7;
75, pp. 2, 6, 9, 12; 76, pp. 1 through 4, 9, 13; 77, pp.
11,20; 78, p. 1; 79, p. 5
T etrachloroethene
Product (seep)
sample
32, pp. 6, 7
1,2,4-Trimethyl
benzene
Product (seep)
sample
32, pp. 6, 7
31
-------
SD - Characterization and Containment
Source No.: 1
TABLE 1 (Continued)
HAZARDOUS SUBSTANCES ASSOCIATED WITH SOURCE 1
Hazardous
Substance
Evidence
Reference
Volatile Organic Compounds (Continued)
1,3,5-Trimethyl
benzene
Product (seep)
sample
32, pp. 6, 7
Xylene
Product (seep)
sample
10, pp. 25, 27; 31, pp. 4-25, 6-9, Table 5-20; Figure 3-
2 in Reference 31; 32, pp. 6, 7; 75, pp. 2, 6, 9; 76, pp. 1
through 4, 9, 13; 77, pp. 11, 20; 79, pp. 2, 5
Semivolatile Organic Compounds
Benzo(a)pyrene
Product sample
78, pp. 1 through 4, 13; 79, p. 28
Chrysene
Product sample
78, pp 1 through 4, 13; 79, p. 28
Fluoranthene
Product sample
76, pp. 1 through 4, 9, 20; 77, p. 45; 78, pp. 1 through
4, 10; 79, p. 23
2-Methylnaphthalene
Product (seep)
sample
31, pp. 4-25, 6-9, Table 5-20, Figure 3-2; 75, pp. 2, 6,
9, 19, 35, 44; 78, pp. 6, 11; 79, pp. 12, 17
Naphthalene
Product (seep)
sample
31, pp. 4-25, 6-9, Table 5-20, Figure 3-2; 32, pp. 6, 7;
75, pp. 2, 6, 9; 76, pp. 1 through 4, 16, 19, 35, 44; 78,
pp.6, 9, 11; 79, pp. 12, 17, 22
Soil Samples - Source 1
1987 Investigation
In 1987, contaminated soil was identified in the area of Buildings 50 and 67 during a subsurface soil
investigation (Ref. 10, p. 5). The source of the contaminated soil is the free-phase product. Soil samples
were analyzed for priority pollutants and total petroleum hydrocarbons (Ref. 10, p. 6), revealing the
presence of petroleum hydrocarbons, VOCs (xylene), SVOCs [pentachlorophenol, di-n-butyl phthalate,
bis(2-ethylhexyl)phthalate)], cyanide, chromium, copper, and lead (Ref. 10, pp. 10 and 25 through 39).
Remedial Investigation
Hazardous substances associated with Source 1 were identified during numerous soil sampling
investigations conducted in the area of the free-phase product ground water plume. The most recent
32
-------
SD - Characterization and Containment
Source No.: 1
investigation was a five-phase RI for the Lucas plant (Ref. 31, p. 3-3). The soil samples collected during
the RI are used to characterize Source 1 because the soil contamination is a result of the ground water
plume. The RI identifies Source 1 as AEC I/III (Ref. 31, p. 3-3 to 3-6). The RI report refers to AEC I/III
when soil samples were collected from Source 1. Figure 3-2, in Reference 31, was used to identify soil
sampling locations specifically associated with Source 1, free-phase product.
Soil samples were collected from Source 1 during three phases of the RI as described in the sections
below.
Phase I RI
Soil samples were collected in the area of Source 1 (AEC I/III) (Ref. 31, p. 3-7) from August 1991 through
lanuary 1992, during a Phase I RI for the Lucas plant (Ref. 31, p. 3-3). The Phase I RI focused in the seep
area (ground water plume in the area of Buildings 50 and 67) and Tank Farm A. Four test borings (TB-6,
TB-7, B-13, and TB-14) were drilled in the area of the free-phase product identified near Building 67 (Ref.
31, Figure 3-2). Two soil samples were collected from each boring at 0 to 2 feet below the bgs and at the
water table. The samples were analyzed for Priority Pollutant Volatile Organic Analysis plus 15-non
target compounds (PP VOA+15), Priority Pollutant Base Neutral Analysis (PP BNA), lead, chromium, and
barium. Two of the test borings were converted into monitoring wells. The monitoring wells, MW-13 and
MW-14, were sampled and analyzed for PP VOA+15, PP BNA, lead, chromium, barium, and phenols
(Ref. 31, p. 3-11). Free-phase product was identified in both MW-13 and MW-14 (Ref. 31, p. 4-18, Table
4-20). MW-14 is located adjacent to the storm sewer systems where free-phase product has been
recovered. The storm system is known to leak product to the surrounding area (Ref. 31, pp. 1-5, 3-22, 3-
23, Figure 3-2).
Six soil borings (TB-1 through TB-4, TB-11 [converted to MW-11], and 12 [converted to MW-12]) were
installed in and around the free-phase product ground water plume in the area of former Tank Farm A.
The soil borings were drilled to a depth of 10 to 20 feet bgs (Ref. 31, pp. 3-7, 3-8, Figure 3-2). Splitspoon
samples were collected continuously until the water table was encountered. Two soil samples from each
boring were collected and analyzed for PP VOA+15, PP BNA, lead, chromium, and barium. Samples
were collected at 0 to 2 feet bgs and at the water table interface (Ref. 31, p. 3-8).
Phase II RI
Screening techniques were employed in the area of Source 1 to evaluate the presence or absence of
sources, to identify hot spots, and to provide additional data concerning the subsurface from lune 1993
and October 1993, during a Phase II RI for the Lucas plant. Soil borings were drilled in the free-phase
areas near Buildings 50 and 67 and Tank Farm A and soil samples were collected at various depths (Ref.
31, pp. 3-3, 3-14, 3-15).
Phase III RI
During Phase III of the RI, from luly 1995 through August 1995, soil samples were collected from Source
1 and 45 hand-augered borings were located throughout the seep area (seep near Buildings 50 and 67) to
delineate the extent of free-phase product (Ref. 31, pp. 3-3, 3-18).
33
-------
SD - Characterization and Containment
Source No.: 1
Analytical results for soil samples collected during the RI from Source 1 indicated the presence of the
following hazardous substances: acetone; 2-butanone; 1,2-dichloroethene; ethylbenzene; 1,1,2,2-
tetrachloroethane; tetrachloroethene; toluene; 1,1,2-trichloroethane; trichloroethene; xylene (total);
benzo(a)anthracene; benzo(a)pyrene; benzo(b)fluoranthene; benzo(k)fluoranthene; chrysene; 2,4-
dimethylphenol; fluoranthene; 2-methylnaphthalene; naphthalene; phenanthrene; pyrene; aluminum;
arsenic; barium; cadmium; chromium; copper; iron; lead; magnesium; mercury; nickel; selenium; silver;
vanadium; and zinc (Ref. 31, Table 4-5, Figure 3-2).
As documented in the RI report, the area of contaminated soil associated with Buildings 50 and 67 is
estimated as 7,000 square feet (Ref. 31, pp. 5-4, 5-5, Figure 3-2). The RI also indicates that the estimated
the volume of contaminated soil in the area of Tank Farm A is 9,000 cubic yards (Ref. 31, p. 5-3).
Provided below is a summary of the analyses for soil samples collected in Source 1 revealing the presence
of contaminated soil in the vicinity of the product seep areas. The sampling locations are shown on Figure
3-2 in Reference 31. Soil samples collected from MW-12 are used to document background
concentrations for shallow soil samples and are used as source samples for deeper soil samples. The soil
in the shallow portion of MW-12 does not contain hazardous substances found in the free-phase product,
Source 1. The free-phase product ground water plume has not contaminated the shallow soil at the
location of MW-12. No other soil sampling location was identified that could be used to establish
background concentrations for shallow soil. All the soil samples are collected from the Westphalia and
Nixonton Urban land complex soil types (Ref. 31, Figure 2-10).
34
-------
SD - Characterization and Containment
Source No.: 1
Source 1 Soil Sample: 013-B001 (The well log for MW-13 indicates that a flame ionization detector
[FID] detected 1,000 [units not listed] units ofVOCs [Ref. 31, Appendix C, p. 12]).
Location ID
MW-13
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
013-B001
012-B001
Date Collected
10/28/1991
10/14/1991
Depth (ft bgs)
0.0-2.0
0.0-2.0
Reference
31, Table 4-5 (p. 1),
31, Table 4-5 (p. 1),
p. 3-11, and Figure 3-2
p. 3-11, and Figure 3-2
Location
E Bldg 67
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
Ethylbenzene
3.9
ND
Xylene (total)
9
ND
Semivolatile Organic Compounds (mg/kg)
2,4-Dimethylphenol
4.1
ND
2-Methylnaphthalene
3.1
ND
Naphthalene
10
ND
Metals (mg/kg)
Barium
37.5
10.6
Lead
27.5
6
Source 1 Soil Sample: 013-B002
Location ID
MW-13
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
013-B002
012-B001
Date Collected
10/28/1991
10/14/1991
Depth (ft bgs)
2.0-4.0
0.0-2.0
Reference
31, Table 4-5 (p. 2, 16),
31, Table 4-5 (p. 2, 15),
p. 3-11, and Figure 3-2
p. 3-11, and Figure 3-2
Location
E Bldg 67
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
2-Butanone
22
ND
Ethylbenzene
61
ND
Xylene (total)
200
ND
Semivolatile Organic Compounds (mg/kg)
2-Methylnaphthalene
10
ND
Naphthalene
42
ND
35
-------
SD - Characterization and Containment
Source No.: 1
Metals (me/ke)
Barium
68.1
10.6
Lead
22.4
4.1
Source 1 Soil Sample: 014-B001
Location ID
MW-14
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
014-B001
012-B001
Date Collected
10/281991
10/14/1991
Depth (ft bgs)
0.0-2.0
0.0-2.0
Reference
31, Table 4-5 (p. 1),
31, Table 4-5 (p. 15),
p. 3-11, and Figure 3-2
p. 3-11, and Figure 3-2
Location
N Bldg 67
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
2-Butanone
0.24
ND
Toluene
0.009
ND
Trichloroethene
0.01
ND
Metals (mg/kg)
Barium
67.3
10.6
Lead
24.6
4.1
Source 1 Soil Sample: PS-01 (Background soil samples are not available; no other surface soil samples
were collected. [Ref. 31, Appendix C, p. 577]).
Location ID
PS-01
Sample Type
Source - Soil
Field Sample ID
PS-01
Date Collected
2/21/1996
Depth (ft bgs)
Surface
Reference
31, Table 4-5 (pp. 9, 16) and
Figure 3-2
Location
W Bldg 50
Volatile Organic Compounds (mg/kg)
Xylene 64
Semivolatile Organic Com
Dounds (mg/kg)
3cnzo(a)anthraccnc
1.4
J
3cnzo(a)pvrcnc
1.5
J
3enzo(b)fluoranthene
1.2
J
3enzo(k)fluoranthene
1.3
J
~irvsene
1.6
J
"luoranthene
2.6
J
36
-------
SD - Characterization and Containment
Source No.: 1
Location ID
PS-01
Sample Type
Source - Soil
Field Sample ID
PS-01
Date Collected
2/21/1996
Depth (ft bgs)
Surface
Reference
31, Table 4-5 (pp. 9, 16) and
Figure 3-2
Location
W Bldg 50
'-Methyl naphthalene
6.8
J
Naphthalene
18
Phenanthrene
2
J
Pyrene
2.3
J
Metals (mg/kg)
Arsenic
29.3
Barium
493
Cadmium
0.44
Chromium
200
Lead
1180
Mercury
0.29
Nickel
3.9
Selenium
0.38
Vanadium
10.8
Zinc
130
Source 1 Soil Sample: 007-B001 (The soil boring log for TB-07 indicates that an organic vapor analyzer
[OVA] detected 300 to 1,000 [units not provided] units ofVOCs [Ref. 31, Appendix C, p. 237]).
Location ID
TB-07
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
007-B001
012-B001
Date Collected
10/29/1991
10/14/1991
Depth (ft bgs)
0.0-3.0
0.0-2.0
Reference
31, Table 4-5 (p. 3), p. 3-11,
31, Table 4-5 (p. 2), p. 3-11,
and Figure 3-2
and Figure 3-2
Location
SE Bldg 67
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
Xvlene (total)
0.028
ND
37
-------
SD - Characterization and Containment
Source No.: 1
Source 1 Soil Sample: 007-B001 (The soil boring log for TB-08 indicates that an OVA detected 1,000
[units not provided] units of VOCs and the soil had a solvent odor [Ref. 31, Appendix C, p. 238]).
Location ID
TB-08
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
007-B001
012-B001
Date Collected
10/22/1991
10/14/1991
Depth (ft bgs)
0.0-2.0
0.0-2.0
Reference
31, Table 4-5 (pp.4, 11, 17),
31, Table 4-5 (pp.2, 9, 15),
p. 3-11, and Figure 3-2
p. 3-7, and Figure 3-2
Location
E Bldg 67
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
ithylbenzene
0.015
ND
Semivolatile Organic Compounds (mg/kg)
2-Methylnaphthalene
1.7
ND
Naphthalene
4.6
ND
Metals (mg/kg)
Barium
2,940
10.1
Chromium
90.7
7.7
Lead
2.070
4.1
Source 1 Soil Sample: 030-B001 (The soil boring log for TB-30 indicates that an OVA detected up to
1,000 [units not provided] units of VOCs [Ref. 31, Appendix C, p. 264]).
Location ID
TB-30
TB-37
Sample Type
Source - Soil
Background - Soil
Field Sample ID
030-B001
007-B001
Date Collected
7/7/1993
7/7/1993
Depth (ft bgs)
4.2-5.0
4.7-5.5
Reference
31, Table 4-5 (pp.4, 11),
31, Table 4-5 (pp. 5, 12),
p. 3-14, and Figure 3-2
p. 3-14, and Figure 3-2
Location
E Bldg 67
SE Tank Farm A
Volatile Organic Compounds (mg/kg)
Ethylbenzene
3.5
ND
Xylene
27
ND
Semivolatile Organic Compounds (mg/kg)
2-Methylnaphthalene
48
ND
Naphthalene
180
0.049 J
38
-------
SD - Characterization and Containment
Source No.: 1
Source 1 Soil Sample: 030-B001
Location ID
TB-30
SGW-236
Sample Type
Source - Soil
Background - Soil
Field Sample ID
030-B001
236-B002
Date Collected
7/7/1993
7/6/1993
Depth (ft bgs)
4.2-5.0
3.5-4.0
Reference
31, Table 4-5 (pp.4, 11),
31, Table 4-5 (p. 1),
p. 3-14, and Figure 3-2 A
p. 3-14, and Figure 3-2
Location
SE Bldg 67
SE Tank A
Volatile Organic Compounds (mg/kg)
Ethylbenzene
3.5
ND
Xylene (total)
27
ND
Semivolatile Organic Compounds (mg/kg)
2-Methylnaphthalene
48
NA
Naohthalene
180
NA
Source 1 Soil Sample: 011-B001 (The soil boring log for MW-11 indicates that a FID detected up to
1,000 [units not provided] units of VOCs [Ref. 31, Appendix C, p. 6]).
Location ID
MW-11
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
011-B001
012-B001
Date Collected
10/14/1991
10/14/1991
Depth (ft bgs)
0.0-2.0
0.0-2.0
Reference
31, Table 4-5 (p. 9), pp. 3-7,
31, Table 4-5 (p. 9),
and Figure 3-2
p. 3-7, and Figure 3-2
Location
SW Tank Farm A
NW Tank Farm A
Semivolatile Organic Compounds (mg/kg)
2-Methylnaphthalene
0.37
ND
Naphthalene
1.6
ND
39
-------
SD - Characterization and Containment
Source No.: 1
Source 1 Soil Sample: 012-B002 (The soil boring log for MW-12 indicates that the FID detected up to
800 [units not provided] units ofVOCs [Ref. 31, Appendix C, p. 9]).
Location ID
MW-12
TB-6
Sample Type
Source - Soil
Background - Soil
Field Sample ID
012-B002
006-B002
Date Collected
10/14/1991
10/22/1991
Depth (ft bgs)
6.0-8.0
6.0-7.0
Reference
31, Table 4-5 (pp. 2, 9), pp.
3-7, and Figure 3-2
31, Table 4-5 (pp. 3, 10),
and Figure 3-2
Location
NW Tank Farm A
S Corner Bldg 55
Volatile Organic Compount
s (mg/kg)
Ethylbenzene
19
ND
Xylene (total)
69
ND
Semivolatile Organic Compounds (mg/kg)
2-Methylnaphthalene
8.4
ND
Naohthalene
39
ND
Source 1 Soil Sample: 001-B001 (The soil boring log for TB-01 indicates that an OVA detected up to
1,000 [units not provided] units ofVOCs [Ref. 31, Appendix C, p. 230]).
Location ID
TB-01
MW-12
Sample Type
Soil
Soil
Field Sample ID
001-B001
012-B001
Date Collected
10/14/1991
10/14/1991
Depth (ft bgs)
0.0-2.0
0.0-2.0
Reference
31, Table 4-5 (p. 10), pp.
31, Table 4-5 (p. 9),
3-7, and Figure 3-2
p. 3-7, and Figure 3-2
Location
NE Tank Farm A
NW Tank Farm A
Semivolatile Organic Compounds (mg/kg)
Benzo(k)fluoranthene
0.42
ND
Chrysene
0.52
ND
Fluoranthene
1
ND
Naphthalene
0.55
J
ND
Phenanthrene
0.7
ND
Pvrene
0.81
ND
40
-------
SD - Characterization and Containment
Source No.: 1
Source 1 Soil Sample: 001-B001
Location ID
TB-01
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
001-B002
012-B001
Date Collected
10/14/1991
10/14/1991
Depth (ft bgs)
10.0-12.0
6.0-8.0
Reference
31, Table 4-5 (pp. 1), pp. 3-7 and
31, Table 4-5 (pp. 2, 9), p. 3-7,
Figure 3-2
and Figure 3-2
Location
NE Tank Farm A
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
Ethylbenzene
1,300
19
Toluene
24
ND
Xylene (total)
6.900
69
Source 1 Soil Sample: 002-B001 (The soil boring log for TB-02 indicates that an OVA detected up to 200
[units not provided] units ofVOCs [Ref. 31, Appendix C, p. 232]).
Location ID
TB-02
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
002-B001
012-B002
Date Collected
10/14/1991
10/14/1991
Depth (ft bgs)
0.0-2.0
0.0-2.0
Reference
31, Table 4-5 (1, 10), pp. 3-7,
and Figure 3-2
31, Table 4-5 (pp. 2, 9), p. 3-7,
and Figure 3-2
Location
Tank Farm A
NW Tank Farm A
Volatile Organic Compount
s (mg/kg)
Ethylbenzene
5.5
ND
Trichloroethene
0.55
ND
Xylene (total)
37
ND
Semivolatile Organic Compounds (mg/kg)
2,4-Dimethylphenol
0.66
ND
2-Methylnaphthalene
0.072
J
ND
Benzo(a)anthracene
0.055
J
ND
Benzo(a)pyrene
0.038
J
ND
Benzo(b)fluoranthene
0.056
J
ND
Benzo(k)fluoranthene
0.038
J
ND
Chrysene
0.063
J
ND
Semivolatile Organic ComDOunds (mg/kg)
Fluoranthene
0.12
J
ND
Naphthalene
0.053
J
ND
41
-------
SD - Characterization and Containment
Source >
Location ID
TB-02
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
002-B001
012-B002
Date Collected
10/14/1991
10/14/1991
Depth (ft bgs)
0.0-2.0
0.0-2.0
Reference
31, Table 4-5 (1, 10), pp. 3-7,
31, Table 4-5 (pp. 2, 9), p. 3-7,
and Figure 3-2
and Figure 3-2
Location
Tank Farm A
NW Tank Farm A
Phenanthrene
0.14
J
ND
Pvrene
0.1
J
ND
Source 1 Soil Sample: 002-B002
Location ID
TB-02
TB-06
Sample Type
Source - Soil
Background - Soil
Field Sample ID
002-B002
006-B002
Date Collected
10/14/1991
10/22/1991
Depth (ft bgs)
8.0-10.0
6.0-7.00
Reference
31, Table 4-5 (pp. 3, 10), pp.
3-7, and Figure 3-2
31, Table 4-5 (pp. 3, 10),
pp. 3-7, 3-11 and Figure 3-
2
Location
Tank Farm A
S Corner Bldg 55
Volatile Organic Compounds (mg/kg)
Ethylbenzene
31
ND
Xylene
150
ND
Semivolatile Organic Compounds (mg/kg)
2-Methylnaphthalene
7.5
ND
Naohthalene
25
ND
42
-------
SD - Characterization and Containment
Source No.: 1
Source 1 Soil Sample: 003-B001 (The soil boring log for TB-03 indicates that an OVA detected up to 300
[units not provided] units ofVOCs [Ref. 31, Appendix C, p. 233]).
Location ID
TB-03
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
003-B001
012-B001
Date Collected
10/14/1991
10/14/1991
Depth (ft bgs)
0.0-2.0
0.0-2.0
Reference
31, Table 4-5 (pp. 3, 10),
31, Table 4-5 (pp. 2, 9),
pp. 3-7, and Figure 3-2
p. 3-7, and Figure 3-2
Location
Tank Farm A
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
Ethylbenzene
0.28
ND
Xylene
1.6
ND
Semivolatile Organic Compounds (mg/kg)
2-MethvlnaDhthalene
0.39
ND
Source 1 Soil Sample: 003-B002
Location ID
TB-03
TB-06
Sample Type
Source - Soil
Background - Soil
Field Sample ID
003-B002
006-B002
Date Collected
10/14/1991
10/22/1991
Depth (ft bgs)
8.0-10.0
6.0-7.0
Reference
31, Table 4-5 (pp. 3, 10),
31, Table 4-5 (pp. 3, 10),
pp. 3-7, and Figure 3-2
pp. 3-7, 3-11 and Figure 3-
2
Location
Tank Farm A
S Corner Bldg 55
Volatile Organic Compounds (mg/kg)
Ethylbenzene
18
ND
Xylene
84
ND
Semivolatile Organic Compounds (mg/kg)
2-Methylnaphthalene
15
ND
Naphthalene
72
ND
43
-------
SD - Characterization and Containment
Source No.: 1
Source 1 Soil Sample: 004-B001 (The soil boring log for TB-04 indicates that an OVA detected up to 900
[units not provided] units ofVOCs [Ref. 31, Appendix C, p. 234]).
Location ID
TB-04
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
004-B001
012-B001
Date Collected
10/14/1991
10/14/1991
Depth (ft bgs)
0.0-2.0
0.0-2.0
Reference
31, Table 4-5 (p. 3), pp.
31, Table 4-5 (p. 2), p.
3-7, and Figure 3-2
3-7, and Figure 3-2
Location
Tank Farm A
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
Ethvlbenzene
0.14
ND
Source 1 Soil Sample: 004-B002
Location ID
TB-04
TB-06
Sample Type
Source - Soil
Background - Soil
Field Sample ID
004-B002
006-B002
Date Collected
10/14/1991
10/22/1991
Depth (ft bgs)
8.0-10.0
6.0-7.00
Reference
31, Table 4-5 (pp. 3, 10), pp.
31, Table 4-5 (pp. 3, 10),
3-7, and Figure 3-2
and Figure 3-2
Location
Tank Farm A
S Corner Bldg 55
Volatile Organic Compounds (mg/kg)
Ethylbenzene
4.8
ND
Xylene
33
ND
Semivolatile Organic Compounds (mg/kg)
2-Methylnaphthalene
18
ND
Naohthalene
92
ND
44
-------
SD - Characterization and Containment
Source No.: 1
Source 1 Soil Sample: 001-B002 (The soil boring log for TB-11 (MW-11) indicates that an OVA
detected up to 1,000 [units not provided] units of VOCs [Ref. 31, Appendix C, p. 6]).
Location ID
TB-11
TB-6
Sample Type
Source - Soil
Background - Soil
Field Sample ID
011-B002
006-B002
Date Collected
10/14/1991
10/22/1991
Depth (ft bgs)
8.0-10.0
6.0-7.0
Reference
31, Table 4-5 (pp.4, 11),
pp. 3-7, 3-8, and Figure 3-2
31, Table 4-5 (pp. 3, 10),
and Figure 3-2
Location
MW-11, Tank Farm A
S Corner Bldg 55
Volatile Organic Compount
s (mg/kg)
Ethylbenzene
55
ND
Xylene (total)
560
ND
Semivolatile Organic Compounds (mg/kg)
2-Methylnaphthalene
2.5
ND
Naphthalene
11
ND
Source 1 Soil Sample: 028-B001 (The soil boring log for TB-28 indicates that an OVA detected up to
1,000 [units not provided] units of VOCs [Ref. 31, Appendix C, p. 262]).
Location ID
TB-28
MW-20
Sample Type
Source - Soil
Background - Soil
Field Sample ID
028-B001
020-B101
Date Collected
7/6/1993
7/14/1993
Depth (ft bgs)
1.5-2.0
0.0-2.0
Reference
31, Table 4-5 (p. 4),
31, Table 4-5 (p. 1), p. 3-15,
p. 3-14, and Figure 3-2
and Figure 3-2
Location
N Tank Farm A
NW Bldg 55
Volatile Organic Compounds (mg/kg)
1.1.2-Trichloroethane
0.014
ND
45
-------
SD - Characterization and Containment
Source No.: 1
Source 1 Soil Sample: 029-B002 (The soil boring log for TB-29 indicates that an OVA detected up to 500
[units not provided] units ofVOCs [Ref. 31, Appendix C, p. 263]).
Location ID
TB-29
SGW-236
Sample Type
Source - Soil
Background - Soil
Field Sample ID
029-B002
236-B002
Date Collected
7/7/1993
7/6/1993
Depth (ft bgs)
5.2-5.7
3.5-4.0
Reference
31, Table 4-5 (p. 4), p. 3-14,
31, Table 4-5 (p.l),p.
and Figure 3-2
3-14, and Figure 3-2
Location
NW Tank Farm A
SE Tank Farm A
Volatile Organic Compounds (mg/kg)
Acetone
0.066
ND
Source 1 Soil Sample: TB-54-10 (The soil boring log for TB-54 indicates that an FID detected up to 480
[units not provided] units ofVOCs [Ref. 31, Appendix C, p. 314]).
Location ID
TB-54
TB-58
Sample Type
Source - Soil
Background - Soil
Field Sample ID
TB-54-10
TB-58-09
Date Collected
9/30/1996
9/30/1996
Depth (ft bgs)
10.0-10.5
9.0-9.5
Reference
31, Table 4-5 (p. 7), p.
3-25, and Figure 3-2
31, Table 4-5 (p. 8), and
Figure 3-2
Location
E Tank Farm A
NW Tank Farm A
Volatile Organic Compount
s (mg/kg)
Ethylbenzene
98
11
J
Xvlene (total)
420
56
46
-------
SD - Characterization and Containment
Source No.: 1
Source 1 Soil Sample: TB-55-10.5 (The soil boring log for TB-55 indicates that an organic vapor monitor
(OVM) detected up to 1,246 [units not provided] units of VOCs [Ref. 31, Appendix C, p. 316]).
Location ID
TB-55
TB-58
Sample Type
Source - Soil
Background - Soil
Field Sample ID
TB-55-10.5
TB-58-09
Date Collected
9/30/1996
9/30/1996
Depth (ft bgs)
10.5-11.0
9.0-9.5
Reference
31, Table 4-5 (pp. 7, 13), p.
3-25, and Figure 3-2
31, Table 4-5 (pp. 8, 13),
p. 3-25 and Figure 3-2
Location
Tank Farm A
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
Ethylbenzene
1,500
11
J
Xvlene (total)
11.000
D
56
Source 1 Soil Sample: TB-56-13 (The soil boring log for TB-56 indicates that a FID detected up to 920
[units not provided] units of VOCs [Ref. 31, Appendix C, p. 320]).
Location ID
TB-56
TB-58
Sample Type
Source - Soil
Background - Soil
Field Sample ID
TB-56-13
TB-58-09
Date Collected
9/30/1996
9/30/1996
Depth (ft bgs)
13.0-13.5
9.0-9.5
Reference
31, Table 4-5 (pp. 7, 13), p.
31, Table 4-5 (pp. 7, 13), p.
3-25, and Figure 3-2
3-25 and Figure 3-2
Location
E Tank Farm A
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
Ethylbenzene
170
11
J
Xvlene (total)
1.200
58
47
-------
SD- Characterization and Containment
Source No.: 1
Source 1 Soil Sample: TB-57-12.5 (The soil boring log for TB-57 indicates that a FID detected up to
4,200 [units not provided] units of VOCs [Ref. 31, Appendix C, p. 323]).
Location ID
TB-57
TB-58
Sample Type
Source - Soil
Background
-Soil
Field Sample ID
TB-57-12.5
TB-58-09
Date Collected
9/30/1996
9/30/1996
Depth (ft bgs)
12.0-12.5
9.0-9.5
Reference
31, Table 4-5 (p. 7), p.
31, Table 4-5 (p. 8), and p.
3-25, and Figure 3-2
3-25 Figure 3-2
Location
E Tank Farm A
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
Ethylbenzene
750
11
J
Xylene (total)
4.700
58
Notes:
B
Boring
N
North
bgs
Below ground surface
NA
Not analyzed
Bldg
Building
ND
Not detected
D
Diluted
NE
Northeast
E
East
NW
Northwest
ft
Foot
PS
Point sample
ID
Identification
s
South
J
Estimated concentration
SE
Southeast
mg/kg
Milligrams per kilogram
SW
Surface water
MW
Monitoring well
TB
Test boring
W
West
48
-------
SD - Hazardous Waste Quantity
Source No.: 1
2.4.2 Hazardous Waste Quantity
2.4.2.1.1 Hazardous Constituent Quantity
The information available is not sufficient to adequately support the evaluation of the hazardous
constituent quantity for Source No. 1.
Sum (pounds): Unknown
Hazardous Constituent Quantity Value (C): Not available (NA)
2.4.2.1.2 Hazardous Waste Stream Quantity
The information available is not sufficient to adequately support the evaluation of the hazardous waste
stream quantity for Source No. 1.
Sum (pounds): Unknown
Hazardous Waste Stream Quantity Value: NA
2.4.2.1.3 Volume
During the Phase III activities, free-phase product was measured for the mobile thickness of the product,
the volume of recoverable product, and the recharge rates of the product (Ref. 31, p. 3-20). A bail-down
test was conducted to identify the thickness of the product (Ref. 31, Appendix K, Tables El through E4).
The bail-down test completed in WP-3 in the area of the Building 50 indicated that the thickness of the
product in July 1995 as 0.33 foot and in August 1995 as 0.48 foot (Ref. 31, Figures 4-11 and 4-12). The
bail-down test completed in the area of the Building 67 indicated that the thickness of the product in July
1995 at MW-21 as 2.21 feet, at MW-13R as 0.98 foot, and at WP-1 as 1.33 feet (Ref. 31, Figure 4-11). In
August 1995 the thickness of product was recorded at MW-21 as 0.66 foot, at MW-13R as 1.28 feet, and
at WP-1 as 1.33 feet (Ref. 31, Figure 4-12). The bail-down test completed in MW-11 in the area of the
Tank Farm A identified the thickness of product as 1.47 feet in July 1995 and 0.45 foot in August 1995
(Ref. 31, Appendix K, Table E2, and Figures 4-11 and 4-12). The lateral extent of three separate product
plumes in ground water are shown on Figures 4-11 and 4-12, Appendix K, Reference 31. The plumes are
considered separate because of the absence of product in the monitoring wells located between the plumes
(Ref. 31, p. 4-20). The total volume of the free-phase product cannot be estimated.
Dimension of source (yd3 or gallons): Unknown, but greater than zero
Volume Assigned Value: Unknown, > 0
2.4.2.1.4 Area
The information available is not sufficient to adequately support the evaluation of the area or the area of
observed contamination for Source No. 1.
Area of Source (ft2): Not Scored
Area Assigned Value: Not Scored
2.4.2.1.5 Source Hazardous Waste Quantity Value
49
-------
SD - Hazardous Waste Quantity
Source No.: 1
The source HWQ value for Source No. 1 is assigned a source HWQ value of greater than zero because the
waste quantity associated with Source 1 has not been adequately documented; however, the presence of
free-phase product in ground water has been documented.
Source Hazardous Waste Quantity Value: Unknown, but greater than zero
50
-------
SD - Characterization and Containment
Source No.: 2
2.2 SOURCE CHARACTERIZATION
2.2.1 SOURCE IDENTIFICATION
Name of source: Areas of Contaminated Soil
Number of source: 2
Source Type: Contaminated Soil
This source includes three areas of contaminated soil. The areas of contaminated soil are combined as one
source because they are of the same type, from the same operations, near each other, potentially from the
same releases, contain the same type of contaminants, and were investigated as one source during an RI, as
documented in the sections below.
Contaminated Soil: Pump House
The pump house transferred wastewater from the Lucas plant operations to the lagoon area (Ref. 31, p. 5-
6). Lead contamination has been identified in the soil surrounding the former pump house (Ref. 31, pp.
ES-2, 6-4).
In 1994, NJDEP advanced augers into the bank of Hilliards Creek adjacent to the pump house.
Approximately 1 foot of paint sludge was observed when the augers were retrieved. The sludge tapered to
a faint greenish color about 15 feet downstream of the pump house (Ref. 66, pp. 1,2).
In 1999, a waste sample was collected adjacent to the pump house and was found to contain barium
(14,400 parts per million [ppm]), lead (1,090 ppm), magnesium (7,340 ppm), and mercury (17.8 ppm)
(Ref. 26, pp. 5, 8). An RI confirmed that lead-contaminated soil was associated with the pump house (Ref.
31, pp. ES-2, 3-27, 5-7, and 5-8).
Contaminated Soil: Northwest of Building 55
The RI for the Lucas plant identified contaminated soil northwest of Building 55, in the area of soil boring
B-76 (Ref. 31, p. 5-5, Table 4-11, Figure 3-2). The contaminated soil may have resulted from operations
in former Buildings 15 and 49, formerly located west of the Tank Farm A. Building 15 was used to store
varnish in 440-, 960-, and 2,200-gallon ASTs. Building 49 was used to store varnish in 2,500- and 6,000-
gallon tanks (Refs. 5; 60, p. 33). Soil may have become contaminated during transfer and temporary
storage of materials near the tanks, which may have resulted in leaks and spills (Ref. 59, Appendix II, p.
1155).
Other sources of the soil contamination are shown on an insurance map, dated April 16, 1964, including a
solvent pump house formerly located northwest of Building 55 and leaks from raw materials stored in
Building 55 (Refs. 5; 60, pp. 99, 100).
51
-------
SD - Characterization and Containment
Source No.: 2
Contaminated Soil: Southeast Corned of Building 55
A soil boring (TB-06) was completed at the southeast corner of Building 55. Analytical results for soil
samples collected from the boring indicated the presence of contaminated soil as documented in Section
2.4.1. The contamination at TB-06 is considered separate from the contaminated soil detected south of
TB-06 in the area of free-phase product ground water plume because the plume does not exceed to
sampling location TB-06 (Ref. 31, pp. 4-11 and 4-12).
Location of the source, with reference to a map of the site: The areas of contaminated soil are located
on the northwest side of Building 55 in the area of test boring 76 (TB-76), on the southeast corner of
Building 55, and in the area of the pump house located west of Building 67 (Ref. 31, Figures 2-2 and 3-2).
The locations where soil sample analyses revealed the presence of contaminated soil and defined the area
of Source 2 are shown on Figure 3-2 of Reference 31.
Containment:
Release to ground water: As documented in the section above, Source 2 is an area of contaminated soil.
No liners, covers, or other containment features are associated with the source; therefore, a containment
factor value of 10 is assigned to this source. Additionally, as documented in Section 4.2.1.5, there is
evidence that hazardous substances have migrated from the source to ground water (Ref. 1, Table 3-2).
Release via overland migration and/or flood: As documented in the section above, Source 2 is an area
of contaminated soil. No runoff control systems are associated with the source; therefore, a containment
factor value of 10 is assigned to this source. Additionally, as documented in Section 4.1.2.1.1, there is
evidence that hazardous materials have migrated from the source (Ref. 1, Table 4-2).
Gas release to air: The air migration pathway was not scored.
Particulate release to air: The air migration pathway was not scored.
52
-------
SD - Characterization and Containment
Source No.: 2
2.4 WASTE CHARACTERISTICS
2.4.1 Hazardous Substances:
The hazardous substances associated with Source 2 were identified during numerous soil sampling
investigations. The most recent investigation was a five-phase RI for the Lucas plant (Ref. 31, p. 3-3).
The data from the RI are used to characterize Source 2. Figure 3-2, in Reference 31, was used to identify
soil sampling locations specifically associated with Source 2. The soil samples were analyzed for Priority
Pollutant Volatile Organic Analysis plus 15-non target compounds (PP VOA+15), Priority Pollutant Base
Neutral Analysis (PP BNA), lead, chromium, and barium (Ref. 31, p. 3-11). During Phase IV of the RI
for the Lucas plant, three soil borings were drilled around the pump house. Sludge and paint were
observed in one of the borings, TB-73. A sample of the sludge and paint was collected from the boring
(Ref. 31, p. 5-7). Additional investigations were conducted in the area of pump house to further delineate
the extent of soil contamination (Ref. 31, pp. 3-26, 3-27). Three soil borings were hand augered in the
area of the pump house (Ref. 31, pp. 3-3, 2-27). The borings were installed to delineate the extent of
sludge and paint chips observed in a boring, TB-73, previously drilled in the area of the pump house (Ref.
31, p. 3-27).
The tables below provide a summary of hazardous substances detected in soil samples collected from
Source 2 during numerous phases of the RI. The result for a background soil sample is listed to provide a
reference concentration for the hazardous substances. Background soil sample selection is based on
whether the background and source soil sample were collected within the same depth range, period of
time, and whether the samples were analyzed for the same hazardous substances. All soil samples
collected from 1990 to 1997 were analyzed by Weston Analytics Division, a New Jersey-certified
laboratory. All samples collected from 1998 to 2000 were analyzed by Severn-Trent Laboratories (STL),
a New Jersey-certified laboratory (Ref. 31, p. 3-37). Reference 111 provides a Quality Assurance Project
Plan used by Sherwin-Williams' environmental consultant. The plan provides analytical methods,
quantitation limits, and detection limits for some of the investigations conducted by Sherwin-Williams'
(Ref. 111). It is likely that these same methods were used for analyzing the samples summarized in this
section. Analytical data sheets from the laboratories are not available; however, the RI report that
Sherwin-Williams prepared indicates that the analytical data are valid. The analytical results in the tables
below are considered usable and of known quality (Ref. 31, p. 3-38). Table 3-1 of Reference 31 provides
a summary of the analytical suite for the soil samples.
The locations of the soil samples are provided on Figure 3-2, in Reference 31, and are circled.
Contaminated soil southeast corner of Building 55:
Analytical results for a soil boring sample collected from the southeast corner of Building 55 indicated the
presence of a number hazardous substances three times above the background concentrations. The soil
sample does not contain the same hazardous substances as detected in the product samples and is therefore,
considered a separate area of contamination, as documented below.
53
-------
SD - Characterization and Containment
Source No.: 2
Source 2 Soil Sample:006-B001 (The soil boring log for TB-06 indicates that an OVA detected up to 700
[units not provided] units ofVOCs [Ref. 31, Appendix C, p. 236]).
Location ID
TB-06
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
006-B001
012-B001
Date Collected
10/22/1991
10/14/1991
Depth (ft bgs)
1.0-2.0
0.0-2.0
Reference
31, Table 4-5 (pp. 3, 17),
31, Table 4-5 (pp.2, 15),
and Figure 3-2
p. 3-11, and Figure 3-2
Location
SE Corner of Bldg 55
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
1,1,2,2-Tetrachloroethane
0.05
ND
Tetrachloroethene
0.019
ND
Total-1,2-dichloroethene
0.019
ND
Trichloroethene
0.071
ND
Metals (mg/kg)
Lead
78.3
4.1
Contaminated Soil Associated with the Pump House
Provided below is a summary of analytical results for soil samples collected in the area of the pump house.
The results indicate the presence of contaminated soil.
Source 2 Soil Sample: TB-73 (Red and white paint like fakes were observed in the soil boring [Ref. 31,
Appendix C, p. 370]).
Location ID
TB-73
TB-95
Sample Type
Source - Soil
Background - Soil
Date Collected
1/15/1999
1/15/1999
Depth (ft bgs)
0.5-1.5
0.8-1.3
Reference
31, pp. 5-7, 5-8, Table 4-5
31, pp. 5-7, 5-8, Table 4-5
(p. 18), and Figure 3-2
(p. 19), and Figure 3-2
Location
W Pump House
Background SW Pump House
Metals (mg/kg)
Antimony
5.4
1.6
Barium
14,500
841
Chromium
55.7
15.5
Cobalt
78.5
7.2
Copper
1,080
73
Lead
1,040
231
Magnesium
2,900
257
Mercury
25.2
1.8
54
-------
SD - Characterization and Containment
Source No.: 2
Location ID
TB-73
TB-95
Sample Type
Source - Soil
Background - Soil
Date Collected
1/15/1999
1/15/1999
Depth (ft bgs)
0.5-1.5
0.8-1.3
Reference
31, pp. 5-7, 5-8, Table 4-5
31, pp. 5-7, 5-8, Table 4-5
(p. 18), and Figure 3-2
(p. 19), and Figure 3-2
Location
W Pump House
Background SW Pump House
Metals (mg/kg)
Nickel
46.2
5.8
Zinc
3.240
564
Contaminated Soil Located Northwest of Building 55
Provided below is a summary of analytical results for soil samples collected in the area northwest of
Building 55. The results indicate the presence of contaminated soil.
Source 2 Soil Sample: TB-176 [odors and staining observed in the sample (Ref. 31, p. 5-5)].
Location ID
B-76
B-75
Sample Type
Source - Soil
Background - Soil
Field Sample ID
B-176
B-75
Date Collected
4/16/1997
4/16/1997
Depth (ft bgs)
10.0-12.0
11.5-17.0
Reference
31, Tables 3-1, 4-5 (pp. 9, 15),
31, Tables 3-1,4-5 (p. 15),
and Figure 3-2
and Figure 3-2
Location
NW Bldg 55
W Bldg 58
Semivolatile Organic Compounds (mg/kg)
2-Methylnaphthalene
1.9
J
ND
Naphthalene
9.4
J
ND
Metals (mg/kg)
Arsenic
4.2
ND
Barium
224
29.1
Beryllium
0.11
ND
Copper
197
1.1
Lead
401
8.5
Mercury
0.12
ND
Nickel
3.2
ND
55
-------
SD - Characterization and Containment
Source No.: 2
Source 2 Soil Sample: B-76 [odors and staining observed in the sample (Ref. 31, p. 5-5)].
Location ID
B-76
B-78
Sample Type
Source - Soil
Background - Soil
Field Sample ID
B-76
B-78
Date Collected
4/16/1997
4/16/1997
Depth (ft bgs)
3.0-3.5
3.5-4.0
Reference
31, Table 4-5 (pp. 2, 9, 15), and
31, Tables 3-1, 4-5 (pp.2, 15),
Figure 3-2
and Figure 3-2
Location
NW Bldg 55
150 ft S Bldg 67
Volatile Organic Compounds (mg/kg)
Ethylbenzene
20
ND
Xylene (total)
8.8
ND
Semivolatile Organic Compounds (mg/kg)
Naphthalene
8.3
J
NA
Metals (mg/kg)
Barium
82.5
10.6
Cadmium
0.42
ND
Chromium
13.2
3.6
Copper
12.1
2.2
Lead
171
6
Mercury
0.08
ND
Nickel
2.2
ND
Zinc
62.1
6.7
Source 2 Soil Sample: 020-B001 (The soil boring log for MW-20 indicates that an OVA detected up to
110 [units not provided] units of VOCs [Ref. 31, Appendix C, p. 48]).
Location ID
MW-20
SGW-236
Sample Type
Source - Soil
Background - Soil
Field Sample ID
020-B001
236-B001
Date Collected
7/14/1993
7/06/1993
Depth (ft bgs)
1.5-2.0
1.5-2.0
Reference
31, Table 4-5 (p. 1), and
31, Table 4-5 (p. 1), Figure
Figure 3-2
3-2, and p. 3-11
Location
NW Bldg 55
SE Tank Farm A
Volatile Organic Com
pounds (mg/kg)
Ethylbenzene
24
0.76 J
Xvlene
4.4
ND
56
-------
SD - Characterization and Containment
Source No.: 2
Source 2 Soil Sample: TB-59-01 (The soil boring log for TB-59 indicates that the FID detected up to 110
[units not provided] units ofVOCs [Ref. 31, Appendix C, p. 328]).
Location ID
TB-59
SGW-236
Sample Type
Source - Soil
Background - Soil
Field Sample ID
TB-59-01
236-B001
Date Collected
10/1/1996
7/06/1993
Depth (ft bgs)
1.5-2.0
1.5-2.0
Reference
31, Table 4-5 (p. 8), and
31, Table 4-5 (p. 2), p. 3-11, and
Figure 3-2
Figure 3-2
Location
NW Bldg 55
SE Tank Farm A
Volatile Organic Compount
s (mg/kg)
Ethylbenzene
7
0.76 J
Xvlene
24
ND
Source 2 Soil Sample: TB-60-04 (No background soil samples were collected within the depth range of
4.0 to 4.5 feet bgs in 1996; therefore, the result for a background sample collected from 1993 is provided
in the table below. The background concentrations are not critical for this sample because the hazardous
substances detected in the source soil sample are not naturally occurring. A strong petroleum odor was
detected in the soil boring. The soil boring log for TB-60 indicates that the FID detected up to 4,200 [units
not provided] units ofVOCs [Ref. 31, Appendix C, p. 330]).
Location ID
TB-60
TB-37
Sample Type
Source - Soil
Background - Soil
Field Sample ID
TB-60-04
007-B001
Date Collected
10/1/1996
7/06/1993
Depth (ft bgs)
4.0-4.5
4.7-5.5
Reference
31, Table 4-5 (p. 8), and
31, Table 4-5 (p. 5), and
Figure 3-2
Figure 3-2
Location
NW Bldg 55
SE Tank Farm A
Volatile Organic Compounds (me/ke)
Ethylbenzene
28
ND
Xvlene
56
ND
57
-------
SD - Characterization and Containment
Source No.: 2
Source Soil Sample: TB-61-04 (No background soil samples were collected within the depth range of 4.0
to 4.5 feet bgs in 1996; therefore, the result for a background sample collected from 1993 is provided in
the table below. The background concentrations are not critical for this sample because the hazardous
substances detected in the source soil sample are not naturally occurring. A petroleum odor was detected
in the soil boring. The soil boring log for TB-61 indicates that the FID detected up to 3,000 [units not
provided] units of VOCs [Ref. 31, Appendix C, p. 332]).
Location ID
TB-61
TB-37
Sample Type
Source - Soil
Background - Soil
Field Sample ID
TB-61-04
007-B001
Date Collected
10/1/1996
7/6/1993
Depth (ft bgs)
4.0-4.5
4.7-5.5
Reference
31, Table 4-5 (p. 8), and
31, Table 4-5 (p. 5), and
Figure 3-2
Figure 3-2
Location
NW Bldg 55
SE Tank Farm A
Volatile Organic Compounds (mg/kg)
Ethylbenzene
27
ND
Xvlene
170
ND
Notes:
B
Boring
N
North
bgs
Below ground surface
NA
Not analyzed
Bldg
Building
ND
Not detected
ft
Foot
NW
Northwest
HA
Hand auger
S
South
ID
Identification
SE
Southeast
J
Estimated concentration
SW
Surface water
mg/kg
Milligram per kilogram
TB
Test boring
MW
Monitoring well
W
West
58
-------
SD - Hazardous Waste Quantity
Source No.: 2
2.4.2 Hazardous Waste Quantity
2.4.2.1.1 Hazardous Constituent Quantity
The information available is not sufficient to adequately support the evaluation of the hazardous
constituent quantity for Source No. 2.
Sum (pounds): Unknown
Hazardous Constituent Quantity Value (C): Not available (NA)
2.4.2.1.2 Hazardous Waste Stream Quantity
The information available is not sufficient to adequately support the evaluation of the hazardous waste
stream quantity for Source No. 2.
Sum (pounds): Unknown
Hazardous Waste Stream Quantity Value: NA
2.4.2.1.3 Volume
The information available is not sufficient to adequately support the determination of the volume
hazardous waste quantity value for Source No. 2.
Dimension of source (yd3 or gallons): 0
Volume Assigned Value: 0
2.4.2.1.4 Area
Since the volume of contaminated soil associated with Source 2 is not adequately estimated, the area of
Source 2 is evaluated (Ref. 1, Section 2.4.2.1.3). The area of contaminated soil associated with Source 2 is
difficult to document because numerous areas within the area are covered with buildings, parking lots, and
roads. Numerous removal actions have been conducted in the area of Source 2; however, based on Section
2.4.1 for Source 2, contamination still remains in Source 2 (Refs. 18, pp. ES-1, 1-1, 1-2, 3-5, 4-1; 31, pp.
3-22, 3-23, 3-24, 5-3, 5-4, 5-5, and Figure 3-2). Therefore, the area of soil contamination for Source 2 is
assigned the value of greater than zero.
Area of Source (ft2): Unknown, > 0
Area Assigned Value: Unknown, > 0
59
-------
SD - Hazardous Waste Quantity
Source No.: 2
2.4.2.1.5 Source Hazardous Waste Quantity Value
The source HWQ value for Source No. 2 is assigned a source HWQ value of greater than zero because the
waste quantity associated with Source 2 has not been adequately documented; however, the presence of
contaminated soil has been documented.
Source Hazardous Waste Quantity Value: Unknown, but greater than zero
60
-------
SD - Characterization and Containment
Source No.: 3
SOURCE DESCRIPTION
2.2 SOURCE CHARACTERIZATION
Source Number: 3
Source Description: Lagoons
Source Type: Backfilled surface impoundment
Source 3 includes five backfilled surface impoundments and an associated pipeline and drainage channel.
Between 1950 and 1977, wastewater generated from the paint manufacturing process was discharged into
five impoundments for treatment and disposal. The lagoons were located south of the facility.
Wastewater was discharged by gravity from the manufacturing plant to a lift station and subsequently
pumped to a 27,000-gallon concrete holding basin. Alum was added to the wastewater, and then the
wastewater was fed by gravity from the basin to Lagoon 1 for coagulation and settling. The wastewater
was then transferred to Lagoons 2, 3, and 4 for biological treatment. A holding basin was also used in the
wastewater treatment system (Refs. 6, pp. 2-3, 2-4, and Figure 2-4; 31, p. 2-5). Tank washout from the
latex system and Sher-dye was disposed of in the lagoons (the sanitary waste system on Lucas plant) (Ref.
70, pp.9, 11).
Aerial photographs from 1940 show two open storage areas along a railroad spur. This area appears to be
the location of the lagoons (Ref. 7, pp. 4, 5). Aerial photographs from 1951 show three impoundments in
the area of the lagoons. An open storage area is located north of the lagoons (Ref. 7, pp. 6, 7, 10, 11). The
1961 aerial photographs indicate that one of the three lagoons (impoundments) was divided into four
separate lagoons, for a total of six lagoons. Several piles of light-toned mounded material were observed
near one of the lagoons (impoundment one) (Ref. 7, p. 8). Aerial photographs from 1973 show the
presence of a pipeline extending from the north bank of one of the lagoons (impoundment one) to a
drainage channel (Hilliards Creek) that runs through the center of the Lucas plant. An outfall from the
western bank of the lagoon area toward a drainage channel (Hilliards Creek) is visible (Ref. 7, pp. 10, 11).
Aerial photographs from 1975 show the presence of leachate scars on the downslope of one of the lagoons.
The lagoons are no longer visible in 1984 aerial photographs (Ref. 7, p. 13).
In 1975, one of the settling lagoons overflowed into Hilliards Creek (Ref. 59, Appendix X, p. X6).
On July 31, 1975, and September 16, 1975, NJDEP inspectors noted foul solvents odors emanating from
monitoring wells in the area of the lagoons, and one of the lagoons was observed to be leaking its contents
into Hilliards Creek (Ref. 32, p. 3).
On May 5, 1976, NJDEP inspectors observed that a feed pipe used for transport of raw materials in the
facility had ruptured causing an oil discharge to the primary settling lagoon and Hilliards Creek (Ref. 32,
p. 3).
61
-------
SD - Characterization and Containment
Source No.: 3
In 1976, NJDEP directed Sherwin-Williams to conduct a subsurface investigation in the former lagoon
area (AEC IV) (Ref. 31, pp. 3-1, 3-33). Approximate depths (from an average existing ground surface)
were as follows:
Lagoon 1 = 5 feet
Lagoon 2=15 feet
Lagoon 3 = 8 feet
Lagoon 4 = 12 feet
Holding Basin =10 feet
Depths are documented in Reference 31 (pp. 3-33, 3-34). According to the RI report, a sludge pit was
located in the area of the lagoons. The depth of the sludge pit was 20 feet (Ref. 31, pp. 3-33, 3-34).
Sludge was encountered at the base of the lagoons at depths of 2 to 5 feet in the lagoons and the base of
the holding basin at a depth of 3 feet. Twenty-eight soil borings were drilled in the lagoon area (Ref. 31,
p. 3-34). A review of Figure 2-4 in Reference 6 indicates that the four impoundments, aholding basin (the
fifth surface impoundment), and a sludge disposal area were associated with the four surface
impoundments. The sludge pit, as referred to in the RI, may be the sludge disposal area shown on Figure
2-4 in Reference 6.
On August 17, 1978, NJDEP issued an administrative order to Sherwin-Williams to remove sludge in the
area of the lagoons and to monitor ground water. The order was based on findings that Sherwin-Williams
operated unlined wastewater treatment lagoons and stored sludge without NJDEP approval or
authorization. NJDEP concluded that the lagoons allowed inadequately treated wastewater to percolate
into the ground water (Ref. 57, pp. 1, 2, 3).
In 1979, a subsurface investigation was conducted in the area of the lagoons, or Site 2 as referenced in
reference documentation (Ref. 41, Plates 2, 6, and 7, p. 10). The report documenting the investigation
indicated that the lagoon area included the following: a holding pond (150 by 180 feet), ponds 1 and 2 (60
by 80 feet each), pond 3 (40 by 40 feet), and pond 4 (100 by 150 feet). (A sludge disposal pond, 40 by
150 feet, was also located adjacent to the lagoons. However, its waste (dried sludge) was included in
another NPL site, the US Avenue Burn site and not included in the waste quantity for this site [Ref. 41, pp.
10, 14, Plate 6].) According to the report, industrial waste including paint sludge and raw sewage was
emptied into the holding pond, where primary sedimentation took place. A pump suctioned material from
the holding pond to pond 1. From pond 1, the fluid was transferred by gravity to pond 2, then to pond 3,
and finally to pond 4. Dried sludge was excavated from ponds 1, 2, 3, and 4 then disposed of in the sludge
holding pond. The report does not identify the location where pond 4 discharges (Refs. 41, p 11; 8, p. 3).
Analytical results for soil borings indicated the presence of dried paint in the holding pond, ponds 1, 2, 3,
and 4, and in the sludge disposal pond. (The waste quantity associated with the sludge disposal pond is
evaluated as part of a separate site, US Avenue Burn Site.) Drainage from the lagoon area was noted to be
toward the west, the location of Hilliards Creek (Refs. 41, p. 14; 9).
In 1979, a total of 8,096 cubic yards of sludge was removed from the lagoon area. After the sludge was
visibly removed, the lagoons were filled in with clean fill. The removal was considered complete when all
the visually identifiable sludge and contaminated soils were removed (Refs. 31, pp. 3-33 and 3-34; 42, p.
4). Since the removal action was based on visually removing the waste associated with Source 3, it cannot
be documented that all the contamination associated with Source 3 has been removed. No confirmatory
samples were collected. Available data, provided in Section 4.0 of this documentation record, indicate that
62
-------
SD - Characterization and Containment
Source No.: 3
Source 3 released hazardous substances to ground water and surface water. The contamination associated
with the releases to ground water and surface water has not been addressed. Since no confirmatory
samples were collected to document that all contamination associated with Source 3 was removed and
releases to ground water and surface water from Source 3 have not been addressed, the removal action
completed in the Source 3 is not considered a qualifying removal action (Refs. 82; 83).
In 1993, a site inspection (SI) report completed by NJDEP indicated that memorandums by Sherwin-
Williams described a breach of the lagoon system (Ref. 59, p. 3).
Location of the source, with reference to a map of the site: Figure 2-4, in Reference 6, shows the
location of the four backfilled surface impoundments (also referred to as lagoons and ponds in reference
documentation) and the holding basin, fifth backfilled surface impoundment. Source 3 is located on the
southeastern portion of the former Lucas plant, on the south side of Foster Avenue and on the east side of
Hilliards Creek (see Figure 2-4 in Reference 6).
Containment:
Release to ground water: The lagoons were unlined (Ref. 57, pp. 1, 2, 3); therefore, a containment factor
value of 10 is assigned to this source. Additionally, as documented in the section above, there is evidence
that hazardous substances migrated from the source (Ref. 1, Table 3-2).
Release via overland migration and/or flood: Migration of hazardous substances from the source area
has been documented; therefore, a containment factor value of 10 is assigned to this source (Ref. 59,
Appendix X, p. X6). Additionally, as documented in the section above, no surface water runoff control
system was associated with Source 3 (Ref. 1, Table 4-2).
Gas release to air: The air migration pathway was not scored.
Particulate release to air: The air migration pathway was not scored.
63
-------
SD - Characterization and Containment
Source No.: 3
2.4 WASTE CHARACTERISTICS
2.4.1 Hazardous Substances:
In 1977, wastewater sludge samples were analyzed for disposal purposes. The leachate analysis revealed
the presence of lead, 0.16 mg/L (Ref. 19, pp. 1, 3). The paint sludge was classified as special waste (Refs.
23; 24). In 1977, analysis of spent iron residue from the wastewater treatment plant revealed 0.007 mg/L
of arsenic and 0.25 mg/L of lead in the leachate (Ref. 22, pp. 1, 2). In 1978, analysis of a paint sludge
sample revealed 0.08 percent by weight of lead (Ref. 20, pp. 1, 2). In April 1978, analysis of a wastewater
sludge sample revealed the presence of arsenic at 0.7 mg/kg (Ref. 25, pp. 1, 2). In March 1978, analysis of
leachate from paint sludge revealed 0.015 mg/L of lead (Ref. 21, p. 1).
Soil samples were collected from the approximate center of each lagoon (referred to as ponds in reference
documentation) (Ref. 31, p. 3-36) in November 1996, during Phase IV of the RI for the Lucas plant (Ref.
31, p. 3-3). Analysis of a soil sample collected from the lagoons revealed the presence of 11 mg/kg of
pentachlorophenol, 4.5 mg/kg of arsenic, and 0.08 mg/kg of mercury (Ref. 31, Table 4-7 [p. 2], Figure 3-
2). The Table 2 summarizes the hazardous substances detected in soil boring samples collected from the
lagoons during Phase IV of the RI for the Lucas plant. The soil samples were collected during the RI to
confirm whether the 1979 remediation was effective. One sample was collected from the approximate
center or each lagoon and the disposal area. Samples SS-P1, SS-P2, SS-P3, and SS-P4 were collected
from the former lagoons. Sample SS-HP was collected from the former holding pond. The samples were
collected immediately below the base of the former features or the fill material to evaluate whether natural
soils were contaminated by the operations of the lagoons and ponds (Ref. 31, p. 3-36). No appropriate
background soil sample was identified for comparison to results for soil samples collected from the
lagoons.
All soil samples collected during the RI from 1990 to 1997 were analyzed by Weston Analytics Division,
a New Jersey-certified laboratory. All samples collected from 1998 to 2000 were analyzed by STL, a New
Jersey-certified laboratory (Ref. 31, p. 3-37). The analytical results in the tables below are considered
usable and of known quality (Ref. 31, p. 3-38). Table 3-1 of Reference 31 provides a summary of the
analytical suite for the soil samples. The detection limits were not provided in the RI report.
TABLE 2
SUMMARY OF WASTE SAI
MPLES ASSOCIATED WITH LAGOONS
Sample type
Hazardous
Substance
Concentration
Date
Reference
Wastewater Sludge
lead
0.16 mg/L
1977
Ref. 19, p. 1, 3
Leachate
arsenic
0.007 mg/L
1977
Ref. 22, pp. 1,2
lead
0.25 mg/L
1977
Ref. 22, p. 1, 2
Paint Sludge
lead
008 % by weight
1978
Ref. 20, pp. 1,2
Wastewater Sludge
arsenic
0.7 mg/kg
1978
Ref. 25, pp. 1, 2
64
-------
SD - Characterization and Containment
Source No.: 3
Sample type
Hazardous
Substance
Concentration
Date
Reference
Leachate/Paint Sludge
lead
0.015 mg/L
1978
Ref. 21, p. 1
SUMMARY OF HAZARDOUS SUBSTANCES DETECTED
IN SOIL SAMPLES COLLECTED FROM SOURCE 3
Site ID
Holding Pond
Lagoon 1
Lagoon 2
Lagoon 3
Lagoon 4
Location ID
SS-HP
SS-P1
SS-P2
SS-P3
SS-P4
Field Sample ID
SS-HP
SS-P1
SS-P2
SS-P3
SS-P4
Date Collected
4/17/1997
4/17/1997
4/17/1997
4/17/1997
4/17/1997
Depth (ft bgs)
10.0-12.0
10.0-12.0
10.0-12.0
10.0-12.0
10.0-12.0
Reference
31, p. 3-36,
31, p. 3-36,
31, p. 3-36,
31, p. 3-36,
31, p. 3-36,
Table 4-7
Table 4-7
Table 4-7
Table 4-7
Table 4-7
[pp. 1, 2, 3]
[pp. 1, 2, 3]
[pp. 1, 2, 3]
[pp. 1, 2, 3]
[pp. 1, 2, 3]
Volatile Organic Compounds (mg/
-------
SD - Hazardous Waste Quantity
Source No.: 3
2.4.2 Hazardous Waste Quantity
2.4.2.1.1 Hazardous Constituent Quantity
The information available is not sufficient to adequately support the evaluation of the hazardous
constituent quantity for Source No. 3.
Sum (pounds): Unknown
Hazardous Constituent Quantity Value (C): Not available (NA)
2.4.2.1.2 Hazardous Waste Stream Quantity
The information available is not sufficient to adequately support the evaluation of the hazardous waste
stream quantity for Source No. 3.
Sum (pounds): Unknown
Hazardous Waste Stream Quantity Value: NA
2.4.2.1.3 Volume
In 1979, a total of 8,096 cubic yards of sludge was removed from the lagoon area. After the sludge was
visibly removed, the lagoons were filled with clean fill. The removal was considered complete when all
the visually identifiable sludge and contaminated soils were removed (Refs. 31, p. 3-34; 42, p. 4).
Analytical results for soil samples collected during a latter investigation, after the removal, indicate that
residual contamination remains in the soil underlying the lagoons. The hazardous waste quantity
associated with the lagoon area cannot be quantified.
Dimension of source (yd3 or gallons): 0
Volume Assigned Value: 0
2.4.2.1.4 Area
In 1979, a subsurface investigation was conducted in the area of the lagoons, or Site 2 as referenced in
reference documentation (Ref. 41, Plates 2, 6, and 7, p. 10). The report documenting the investigation
indicated that the lagoon area included the following: a holding pond (150 by 180 feet), ponds 1 and 2
(60 by 80 feet each), pond 3 (40 by 40 feet), and pond 4 (100 by 150 feet). (The sludge disposal pond, 40
by 150 feet, was also identified, but the waste quantity associated with that source was evaluated as part
of a separate site, the US Avenue Burn site [Ref. 41, pp. 10, 14, Plate 6].) The area associated with the
lagoon area is estimated to be 26,200 sq ft to 32,200 sq ft. Since the Source 3 area cannot be adequately
confirmed, the area of Source 3 is assigned the value of greater than 0.
Area of Source (ft2): Unknown, > 0
Area Assigned Value: Unknown, >0
66
-------
SD - Hazardous Waste Quantity
Source No.: 3
2.4.2.1.5 Source Hazardous Waste Quantity Value
The source HWQ value for Source No. 3 is assigned a value of greater than zero because the waste
quantity associated with Source 3 has not been adequately documented; however, the presence of
contaminated soil has been documented.
Source Hazardous Waste Quantity Value: Unknown, but greater than zero
67
-------
SD - Characterization and Containment
Source No.: 4
SOURCE DESCRIPTION
2.2 SOURCE CHARACTERIZATION
Source Number: 4
Source Description: Contaminated Soil Associated with Tank Farm B
Source Type: Contaminated Soil
Source 4 is an area of contaminated soil identified through sampling in the area of Tank Farm B (Refs. 31,
Table 4-3, Figure 3-2; 59, Appendix II, pp. 1131, 1132). The presence of contaminated soil in the area of
Tank Farm B, as documented in Section 2.4.1, indicates that product leaked and spilled from the tank
farm. Tank Farm B is located in the southern section of the plant on the south side of Foster Avenue and
on the west bank of Hilliards Creek (See Reference 6, Figure 2-4). Raw materials were stored in ASTs
and USTs in the area of Tank Farm B. Seventeen tanks were associated with Tank Farm B (Refs. 31,
Table 2-2; 6, Figure 2-4). Materials stored in the tanks included isobutyl alcohol, C.P. acetone, methyl
amyl acetate, isopropyl acetate, xylene, lacquer solvent, toluene, toluene-based solvent blend, methyl ethyl
ketone, ethyl acetate, isopropanol, solvent, methyl isobutyl ketone, solvent blend, and aromatic naphtha
(Refs. 5; 31, Table 2-2).
All ASTs and USTs were dismantled and removed from the property in June 1981, after the Lucas plant
was sold to Scarborough (Ref. 31, p. 2-4).
The soil sample analytical data generated from an RI in the area of Tank Farm B revealed the presence of
numerous hazardous substances in the area of Tank Farm B, including: acetone; 2-butanone; 2-hexanone;
chloroform; ethylbenzene; toluene; 1,1,1-trichloroethane; trichloroethene; xylenes; benzo(a)anthracene;
benzo(a)pyrene; benzo(b)fluoranthene; benzo(k)fluoranthene; chrysene; di-n-butyl phthalate;
fluoranthene; phenanthrene; pyrene; aluminum; antimony; arsenic; barium; chromium; cobalt; lead;
magnesium; mercury; zinc; and cyanide (Refs. 31, Table 4-3, Figure 3-2; 59, Appendix II, pp. 1131,1132).
Location of the source, with reference to a map of the site: As shown on Figure 2-4, in Reference 6,
Tank Farm B was located on the west side of Hilliards Creek and on the south side of Foster Avenue, just
west of Building 50 (Refs. 6, Figure 2-4; 31, Figure 3-2).
68
-------
SD - Characterization and Containment
Source No.: 4
Containment:
Release to ground water: As documented in the section above, Source 4 is an area of contaminated soil.
No containment structures are associated with the source; therefore, a containment factor value of 10 is
assigned to this source (Ref. 1, Table 3-2).
Release via overland migration and/or flood: As documented in the section above, Source 4 is an area
of contaminated soil. No containment structures are associated with the source; therefore, a containment
factor value of 10 is assigned to this source (Ref. 1, Table 4-2).
Gas release to air: The air migration pathway was not scored.
Particulate release to air: The air migration pathway was not scored.
69
-------
SD - Characterization and Containment
Source No.: 4
2.4 WASTE CHARACTERISTICS
2.4.1 Hazardous Substances:
Liquid hazardous substances were stored in the tanks in the area of Tank Farm B. The contents of the
tanks are summarized in Table 2-2 of Reference 31. The presence of contaminated soil in the area of Tank
Farm B, as documented below, indicates that product leaked and spilled from the tank farm.
Four soil borings (TB-5, MW-16, MW-17, and MW-18) were installed in the vicinity of former Tank
Farm B (Ref. 31, pp. 3-1, 3-31) from August 1991 through January 1992, during Phase I of the RI (Ref.
31, p. 3-3). The soil samples were analyzed for PP VOA+15, PP BNA, lead, barium, and chromium (Ref.
31, p. 3-31).
Additional soil borings (TB-91 through TB-93) were installed to delineate the extent of subsurface xylene
contamination in the area from July 1998 through January 2000, during Phase V of the RI (Ref. 31, pp. 3-
3, 3-33). Two samples were collected from each boring and sent for analysis of VOCs (Ref. 31, p. 3-33).
A summary of soil samples collected from Source 4 during two phases of the RI is provided in the tables
below. The result for a background soil sample is listed when available to provide a reference
concentration for the hazardous substances. Background soil samples were selected based on whether the
background and source soil sample were collected within the same depth range and same period of time
and whether the samples were analyzed for the same hazardous substances. All soil samples collected
from 1990 to 1997 were analyzed by Weston Analytics Division, a New Jersey-certified laboratory. All
samples collected from 1998 to 2000 were analyzed by STL, a New Jersey-certified laboratory (Ref. 31, p.
3-37). The analytical results in the tables below are considered usable and of known quality (Ref. 31, p. 3-
38). Table 3-1 of Reference 31 provides a summary of the analytical suite for the soil samples. No
background soil samples could be identified for the source soil samples collected in 1993 and 1996.
Soil boring samples collected from MW-14 are used as background sampling locations for shallow soil
intervals. The deeper soil intervals in MW-14 is contaminated with hazardous substances associated with
the free-phase product ground water plume in the area of Buildings 55 and 67 as documented in Section
2.4.1 for Source 1.
70
-------
SD - Characterization and Containment
Source No.: 4
Source 4 Soil Sample: 016-B001
Location ID
MW-16
MW-12
Sample Type
Source - Soil
Background - soil
Field Sample ID
016-B001
012-B001
Date Collected
10/18/1991
10/14/1991
Depth (ft bgs)
0.0-2.0
0.0-2.0
Reference
31, Table 4-3 (p. 1), and
31, Table 4-5 (p. 2), p.
Figure 3-2
3-11, and Figure 3-2
Location
Tank Farm B
S Bldg 55
Volatile Organic Compounds (mg/kg)
Chloroform
0.02
ND
Toluene
0.013
ND
Trichloroethane
0.006
ND
Trichloroethene
0.069
ND
Source 4 Soil Sample: 017-B001
Location ID
MW-17
MW-14
Sample Type
Source - Soil
Background - Soil
Field Sample ID
017-B001
014-B002
Date Collected
10/18/1991
10/28/1991
Depth (ft bgs)
2.0-4.0
2.0-4.0
Reference
31, Table 4-3 (pp. 1,5),
31, Table 4-5 (pp.2, 16),
and Figure 3-2
and Figure 3-2
Location
S Tank Farm B
N Bldg 67
Volatile Organic Compounds (mg/kg)
Chloroform
0.046
ND
Toluene
0.013
ND
Trichloroethane
0.017
ND
Trichloroethene
0.17
0.003 J
Xylenes
0.017
ND
Metals (mg/kg)
Barium
165
9.1
Chromium
21.2
2.2
Lead
634
2.1
71
-------
SD - Characterization and Containment
Source No.: 4
Source 4 Soil Sample: 017-B002
Location ID
MW-17
TB-37
Sample Type
Source - Soil
Background - Soil
Field Sample ID
017-B002
007-B002
Date Collected
10/18/1991
10/29/1991
Depth (ft bgs)
4.0-6.0
3.0-6.0
Reference
31, Table 4-3 (p. 1), and
31, Table 4-5 (p. 5), and
Figure 3-2
Figure 3-2
Location
S Tank Farm B
S Tank Farm A
Volatile Organic Compounds (mg/kg)
Chloroform
0.022
ND
Toluene
0.016
ND
Trichloroethane
0.011
ND
Trichloroethene
0.06
ND
Xylenes
0.01
ND
Source 4 Soil Sample: 018-B001
Location ID
MW-18
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
018-B001
012-B001
Date Collected
10/18/1991
10/14/1991
Depth (ft bgs)
0.0-2.0
0.0-2.0
Reference
31, Table 4-3 (p. 1),
and Figure 3-2
31, Table 4-5 (p. 2), p. 3-11,
and Figure 3-2
Location
S Tank Farm B
S Bldg 55
Volatile Organic Compounds (mg/kg)
Chloroform
0.035
ND
Toluene
0.011
ND
Trichloroethane
0.013
ND
Trichloroethene
0.13
ND
72
-------
SD - Characterization and Containment
Source No.: 4
Source 4 Soil Sample: 018-B002
Location ID
MW-18
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
018-B002
012-B002
Date Collected
10/18/1991
10/14/1991
Depth (ft bgs)
6.0-8.0
6.0-8.0
Reference
31, Table 4-3 (pp. 3, 5), and
31, Table 4-5 (pp. 9, 15),
Figure 3-2
and Figure 3-2
Location
Tank Farm B
S Bldg 55
Semivolatile Organic Compounds (mg/kg)
Benzo(b)fluoranthene
0.37
ND
Fluoranthene
0.38
ND
Pyrene
0.41
ND
Metals (mg/kg)
Barium
379
2
Chromium
39.2
4.7
Lead
660
1.8
Source 4 Soil Sample: 005-B001
Location ID
TB-05
TB-37
Sample Type
Source - Soil
Background - Soil
Field Sample ID
005-B001
007-B002
Date Collected
10/18/1991
10/29/1991
Depth (ft bgs)
4.0-6.0
3.0-6.0
Reference
31, Table 4-3 (p. 1), and
31, Table 4-5 (p. 5), and
Figure 3-2
Figure 3-2
Location
Tank Farm B
S Tank Farm A
Volatile Organic Compounds (mg/kg)
Chloroform
0.024
ND
Ethylbenzene
0.01
ND
Toluene
0.024
ND
Trichloroethane
0.009
ND
Trichloroethene
0.082
ND
Xylenes
0.092
ND
73
-------
SD - Characterization and Containment
Source No.: 4
Source 4 Soil Sample: 005-B002
Location ID
TB-05
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
005-B002
012-B002
Date Collected
10/18/1991
10/14/1991
Depth (ft bgs)
6.0-8.0
6.0-8.0
Reference
31, Table 4-3 (p. 1),
31, Table 4-5 (p. 2),
and Figure 3-2
and Figure 3-2
Location
Tank Farm B
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
Chloroform
0.01
ND
Toluene
0.025
ND
Trichloroethane
0.003 J
ND
Trichloroethene
0.035
ND
Source 4 Soil Sample: 005-B102
Location ID
TB-05
MW-12
Sample Type
Source - Soil
Background - Soil
Field Sample ID
005-B102
012-B002
Date Collected
10/18/1991
10/14/1991
Depth (ft bgs)
6.0-8.0
6.0-8.0
Reference
31, Table 4-3 (p. 1), and
31, Table 4-5 (p. 1), and
Figure 3-2
Figure 3-2
Location
Tank Farm B
NW Tank Farm A
Volatile Organic Compounds (mg/kg)
2-Butanone
0.027
ND
Chloroform
0.018
ND
Ethylbenzene
0.037
ND
Toluene
0.027
ND
Trichloroethane
ND
ND
Trichloroethene
0.06
ND
Xylenes
0.46
ND
74
-------
SD - Characterization and Containment
Source No.: 4
Source 4 Soil Sample: 032-B001
Location ID
TB-32
SGW-278
Sample Type
Source - Soil
Background - Soil
Field Sample ID
032-B001
278-B001
Date Collected
7/8/1993
7/8/1993
Depth (ft bgs)
4.5-5.0
4.5-5.2
Reference
31, Table 4-3 (pp. 2, 5,
31, Table 4-3 (pp. 1,5,
7), and Figure 3-2
7) and Figure 3-2
Location
Tank Farm B
NW Tank Farm B
Volatile Organic Compounds (mg/kg)
Acetone
0.07
ND
Metals (mg/kg)
Arsenic
9.7
1.2
Chromium
68.9
10.1
Cobalt
1.6
ND
Lead
859
ND
Magnesium
284
77
Mercury
0.59
ND
Zinc
611
2.6
Cvanide
2.8
NA
Notes:
Bldg
Building
NA
Not analyzed
ft bgs
Feet below ground surface
ND
Not detected
ID
Identification
NW
Northwest
mg/kg
Milligram per kilogram
S
South
MW
Monitoring well
TB
Test boring
N
North
No soil samples were collected in 1996 and 1999 that could be used as background for the 1996 and 1999
soil source samples listed in the tables below. No background concentration is provided. Therefore, only
concentrations of hazardous substances that are not naturally occurring and associated with operations at
the Lucas plant are listed in the tables below and used to characterize Source 4.
75
-------
SD - Characterization and Containment
Source No.: 4
Source 4 Soil Sample: TB-67-01
Location ID
TB-67
Sample Type
Source - Soil
Field Sample ID
TB-67-01
Date Collected
10/1/1996
Depth (ft bgs)
1.5-2.0
Reference
31, Table 4-3 (pp. 2, 6),
and Figure 3-2
Location
Tank Farm B
Volatile Organic Compounds (mg/kg)
Ethylbenzene
19
Toluene
63
Xylenes
370
Metals (mg/kg)
Lead
1.070
Source 4 Soil Sample: TB-69-01
Location ID
TB-69
Sample Type
Source - Soil
Field Sample ID
TB-69-01
Date Collected
10/1/1996
Depth (ft bgs)
1.5-2.0
Reference
31, Table 4-3 (p. 4),
and Figure 3-2
Location
Tank Farm B
Semivolatile Organic Compount
s (mg/kg)
Benzo(a)anthracene
0.46
Benzo(a)pyrene
0.45
Benzo(b)fluoranthene
0.44
Benzo(k)fluoranthene
0.39
Chrysene
0.49
Di-n-butyl Phthalate
0.82
Fluoranthene
0.85
Phenanthrene
0.64
Pvrene
0.86
76
-------
SD - Characterization and Containment
Source No.: 4
Source 4 Soil Sample: TB-69-5.5
Location ID
TB-69
Sample Type
Source - Soil
Field Sample ID
TB-69-5.5
Date Collected
10/1/1996
Depth (ft bgs)
4.0-4.5
Reference
31, Table 4-3 (p. 6), and
Figure 3-2
Location
Tank Farm B
Metals (mg/kg)
Lead
398
Source 4 Soil Sample: TB-91A
Location ID
TB91
Sample Type
Source - Soil
Field Sample ID
TB-91A
Date Collected
2/5/1999
Depth (ft bgs)
3.5-4.0
Reference
31, Table 4-3 (p. 2), and
Figure 3-2
Location
Tank Farm B
Volatile Organic Compounds (mg/kg)
2-Butanone
0.46
Acetone
0.34
Ethylbenzene
0.13
Toluene
0.71
Xylenes
0.80
77
-------
SD - Characterization and Containment
Source No.: 4
Source 4 Soil Sample: TB-91B
Location ID
TB91
Sample Type
Source - Soil
Field Sample ID
TB-91B
Date Collected
2/5/1999
Depth (ft bgs)
4.8-5.0
Reference
31, Table 4-3 (p. 2),
and Figure 3-2
Location
Tank Farm B
Volatile Organic Compounds (mg/kg)
2-Butanone
0.14
2-Hexanone
0.069
Acetone
0.14
Ethylbenzene
1.2
Toluene
1.9
Xylenes
5.8
Source 4 Soil Sample: TB-92A
Location ID
TB-92
Sample Type
Source - Soil
Field Sample ID
TB-92 A
Date Collected
2/5/1999
Depth (ft bgs)
3.5-4.0
Reference
31, Table 4-3 (p. 2), and
Figure 3-2
Location
Tank Farm B
Volatile Organic Compounds (mg/kg)
2-Butanone
0.19
Acetone
0.14
Xylenes
0.59
78
-------
SD - Characterization and Containment
Source No.: 4
Source 4 Soil Sample: TB-92B
Location ID
TB-92
Sample Type
Source - Soil
Field Sample ID
TB-92B
Date Collected
2/5/1999
Depth (ft bgs)
5.0-5.5
Reference
31, Table 4-3, (p. 2)
and Figure 3-2
Location
Tank Farm B
Volatile Organic Compounds (mg/kg)
2-Butanone
0.14
Acetone
0.12
Toluene
0.12
Xylenes
0.18
Source 4 Soil Sample: TB-93A
Location ID
TB-93
Sample Type
Source - Soil
Field Sample ID
TB-93A
Date Collected
2/5/1999
Depth (ft bgs)
1.5-2.0
Reference
31, Table 4-3 (p. 2),
and Figure 3-2
Location
Tank Farm B
Volatile Organic Compounds (mg/kg)
2-Butanone
0.13
Acetone
0.11
79
-------
SD - Characterization and Containment
Source No.: 4
Source 4 Soil Sample: TB-93B
Location ID
TB-93
Sample Type
Source - Soil
Field Sample ID
TB-93B
Date Collected
2/5/1999
Depth (ft bgs)
4.5-5.0
Reference
31, Table 4-3 (p. 2),
and Figure 3-2
Location
Tank Farm B
Volatile Organic Compounds (mg/kg)
2-Butanone
0.19
Acetone
0.21
Notes:
ft bgs Feet below ground surface
ID Identification
mg/kg Milligram per kilogram
TB Test boring
80
-------
SD - Hazardous Waste Quantity
Source No.: 4
2.4.2 Hazardous Waste Quantity
2.4.2.1.1 Hazardous Constituent Quantity
The information available is not sufficient to adequately support the evaluation of the hazardous
constituent quantity for Source No. 4.
Sum (pounds): Unknown
Hazardous Constituent Quantity Value (C): Not available (NA)
2.4.2.1.2 Hazardous Waste Stream Quantity
The information available is not sufficient to adequately support the evaluation of the hazardous waste
stream quantity for Source No. 4.
Sum (pounds): Unknown
Hazardous Waste Stream Quantity Value: NA
2.4.2.1.3 Volume
The information available is not sufficient to adequately support the determination of the volume
hazardous waste quantity value for Source No. 4.
Dimension of source (yd3 or gallons): 0
Volume Assigned Value: 0
2.4.2.1.4 Area
The information available is not sufficient to adequately support the determination of the area hazardous
waste quantity value for Source No. 4. However, the area hazardous waste quantity is considered to be
greater than zero, but unknown because contaminated soil remains in Source 4 as documented in Section
2.4.1.
Area of Source (ft2): Unknown, > 0
Area Assigned Value: Unknown, > 0
2.4.2.1.5 Source Hazardous Waste Quantity Value
The source HWQ value for Source No. 4 is assigned a value of greater than zero because the waste
quantity associated with Source 4 has not been adequately documented; however, the presence of
contaminated soil has been documented.
Source Hazardous Waste Quantity Value: Unknown, but greater than zero
81
-------
Source Summary
SUMMARY OF SOURCE EVALUATED
SHERWIN-WILLIAMS/HILLIARDS CREEK
Source
No.
Source Hazardous
Waste Quantity Value
Ground Water
Surface
Water
Air Gas
Air
Particulate
1
>0
10
10
Not scored
Not scored
2
>0
10
10
Not scored
Not scored
3
>0
10
10
Not scored
Not scored
4
>0
10
10
Not scored
Not scored
Total Source Hazardous Waste Quantity Value: >0
Site Hazardous Waste Quantity Factor Value: 100 (Level II Wetland)
(Ref. 1 [Table 2-6], Section 2.4.2.2)
Other Sources:
Numerous structures are shown on a 1964 insurance map that are potential areas of contaminated soil,
including (1) the soil underlying the empty and dirty drum storage area on the southern portion of the
Lucas plant, east of Hilliards Creek; (2) the soil underlying a solvent railroad and truck tanker unloading
station in the southern section of the Lucas plant, on the east side of Hilliards Creek, and west of the empty
and dirty drum storage area, and north of current Building 67; (3) soil underlying Building 67 (formerly
Building 36) used to store unknown materials, located on the southern portion of the facility, east of
Hilliards Creek; (4) soil underlying the former location of a sewage treatment plant; (5) soil underlying
piping associated with the Building 67 that runs from east to west across the facility and extends from
Building 67 and crosses under Foster Avenue to the north and eastern portions of the former Lucas plant;
(5) soil underlying former Building 56, where drums of finished stock were stored; (6) soil underlying
Building 57 used to store pigments, located on the northwest portion of the former Lucas plant, on the east
side of Gibbsboro-Clementon Road; (7) soil underlying the 22,000-gallon fuel oil tank, former coal
storage bin, latex storage tanks, and drum storage area formerly located on the north side of Foster Avenue
in the areas of former Buildings 37 and 52; (8) soil underlying Building 52, used for mixing lacquers, and
Building 53, used for storing laquer and filling cans with solvent; (9) soil underlying the former railroad
that ran from Foster Avenue, north to numerous locations on the former Lucas plant; (10) soil underlying
former Building 39 where paint products were stored and mixed; (11) soil underlying Buildings 7-1,7-2,
29, and 58, which were used to store cans of paint and finished stock (Refs. 4; 5; 60, pp. 66, 67, 68, 96).
Sampling investigations of many of these potential source areas have not been conducted.
Aerial photographs from 1961 show two open storage areas in the northeastern corner of the Lucas plant
(Ref. 7, p. 8). This area is referred to as the vacant lot in RI documents.
The 1984 aerial photographs show drums stacked around buildings in the northern portion of the Lucas
82
-------
plant and open storage areas in the north and central portions of the plant (Ref. 7, p. 13).
Lacquer storage tanks were located at an unidentified location on the Lucas plant, and the soil underlying
the tanks may be contaminated (Ref. 13, p. 7).
Septic systems located on the plant are also potential sources of soil contamination (Ref. 31, pp. 3-17, 4-
28, 4-29, 4-30, Table 4-21, Figure 3-2).
Surface runoff from the northern section of the former Lucas plant flowed to Silver Lake. The bottom
sediments of Silver Lake were periodically excavated to maintain the volume of water in the lake for water
power and purity. The sediments were removed from the plant area and spread on nearby fields (Ref. 60,
pp. 56, 57). Since potential areas of soil contamination were located on the northern section of the plant,
as evidenced by historical maps, the sediments in Silver Lake may have been contaminated and may have
contaminated nearby fields (Refs. 4; 5).
Gasoline Station
A gasoline station is located on the northeastern section of the former Lucas plant. Free-phase product
was observed in the area of the former gasoline station. Analytical results for a product sample indicated
benzene, ethylbenzene, xylene, naphthalene, and 2-methyl naphthalene (Ref. 31, pp. ES-6, 3-30).
Twelve soil samples (TB-39 through TB-48, TB-52, and TB-53) were collected from the area of the
former gasoline station from July 1995 through August 1995, during Phase III of the RI for the Lucas
plant (Ref. 31, pp. 3-3, 3-18). The soil samples were collected within the vadose zone and were biased
toward intervals that exhibited elevated field screening results (Ref. 31, p. 3-18). Analytical for soil
samples collected during the RI did not identify a significant area of soil contamination in the area of the
gasoline station; however, ground water contamination in the area was identified (Ref. 31, Table 4-11,
Figure 3-2).
Test pits were excavated on the gasoline station property to identify the USTs and the waste oil pit
reportedly located on the property on July 11 and 12, 1995, during Phase III of the RI for the Lucas plant.
Two steel USTs were located and uncovered. The tanks were observed to be corroded, and holes were
visible in the tanks. The waste oil pit was not uncovered during the excavation (Ref. 31, p. 3-21).
The plume identified in the area of gas station was determined to be limited to a small area on the
northwest side of the former gas station building and to be separate from the plumes identified in the areas
of Buildings 50 and 67 and former Tank Farm A (Ref. 31, Figures 4-11 and 4-12).
Lead-Contaminated Soil Surrounding Hilliards Creek
Soil samples were collected from 16 transects set across Hilliards Creek between Clementon-Gibbsboro
Road and Hilliard Road (T1 through T15 and T17) (Ref. 51, pp. 5, 8) between December 1999 and
January 2000. As shown on Reference 97, Hilliards Creek is located downgradient of the former Lucas
plant and received surface water runoff from the plant during and before its operation (see Reference 6,
83
-------
Figure 2-4 and Reference 31, Figure 3-2) (Ref. 31, pp. 2-9, 2-17). The soil samples were collected to
evaluate whether periodic flooding transported contaminated sediments from Hilliards Creek to the flood
plain of Hilliards Creek. A soil sample was collected from the north and south banks of Hilliards Creek at
each transect location. The transects were spaced 200 feet apart. Soil samples were collected at 30-foot
intervals along each transect. The soil samples collected from the banks of Hilliards Creek were collected
from within the 100-year flood plain. Additional soil samples were collected as needed to complete the
horizontal and vertical delineation of lead contamination, and four soil boring samples were collected from
the southern berm of the manmade pond located off Gibbsboro-Clementon Road (Ref. 51, pp. 5, 8).
All samples were analyzed for lead (Ref. 51, p. 5). Approximately 25 percent of all samples were
analyzed for TAL metals plus cyanide, 5 percent for TCLP metals (including copper and zinc), 5 percent
for TCLP VOCs and BNA analyses (Ref. 51, p. 6). All samples were collected in accordance with the
November 1999 work plan for the Hilliard's Creek Site, Gibbsboro, New Jersey, and the December 1999
work plan addendum (Refs. 51, p. 4; 68; 69). The results from the analysis of the soil samples were
validated according to Region II Contract Laboratory Program (CLP) data validation protocols (Ref. 51, p.
20). The analytical laboratory used CLP statement of work (SOW) ILM04.0 for the analysis of lead and
TAL metals (Ref. 68, Table 2).
No background soil sample was collected. However, a transect (T17) was placed across Nicholson
Branch, a tributary of Hilliards Creek. The transect was used to collect surface and subsurface soil from
the two banks of Nicholson Branch (Ref. 51, pp. 5, 8, and Figure 4). The samples collected from transect
17 are used to establish background levels for lead in soil located within the Hilliards Creek flood plain.
Analytical results for soil samples indicating concentrations of lead above three times the background
concentration are provided in the Tables 3 and 4. The background soil samples were analyzed for lead
only. Therefore, lead is the only metal evaluated. As documented in Tables 3 and 4, analytical results for
soil samples collected from the banks or flood plains of Hilliards Creek indicated the presence of lead-
contaminated soil.
84
-------
Source Summary
TABLE 3
SURFACE SOIL SAMPLES COLLECTED FROM THE FLOOD PLAIN
OF HILLIARDS CREEK (0 to 0.5 ft bgs)
Location ID
T17E
T17W
TO IN
T01N15
TO IS
T02N
T02N15
T02N30
T02S
Field Sample ID
SS-T17E-0.0-
SS-T17W-0.0-
SS-T01N-0.0-
SS-T01N15-
SS-T01S-0.0-
SS-T02N-0.0-
SS-T02N15-
SS-T02N30-
SS-T02S-0.0-
0.5
0.5
0.5
0.0-0.5
0.5
0.5
0.0-0.5
0.0-0.5
0.5
Date Collected
12/13/1999
12/13/1999
12/3/1999
12/28/1999
12/3/1999
12/3/1999
12/28/1999
12/28/1999
12/3/1999
Depth (ft bgs)
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
Sample
Background
Background
Source
Source
Source
Source
Source
Source
Source
Type
Reference
51, Table 4-c, p.
51, Table 4-c, p.
51, Table 4-c,
51, Table 4-c,
51, Table 4-c,
51, Table 4-c,
51, Table 4-c,
51, Table 4-c,
51, Table 4-c,
14, Figure 4
14, Figure 4
p. 4, Figure 4
p. 4, Figure 4
p. 4, Figure 4
p. 5, Figure 4
p. 5, Figure 4
p. 5, Figure 4
p. 5, Figure 4
Metals (mg/kg)
Lead
124
49.8
524
420
1.030
1.490
1.070
733
1.370
Notes:
bgs
Below ground surface
E
East
ft
Foot
ID
Identification
mg/kg
Milligram per kilogram
N
North
T
Transect
S
South
ss
Surface soil
w
West
85
-------
Source Summary
TABLE 3 (Continued)
SURFACE SOIL SAMPLES COLLECTED FROM THE FLOOD PLAIN
OF HILLIARDS CREEK (0 to 0.5 ft bgs)
Location ID
T17E
T17W
T02S15
T02S30
T06N
T06S
T07N
T07S
T08N
Field
SS-T17E-
SS-T17W-
SS-T02S15-
SS-T02S30-
SS-T06N-
SS-T06S-
SS-T07N-
SS-T07S-
SS-T08N-
Sample ID
0.0-005
0.0-005
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
Date
12/13/1999
12/13/1999
12/3/1999
12/3/1999
12/8/1999
12/8/1999
12/8/1999
12/8/1999
12/8/1999
Collected
Depth
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
(ft bgs)
Sample
Background
Background
Source
Source
Source
Source
Source
Source
Source
Type
Reference
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
c, p. 14,
c, p. 14,
c, p. 5,
c, p. 6,
c, p. 8,
c, p. 8,
c, p. 8,
c, p. 8,
c, p. 8,
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Metals (mg/kg)
Lead
124
49.8
718
460
4.660
3.460
2.330
2.020
2.810
Notes:
bgs
Below ground surface
E
East
ft
Foot
ID
Identification
mg/kg
Milligram per kilogram
N
North
T
Transect
S
South
ss
Surface soil
w
West
86
-------
Source Summary
TABLE 3 (Continued)
SURFACE SOIL SAMPLES COLLECTED FROM THE FLOOD PLAIN
OF HILLIARDS CREEK (0.0 to 0.5 ft bgs)
Location ID
T17E
T17W
T08S
T09S
T11S
T13S
T14S
Field Sample
[D
SS-T17E-0.0-005
SS-T17W-0.0-005
SS-T08S-0.0-0.5
SS-T09S-0.0-0.5
SS-T11S-0.0-0.5
SS-T13S-0.0-0.5
SS-T14S-0.0-0.5
Date Collected
12/13/1999
12/13/1999
12/8/1999
12/10/1999
12/10/1999
12/10/1999
12/10/1999
Depth (ft bgs)
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
Sample Type
Background
Background
Source
Source
Source
Source
Source
Reference
51, Table 4-c, p.
14, Figure 4
51, Table 4-c, p.
14, Figure 4
51, Table 4-c, p.
8, Figure 4
51, Table 4-c, p.
10, Figure 4
51, Table 4-c, p.
11, Figure 4
51, Table 4-c, p.
12, Figure 4
51, Table 4-c, p.
13, Figure 4
Metals (mg/kg)
Lead
124
49.8
7.530
1.660
409
508
513
Notes:
bgs
Below ground surface
E
East
ft
Foot
ID
Identification
mg/kg
Milligram per kilogram
N
North
T
Transect
S
South
ss
Surface soil
w
West
87
-------
Source Summary
TABLE 4
SUBSURFACE SOIL SAMPLES COLLECTED FROM THE FLOOD PLAIN
OF HILLIARDS CREEK (1.5 to 2.0 ft bgs)
Location ID
T17E
TO IN
TO IS
T01S15
T02N
T02N15
T02N30
T02S
T02S15
T02S30
Field
SS-T17E-
SS-T01N-
SS-T01S-
SS-T01S15—
SS-T02N-
SS-T02N15-
SS-T02N30-
SS-T02S-
SS-T02S15-
SS-T02S30-
Sample ID
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
Date
12/13/1999
12/3/1999
12/3/1999
12/28/1999
12/3/1999
12/28/1999
12/28/1999
12/3/1999
12/3/1999
12/3/1999
Collected
Depth
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
(ft bgs)
Sample
Background
Source
Source
Source
Source
Source
Source
Source
Source
Source
Type
Reference
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-c,
c, p. 14,
c, p. 4,
c, p. 4,
c, p. 14,
c, p. 5,
c, p. 5,
c, p. 5,
c, p. 5,
c, p. 6,
p. 6, Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Metals (mg/kg)
Lead
6
5.720
898
184
5.290
4.430
121
1.080
24.300
916
Notes:
bgs
Below ground surface
E
East
ft
Foot
ID
Identification
mg/kg
Milligram per kilogram
N
North
T
Transect
S
South
ss
Surface soil
w
West
88
-------
Source Summary
TABLE 4 (Continued)
SUBSURFACE SOIL SAMPLES COLLECTED FROM THE FLOOD PLAIN
OF HILLIARDS CREEK (1.5 to 2.0 ft bgs)
Location ID
T17E
T04S
T06N
T06S
T07N
T07S
T08N
T08S
T11N
T12N
Field Sample
SS-T17E-
SS-T04S-
SS-T06N-
SS-T06S-
SS-T07N-
SS-T07S-
SS-T08N-
SS-T08S-
SS-T11N-
SS-T12N-
[D
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
0.0-0.5
Date
12/13/1999
12/3/1999
12/8/1999
12/8/1999
12/8/1999
12/8/1999
12/8/1999
12/8/1999
12/10/1999
12/10/1999
Collected
Source
Background
Source
Source
Source
Source
Source
Source
Source
Source
Source
Type
Depth
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
(ft bgs)
Reference
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
c, p. 14,
c, p. 7,
c, p. 8,
c, p. 8,
c, p. 8,
c, p. 9,
c, p. 9,
c, p. 9,
c, p. 11,
c, p. 12,
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Metals (mg/kg
Lead
6
220
108
56
3.140
3.820
589
16.300
593
2.950
Notes:
bgs
Below ground surface
E
East
ft
Foot
ID
Identification
mg/kg
Milligram per kilogram
N
North
T
Transect
S
South
ss
Surface soil
w
West
89
-------
Source Summary
TABLE 4 (Continued)
SUBSURFACE SOIL SAMPLES COLLECTED FROM THE FLOOD PLAIN
OF HILLIARDS CREEK (1.5 to 2.0 ft bgs)
Location ID
T17E
T12N
T13N
T13N15
T13S
T14N
T14N15
T14N30
T14S
Field
SS-T17E-
SS-T12N-
SS-T13N-
SS-T13N15-
SS-T13S-
SS-T14N-
SS-T14N15-
SS-T14N30-
SS-T14S-
Sample ID
1.5-2.0
0.0-0.5
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
Date
12/13/1999
12/10/1999
12/9/1999
12/28/1999
12/10/1999
12/9/1999
12/28/1999
12/28/1999
12/10/1999
Collected
Depth
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
(ft bgs)
Source
Background
Source
Source
Source
Source
Source
Source
Source
Source
Type
Reference
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
51, Table 4-
c, p. 14,
c, p. 12,
c, p. 12,
c, p. 12,
c, p. 13,
c, p. 13,
c, p. 13,
c, p. 13,
c, p. 13,
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Metals (mg/kg)
Lead
6
2.950
4.330
604
61
562
144
1.330
61
Notes:
bgs
Below ground surface
E
East
ft
Foot
ID
Identification
mg/kg
Milligram per kilogram
N
North
T
Transect
S
South
ss
Surface soil
w
West
90
-------
Source Summary
Lead-Contaminated Soil at 165 Kirkwood Road
Analytical results for soil samples collected as part of the ACO indicated the presence of lead in surface
and subsurface (1 to 6.5 feet bgs) soil on a residential property at 165 Kirkwood Road (Refs. 50, p. 1-2;
51, Appendix A). In April 2000, composite samples were collected from 165 Kirkwood Roadand
analyzed for TCLP metals, VOCs, and SVOCs (Refs. 30, p. 1; 51, Table 1, pp. 24, 25, Appendix A). The
leachate from the samples contained arsenic (up to 1,190 (ig/L). barium (up to 1,740 (ig/L). cadmium (up
to 42.3 (ig/L). chromium (up to 59.1 (ig/L). and lead (up to 53,000 (ig/L) (Ref. 30, pp. 16, 18, 20, 22, 24,
26, 28, 30, 99, 101, 103, 105, 107, 119, 121, 123, 125, 127, 135, 137 through 149, 181, 182, 183, 185,
186, 188, 190, 191, 192, 194, 195, 196). No VOCs or SVOCs were detected in the samples. Analytical
results for soil samples indicated high concentrations of lead in surface and subsurface soil (1.0 to 6.5 feet
bgs) (Ref. 51, Table 4 and Appendix A).
Also in April 2000, soil samples were collected from 165 Kirkwood Road to complete the delineation of
lead-contaminated soil (Ref. 51, p. 6). The property was divided into grids representing no more than 20
cubic yards each. Four borings were completed in each of these grids and samples were collected at
intervals of 0 to 6 inches, 12 to 18 inches, and 24 to 30 inches. The four samples from each interval were
composited on an equal-weight basis and analyzed for total lead. In total, 413 soil samples were collected
during the April 2000 sampling event. The results of the April 2000 investigation indicated that lead was
present at 165 Kirkwood Road at levels ranging from non-detectto 38,800 mg/kg (Ref. 51, p. 7 and Table
4). The address 165 Kirkwood Road is located on the flood plain of Hilliards Creek (Ref. 51, Table 4-b).
Hilliards Creek bisects the backyard the property (Ref. 50, p. 1-2). Lead-contaminated soil at this location
may be caused by releases from the Lucas plant to Hilliards Creek and the subsequent flooding of 165
Kirkwood Road by Hilliards Creek.
In September and November 2001, surface and subsurface soil samples were collected at 165 Kirkwood
Road to complete delineation of lead contamination identified during earlier sampling events. Soil borings
were drilled up to 10 feet bgs. Subsurface soil samples were collected at 1-foot intervals ranging from 0 to
10 feet bgs. The uppermost 6 inches of each interval were collected for analysis (Ref. 51, pp. 13, 14, 19,
23). In October 2003, an interim removal action was completed at 165 Kirkwood Road: the top 6 inches
of soil were excavated from the property and disposed of (Ref. 50, pp. ES-1, 2-3). Lead-contaminated soil
may remain on the property (Ref. 51, Table 4 and Appendix A) since only the top 6 inches of soil were
removed from the property and results for soil samples below this depth indicated concentrations of lead
greater than 400 mg/kg.
91
-------
SWOF - Surface Water Overland Flow/Flood Migration
4.0 SURFACE WATER MIGRATION PATHWAY
4.1 OVERLAND/FLOOD MIGRATION COMPONENT
4.1.1 GENERAL CONSIDERATIONS
4.1.1.1 DEFINITION OF HAZARDOUS SUBSTANCE MIGRATION PATH FOR
OVERLAND/FLOOD COMPONENT
Surface water runoff from the northernmost portion of the Lucas plant discharges directly into Silver Lake
(Ref. 31, p. 2-9). Silver Lake discharges into Hilliards Creek through an underground culvert that crosses
under the parking lot located between the lake and Foster Avenue (Refs. 6, Figure 2-4; 31, p. 2-17). The
north-central portion of the Lucas plant, including portions of Source 2 (contaminated soil northwest and
southeast of Building 55) and the entire area of Source 4, is occupied by buildings andpaved areas. Runoff
generated in the area between Silver Lake and Foster Avenue enters a network of catch basins and storm
sewers, which discharge into Hilliards Creek, immediately south of Foster Avenue (Ref. 31, p. 2-9). From
this point, Hilliards Creek continues to flow in the southwest direction, past Buildings 50 and 67 and the
locations of the surface water impoundments (Source 3), approximately 1,000 feet to Gibbsboro-Clementon
Road, under Gibbsboro-Clementon Road, then past a residential pond located on the north bank of Hilliards
Creek. Hilliards Creek continues in the southwesterly direction and converges with an unnamed tributary
of Bridgewood Lake approximately 800 feet west of Gibbsboro-Clementon Road. The creek continues
approximately 0.85 mile to Kirkwood Lake (Refs. 31, Figures 2-2, 2-4, and 3-2; and 9). Kirkwood Lake
continues in the westerly direction for approximately 4,224 feet to empty into the Cooper River. Cooper
River continues in the northwest direction to complete the 15-mile downstream target distance limit (TDL).
The TDL is documented on Reference 98. Surface features, such as buildings, are shown in Reference 31,
Figures 2-2, 2-4, and 3-2.
Surface water runoff from the southern portion of the Lucas plant, including portions of Source 2
(contaminated soil associated with the pump house) and Sources 1 and 3 flow to Hilliards Creek (Ref. 31,
Figures 2-4 and 3-2, p. 2-9). Free-phase product, Source 1, has been observed entering Hilliards Creek at
the point where the storm sewer north of Building 67 discharges into Hilliards Creek (Refs. 31, Figure 3-2;
18, pp. 2-2, 2-3, Figure 3-1; 48, p. 2-3, Figures 2-1 and 2-4). Aerial photographs from 1973 show the
presence of a pipeline extending from the north bank of one of the surface impoundments (impoundment one)
associated with Source 3 to a drainage channel (Hilliards Creek) that runs through the center of the Lucas
plant. An outfall also was observed extending from the western bank of the impoundment area toward the
drainage channel (Hilliards Creek) (Ref. 7, p. 10).
Historically, surface water runoff from the Lucas plant followed the contours of the land and entered a storm
sewer system that discharged into Hilliards Creek (Refs. 6, Figure 2-4; 18, pp. 2-2, 2-3, 3-2; 31, p. 2-9; 73,
pp. 2, 4). The 1981 United States Geological Survey (USGS) topographic map of Clementon, New Jersey
does not show Hilliards Creek from Foster Avenue to Gibbsboro-Clementon Road (Ref. 9). Observations
made by personnel studying the Sherwin-Williams/Hilliards Creek area indicate that the creek is perennial
in this section (Ref. 80). Therefore, the probable point of entry (PPE) into surface water, Hilliards Creek,
is the point at which the storm sewer empties into Hilliards Creek because free-phase product (Source 1)
contained in the storm sewer has been observed to discharge into Hilliards Creek. Free-phase product has
been observed discharging into the sewer and then entering the creek at this point. This is the location where
the storm sewer north of Building 67 discharges into the creek at sampling location SGW-292 (Refs. 31,
92
-------
SWOF - Surface Water Overland Flow/Flood Migration
Figure 2-3; 10, pp. 1, 2; 31, p. 3-3; 32, p. 5; 36; 37; 48, p. 2-3; 65, pp. 1, 2, 3; 72, pp. 2, 4; 73, pp. 2, 4). The
overland flow distance from Source 1 on the Lucas plant property to perennial surface water is zero since
free-phase product (Source 1) was observed discharging directly into Hilliards Creek (Refs. 8, pp. 2-2,2-3,
3-2; 18, pp. 2-2, 2-3, 3-2; 31, p. 2-9; 48, p. 2-3 9;73, pp. 2, 4) (Ref. 31, Figures 2-4 and 3-2). This PPE to
surface water is shown on Reference 97 as PPE-1.
The PPE from Source 2 is at sampling location TB-73 collected adjacent to the pump house and to Hilliards
Creek (Ref. 31, Figure 3-2) and is shown in Reference 97 as PPE-2. The most downstream PPE to surface
water is the point at which Source 3, former impoundments, discharged into Hilliards Creek, as shown on
Reference 7, page. 10. Aerial photographs from 1973 show the presence of a pipeline extending from the
north hank of one of the surface impoundments (impoundment one) associated with Source 3 to a drainage
channel (Hilliards Creek) that runs through the center of the Lucas plant. An outfall also was observed
extending from the western hank of the impoundment area toward the drainage channel (Hilliards Creek)
(Ref. 7, p. 10). The overland flow distance is estimated to be 333 feet as measured along the pipe line shown
on Reference 7, page 11. The PPE for Source 3 is the point at which the drainage ditch discharges into
Hilliards Creek, shown as PPE-3 on Reference 97. The PPE to Hilliards Creek from Source 4 (Former Tank
FarmB) is adjacent to sampling location MW-14 (Ref. 31, Figure 3-2) as shown on Reference 98 as PPE-4.
4.1.1.2 Target Distance Limit
Surface water from PPE-4, the most upstream PPE, flows into Hilliards Creek and travels approximately 1.3
miles west to Kirkwood Lake. Kirkwood Lake continues in a westerly direction for approximately 4,224 feet
then empties into the Cooper River. The Cooper River continues in a northwesterly direction to complete
the 15-mile surface water downstream TDL. The TDL is documented on Reference 98.
Surface water from PPE-3, the most downstream PPE, flows into Hilliards Creek and flows approximately
1.2 miles west to Kirkwood Lake. Kirkwood Lake continues in a westerly direction for approximately 4,224
feet then empties into the Cooper River. The Cooper River continues in a northwesterly direction to
complete the 15-mile surface water downstream TDL. The TDL is documented on Reference 98.
4.1.2.1 LIKELIHOOD OF RELEASE
Numerous investigations have been conducted in Hilliards Creek to determine whether the Lucas plant
released hazardous substances to the creek. Only analytical data from the most recent investigations are used
to document an observed release to surface water from the Lucas plant by chemical analysis. However,
summaries of previous investigations, presented in the attribution section, provide additional documentation
of releases to Hilliards Creek.
4.1.2.1.1 Observed Release
An observed release to Hilliards Creek by both direct observation and chemical analysis is documented in
the sections below.
Direct Observation
The free-phase product (Source 1) in the area of Buildings 50 and 67 was initially identified in 1983 when
a seep of an oily substance was observed in the parking lot between former Buildings 50 and 67 (also known
93
-------
SWOF - Observed Release
as the Academy Paints Building). The seep (Buildings 50 and 67 seep) is the surface expression of the free-
phase product in ground water in the area of Buildings 50 and 67 (Source 1). The seep flowed overland to
a storm water catch basin in the parking lot, through the storm sewer, and then discharged through rip rap
into Hilliards Creek (Refs. 32, p. 5; 65, pp. 1, 2, 3). The seep was observed on many occasions during
construction of the new office complex that now occupies the Lucas plant (Ref. 65, p. 1).
On February 7, 1985, and March 6, 1987, New Jersey Department of Environmental Protection (NJDEP)
personnel collected an aqueous sample of Building 50 and 67 seep (Source 1) while it was discharging into
Hilliards Creek (Ref. 32, pp. 5, 6, 7). The exact location of the sample is not provided in reference
documentation. Analytical results for the seep sample indicated the presence of the following hazardous
substances (Refs. 6, Figure 2-4; 10, pp. 1, 2, 25 to 39; 31, pp. 3-2, 3-3 and Figures 2-2 and 3-2; Ref. 32, pp.
5, 6, 7).
Hazardous Substance Concentration Concentration
(February 7,1987) (March 6,1987)
benzene
700 ppb
18,000 ppb
1,2,4-trimethylbenzene,
280 ppb
1,3,5-trimethylbenzene,
220 ppb
3,490 ppb
naphthalene,
130 ppb
xylenes,
180 ppb
ethylbenzene,
76 ppb
7,380 ppb
cumene,
40 ppb
1,280 ppb
tetrachloroethene
7,605 ppb
toluene
7,750 ppb
sec-butylbenzene
3,025 ppb
n-propylbenzene
1,580 ppb
1,2,3-trimethylbenzene
5,900 ppb
p-xylene
1,170 ppb
m-xylene
7,530 ppb
On February 19, 1988, and again on February 25, 1988, NJDEP observed the Building 50 and 67 seep
(Source 1) discharging into Hilliards Creek (Refs. 36; 37).
In 1989, NJDEP submitted a sample of the Building 50 and 67 seep to an analytical laboratory for
comparison to known petroleum and solvent products. Results of the comparison indicated that constituents
in the seep sample were most similar to a mixture of solvents and to 627 solvent (a solvent), Varsol 18 (an
oil), and mineral spirits (a solvent), which were used at the Lucas plant (Refs. 63, pp. 1, 2; 31, Table 2-2).
On April 9, 2002, free-phase product (Source 1) from an on-site free-phase product recovery system was
observed in the storm water drain north of Building 67. The storm drain discharges into Hilliards Creek.
Product was pumped out of the storm water drain, and additional measures were taken to prevent further
releases to the drain and Hilliards Creek (Refs. 48, p. 2-3; 72, pp. 2, 4; 73, pp. 2, 4).
94
-------
SWOF - Observed Release
Chemical Analysis - 2004
From December 6 through December 9,2004, Tetra Tech collected sediment and surface water samples from
Hilliards Creek and wetlands adjacent to Hilliards Creek. Background surface water and sediment samples
also were collected from Cooper River, Cedar Lake, and an unnamed tributary of Cedar Lake. Background
wetland sediment samples were collected from Linden Lake (Ref. 84, Table 1, and Figure 2). Tetra Tech
collected the surface water and sediment samples beginning at the sample location closest to the point where
Hilliards Creek discharges into Kirkwood Lake (Ref. 84, p. 5, Figure 1). Surface water samples were
collected before the sediment sample at each sample location by submerging the sample container in the
creek. At each location, T etra T ech collected three 40-milliliter vials pre-preserved with hydrochloric acid
for target compound list (TCL) volatile organic compound (VOC) analysis; four 1-liter amber bottles
preserved with ice for TCL semivolatile organic compounds (SVOC), pesticide, and polychlorinated
biphenyls (PCB) analyses; one 1 -liter polyethylene bottle for hardness analyses; and one 1 -liter polyethylene
bottle for dissolved TAL metals and cyanide analyses. The aqueous samples collected for dissolved TAL
metals analysis were filtered and then preserved with nitric acid to a pH of less than 2 prior to sample
shipment (Ref. 84, p. 14).
Tetra Tech collected grab sediment samples for TCL VOC analysis and placed samples directly in the sample
jars. Water was decanted from sediment samples collected for total organic carbon (TOC), grain size, TAL
metals, TCL SVOC, pesticide, and PCB analysis prior to placing the sample in a sample container. Tetra
Tech used these techniques for the collection of all sediment samples (Ref. 84, p. 14).
The TCL organic samples were packaged and shipped to Ceimic Corporation in Narragansett, Rhode Island
for analysis. The samples collected for dissolved TAL metals analysis were packaged and shipped to
ChemTech Consulting Group (CHEMED) in Mountainside, New Jersey for analysis. All samples were sent
for analysis under the U.S. Environmental Protection Agency (EPA) Contract Laboratory Program (CLP)
Case No. 33650. A summary of the sample analysis and analytical methods is provided in T able 5 (Ref. 84,
p. 14).
TABLE 5
ANALYTICAL PARAMETERS AND METHODS
Matrix
Analysis
Analytical Method
Sediment
TAL Metals
CLP SOW ILM05.3 ICPAES + Hg
Sediment
TOC
American Society of Agronomy 3rd ed., Ch. 34
Sediment
pH
9045
Sediment
Grain size
ASTM D422
Sediment
TCL VOCs
CLP SOW OLM04.3
Sediment
TCL SVOCs
CLP SOW OLM04.3
Aqueous
Dissolved TAL
Metals
CLP SOW ILM05.3
ICPAES + Hg
95
-------
SWOF - Observed Release
Matrix
Analysis
Analytical Method
Aqueous
TOC
9060A
Aqueous
pH
150.1/9040C
Aqueous
TCL VOCs
CLP SOW OLM04.3
Aqueous
TCL SVOCs
CLP SOW OLM04.3
Aqueous
Hardness (Mn, Ca)
130.1
Notes:
ASTM
American Society for Testing and
Mn
Manganese
Materials
OLM
Organic low to medium
Ca
Calcium
SOW
Statement of work
CLP
Contract Laboratory Program
svoc
Semivolatile organic compound
Hg
Mercury
TAL
Target analyte list
ICPAES
Inductively coupled plasma/atomic
TCL
Target compound list
emission spectroscopy
TOC
Total organic carbon
ILM
Inorganic low to medium
VOC
Volatile organic compound
Sediment and surface water samples analyzed for TCL and TAL constituents were analyzed under the EPA
CLP (Ref. 84, p. 14). All analytical results were validated in accordance with EPA Region 2 "Evaluation
of Metals Data for the CLP Program," and "CLP Organic Data Review and Preliminary Review" (Refs. 85,
p. 15; 86, Standard Operating Procedure Number HW-2).
The locations of the background and release surface water and sediment samples and concentrations of
hazardous substances detected in the samples are provided in the sections below. As documented in Tables
5, 6, and 10, the background and release samples are considered to be comparable because they were
collected within the same time frame, analyzed using the same methods, are located within the same type of
environment (creek or wetland), and have the same composition (see Tables 7, 8, and 9 for concentrations).
2004 Background Sampling Locations
During the Tetra Tech 2004 investigation of Hilliards Creek, Hilliards Creek background surface water and
sediment samples were collected from locations outside of areas known to be contaminated by lead as
indicated by previous investigations. The background locations were selected based on the similarity of
surface water, drainage area, and wetland and soil type (Ref. 85, p. 8). A summary of the background
sampling locations is provided in Table 6. The background sampling locations are provided in Reference
84, Figure 2.
96
-------
SWOF - Observed Release
TABLE 6
BACKGROUND SEDIMENT
AND SURFACE WATER SAMPLING LOCATIONS
2004 Hilliards CREEK INVESTIGATION
Sample ID
Date
Time Depth
Sampling Location
Reference
Sediment Samples
HC-BSD-1
12/09/04
9:00
0-2
inches
Wetland area on the northern side of
Linden Lake, about 3,000 feet
upstream of the confluence of Cooper
River and Hilliards Creek.
84, p. 10, Figure
2, Appendix B, p.
17
HC-BSD-2
12/09/04
9:45
0-2
inches
Wetland area on the south side of
Linden Lake, about 3,500 feet
upstream from the confluence of
Cooper River and Hilliards Creek.
84, p. 10, Figure
2, Appendix B, p.
18
HC-BSD-3
12/09/04
10:30
0-2
inches
Cooper River, about 1,500 feet
upstream from the confluence of
Cooper River and Hilliards Creek.
84, p. 10, Figure
2, Appendix B, p.
18
HC-BSD-7
12/09/04
12:40
0-2
inches
Northeast bank of Oles Lake below
the water line. Oles Lake is located
1.5 miles northeast of the Lucas plant
property and south of Cedar Lake.
84, p. 10, Figure
2, Appendix B, p.
19
HC-BSD-8
12/09/04
12:50
0-2
inches
From bottom of an unnamed tributary
of Oles Lake.
84, p. 10, Figure
2, Appendix B, p.
20
Surface Water SamDles
HC-BSW-1
12/09/04
9:00
Surface
Wetland area on the northern side of
Linden Lake, about 3,000 feet
upstream of the confluence of Cooper
River and Hilliards Creek.
84, p. 12, Figure
2, Appendix B, p.
17
HC-BSW-2
12/09/04
9:45
Surface
Wetland area on the south side of
Linden Lake, about 3,500 feet
upstream from the confluence of
Cooper River and Hilliards Creek.
84, p. 12, Figure
2, Appendix B, p.
18
HC-RSW-3
12/09/04
10:30
Surface
Cooper River, about 1,500 feet
upstream from the confluence of
Cooner River and Hilliards Creek.
84, p. 12, Figure
2, Appendix B, p.
18
97
-------
TABLE 6 (Continued)
SWOF - Observed Release
BACKGROUND SEDIMENT
AND SURFACE WATER SAMPLING LOCATIONS
2004 HILLIARDS CREEK INVESTIGATION
Sample ID
Date
Time Depth
Sampling Location
Reference
Surface Water SamDles (C
Continued}
HC-BSW-5
12/09/04
11:55
Surface
About 600 feet east of Haddonfield
Road, in an unnamed tributary
draining Clement Lake, at Clement
Lake discharge to an unnamed
tributary.
84, p. 12, Figure
2, Appendix B, p.
19
HC-BSW-6
12/09/04
12:30
Surface
In Oles Lake, taken from the west
bank.
84, p. 12, Figure
2, Appendix B, p.
19
HC-BSW-7
12/09/04
12:40
Surface
Northeast bank of Oles Lake below
the water line. Oles Lake is located
1.5 miles northeast of the Lucas plant
property and south of Cedar Lake.
84, p. 12, Figure
2, Appendix B, p.
19
HC-BSW-8
1 2/09/04
12:50
Surface
From bottom of an unnamed tributary
of Oles Lake, north of Oles Lake.
84, p. 12, Figure
2, Appendix B, p.
19
Notes:
BSD Background sediment HC
BSW Background surface water ID
Hilliards Creek
Identification
98
-------
SWOF - Observed Release
2004 Background Concentrations:
The concentrations of hazardous substances detected in the background surface water and sediment samples
are provided in the Tables 7, 8, and 9. As shown in Reference 84, Figure 2, two background sediment and
surface water samples were collected from wetlands, two sediment and four surface water samples were
collected from tributaries, and one sediment and one surface water sample were collected from a lake (Ref. 84,
Figure 2). The highest concentrations of arsenic, lead, and SVOCs detected in the background samples are
used to establish the background arsenic, lead, and SVOCs concentrations for the Hilliards Creek and wetland
release samples. The wetland sediment sample used to establish background concentrations for arsenic, lead,
and SVOCs is HC-BSD-2 (Tables 7 and 8; Ref. 1, Table 2-3).
The TOC values are presented in Table 7. The TOC values in background sediment samples can be compared
to release sediment sample TOC values to determine whether the background and release samples have
relatively the same amount of carbon.
99
-------
SWOF - Observed Release
TABLE 7
INORGANIC CONCENTRATIONS - 2004 BACKGROUND SEDIMENT SAMPLES
Sample Identification
HC-BSD-1
HC-BSD-2
HC-BSD-3
HC-BSD-7
HC-BSD-8
CLP Sample Number
MB5797
MB5798
MB5799
MB57A3
MB57A4
Location
Wetland
Wetland
Creek
Lake
Creek
Reference
86, p. 87; 87, p. 8; 94,
86, p. 88; 87, p. 8; 94,
86, p. 89; 87, p. 8; 94,
86, p. 91; 87, p. 8; 94,
86, p. 92; 87, p. 8; 94,
P-
72
P-
73
P-
74
P-
76
P-
77
CRDL
Cone.
Q
Cone.
Q
Cone.
Q
Cone.
Q
Cone.
Q
Inorganic Compounds
:mg/kg)
Arsenic
3
4.3
J
7.2
J
6.8
J
1
J
0.47
J
Lead
2
58.9
J
183
J
93.2
J
12.2
J
2
J
Total Organic Carbon
-
57,000
-
46,000
-
30,000
-
6,200
-
6,100
-
(mg/kg)
Notes:
BSD
Cone.
CLP
CRDL
HC
J
mg/kg
Q
100
Not applicable
Background sediment
Concentration
Contract laboratory program
Contract-required detection limit
Hilliards Creek
Estimated value, the percent solids were less than 50 but greater than 10 (Ref. 86, p. N-4) or below the CRDLs (Ref. 86, pp. N-4 and
N-5). These concentrations have no bias (Ref. 81).
Milligram per kilogram
Data qualifier
-------
SWOF - Observed Release
TABLE 8
ORGANIC CONCENTRATIONS - BACKGROUND SEDIMENT
Sample Identification
HC-BSD-1
HC-BSD-2
HC-BSD-3
HC-BSD-7
HC-BSD-8
CLP Sample Number
B5797
B5798
B5799
B57A3
B57A4
Location
Wetland
Wetland
Creek
Lake
Creek
Reference
90, p. D-100; 87, p.
90, p. D-104; 87, p.
90, p. D-106; 87, p.
90, p. D-112; 87, p.
90, p. D-115; 87, p.
CRQL
19
19
19
19
19
Cone.
Q
Cone.
Q
Cone.
Q
Cone.
Q
Cone.
Q
Organic Compounds (ng/kg)
Benzo(a)anthracene
330
620
u
3000
u
1600
u
460
u
380
u
Benzo(a)pyrene
330
620
u
3000
u
1600
u
460
u
380
u
Benzo(b)fluoranthene
330
620
u
3000
u
1600
u
460
u
380
u
Benzo(g,h,i)perylene
330
620
u
3000
u
1600
u
460
u
380
u
Benzo(k)fluoranthene
330
620
u
3000
u
1600
u
460
u
380
u
Bis(2-ethylhexyl)phthalate
330
190
J
850
J
640
J
230
J
110
J
Chrysene
330
620
u
3000
u
1600
u
430
u
380
u
Fluoranthene
330
87
J
330
J
1600
u
51
J
380
J
Phenanthrene
330
620
u
3000
u
1600
u
430
u
380
u
Notes:
fxg/kg Microgram per kilogram
CLP Contract laboratory program
Cone. Concentration
CRQL Contract-required quantitation limit
J Estimated value, the percent solids were less than 50 but
greater than 10 (Ref. 90, Attachment 1, p. 7 of 7) or below
the CRQLs (Ref. 90, Attachment 1, p. 5 of 7). These
concentrations have no bias (Ref. 81).
Q Data qualifier
U Not detected. The concentration provided is the adjusted
CRQL based on dilutions and sample moisture (Ref. 90, p.
24).
Since all other concentrations are below CRQLs, the release
concentrations need to exceed the CRQL to document an observed
release (Ref. 1,Table 2-3)
101
-------
SWOF - Observed Release
TABLE 9
INORGANIC CONCENTRATIONS - BACKGROUND SURFACE WATER SAMPLES
Sample
Identification
HC-BSW-1
HC-BSW-2
HC-BSW-3
HC-BSW-5
HC-BSW-6
HC-BSW-7
HC-BSW-8
CLP Sample
Number
MB57A5
MB57A6
MB57A7
MB57A9
MB57B0
MB57B1
MB57B2
Location
Wetland
Wetland
Creek
Creek
Creek
Lake
Creek
Reference
86, p. 149; 87,
p.8
86, p. 58; 87,
p.8
89, p. 59; 87,
p.8
86, p. 61; 87,
p.8
86, p. 150; 87,
p. 9
86, p. 151; 87,
p. 9
86, p. 152; 87
p. 9
CRQL
Cone.
Q
Cone.
Q
Cone.
Q
Cone.
Q
Cone.
Q
Cone.
Q
Cone.
Q
Lead fua/L)
10
10
u
10
u
10
u
10
u
10
u
10
u
10
u
Notes:
Hg/L
Microgram per liter
BSW
Background surface water
CLP
Contract laboratory program
Cone.
Concentration
CRQL
Contract-required quantitation limit
HC
Hilliards Creek
Q
Data qualifier
U
Not detected above the detection limit. The reported value is the quantitation limit.
No release of organic compounds are documented for surface water; therefore, background surface water concentrations for organic compounds are
not presented.
102
-------
SWOF-Observed Release
2004 Release Sampling Locations
During the Tetra Tech 2004 investigation of Hilliards Creek, surface water and sediment samples were
collected from Hilliards Creek and wetlands of Hilliards Creek downstream of the Lucas plant (Ref. 84, p.
6). As documented in the section below, the samples contained concentrations of arsenic, lead, and SVOCs
at concentrations exceeding three times the background concentration. A summary of the release sampling
locations is provided in the Table 10. The release sampling locations are provided on Reference 97.
TABLE 10
LOCATION OF RELEASE SURFACE WATER AND SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
Sampling Location
Reference
Sediment Samples
HC-SD-01
12/09/01
7:20
0-2
inches
Hilliards Creek, about 230
feet upstream of Gibbsboro-
Clementon Road.
84, p. 6, Figure 1,
Appendix B, p. 17
HC-SD-03
12/09/01
10:30
0-2
inches
Hilliards Creek, about 200
feet upstream of HC-SD-04.
84, p. 6, Figure 1,
Appendix B, p. 18
HC-SD-04
12/08/04
18:45
0-2
inches
Hilliards Creek, about 250
feet downstream of
Gibbsboro-Clementon Road.
84, p. 6, Figure 1,
Appendix B, p. 16
HC-SD-05
12/08/04
16:45
0-2
inches
Hilliards Creek, about 250
feet upstream of HC-SD-06.
84, p. 6, Figure 1,
Appendix B, p. 15
HC-SD-06
12/08/04
16:30
0-2
inches
Wetland area, on the north
bank of Hilliards Creek,
about 1,000 feet downstream
of HC-SD-04.
84, p. 6, Figure 1,
Appendix B, p. 15
HC-SD-08
12/08/04
12:20
0-2
inches
Hilliards Creek, about 270
feet downstream of HC-SD-
06.
84, p. 7, Figure 1,
Appendix B, p. 14
HC-SD-08-2
12/08/04
12:20
0-2
inches
Duplicate of HC-SD-08.
84, p. 7, Figure 1,
Appendix B, p. 14
HC-SD-12
12/08/04
11:00
0-2
inches
Hilliards Creek, about 230
feet downstream of HC-SD-
08.
84, p. 7, Figure 1,
Appendix B, p. 13
103
-------
SWOF - Observed Release
TABLE 10 (Continued)
LOCATION OF RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
Sampling Location
Reference
Sediment Samples (Continued)
Hilliards Creek, about 120
0-2
feet downstream of HC-SD-
84, p. 7, Figure 1,
HC-SD-13
12/08/04
10:30
inches
12.
Appendix B, p. 13
Hilliards Creek, about 120
0-2
feet downstream of HC-SD-
84, p. 7, Figure 1
HC-SD-14
12/08/04
10:10
inches
13.
Appendix B, p. 13
Hilliards Creek, about 120
0-2
feet downstream of HC-SD-
84, p. 7, Figure 1
HC-SD-15
12/08/04
9:50
inches
14.
Appendix B, p. 12
Hilliards Creek, about 320
0-2
feet downstream of HC-SD-
84, p. 7, Figure 1,
HC-SD-17
12/08/04
08:50
inches
15.
Appendix B, p. 10
Hilliards Creek, about 150
0-2
feet downstream of HC-SD-
84, p. 7, Figure 1,
HC-SD-18
12/08/04
08:50
inches
17.
Appendix B, p. 10
Hilliards Creek, about 620
0-2
feet downstream of HC-SD-
84, p. 7, Figure 1,
HC-SD-19
12/07/04
16:10
inches
15.
Appendix B, p. 10
Hilliards Creek, about 150
0-2
feet downstream of HC-SD-
84, p. 7, Figure 1,
HC-SD-20
12/07/04
16:25
inches
19.
Appendix B, p. 11
Hilliards Creek, about 120
0-2
feet downstream of HC-SD-
84, p. 8, Figure 1,
HC-SD-21
12/07/04
16:40
inches
20.
Appendix B, p. 11
Hilliards Creek, about 200
0-2
feet downstream of HC-SD-
84, p. 8, Figure 1,
HC-SD-22
12/07/04
15:00
inches
21.
Appendix B, p. 10
Hilliards Creek, about 150
0-2
feet downstream of HC-SD-
84, p. 8, Figure 1,
HC-SD-23
12/07/04
14:55
inches
22.
Appendix B, p. 10
Hilliards Creek, about 275
0-2
feet downstream of HC-SD-
84, p. 8, Figure 1,
HC-SD-25
12/07/04
13:45
inches
23.
Appendix B, p. 9
104
-------
TABLE 10 (Continued)
SWOF - Observed Release
LOCATION OF RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
Sampling Location
Reference
Sediment Samples (Continued)
Wetland area on the south
hank of Hilliards Creek,
0-2
about 150 feet downstream of
84, p. 8, Figure 1,
HC-SD-26
12/07/04
13:10
inches
HC-SD-25.
Appendix B, p. 9
Hilliards Creek, about 200
0-2
feet west of HC-SW/SD-31,
84, p. 8, Figure 1,
HC-SD-27
12/07/04
13:00
inches
from the south bank of creek.
Appendix B, p. 8
Wetland area adjacent to
south bank of Hilliards
0-2
Creek, about 270 feet
84, p. 8, Figure 1,
HC-SD-28
12/07/04
10:30
inches
downstream of HC-SD-25.
Appendix B, p. 7
Wetland area adjacent to
south bank of Hilliards
0-2
Creek, about 155 feet
84, p. 8, Figure 1,
HC-SD-29
12/07/04
10:20
inches
downstream of HC-SD-25.
Appendix B, p. 7
Hilliards Creek, about 400
0-2
feet downstream of HC-SD-
84, p. 8, Figure 1,
HC-SD-31
12/07/04
inches
29.
Appendix B, p. 7
Wetland area on north bank
of Hilliards Creek, about 275
0-2
feet downstream of HC-SD-
84, p. 9, Figure 1,
HC-SD-32
12/07/04
10:50
inches
25.
Appendix B, p. 7
Wetland area on north bank
of Hilliards Creek, about 540
0-2
feet downstream from HC-
84, p. 9, Figure 1,
HC-SD-33
12/07/04
8:40
inches
SD-27.
Appendix B, p. 6
Wetland area on north bank
of Hilliards Creek, about 465
0-2
feet downstream of HC-SD-
84, p. 9, Figure 1,
HC-SD-34
12/07/04
8:47
inches
27.
Appendix B, p. 6
Hilliards Creek, about 200
0-2
feet downstream of HC-SD-
84, p. 9, Figure 1,
HC-SD-35
12/06/04
15:10
inches
33.
Appendix B, p. 5
Wetland area about 150 feet
0-2
north of HC-SD-35, north of
84, p. 9, Figure 1,
HC-SD-36
12/06/04
15:40
inches
Nicholson Branch.
Appendix B, p. 5
105
-------
TABLE 10 (Continued)
SWOF - Observed Release
LOCATION OF RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
Sampling Location
Reference
Sediment Samples (Continued)
Wetland area on the south
hank of Hilliards Creek,
0-2
about 100 feet south of HC-
84, p. 9, Figure 1,
HC-SD-37
12/06/04
14:55
inches
SD-35.
Appendix B, p. 4
North hank of Hilliards Creek
below water line, about 200
0-2
feet downstream from HC-
84, p. 9, Figure 1,
HC-SD-38
12/06/04
13:15
inches
SD-35.
Appendix B, p. 4
Hilliards Creek, about 100
0-2
feet downstream from HC-
84, p. 9, Figure 1,
HC-SD-39
12/06/04
13:00
inches
SD-38.
Appendix B, p. 4
North bank of Hilliards Creek
0-2
below water line, about 150
84, p. 9, Figure 1,
HC-SD40
12/06/04
10:45
inches
downstream of HC-SD-38.
Appendix B, p. 2
Wetland area on the north
bank of Hilliards Creek,
0-2
about 200 feet northwest of
84, p. 9, Figure 1,
HC-SD41
12/06/04
9:50
inches
HC-SD-40.
Appendix B, p. 1
Wetland area on the north
bank of Hilliards Creek,
0-2
about 80 feet west of HC-SD-
84, p. 10, Figure 1,
HC-SD43
12/06/04
9:00
inches
41, beside large metal duct.
Appendix B, p. 1
Wetland area between
Cooper River and Hilliards
Creek, about 250 feet
0-2
upstream of the convergence
of Hilliards Creek and
84, p. 10, Figure 1,
HC-SD-44
12/06/04
11:35
inches
Cooper River.
Appendix B, p. 2
Wetland area between
Cooper River and Hilliards
0-2
Creek, about 100 feet south
84, p. 10, Figure 1,
HC-SD45
12/06/04
11:55
inches
from HC-SD-44.
Appendix B, p. 3
Wetland area south of
0-2
Hilliards Creek, about 200
84, p. 10, Figure 1,
HC-SD46
12/06/04
12:05
inches
feet east of HC-SD-39.
Annendix B. n. 3
106
-------
TABLE 10 (Continued)
SWOF - Observed Release
LOCATION OF RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
Sampling Location
Reference
Surface Water Samples
HC-SD48
12/06/04
10:50
0-2
inches
Wetland area on the north
hank of Hilliards Creek,
about 100 feet north of HC-
SD-40.
84, p. 10, Figure 1,
Appendix B, p. 2
HC-SW-08
12/08/04
12:05
Surface
Hilliards Creek, about 500
feet downstream of the
convergence of Hilliards
Creek and an unnamed
tributary of Bridgewood
Lake.
84, p. 11, Figure 1,
Appendix B, p. 14
HC-SW-17
12/08/04
8:50
Surface
Hilliards Creek, about 1,600
feet downstream of trFthe
convergence of Hilliards
Creek and an unnamed
tributary of Bridgewood
Lake.
84, p. 11,
Appendix B, p. 11
HC-SW-22
12/07/04
15:00
Surface
Hilliards Creek, about 200
feet downstream of HC-SD-
21.
84, p. 11,
Appendix B, p. 10
HC-SW-22-2
12/07/04
15:05
Surface
Duplicate of HC-SW-22.
84, p. 11,
Appendix B, p. 10
HC-SW-23
12/07/04
14:55
Surface
Hilliards Creek, about 150
feet downstream of HC-SD-
22.
84, p. 11,
Appendix B, p. 9,
10
HC-SW-25
12/07/04
13:45
Surface
Hilliards Creek, about 275
feet downstream of HC-SD-
23.
84, p. 11,
Appendix B, p. 9
HC-SW-27
12/07/04
13:00
Surface
Hilliards Creek, about 200
feet west of HC-SW/SD-31,
from the south bank of creek.
84, p. 11,
Appendix B, p. 8
HC-SW-31
12/07/04
10:55
Surface
Hilliards Creek, about 200
feet west of HC-SD-25.
84, p. 11,
Appendix B, p. 7,
8
107
-------
SWOF - Observed Release
TABLE 10 (Continued)
LOCATION OF RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
Sampling Location
Reference
Surface Water Samples (Continued)
HC-SW-33
12/07/04
8:40
Surface
Wetland area on the north
bank of Hilliards Creek,
about 200 feet upstream from
HC-SD-35.
84, p. 11,
Appendix B, p. 6
HC-SW-34
12/07/04
8:47
Surface
Wetland area on the north
bank of Hilliards Creek,
about 100 feet north from
HC-SD-33.
84, p. 11,
Appendix B, p. 6
HC-SW-35
12/06/04
15:10
Surface
Hilliards Creek, about 200
feet upstream of HC-SD-46
84, p. 11,
Appendix B, p. 5
HC-SW-39
12/06/04
13:00
Surface
Hilliards Creek, about 100
feet upstream from HC-SD-
40.
84, p. 11,
Appendix B, p. 4
HC-SW-41
12/06/04
9:50
Surface
Wetland area on the north
bank of Hilliards Creek,
about 200 feet northwest of
HC-SD-40.
84, p. 11,
Annendix B. n. 1
Notes:
HC Hilliards Creek
ID Identification
SD Sediment
SW Surface water
2004 Release Concentrations:
The concentrations of hazardous substances detected in sediment and surface water samples document an
observed release Hilliards Creek are summarized in Tables 11 and 12, respectively. The sampling locations
are shown on Reference 97. Concentration of the hazardous substance have a data qualifier of "J," estimated
concentration, because the percent moisture was high (Ref. 86, pp. N-4 and N-5 ).
The highest concentrations of arsenic, lead, and SVOCs detected in the background samples are used to
establish the background arsenic, lead, and SVOCs concentrations for the Hilliards Creek and wetland
release samples. The wetland sediment sample usedto establish background concentrations for arsenic, lead,
and SVOCs is HC-BSD-2. The wetland background concentrations are arsenic 7.2 mg/kg x 3 = 21.6; lead
183 mg/kg x 3 = 549 mg/kg; and bis(2-ethylhexyl)phthalate 850 (xg/kg x 3 = 2,550 (xg/kg (no other SVOCs
108
-------
SWOF - Observed Release
were detected in the background sample). The creek sediment sample used to establish background
concentrations for arsenic, lead, and SVOCs is HC-BSD-3. The creek background concentrations are arsenic
6.8 mg/kg x 3 = 20.4; lead 93.2 mg/kg x 3 = 280 mg/kg; and bis(2-ethylhexyl)phthalate 640 (xg/kg x 3 =
1,920 |ig/kg (no other SVOCs were detected in the background sample) (Tables 7 and 8; Ref. 1, Table 2-3).
To document an observed release, the concentration of the hazardous substances must be three times the
background concentration and above the sample quantitation limit (SQL) if detected in the background or
greater than or equal to the SQL if not detected in the background sample (Ref. 1, Table 2-3). The SQL for
the release samples are provided in Reference 88. The TOC values are provided in Tables 11 and 12. The
TOC values can be used to compare release and background sample TOC contents.
TABLE 11
CONCENTRATIONS OF HAZARDOUS SUBSTANCES DETECTED
IN RELEASE SEDIMENT SAMPLES COLLECTED FROM
HILLIARDS CREEK
Sample ID
Hazardous Substance
Cone.
Q
SQL*
Units
Reference
HC-SD-01
Arsenic
23.2
J
4.39
mg/kg
86, p. 110; 87, p. 3; 88, p. 1
91, p. D-70; 87, p. 12; 88,
p. 3; 94, p. 9
Lead
468
J
2.03
mg/kg
Benzo(a)anthracene
2,600
-
1,760
^ig/kg
Benzo(a)pyrene
3,400
-
1,760
^ig/kg
Benzo(b)fluoranthene
5,100
-
1,760
^ig/kg
B enzo(g,h,i)p erylene
3,000
-
1,760
^ig/kg
Benzo(k)fluoranthene
1,900
-
1,760
^ig/kg
Chrysene
3,600
-
1,760
^ig/kg
Fluoranthene
6,200
J
1,760
^ig/kg
Phenanthrene
3,100
-
1,760
^ig/kg
Pyrene
6,400
-
1,760
^ig/kg
Total organic carbon
4,200
-
-
mg/kg
HC-SD-03
Arsenic
22.9
J
3.8
mg/kg
86, p. 113; 87, p. 3; 88, p. 1
91, p. D-79; 87, p. 12; 88,
p. 3; 94, p. 12
Fluoranthene
1,100
-
805
^ig/kg
Total organic carbon
9,000
-
-
mg/kg
HC-SD-04
Benzo(a)anthracene
2,100
-
857
^ig/kg
91, p. D-82; 87, p. 12; 88,
p. 3; 94, p. 13
Benzo(a)pyrene
1,900
-
857
^ig/kg
Benzo(b)fluoranthene
2,400
-
857
^ig/kg
Benzo(g,h,i)perylene
1,100
-
857
^ig/kg
Benzo(k)fluoranthene
920
-
857
^ig/kg
Chrysene
2,000
-
857
^ig/kg
Fluoranthene
4,700
-
857
^ig/kg
Phenanthrene
2,600
-
857
^ig/kg
Pyrene
4,300
-
857
^ig/kg
Total organic carbon
8,600
-
-
mg/kg
109
-------
SWOF - Observed Release
TABLE 11 (Continued)
CONCENTRATIONS OF HAZARDOUS SUBSTANCES DETECTED
IN RELEASE SEDIMENT SAMPLES COLLECTED FROM
HILLIARDS CREEK
Sample ID
Hazardous Substance
Cone.
Q
SQL*
Units
Reference
HC-SD-05
Arsenic
40.6
J
3.62
mg/kg
86, p. 115; 87, p. 3; 88, p. 1
Lead
1,010
J
2.41
mg/kg
HC-SD-06
Benzo(b)fluoranthene
410
-
402
^ig/kg
91, p. D-88; 87, p. 12; 88,
p. 3; 94, p. 15
Pyrene
570
-
402
^ig/kg
Total organic carbon
2,000
-
-
^ig/kg
HC-SD-08
Arsenic
580
J
15.31
mg/kg
86, p. 118; 87, p. 3; 88, p.
1; 90, p. D-73; 87, p. 12;
88, p. 3; 94, p. 17
Lead
7,440
J
10.20
mg/kg
Benzo(b)fluoranthene
5,000
J
2,640
^ig/kg
Chrysene
3,200
J
2,640
^ig/kg
Fluoranthene
4,800
J
2,640
^ig/kg
Pyrene
5,200
J
2,640
^ig/kg
Total organic carbon
44,100
-
-
mg/kg
HC-SD-08-2
Arsenic
506
J
11.45
mg/kg
86, p. 119; 87, p. 3; 88, p.
1; 90, p. D-76; 87, p. 12;
88, p. 3; 94, p. 18
Lead
6,190
J
7.63
mg/kg
Benzo(b)fluoranthene
7,500
J
6,286
^ig/kg
Fluoranthene
7,100
J
6,286
^ig/kg
Pyrene
7,300
J
6,286
^ig/kg
Total organic carbon
42,000
-
-
mg/kg
HC-SD-12
Arsenic
150
J
19.11
mg/kg
86, p. 79; 87, p. 4; 88, p. 1;
94, p. 20
Lead
5,910
J
12.74
mg/kg
Total organic carbon
38,000
-
-
mg/kg
HC-SD-13
Arsenic
763
J
20.00
mg/kg
86, p. 80; 87, p. 4; 88, p. 1;
94, p. 21
Lead
9,140
J
13.33
mg/kg
Total organic carbon
39,000
-
-
mg/kg
HC-SD-14
Arsenic
1,110
J
19.11
mg/kg
86, p. 81; 87, p. 4; 88, p. 1;
94, p. 23
Lead
6,350
J
12.74
mg/kg
Total organic carbon
49,000
-
-
mg/kg
HC-SD-15
Arsenic
300
J
21.90
mg/kg
86, p. 82; 87, p. 4; 88, p. 1;
94, p. 23
Lead
7,260
J
14.60
mg/kg
Total organic carbon
31,000
-
-
mg/kg
110
-------
SWOF - Observed Release
TABLE 11 (Continued)
CONCENTRATIONS OF HAZARDOUS SUBSTANCES DETECTED
IN RELEASE SEDIMENT SAMPLES COLLECTED FROM
HILLIARDS CREEK
Sample ID
Hazardous Substance
Cone.
Q
SQL*
Units
Reference
HC-SD-17
Arsenic
211
J
8.67
mg/kg
86, p. 84; 87, p. 4; 88, p. 1;
94, p. 25
Lead
2,650
J
5.78
mg/kg
Total organic carbon
25,000
-
-
mg/kg
HC-SD-18
Arsenic
209
J
11.36
mg/kg
86, p. 85; 87, p. 4; 88, p. 1;
94, p. 26
Lead
2,380
J
7.58
mg/kg
Total organic carbon
23,000
-
-
mg/kg
HC-SD-19
Arsenic
244
J
13.45
mg/kg
86, p. 86; 87, p. 4; 88, p. 1;
94, p. 27
Lead
2,640
J
8.97
mg/kg
Total organic carbon
25,000
-
-
mg/kg
HC-SD-20
Arsenic
875
J
9.06
mg/kg
86, p. 20; 87, p. 5; 88, p. 1;
94, p. 28
Lead
3,450
J
6.04
mg/kg
Total organic carbon
43,000
-
-
mg/kg
HC-SD-21
Arsenic
374
J
11.03
mg/kg
86, p. 21; 87, p. 5; 88, p. 1;
94, p. 29
Lead
3,000
J
7.353
mg/kg
Total organic carbon
46,000
-
-
mg/kg
HC-SD-22
Arsenic
435
J
8.88
mg/kg
86, p. 22; 87, p. 5; 88, p. 1;
94, p. 31
Lead
3,200
J
5.92
mg/kg
Total organic carbon
28,000
-
-
mg/kg
HC-SD-23
Arsenic
108
J
6.1
mg/kg
86, p. 24; 87, p. 5; 88, p. 1;
94, p. 32
Lead
1,470
J
4.08
mg/kg
Total organic carbon
34,000
-
-
mg/kg
HC-SD-25
Arsenic
213
J
13.39
mg/kg
86, p. 120; 87, p. 5; 88,
p. 1; 94, p. 34
Lead
1,750
J
8.93
mg/kg
Total organic carbon
51,000
-
-
mg/kg
HC-SD-26
Arsenic
180
J
7.96
mg/kg
86, p. 121; 87, p. 5; 88,
p. 1; 94, p. 35
Lead
2,270
J
5.30
mg/kg
Total organic carbon
25,000
-
-
mg/kg
HC-SD-27
Arsenic
176
J
9.62
mg/kg
86, p. 122; 87, p. 5; 88,
p. 1; 94, p. 36
Lead
2,470
J
6.41
mg/kg
Total organic carbon
36,000
-
-
mg/kg
111
-------
SWOF - Observed Release
TABLE 11 (Continued)
CONCENTRATIONS OF HAZARDOUS SUBSTANCES DETECTED
IN RELEASE SEDIMENT SAMPLES COLLECTED FROM
HILLIARDS CREEK
Sample ID
Hazardous Substance
Cone.
Q
SQL*
Units
Reference
HC-SD-28
Arsenic
311
J
6.62
mg/kg
86, p. 123; 87, p. 5; 88,
p. 4 ; 94, p. 37
Lead
2,920
J
4.41
mg/kg
Total organic carbon
28,000
-
-
mg/kg
HC-SD-29
Arsenic
185
J
7.01
mg/kg
86, p. 124; 87, p. 5; 88,
p. 2; 94, p. 38
Lead
2,230
J
4.67
mg/kg
Total organic carbon
46,000
-
-
mg/kg
HC-SD-31
Arsenic
256
J
10.14
mg/kg
86, p. 126; 87, p. 6; 88,
p. 2; 94, p. 40
Lead
3,060
J
6.76
mg/kg
Total organic carbon
41,000
-
-
mg/kg
HC-SD-32
Arsenic
542
J
6.74
mg/kg
86, p. 127; 87, p. 6; 88,
p. 2; 94, p. 41
Lead
4,180
J
4.49
mg/kg
Total organic carbon
37,000
-
-
mg/kg
HC-SD-33
Arsenic
449
J
6.98
mg/kg
86, p. 128; 87, p. 6; 88,
p. 2; 94, p. 42
Lead
4,290
J
4.65
mg/kg
Total organic carbon
27,000
-
-
mg/kg
HC-SD-34
Arsenic
242
J
7.61
mg/kg
86, p. 129; 87, p. 6; 88,
p. 2; 94, p. 43
Lead
2,330
J
5.08
mg/kg
Total organic carbon
36,000
-
-
mg/kg
HC-SD-35
Arsenic
360
J
8.57
mg/kg
86, p. 6; 87, p. 1; 88, p. 2;
94, p. 44
Lead
4,090
J
5.71
mg/kg
Total organic carbon
35,000
-
-
mg/kg
HC-SD-36
Arsenic
680
J
13.33
mg/kg
86, p. 7; 87, p. 1; 88, p. 2;
94, p. 45
Lead
3,440
J
8.89
mg/kg
Total organic carbon
33,000
-
-
mg/kg
HC-SD-37
Arsenic
161
J
7.87
mg/kg
86, p. 8; 87, p. 1; 88, p. 2;
94, p. 46
Total organic carbon
46,000
-
-
mg/kg
HC-SD-38
Arsenic
381
J
11.07
mg/kg
86, p. 10; 87, p. 1; 88, p. 2;
94, p. 48
Lead
3,640
J
7.38
mg/kg
Total organic carbon
26,000
-
-
mg/kg
HC-SD-39
Arsenic
322
J
10.27
mg/kg
86, p. 11; 87, p. 1; 88, p. 2;
94, p. 49
Lead
3,830
J
6.85
mg/kg
Total organic carbon
25,000
-
-
mg/kg
HC-SD-40
Arsenic
643
J
11.86
mg/kg
86, p. 12; 87, p. 1; 88, p. 2;
94, p. 50
Lead
4,830
J
7.90
mg/kg
Total organic carbon
23,000
-
-
mg/kg
112
-------
SWOF - Observed Release
TABLE 11 (Continued)
CONCENTRATIONS OF HAZARDOUS SUBSTANCES DETECTED
IN RELEASE SEDIMENT SAMPLES COLLECTED FROM
HILLIARDS CREEK
Sample ID
Hazardous Substance
Cone.
Q
SQL*
Units
Reference
HC-SD-41
Arsenic
108
J
14.02
mg/kg
86, p. 13; 88, p. 2; 94, p. 51
Lead
1,900
J
9.35
mg/kg
Total organic carbon
35,000
-
-
mg/kg
HC-SD-43
Benzo(a)anthracene
760
-
478
^ig/kg
92, p. D-99; 88, p. 3; 94, p.
53
Benzo(a)pyrene
720
-
478
^ig/kg
Chrysene
810
-
478
^ig/kg
Phenanthrene
600
-
478
^ig/kg
Total organic carbon
34,000
-
-
mg/kg
HC-SD-44
Arsenic
323
J
11.81
mg/kg
86, p. 16; 88, p. 2; 94,
p. 54
Lead
3,000
J
7.87
mg/kg
Total organic carbon
29,000
-
-
mg/kg
HC-SD-45
Arsenic
630
J
16.76
mg/kg
86, p. 17; 88, p. 2; 94,
p. 55
Lead
5,220
J
11.17
mg/kg
Total organic carbon
38,000
-
-
mg/kg
HC-SD46
Arsenic
1,110
J
16.04
mg/kg
86, p. 18; 88, p. 2; 94,
p. 56
Lead
2,770
J
10.7
mg/kg
Total organic carbon
44,000
-
-
mg/kg
HC-SD48
Arsenic
349
J
12.10
mg/kg
86, p. 19; 88, p. 2; 94,
p. 57
Lead
2,820
J
8.07
mg/kg
Total organic carbon
29.000
-
-
mg/kg
Notes:
Not applicable
* See Reference 88
fxg/kg Microgram per kilogram
Cone. Concentration
HC Hilliards Creek
ID Identification
J Estimated concentration. The arsenic, lead, and SVOCs concentrations were "J" qualified because
of the percent moisture was high (Refs. 86, pp. N-4 and N-5; 90, Attachment 1, p. 7 of 7). The
concentrations are not adjusted due to the data qualifier because no bias is assigned to samples
qualified because the percent moisture is high (Ref. 81).
mg/kg Milligram per kilogram
Q Data qualifier
SD Sediment
SQL Sample quantitation limit
113
-------
SWOF - Observed Release
TABLE 12
Notes:
Hg/L
Cone.
CRQL
HC
ID
SW
114
CONCENTRATIONS OF HAZARDOUS SUBSTANCES DETECTED
IN RELEASE SURFACE WATER SAMPLES COLLECTED FROM
HILLIARDS CREEK
Hazardous
Cone.
CRQL
Sample ID
Substance
(^ig/L)
(^ig/L)
Reference
HC-SW-22
Lead
15.0
10
86, p. 48; 87, p. 6; 89, p. 1
HC-SW-34
Arsenic
30.1
10
86, p. 55; 87, p. 7; 89, p. 1
Lead
29
10
HC-SW-35
Lead
12.4
10
86, p. 42; 87, p. 2; 89, p. 1
HC-SW-39
Lead
24.1
10
86. d. 43: 87. o. 2: 89. o. 1
Microgram per liter
Concentration
Contract-required quantitation limit
Hilliards Creek
Identification
Surface water
-------
SWOF - Observed Release
Chemical Analysis -1998
InNovember 1998, 676 sediment samples, 42 soil samples, three waste samples, and eight aqueous samples
were collected from Hilliards Creek between Foster Avenue and Hilliards Road and tributaries to Hilliards
Creek to determine the extent of lead contamination within the creek and the creek's flood plain. Samples
were collected from Hilliards Creek every 50 feet upstream from Hilliards Creek Road to Silver Lake,
covering a total distance of approximately 4,600 feet. In total, 92 stream sampling points or 92 transects
were established within Hilliards Creek. Three sets of samples were collected from each of the transects:
one set of samples from the north bank, one set of samples from the south bank, and one set of samples from
the center of the creek. Each set of samples consisted of two composite samples collected at depths of
approximately 0 to 2 inches below ground surface (bgs) and 1 to 1.5 feet bgs. The samples collected from
the center of Hilliards Creek are used to document an observed release to the creek. The sample identifier,
SD, indicates that the sample was collected from the center of the creek. The last two numbers in the sample
identification indicated the depth at which the sample was collected. For example, sample SD-60-0-2,
indicates that the sample was collected at the center of the creek (SD), at transect location number 60, and
at the depth of 0 to 2 inches bgs (Ref. 26, p. 1, Figure 1, Table 1).
Soil samples also were collected on the north and south flood plains of Hilliards Creek at distances of 7 and
12 feet from the north and south bank of Hilliards Creek (Ref. 26, pp. 2, Figures 1 and 2, and Table 1, pp.
4 and 5).
Blue-stained material, believed to be paint, was observed in the sediments of Hilliards Creek and in soil
adjacent to the creek (Ref. 26, Table 1, p. 5).
A sediment sample (N49A-10) collected from Hilliards Creek containing blue-stained material (paint) also
contained arsenic (1,280 mg/kg) and lead (68,000 mg/kg) (Refs. 26, p. 5; 27, p. 9). Three waste samples
collected from the banks of Hilliards Creek contained arsenic up to 759 mg/kg, and lead up to 65,000 mg/kg
(Refs. 26, p. 5; 27, p. 11).
No background sample was collected during the sampling event. A sediment sample was collected from an
unnamed tributary draining Bridgewood Lake, on the west side of Gibbsboro-Clementon Road (Ref. 26,
Figure 1, p. 4). That sample, SD-60, is used to establish background concentrations of lead for the 1998
analytical data collected for Hilliards Creek. The concentrations of arsenic and lead detected in the
background sample, as documented in Table 14, indicate that the sampling location was not impacted by
activities on the Lucas plant. The background and release samples are considered to be comparable because
they were collected within the same time frame, analyzed using the same methods, are located within the
same type of environment (creek), receive drainage from similar areas, collected from the same depths, and
are located within the same drainage basin (Refs. 9; 26).
All samples were analyzed for total lead using EPA Method 6010B (Ref. 28, p. 2). The detection limits are
summarized in Reference 110.
115
-------
SWOF - Observed Release
Location of Background Samples -1998
The location of the 1998 background samples is summarized in Table 13.
TABLE 13
BACKGROUND SEDIMENT
1998 HILLIARDS CREEK INVESTIGATION
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-60-0-2
11/17/1998
14:14
0-2
inches
Center of unnamed tributary
draining Bridgewood Lake. On
the west side of Gibbsboro-
Clementon Road.
26, Figure 1,
p. 4; 28, p.
100078
SD-60-1-11.5
11/17/1998
14:16
1 - 1.5
feet
Center of unnamed tributary
draining Bridgewood Lake. On
the west side of Gibbsboro-
Clementon Road.
26, Figure 1,
p. 4; 28, p.
100078
Notes:
bgs below ground surface
ft foot
ID identification
SD sediment
Background Concentration 1998
The concentration of lead detected in the background sediment sample is summarized in the table below.
TABLE 14
1998 BACKGROUND SEDIMENT LEAD CONCENTRATION
Sample Identification
SD-60-0-2
SD-60-1-1.5
Percent Moisture
44.8
56.8
Sample Quantitation Limit
23.73
39.81
Reference
28, p. 15; 110
28, p. 15; 110
Lead
22.6
111
116
-------
SWOF - Observed Release
Locations of Release Samples 1998
A summary of the release sampling locations is provided in Table 15. The release sampling locations are
provided on Figure 1 in Reference 26. The sampling locations on Figure 1 in Reference 26 identify each
sampling location by the number used to designate the transect location. The distances measured from Foster
Avenue, Gibbsboro-Clementon Road, and Hilliards Road to the sampling locations provided in Table 15
below are measured from the intersection of Hilliards Creek and the road along the contours of Hilliards
Creek. Rather than straight line distances from the road to the sampling location. The samples were
collected at 50-foot intervals (Ref. 26).
TABLE 15
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-104-0-2
11/20/1998
14:39
2 inches
Center of Hilliards Creek,
approximately 150 feet
west of Foster Avenue
28,p.100103
SD-103-1-1.5
11/20/1998
14:00
1 to 1.5 feet
Center of Hilliards Creek,
approximately 200 feet
west of Foster Avenue
28,p.100102
SD-102-1-1.5
11/20/1998
14:20
1 to 1.5 feet
Center of Hilliards Creek,
approximately 250 feet
west of Foster Avenue
28,p.100102
SD-101-0-2
11/20/1998
13:48
2 inches
Center of Hilliards Creek,
approximately 300 feet
west of Foster Avenue
28,p.100101
SD-100-0-2
11/20/1998
13:41
1 to 1.5 feet
Center of Hilliards Creek,
approximately 350 feet
west of Foster Avenue
28,p.100101
SD-97-1-1.5
11/20/1998
10:44
1 to 1.5 feet
Center of Hilliards Creek,
approximately 500 feet
west of Foster Avenue
28,p.100099
SD-96-0-2
11/20/1998
10:05
2 inches
Center of Hilliards Creek,
approximately 550 feet
west of Foster Avenue
28,p.100099
SD-95-0-2
11/20/1998
09:46
2 inches
Center of Hilliards Creek,
approximately 600 feet
west of Foster Avenue
28,p. 100098
117
-------
SWOF - Observed Release
TABLE 15 (Continued)
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-95-1-1.5
11/20/1998
09:47
1 to 1.5 feet
Center of Hilliards Creek,
approximately 600 feet
west of Foster Avenue
28,p. 100098
SD-94-1-1.5
11/20/1998
09:37
1 to 1.5 feet
Center of Hilliards Creek,
approximately 650 feet
west of Foster Avenue
28,p. 100098
SD-93-1-1.5
11/20/1998
09:20
1 to 1.5 feet
Center of Hilliards Creek,
approximately 700 feet
west of Foster Avenue
28,p. 100098
SD-90-0-2
11/20/1998
08:25
2 inches
Center of Hilliards Creek,
approximately 800 feet
west of Foster Avenue
28,p. 100096
SD-88-0-2
11/19/1998
14:55
2 inches
Center of Hilliards Creek,
approximately 300 feet
east of Gibbsboro-
Clementon Road
28,p.100095
SD-88-1-1.5
11/19/1998
15:00
1 to 1.5 feet
Center of Hilliards Creek,
approximately 300 feet
east of Gibbsboro-
Clementon Road
28,p. 100095
SD-87-0-2
11/19/1998
14:26
2 inches
Center of Hilliards Creek,
approximately 250 feet
east of Gibbsboro-
Clementon Road
28,p.100095
SD-86-0-2
11/19/1998
13:54
2 inches
Center of Hilliards Creek,
approximately 200 feet
east of Gibbsboro-
Clementon Road
28, p. 100094
SD-86-1-1.5
11/19/1998
13:58
1 to 1.5 feet
Center of Hilliards Creek,
approximately 200 feet
east of Gibbsboro-
Clementon Road
28, p. 100094
118
-------
SWOF - Observed Release
TABLE 15 (Continued)
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-83-0-2
11/19/1998
Not
listed
2 inches
Center of Hilliards Creek,
approximately 50 feet east
of Gibbsboro-Clementon
Road
28,p.100041
SD-83-1-1.5
11/19/1998
Not
listed
1 to 1.5 feet
Center of Hilliards Creek,
approximately 50 feet east
of Gibbsboro-Clementon
Road
28,p. 100041
SD-82-0-2
11/19/1998
11:19
2 inches
Center of Hilliards Creek,
approximately 50 feet west
of Gibbsboro-Clementon
Road
28,p.100094
SD-82-1-1.5
11/19/1998
11:22
1 to 1.5 feet
Center of Hilliards Creek,
approximately 50 feet west
of Gibbsboro-Clementon
Road
28, p. 100094
SD-80-0-2
11/19/1998
10:18
2 inches
Center of Hilliards Creek,
approximately 150 feet
west of Gibbsboro-
Clementon Road
28, p. 100093
SD-80-1-1.5
11/19/1998
10:21
1 to 1.5 feet
Center of Hilliards Creek,
approximately 150 feet
west of Gibbsboro-
Clementon Road
28,p. 100093
SD-79-0-2
11/19/1998
11:07
2 inches
Center of Hilliards Creek,
approximately 200 feet
west of Gibbsboro-
Clementon Road
28,p.100093
SD-79-1-1.5
11/19/1998
11:08
1 to 1.5 feet
Center of Hilliards Creek,
approximately 200 feet
west of Gibbsboro-
Clementon Road
28,p.100093
119
-------
SWOF - Observed Release
TABLE 15 (Continued)
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-78-0-2
11/19/1998
10:28
2 inches
Center of Hilliards Creek,
approximately 250 feet
west of Gibbsboro-
Clementon Road
28, p. 100092
SD-78-1-1.5
11/19/1998
10:32
1 to 1.5 feet
Center of Hilliards Creek,
approximately 250 feet
west of Gibbsboro-
Clementon Road
28, p. 100092
SD-77-1-1.5
11/19/1998
10:15
1 to 1.5 feet
Center of Hilliards Creek,
approximately 300 feet
west of Gibbsboro-
Clementon Road
28,p. 100092
SD-76-0-2
11/19/1998
09:18
2 inches
Center of Hilliards Creek,
approximately 350 feet
west of Gibbsboro-
Clementon Road
28,p.100092
SD-76-1-1.5
11/19/1998
09:20
1 to 1.5 feet
Center of Hilliards Creek,
approximately 350 feet
west of Gibbsboro-
Clementon Road
28,p.100092
SD-75-0-2
11/19/1998
08:47
2 inches
Center of Hilliards Creek,
approximately 400 feet
west of Gibbsboro-
Clementon Road
28,p.100091
SD-74-0-2
11/19/1998
08:12
2 inches
Center of Hilliards Creek,
approximately 450 feet
west of Gibbsboro-
Clementon Road
28,p.100091
SD-74-1-1.5
11/19/1998
08:14
1 to 1.5 feet
Center of Hilliards Creek,
approximately 450 feet
west of Gibbsboro-
Clementon Road
28,p.100091
120
-------
SWOF - Observed Release
TABLE 15 (Continued)
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-73-0-2
11/19/1998
09:21
2 inches
Center of Hilliards Creek,
approximately 500 feet
west of Gibbsboro-
Clementon Road
28,p.100091
SD-73-1-1.5
11/19/1998
09:27
1 to 1.5 feet
Center of Hilliards Creek,
approximately 500 feet
west of Gibbsboro-
Clementon Road
28,p. 100091
SD-72-0-2
11/19/1998
08:46
2 inches
Center of Hilliards Creek,
approximately 550 feet
west of Gibbsboro-
Clementon Road
28,p.100090
SD-72-1-1.5
11/19/1998
08:50
1 to 1.5 feet
Center of Hilliards Creek,
approximately 550 feet
west of Gibbsboro-
Clementon Road
28,p.100090
SD-71-0-2
11/19/1998
08:17
2 inches
Center of Hilliards Creek,
approximately 600 feet
west of Gibbsboro-
Clementon Road
28,p. 100090
SD-71-1-1.5
11/19/1998
08:20
1 to 1.5 feet
Center of Hilliards Creek,
approximately 600 feet
west of Gibbsboro-
Clementon Road
28,p.100090
SD-70-0-2
11/18/1998
15:11
2 inches
Center of Hilliards Creek,
approximately 650 feet
west of Gibbsboro-
Clementon Road
28,p.100089
SD-70-1-1.5
11/18/1998
15:21
1 to 1.5 feet
Center of Hilliards Creek,
approximately 650 feet
west of Gibbsboro-
Clementon Road
28,p.100089
121
-------
SWOF - Observed Release
TABLE 15 (Continued)
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-65-0-2
11/17/1998
15:15
2 inches
Center of Hilliards Creek,
approximately 700 feet
west of Gibbsboro-
Clementon Road
28,p.100080
SD-65-1-1.5
11/17/1998
15:20
1 to 1.5 feet
Center of Hilliards Creek,
approximately 700 feet
west of Gibbsboro-
Clementon Road
28,p.100080
SD-64-0-2
11/17/1998
15:38
2 inches
Center of Hilliards Creek,
approximately 750 feet
west of Gibbsboro-
Clementon Road
28,p.100079
SD-63-0-2
11/17/1998
14:55
2 inches
Center of Hilliards Creek,
approximately 800 feet
west of Gibbsboro-
Clementon Road
28,p.100079
SD-62-0-2
11/17/1998
14:30
2 inches
Center of Hilliards Creek,
approximately 850 feet
west of Gibbsboro-
Clementon Road
28,p.100079
SD-61-0-2
11/17/1998
14:14
2 inches
Center of Hilliards Creek,
approximately 900 feet
west of Gibbsboro-
Clementon Road
28,p. 100078
SD-49-0-2
11/16/1998
08:28
2 inches
Center of Hilliards Creek,
approximately 1,000 feet
west of Gibbsboro-
Clementon Road
28,p.100073
SD-48-0-2
11/13/1998
14:22
2 inches
Center of Hilliards Creek,
approximately 1,050 feet
west of Gibbsboro-
Clementon Road
28,p.100071
122
-------
SWOF - Observed Release
TABLE 15 (Continued)
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-47-0-2
11/13/1998
14:10
2 inches
Center of Hilliards Creek,
approximately 1,100 feet
west of Gibbsboro-
Clementon Road
28,p.100071
SD-45-0-2
11/13/1998
10:16
2 inches
Center of Hilliards Creek,
approximately 1,200 feet
west of Gibbsboro-
Clementon Road
28,p. 100070
SD-45-1-1.5
11/13/1998
10:30
1 to 1.5 feet
Center of Hilliards Creek,
approximately 1,200 feet
west of Gibbsboro-
Clementon Road
28,p.100070
SD-44-0-2
11/13/1998
10:05
2 inches
Center of Hilliards Creek,
approximately 1,250 feet
west of Gibbsboro-
Clementon Road
28,p. 100068
SD-44-1-1.5
11/13/1998
10:02
1 to 1.5 feet
Center of Hilliards Creek,
approximately 1,250 feet
west of Gibbsboro-
Clementon Road
28,p. 100069
SD-43-0-2
11/13/1998
09:30
2 inches
Center of Hilliards Creek,
approximately 1,300 feet
west of Gibbsboro-
Clementon Road
28,p. 100068
SD-43-1-1. 5
11/13/1998
09:35
1 to 1.5 feet
Center of Hilliards Creek,
approximately 1,300 feet
west of Gibbsboro-
Clementon Road
28,p. 100068
SD-42-0-2
11/13/1998
09:40
2 inches
Center of Hilliards Creek,
approximately 1,350 feet
west of Gibbsboro-
Clementon Road
28,p.100067
123
-------
SWOF - Observed Release
TABLE 15 (Continued)
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-42-1-1.5
11/13/1998
09:42
1 to 1.5 feet
Center of Hilliards Creek,
approximately 1,350 feet
west of Gibbsboro-
Clementon Road
28,p.100067
SD-41-0-2
11/13/1998
08:58
2 inches
Center of Hilliards Creek,
approximately 1,400 feet
west of Gibbsboro-
Clementon Road
28,p. 100067
SD-41-1-1.5
11/13/1998
09:00
1 to 1.5 feet
Center of Hilliards Creek,
approximately 1,400 feet
west of Gibbsboro-
Clementon Road
28,p.100067
SD-40-0-2
11/13/1998
08:40
2 inches
Center of Hilliards Creek,
approximately 1,450 feet
west of Gibbsboro-
Clementon Road
28,p.100067
SD-39-0-2
11/12/1998
08:25
2 inches
Center of Hilliards Creek,
approximately 1,500 feet
west of Gibbsboro-
Clementon Road
28,p. 100065
SD-3 8-0-2
11/12/1998
14:40
2 inches
Center of Hilliards Creek,
approximately 1,550 feet
west of Gibbsboro-
Clementon Road
28,p.100065
SD-37-0-2
11/13/1998
14:21
2 inches
Center of Hilliards Creek,
approximately 1,600 feet
west of Gibbsboro-
Clementon Road
28,p.100066
SD-36-0-2
11/13/1998
13:54
2 inches
Center of Hilliards Creek,
approximately 1,650 feet
west of Gibbsboro-
Clementon Road
28,p. 100066
124
-------
SWOF - Observed Release
TABLE 15 (Continued)
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-35-0-2
11/13/1998
13:25
2 inches
Center of Hilliards Creek,
approximately 1,700 feet
west of Gibbsboro-
Clementon Road
28,p.100086
SD-35-1-1.5
11/13/1998
13:33
1 to 1.5 feet
Center of Hilliards Creek,
approximately 1,700 feet
west of Gibbsboro-
Clementon Road
28,p. 100066
SD-34-0-2
11/13/1998
10:55
2 inches
Center of Hilliards Creek,
approximately 1,750 feet
west of Gibbsboro-
Clementon Road
28,p.100086
SD-34-1-1.5
11/13/1998
11:00
1 to 1.5 feet
Center of Hilliards Creek,
approximately 1,750 feet
west of Gibbsboro-
Clementon Road
28,p.100086
SD-33-0-2
11/13/1998
10:38
2 inches
Center of Hilliards Creek,
approximately 1,800 feet
west of Gibbsboro-
Clementon Road
28,p.100086
SD-32-0-2
11/12/1998
10:00
2 inches
Center of Hilliards Creek,
approximately 1,850 feet
west of Gibbsboro-
Clementon Road
28,p.100064
SD-31-0-2
11/12/1998
09:35
2 inches
Center of Hilliards Creek,
approximately 1,900 feet
west of Gibbsboro-
Clementon Road
28,p.100064
SD-30-0-2
11/12/1998
09:15
2 inches
Center of Hilliards Creek,
approximately 1,950 feet
west of Gibbsboro-
Clementon Road
28,p.100063
125
-------
SWOF - Observed Release
TABLE 15 (Continued)
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-29-0-2
11/12/1998
08:40
2 inches
Center of Hilliards Creek,
approximately 2,000 feet
west of Gibbsboro-
Clementon Road
28,p.100063
SD-29-1-1.5
11/12/1998
08:43
1 to 1.5 feet
Center of Hilliards Creek,
approximately 2,000 feet
west of Gibbsboro-
Clementon Road
28,p. 100063
SD-27-0-2
11/11/1998
16:30
2 inches
Center of Hilliards Creek,
approximately 1,350 feet
east of Hilliards Road
28,p.100061
SD-26-0-2
11/11/1998
15:48
2 inches
Center of Hilliards Creek,
approximately 1,300 feet
east of Hilliards Road
28,p.100061
SD-25-0-2
11/11/1998
14:30
2 inches
Center of Hilliards Creek,
approximately 1,250 feet
east of Hilliards Road
28,p. 100061
SD-24-0-2
11/11/1998
13:25
2 inches
Center of Hilliards Creek,
approximately 1,200 feet
east of Hilliards Road
28,p.100061
SD-23-0-2
11/10/1998
14:40
2 inches
Center of Hilliards Creek,
approximately 1,150 feet
east of Hilliards Road
28,p.100060
SD-22-1-1.5
11/11/1998
11:48
1 to 1.5 feet
Center of Hilliards Creek,
approximately 1,100 feet
east of Hilliards Road
28,p.100059
SD-21-0-2
11/11/1998
11:20
2 inches
Center of Hilliards Creek,
approximately 1,050 feet
east of Hilliards Road
28,p.100059
SD-20-0-2
11/11/1998
11:00
2 inches
Center of Hilliards Creek,
approximately 1,000 feet
east of Hilliards Road
28,p.100058
126
-------
SWOF - Observed Release
TABLE 15 (Continued)
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-20-1-1.5
11/11/1998
11:10
1 to 1.5 feet
Center of Hilliards Creek,
approximately 1,000 feet
east of Hilliards Road
28,p.100058
SD-19-0-2
11/11/1998
10:45
2 inches
Center of Hilliards Creek,
approximately 950 feet
east of Hilliards Road
28,p.100058
SD-19-1-1.5
11/11/1998
10:50
1 to 1.5 feet
Center of Hilliards Creek,
approximately 950 feet
east of Hilliards Road
28,p.100058
SD-18-0-2
11/11/1998
09:45
2 inches
Center of Hilliards Creek,
approximately 900 feet
east of Hilliards Road
28,p.100058
SD-16-0-2
11/11/1998
09:15
2 inches
Center of Hilliards Creek,
approximately 800 feet
east of Hilliards Road
28, p. 100057
SD-16-1-1.5
11/11/1998
09:19
1 to 1.5 feet
Center of Hilliards Creek,
approximately 800 feet
east of Hilliards Road
28, p. 100057
SD-15-0-2
11/11/1998
09:15
2 inches
Center of Hilliards Creek,
approximately 750 feet
east of Hilliards Road
28,p.100057
SD-14-0-2
11/11/1998
09:10
2 inches
Center of Hilliards Creek,
approximately 700 feet
east of Hilliards Road
28,p.100056
SD-14-1-1.5
11/11/1998
09:00
1 to 1.5 feet
Center of Hilliards Creek,
approximately 700 feet
east of Hilliards Road
28,p.100056
SD-13-0-2
11/11/1998
08:45
2 inches
Center of Hilliards Creek,
approximately 650 feet
east of Hilliards Road
28,p. 100056
127
-------
SWOF - Observed Release
TABLE 15 (Continued)
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-13-1-1.5
11/11/1998
08:47
1 to 1.5 feet
Center of Hilliards Creek,
approximately 650 feet
east of Hilliards Road
28, p. 100056
SD-12-0-2
11/11/1998
15:00
2 inches
Center of Hilliards Creek,
approximately 600 feet
east of Hilliards Road
28, p. 100055
SD-12-1-1.5
11/11/1998
15:30
1 to 1.5 feet
Center of Hilliards Creek,
approximately 600 feet
east of Hilliards Road
28,p. 100055
SD-11-0-2
11/11/1998
14:30
2 inches
Center of Hilliards Creek,
approximately 550 feet
east of Hilliards Road
28,p.100054
SD-10-0-2
11/11/1998
14:20
2 inches
Center of Hilliards Creek,
approximately 500 feet
east of Hilliards Road
28,p.100054
SD-09-0-2
11/11/1998
13:30
2 inches
Center of Hilliards Creek,
approximately 450 feet
east of Hilliards Road
28,p.100054
SD-08-0-2
11/10/1998
13:00
2 inches
Center of Hilliards Creek,
approximately 400 feet
east of Hilliards Road
28, p. 100053
SD-08-1-1.5
11/10/1998
13:04
1 to 1.5 feet
Center of Hilliards Creek,
approximately 400 feet
east of Hilliards Road
28, p. 100053
SD-07-0-2
11/10/1998
11:45
2 inches
Center of Hilliards Creek,
approximately 350 feet
east of Hilliards Road
28,p. 100053
SD-07-1-1.5
11/10/1998
11:47
1 to 1.5 feet
Center of Hilliards Creek,
approximately 350 feet
east of Hilliards Road
28,p.100053
128
-------
SWOF - Observed Release
TABLE 15 (Continued)
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Sample ID
Date
Time
Depth
(bgs)
Sampling Location
Reference
SD-06-0-2
11/10/1998
11:30
2 inches
Center of Hilliards Creek,
approximately 300 feet
east of Hilliards Road
28, p. 100052
SD-05-0-2
11/10/1998
11:08
2 inches
Center of Hilliards Creek,
approximately 250 feet
east of Hilliards Road
28,p.100052
SD-05-1-1.5
11/10/1998
11:10
1 to 1.5 feet
Center of Hilliards Creek,
approximately 250 feet
east of Hilliards Road
28,p. 100052
SD-04-0-2
11/10/1998
10:47
2 inches
Center of Hilliards Creek,
approximately 200 feet
east of Hilliards Road
28,p.100052
SD-03-0-2
11/10/1998
09:22
2 inches
Center of Hilliards Creek,
approximately 150 feet
east of Hilliards Road
28,p.100051
SD-03-1-1.5
11/10/1998
09:25
1 to 1.5 feet
Center of Hilliards Creek,
approximately 150 feet
east of Hilliards Road
28,p. 100052
SD-02-0-2
11/10/1998
08:54
2 inches
Center of Hilliards Creek,
approximately 100 feet
east of Hilliards Road
28,p.100051
SD-02-1-1.5
11/10/1998
08:55
1 to 1.5 feet
Center of Hilliards Creek,
approximately 100 feet
east of Hilliards Road
28,p.100051
SD-01-0-2
11/10/1998
08:00
2 inches
Center of Hilliards Creek,
approximately 50 feet east
of Hilliards Road
28,p.100051
SD-01-1-1.5
11/10/1998
08:00
1 to 1.5 feet
Center of Hilliards Creek,
approximately 50 feet east
of Hilliards Road
28,p.100051
129
-------
SWOF - Observed Release
TABLE 15 (Continued)
LOCATION OF 1998 RELEASE SEDIMENT SAMPLES
HILLIARDS CREEK
Notes:
bgs below ground surface
ID Identification
SD sediment
130
-------
SWOF - Observed Release
Release Concentrations 1998
The concentration of hazardous substances detected in Hilliards Creek sediment samples collected during
the 199 8 investigation documenting an observed release to Hilliards Creek are summarized in Table 16. All
samples were analyzed for lead using EPA Method 601 OB (Refs. 26, p. 1 andTable 1, p. 4; 28, p. 2). SQLs
are summarized in Reference 110.
TABLE 16
CONCENTRATIONS OF LEAD DETECTED IN 1998
RELEASE SEDIMENT SAMPLES
COLLECTED FROM HILLIARDS CREEK
Sample ID
Hazardous
Substance
Cone,
(mg/kg)
Percent
Moisture
SQL
(mg/kg)
Reference
SD-104-0-2
Lead
344
23.5
12.33
28, p. 24; 110, p. 1
SD-102-1-1.5
Lead
1,550
39
19.51
28, p. 24; 110, p. 1
SD-101-0-2
Lead
416
20.1
11.09
28, p. 24; 110, p. 1
SD-100-0-2
Lead
743
67.4
70.55
28, p. 23; 110, p. 1
SD-97-1-1.5
Lead
434
44.7
23.33
28, p. 23; 110, p. 1
SD-96-0-2
Lead
772
67.2
69.82
28, p. 23; 110, p. 1
SD-95-0-2
Lead
21,700
79.8
363.86
28, p. 22; 110, p. 1
SD-95-1-1.5
Lead
24,100
66
252.06
28, p. 22; 110, p. 1
SD-94-1-1.5
Lead
1,040
52.4
31.30
28, p. 22; 110, p. 1
SD-93-1-1.5
Lead
1,110
22.8
12.34
28, p. 22; 110, p. 1
SD-90-0-2
Lead
155
40.8
20.44
28, p. 21; 110, p. 1
SD-88-0-2
Lead
182
32.1
16.35
28, p. 21; 110, p. 1
SD-88-1-1.5
Lead
80,700
78.2
633.03
28, p. 21; 110, p. 1
SD-87-0-2
Lead
14,300
78
151.82
28, p. 21; 110, p. 1
SD-86-1-1.5
Lead
32,400
79.9
357.21
28, p. 21; 110, p. 1
SD-83-0-2
Lead
2,250
33.9
16.49
28, p. 20; 110, p. 1
SD-83-1-1.5
Lead
1,870
31.7
15.37
28, p. 20; 110, p. 1
SD-82-0-2
Lead
10,400
30.1
28.76
28, p. 20; 110, p. 1
131
-------
SWOF - Observed Release
TABLE 16 (Continued)
CONCENTRATIONS OF LEAD DETECTED IN 1998
RELEASE SEDIMENT SAMPLES
COLLECTED FROM HILLIARDS CREEK
Sample ID
Hazardous
Substance
Cone,
(mg/kg)
Percent
Moisture
SQL
(mg/kg)
Reference
SD-82-1-1.5
Lead
4,160
19.8
10.80
28, p. 20; 110, p. 1
SD-80-0-2
Lead
10,600
37.1
93.80
28, p. 19; 110, p. 1
SD-80-1-1.5
Lead
4,940
30.6
14.84
28, p. 19; 110, p. 1
SD-79-0-2
Lead
76.7
15.6
10.02
28, p. 19; 110, p. 1
SD-79-1-1.5
Lead
1,360
15.5
10.40
28, p. 19; 110, p. 1
SD-78-0-2
Lead
74.5
15.3
10.46
28, p. 19; 110, p. 1
SD-78-1-1.5
Lead
10,900
65.4
64.14
28, p. 19; 110, p. 1
SD-77-1-1.5
Lead
21,900
50.9
146.84
28, p. 19; 110, p. 1
SD-76-1-1.5
Lead
718
40.2
20.57
28, p. 19; 110, p. 1
SD-75-0-2
Lead
83.8
17.5
21.21
28, p. 18; 110, p. 1
SD-74-0-2
Lead
102
13
9.53
28, p. 18; 110, p. 1
SD-74-1-1.5
Lead
27,000
68.3
146.37
28, p. 18; 110, p. 1
SD-73-0-2
Lead
97.4
23
11.82
28, p. 18; 110, p. 1
SD-73-1-1.5
Lead
818
30.7
15.15
28, p. 18; 110, p. 1
SD-72-0-2
Lead
1,820
76
1,304.17
28, p. 18; 110, p. 2
SD-72-1-1.5
Lead
4,830
62.7
51.74
28, p. 18; 110, p. 2
SD-71-0-2
Lead
69.6
17.8
10.47
28, p. 18; 110, p. 2
SD-71-1-1.5
Lead
658
34.7
16.69
28, p. 18; 110, p. 2
SD-70-0-2
Lead
70,300
60.7
486.01
28, p. 17; 110, p. 2
SD-70-1-1.5
Lead
10,500
44.9
121.05
28, p. 17; 110, p. 2
SD-65-0-2
Lead
149
12.5
9.70
28, p. 16; 110, p. 2
SD-65-1-1.5
Lead
1,540
22.8
11.76
28, p. 16; 110, p. 2
132
-------
SWOF - Observed Release
TABLE 16 (Continued)
CONCENTRATIONS OF LEAD DETECTED IN 1998
RELEASE SEDIMENT SAMPLES
COLLECTED FROM HILLIARDS CREEK
Sample ID
Hazardous
Substance
Cone,
(mg/kg)
Percent
Moisture
SQL
(mg/kg)
Reference
SD-64-0-2
Lead
373
13
9.62
28, p. 16; 110, p. 2
SD-63-0-2
Lead
708
59.1
41.81
28, p. 16; 110, p. 2
SD-62-0-2
Lead
406
16.6
10.78
28, p. 16; 110, p. 2
SD-61-0-2
Lead
16,300
79.5
178.54
28, p. 16; 110, p. 2
SD-49-0-2
Lead
909
28
13.89
28, p. 13; 110, p. 2
SD-48-0-2
Lead
1,120
30.3
14.78
28, p. 13; 110, p. 2
SD-47-0-2
Lead
483
20.1
11.75
28, p 13; 110, p. 2
SD-45-0-2
Lead
1,630
41.3
20.95
28, p. 13; 110, p. 2
SD-45-1-1.5
Lead
595
65.6
61.63
28, p. 12; 110, p. 2
SD-44-0-2
Lead
911
27.3
14.03
28, p. 12; 110, p. 2
SD-44-1-1.5
Lead
1,620
44.7
24.05
28, p. 12; 110, p. 2
SD-43-0-2
Lead
377
19.4
10.89
28, p. 12; 110, p. 2
SD-43-1-1.5
Lead
2,200
38.8
18.95
28, p. 12; 110, p. 2
SD-42-0-2
Lead
5,540
30.8
15.03
28, p. 12; 110, p. 2
SD-42-1-1.5
Lead
1,120
27.8
13.45
28, p. 12; 110, p. 2
SD-41-0-2
Lead
582
26.3
7.60
28, p. 12; 110, p. 2
SD-41-1-1.5
Lead
4,490
41
9.49
28, p. 12; 110, p. 2
SD-40-0-2
Lead
5,290
67.2
17.10
28, p. 12; 110, p. 2
SD-39-0-2
Lead
18,000
59.5
444.44
28, p. 11; 110, p. 2
SD-3 8-0-2
Lead
3,800
59.9
43.89
28, p. 11; 110, p. 2
SD-37-0-2
Lead
5,190
70.5
83.73
28, p. 11; 110, p. 2
SD-36-0-2
Lead
4,690
67.7
69.66
28, p. 11; 110, p. 2
133
-------
SWOF - Observed Release
TABLE 16 (Continued)
CONCENTRATIONS OF LEAD DETECTED IN 1998
RELEASE SEDIMENT SAMPLES
COLLECTED FROM HILLIARDS CREEK
Sample ID
Hazardous
Substance
Cone,
(mg/kg)
Percent
Moisture
SQL
(mg/kg)
Reference
SD-35-0-2
Lead
5,880
76.5
134.47
28, p. 10; 110, p. 2
SD-35-1-1.5
Lead
6,080
82.8
246.51
28, p. 10; 110, p. 2
SD-34-0-2
Lead
11,200
79.2
176.96
28, p. 10; 110, p. 2
SD-34-1-1.5
Lead
72,400
72.6
959.85
28, p. 10; 110, p. 2
SD-33-0-2
Lead
21,400
80
185.50
28, p. 10; 110, p. 2
SD-32-0-2
Lead
18,000
81.8
213.74
28, p. 10; 110, p. 3
SD-31-0-2
Lead
5,190
82.3
232.20
28, p. 10; 110, p. 3
SD-30-0-2
Lead
2,040
69.3
80.46
28, p. 9; 110, p. 3
SD-29-0-2
Lead
3,240
82.5
235.43
28, p. 9; 110, p. 3
SD-29-1-1.5
Lead
396
74.8
119.44
28, p. 9; 110, p. 3
SD-27-0-2
Lead
2,290
78.3
153.00
28, p. 9; 110, p. 3
SD-26-0-2
Lead
161
20.9
7.07
28, p. 9; 110, p. 3
SD-25-0-2
Lead
1,050
60
45.50
28, p. 8; 110, p. 3
SD-24-0-2
Lead
4,490
54.9
36.59
28, p. 8; 110, p. 3
SD-23-0-2
Lead
255
37.2
18.15
28, p. 8; 110, p. 3
SD-22-1-1.5
Lead
5,670
63.3
53.95
28, p. 8; 110, p. 3
SD-21-0-2
Lead
260
16.4
10.84
28, p. 8; 110, p. 3
SD-20-0-2
Lead
39,500
83.6
2,682.93
28, p. 7; 110, p. 3
SD-20-1-1.5
Lead
993
76.8
137.93
28, p. 7; 110, p. 3
SD-19-0-2
Lead
765
38.4
18.99
28, p. 7; 110, p. 3
SD-19-1-1.5
Lead
897
47.3
26.57
28, p. 7; 110, p. 3
134
-------
SWOF - Observed Release
TABLE 16 (Continued)
CONCENTRATIONS OF LEAD DETECTED IN 1998
RELEASE SEDIMENT SAMPLES
COLLECTED FROM HILLIARDS CREEK
Sample ID
Hazardous
Substance
Cone,
(mg/kg)
Percent
Moisture
SQL
(mg/kg)
Reference
SD-18-0-2
Lead
2,230
74.2
108.53
28, p. 7; 110, p. 3
SD-16-0-2
Lead
1,540
56.1
37.13
28, p. 7; 110, p. 3
SD-16-1-1.5
Lead
2,780
68.7
72.20
28, p. 7; 110, p. 3
SD-15-0-2
Lead
266
27.1
13.57
28, p. 7; 110, p. 3
SD-14-0-2
Lead
26,800
82
231.67
28, p. 6; 110, p. 3
SD-14-1-1.5
Lead
66,800
84.1
2,798.74
28, p. 6; 110, p. 3
SD-13-0-2
Lead
964
81.2
212.23
28, p. 6; 110, p. 3
SD-13-1-1.5
Lead
5,400
83.4
260.84
28, p. 6; 110, p. 3
SD-12-0-2
Lead
6,120
69.3
78.83
28, p. 6; 110, p. 3
SD-12-1-1.5
Lead
434
56.9
40.37
28, p. 6; 110, p. 3
SD-11-0-2
Lead
241
36
17.50
28, p. 6; 110, p. 3
SD-09-0-2
Lead
385
51.3
30.80
28, p. 6; 110, p. 3
SD-08-0-2
Lead
18,100
84.8
324.34
28, p. 5; 110, p. 3
SD-08-1-1.5
Lead
2,450
77.5
148.00
28, p. 5; 110, p. 3
SD-07-0-2
Lead
9,920
84
276.25
28, p. 5; 110, p. 3
SD-07-1-1.5
Lead
3,310
80.7
197.41
28, p. 5; 110, p. 3
SD-05-0-2
Lead
78,300
89
5,900
28, p. 4; 110, p. 3
SD-05-1-1.5
Lead
59,200
89.3
6,242.99
28, p. 4; 110, p. 4
SD-04-0-2
Lead
6,780
86.1
388.49
28, p. 4; 110, p. 4
SD-03-0-2
Lead
3,640
76.3
128.27
28, p. 4; 110, p. 4
SD-03-1-1.5
Lead
1,030
59.4
43.35
28, p. 4; 110, p. 4
135
-------
SWOF - Observed Release
TABLE 16 (Continued)
CONCENTRATIONS OF LEAD DETECTED IN 1998
RELEASE SEDIMENT SAMPLES
COLLECTED FROM HILLIARDS CREEK
Sample ID
Hazardous
Substance
Cone,
(mg/kg)
Percent
Moisture
SQL
(mg/kg)
Reference
SD-02-0-2
Lead
7,660
63.3
54.50
28, p. 4; 110, p. 4
SD-02-1-1.5
Lead
8,810
71.1
87.20
28, p. 4; 110, p. 4
Notes:
Cone.
Concentration
ID
identification
mg/kg
milligram per kilogram
SD
sediment
SQL
sample quantitation limit
136
-------
SWOF - Attribution
Attribution:
The significant increase in concentrations of lead, arsenic, and SVOCs to Hilliards Creek is clearly
attributable in part to historic and ongoing releases from the activities at the Sherwin-Williams/Hilliards
Creek site. The history of the use of lead, arsenic, and SVOCs at the paint works is well documented.
Although the operations that led to the historic releases most likely terminated by the 1980s, this does not
mean the contamination documented downstream from the paint works area in Hilliards Creek did not at least
in part originate from these operations. Further, at least part of the lead, arsenic, and SVOCs in Hilliards
Creek is entering Hilliards Creek via ground water seeps flowing overland to the creek (perhaps via the
Sherwin-Williams treatment system) or by direct discharge of ground water to the creek.
Besides the historic information linking lead and arsenic to the paint works operations, these substances are
also associated with four sources evaluated at the site. In addition, numerous studies by both EPA and
Sherwin-Williams have shown continuous increased contamination of these substances in Hilliards Creek
downstream of the paint works area and the PPEs for the four site sources.
The 1998 investigation of Hilliards Creek documented the presence of lead in the sediments of Hilliards
Creek from the Lucas plant property to Gibbsboro-Clementon Road and extending to Hilliards Road at
concentrations three times the background amount, which indicated an observed release of lead to Hilliards
Creek. (Lead was the only hazardous substance analyzed for during this investigation.) This includes a
distance of approximately 4,600 feet (Ref. 26, p. 8). A 2004 Hilliards Creek investigation included the
collection of sediment samples from Hilliards Creek between Gibbsboro-Clementon Road and Hilliard Road.
The 2004 investigation documented a significant increase in lead concentrations to Hilliards Creek along this
entire section, Gibbsboro-Clementon Road to Hilliards Road.
The Lucas plant, located at the headwaters of Hilliards Creek, was used to manufacture paints that contained
lead (Refs. 9; 12; 6, Figure 2-4; 61, pp. 3, 4, 5, 6, 8, 12, 19, 22, 26,30). Surface water runoff from the Lucas
plant flowed to Hilliards Creek during the entire operational period ofthe Lucas plant (Refs. 3,4,5; 6, Figure
2-4; 18, pp. 2-2, 2-3, 3-2; 31, p. 2-9; 73, p. 2, 4). The wastewater lagoons (Source 3), used to treatand store
lead-contaminated paint sludge, also discharged to Hilliards Creek (Refs. 7, pp. 10, 11; 8, p. 3; 19, pp. 1,3;
20, pp. 1,2; 21, p. l;25,pp. 1,2; 41, p. 11). Lead was used extensively at the Lucas plant (Refs. 13, p. 3;
31, p. 2-3; 60, pp. 6, 8,10,12,22,26). The presence of lead within Hilliards Creek extending from the Lucas
plant to Hilliards Road indicates that over time, from operations at the Lucas plant, lead has accumulated in
the sediments of Hilliards Creek and its flood plain.
The 2004 Hilliards Creek investigation also documented a significant increase in arsenic concentrations to
Hilliards Creek from Gibbsboro-Clementon Road to Hilliard Road. As documented in source section of this
HRS documentation record, arsenic was detected in source samples at concentrations exceeding three times
background. Arsenic is a common constituent in paint and a constituent of Paris green, a pigment
manufactured at the Lucas plant (Refs. 12; 99, p. 1; 100, p. 1; 101, p. 2). Arsenic is also used in paint for
the bottom of ships as was manufactured at the Lucas plant (Refs. 13, p. 10; 99, p. 3). As documented in the
sections below, no other significant source of arsenic, other than the disposal areas used by Lucas plant, are
located within the Hilliards Creek watershed.
Similarly SV OCs are associated with all four of the site sources, being found in soil samples and free product
samples as discussed earlier in the source sections of this document.
137
-------
SWOF - Attribution
The five sections below provide further information related to the attribution of arsenic and lead (as well as
the SVOCs found in the observed releases by direct observation) in Hilliards Creek to the Lucas plant.
The first section provides information on the land use surrounding Hilliards Creek. This section contains
both historical and recent information showing that the paint works area has been a main source of
contamination to the creek. It also discusses other facilities and other proposed and final NPL sites in the
watershed that might have contributed lead or arsenic to Hilliards Creek. However, releases from these
facilities would negate that part of the significant increase in contaminant concentrations at least in part is
due to the releases from the sources.
The second section describes investigations that have been conducted in Hilliards Creek to determine
whether the paint works area released hazardous substances to the creek. Besides the analytical data from
the most recent investigations used to document an observed release to surface water from the paint works
area by chemical analysis, a summary of previous investigations is provided in the section below to provide
additional documentation of releases to Hilliards Creek. These studies show that the lead and arsenic
concentrations are significantly higher below the PPEs for this site and the contamination appears to be
continuous from these PPEs downstream to Kirkwood Lake.
The third section describes documentation of historic releases from site activities to Hilliards Creek that have
been observed over time. It clearly supports that the paint works area is historically a source of lead and
arsenic releases.
The fourth section describes operations at the paint works area that may have released arsenic, lead, and
SVOCs to Hilliards Creek and Hilliards Creek wetlands.
The fifth section describes ground water releases directly to surface water.
Land Use Surrounding Hilliards Creek
Historical aerial photography indicates that, west of Gibbsboro-Clementon Road, land use along the course
of Hilliards Creek has changed over time. Historically, properties along that portion of the creek were used
for farming, but were gradually abandoned and either subdivided for residential development or were
acquired by the Borough of Gibbsboro under the Green Acres program. To the East of Gibbsboro-Clementon
Road, Hilliard Creek is bordered by a cemetery, Lucas plant, and residential properties (Refs. 3; 4; 5; 6, p.
2-11).
The 1964 insurance map of the Lucas plant identified Hilliards Creek as a drainage ditch located between
ASTs and a garage with a gasoline storage tank and pump. The map shows that Building 67 located east of
Hilliards Creek was used as a warehouse, with a railroad and tanker truck solvent unloading station at its
northern side and a sewage treatment plant and drum storage area to its southern side. This same map also
shows the Lucas plant former wastewater lagoon located directly south of Building 67 and east of Hilliards
Creek (Refs. 5; 6, p. 2-13).
The 1947 site map shows drainage from the above ground solvent storage tanks flowing in an eastern
direction into Hilliards Creek. The maps indicated that the ground slopes to a small brook (Hilliards Creek).
The map indicates a flood occurred in September 1940 that broke a dam wall and caused water to enter parts
of the building to a depth of 4 to 5 feet (Refs. 3; 6, p. 2-12).
138
-------
SWOF - Attribution
A historical report about Gibbsboro New Jersey provides historic information related to the land-use
surrounding Hilliards Creek. In the 1800s, Gibbsboro was used mainly for farming (Ref. 17, p. D4) and a
grist mill operated on Hilliards Creek (Refs. 17, pp. D7, D16; 60, p. 15). The Lucas plant began operating
in the mid-1800s and houses were constructed in the area around Hilliards Creek (Ref. 17, pp. D10, D16).
A railroad provided transportation of goods (Ref. 17, p. Dll). The only manufacturing conducted in
Gibbsboro in 1906 was done by the Lucas plant (Ref. 17, p. D-18). In 1924, Gibbsboro was a self-contained
community of workers who for the most part were engaged in the production of Lucas Paint and Varnish
Products (Ref. 17,p.D-18). Inl931 the Labrusca Vineyard and a concrete block manufacturer were located
in Gibbsboro (Ref. 17, p. D-20). In 1960, the Labrusca Vineyards closed and 500 homes were constructed
on the 100-acre parcel (Ref. 17, p. D-20). The Lucas plant was the major industry in Gibbsboro, New Jersey,
from the 1800s to 1970s (Ref. 60, p. 6).
The date at which lead was no longer used at the Lucas plant has not been determined. During the 1940s and
1950s, paint manufacturers essentially discontinued the use oflead pigments in consumerpaints and in 1954,
a voluntary standard to remove lead pigment from consumer paints, was developed by the American
Standards Association (Ref. 106). The lead contamination in Hilliards Creek is expected to have moved
downstream from the plant, since the lead discharges from the plant ceased over 50 years ago. Additionally,
discharge from the former lagoons (Source 3) containing lead-contaminated wastewater ceased in 1977, over
28 years ago (Ref. 31, p. 2-5). The concentrations oflead detected in Hilliards Creek, as documented earlier
in this section, also indicate that the lead contamination from the Lucas plant has migrated downstream. For
example, at sampling location HC-SD-45, lead was detected up to 5,220 mg/kg (Refs. 86, p. 17; 88, p. 2).
The sampling location is about 6,600 feet downstream from PPE-4, the most upstream PPE (Ref. 97).
West of the site, on Kirkwood Lake, an ice harvesting company and gristmill operated in the early 1900s
(Refs 9; 49, p. 2-1).
Other Possible Facilities and Off-Site Sources
A gun club is located on Bridgewood Lake (43, p. C-2-5). Bridgewood Lake flows to Hilliards Creek (Ref.
9). The gun club is a potential source oflead contamination from lead bullets. Releases from the gun club
would not be a source of arsenic.
Academy Paints and Scotko Sign and Display, Inc. are facilities listed as RCRA facilities and are generators
of hazardous waste (Refs. 31, p. 2-6; 59, Appendix n, p. 1110 ). Both are tenants of the industrial park that
replaced the Paint Works facility (Refs. 31, p. 2-6; 56, Appendix 119). Scotko Sign and Display, Inc.
occupied Building 56 (Ref. 31, p. 2-7). Academy Paints manufactured paint (latex and oil based) from 1982
to 1989 in Building 67 (Refs. 67, p. 1; 31, p. 2-6). Academy Paints used the following materials: toluidine,
ammonia 260, driers (solvents), ethylene glycol, flammable liquids, naphtha, paint, potassium chlorate, resin
solution, mineral spirits, xylene, and ethylbenzene (Refs. 33, p. 9; 67, pp. 7, 8;). Two 5,000-gallon ASTs
were located north of the Academy Works building, which stored solvents, alkyl resins, and mineral spirits.
Fifty-five-gallon drums were located on the back of the building on a concrete pad as well as directly on the
ground (Ref. 59, Appendix n, 1110).
Several commercial and industrial operations are present in the immediate vicinity of the plant. A former
gasoline service station, previously leased to CITGO and the Sun Oil Company, was located directly
northeast of the intersection of Foster Avenue and US Avenue, east of the Lucas plant, within 120 feet of
Building 55 (Ref. 31, p. 2-17 and Figure 3-2).
139
-------
SWOF - Attribution
The former General Electric (GE) Company Aerospace Government Electronic Systems facility is located
immediately to the north of the facility, at the intersection of Route 561 and US Avenue. When it was in
operation, the facility was listed on the Toxic Release Inventory (TRI) as releasing to the air and disposing
of 1,1,1 -trichloroethane off site.
Additionally, numerous RCRA facilities are located in Gibbsboro but are not associated with significant
releases of lead or arsenic (Ref. 31, p. 2-17).
Hazardous wastes sites identified within 1 mile of the Hilliards Creek site include the Shell gasoline service
station and the Buzby landfill (Ref. 59, Appendix n, p. 118).
The concentrations of lead in Hilliards Creek may be partially attributable to surface runoff from nearby
roads and parking lots and the former use of leaded fuels (Ref. 59, Appendix II, 1156).
Land uses in the area of Hilliards Creek that may have contributed to the PAH contamination in Hilliards
include wood burning, exhaust from automobiles and trucks, and runoff from asphalt roads (Refs. 9; 105,
pp. 2, 3, 4).
If during further investigation releases from these above mentioned facilities or sources are found to be
contributing significant contamination to Hilliards Creek, appropriate actions will be undertaken and, if
appropriate, will be included as part of this site. However, they are not thought to be ongoing sources of lead
or arsenic.
NPL and Proposed NPL Sites
Two hazardous waste sites are located a short distance from the Lucas plant, Route 561 Dump Site, and the
US Avenue Burn Site (Ref. 41, p. 6). The US Avenue Burn Site is listed on the NPL and the Route 561
Dump Site has been proposed for listing on the NPL (Refs. 44, p. 1; 45, p. 2). The sites are described below.
Locations of the sites are shown on Figure 2-1 of Reference 6.
US Avenue Burn Site
The US Avenue Burn site, a site listed on the NPL, was used and owned for waste management by the Lucas
plant. The site was used for the disposal of wastes generated solely by the Lucas plant. The site is located
approximately 500 feet southeast of Building 67 on the Lucas plant property on vacant land east of
BridgewoodLake in Gibbsboro, New Jersey. The site includes, but is not limitedto, three sources: the Burn
Area, the Burn Landfill, and the Railroad Track. The Burn Area portion of the site was previously used for
disposal and burning of paint wastes from the Lucas plant. The Burn Landfill portion of the site was used
for the disposal of sludge from the Lucas plant's wastewater treatment system. The Railroad Track portion
of the site was used to transport materials to and from the Lucas plant (Refs. 45, pp. 1, 2; 6, p. 2-6, Figure
2-1).
Hazardous substances detected in samples from the Landfill Area included barium, cadmium, lead, and zinc
(Ref. 61, pp. 7, 8). Analytical results for soil samples from the Burn Area indicated antimony, arsenic,
barium, cadmium, total chromium, copper, lead, and zinc (Ref. 61, p. 9). Contaminated soil is associated
with the Railroad Track portion of the US Avenue Burn site. Hazardous substances detected in the soil
include arsenic, barium, chromium, and lead (Ref. 61, p. 7).
140
-------
SWOF - Attribution
White Sand Branch and Haney Run Brooke flow across the US Avenue Burn site into Bridgewood Lake,
which discharges into Hilliards Creek downstream of the Lucas plant (Refs. 97; 6, Figure 2-1). The Burn
Area source of the US Avenue Burn site is located in a wetland of White Sand Branch. The wetland is
contaminated (Ref. 61, pp. 3, 6). During the investigations conducted at the site, the field crew observed
the presence of discolored soils (green) along a section of the railroad track used to transport materials (Ref.
59, Appendix Z, p. Zl, Appendix FF, p. FF1).
Route 561 Dump Site
The Route 561 Dump Site, a site proposed for listing on the NPL, is located approximately 1,000 feet
northeast of Building 55 on the Lucas plant property on a vacant parcel located on Route 561 near
Milford/Kresson Road in Gibbsboro, New Jersey. The site was previously owned and used by the Lucas
plant as a paint waste disposal area (Refs. 44, p. 1; 61, 3; 9; 6, p. 2-9). The Route 561 Dump site released
paint wastes, arsenic, and lead into White Sand Branch, which eventually discharges into Bridgewood Lake
(Refs. 9; 59, pp. 10, 11, 13, 17). White Sand Branch flows south through the Route 561 Dump Site and
leaves the site through a culvert under Route 561 and continues southwest to Bridgewood Lake.
Bridgewood Lake flows into an unnamed tributary that converges with Hilliards Creek downstream of the
Lucas plant (Refs. 44, p. 1; 61, 3; 9; 6, p. 2-9). Analytical results for soil samples collected from the dump
site indicated the presence of arsenic, barium, cadmium, and lead. Arsenic and lead were also detected in
sediment samples from White Sand Branch (Ref. 61, pp. 6, 7).
Investigations of Hilliards Creek
This section describes investigations conducted of Hilliards Creekthat were not used in the observed release
to surface water section of this HRS documentation record.
Investigations of Hilliards Creek 1983 to 1991
On February 7, 1985, NJDEP personnel sampled Hilliards Creek and a seep (Source 1) discharging into
Hilliards Creek (Ref. 32, p. 5). Analytical results for creek samples indicated the presence of benzene,
ethylbenzene, 1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene, xylenes, and toluene (Ref. 32, p. 6).
In March 1987, NJDEP collected surface water samples from Hilliards Creek at the point where a seep
(Source 1) discharged into the creek and upstream and downstream of the seep. The upstream surface water
sample contained less then 5 micrograms per liter (fxg/L) of lead and the surface water sample collected at
the seep contained 450 (xg/L of lead (Refs. 62, pp. 16, 63; 64, p. 10).
In 1991, two sediment samples were collected from Hilliards Creek near the seep, Source 1. Analytical
results for the samples indicated the presence of numerous SVOCs (Ref. 59, Appendix II, 113 8).
Remedial Investigations - Hilliards Creek
From August 1991 through January 1992, during a Phase I RI for the Lucas plant (Ref. 31, p. 3-3), three
sediment samples (001-SD01, 002-SD01, and 003-SD01) were collected from Hilliards Creek. No
background sediment sample was collected in Hilliards Creek. Analytical results for the sediment samples
indicated the presence of numerous SVOCs including acenaphthene, acenaphthylene, anthracene,
benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, carbazole, chrysene, di-n-octyl phthalate,
dibenzo(a,h)anthracene,dibenzofuran,fluoranthene, fluorene,indeno(l,2,3-cd)pyrene, pentachlorophenol,
141
-------
SWOF - Attribution
phenanthrene, and pyrene. Numerous metals were also detected in the sediment samples (Ref. 31, Table 4-
16). However, since metals are naturally occurring and no background sediment sample was collected, the
significance of the metal concentrations can not be determined.
Three surface water samples (001-SW01, 002-SW01, and 003-SW01) were collected from Hilliards Creek
during the Phase IRI. A background surface water sample (004-S WO 1) was collected from the northeastern-
most point of Silver Lake, upgradient of sources on the Lucas plant property to provide data representing
background conditions (Ref. 31, pp. 3 -3, 3 -12,3 -17). Hazardous substances detected in the Hilliards Creek
surface water samples at concentrations greater than three times the background concentration (with the
consideration of data qualifiers) or above the detection limit if not detected in the background sample include
benzene, xylene, phenols, aluminum, arsenic, chromium, copper, lead, magnesium, manganese, vanadium,
and zinc (Refs. 31, Table 5-8; 81).
From September 1996 through January 1997, during Phase IV of the RI, one sediment sample (SD-09) was
collected in Hilliards Creek immediately adjacent to the former pump house, at Source 2 (Ref. 31, pp. 3-3,
3-26). The sediment sample contained the highest concentrations of poly chlorinated aromatic hydrocarbons
(PAHs), ranging from 1.7 to 31 mg/kg, of all the sediment samples collected during RI activities. These
results indicate that the contaminated soil associated with the pump house has released PAHs to Hilliards
Creek (Ref. 31, pp. 5-13, 6-8, Table 4-16).
November 1998 Soil and Sediment Investigation Hilliards Creek
In 1998, lead contamination in Hilliards Creek was identified when sediment samples were collected from
the creek to establish reference (background) concentrations. One of the sediment samples collected from
the creek contained 221,900 ppm of lead. That sample was collected adjacent to a trail in the Hilliards Creek
Wildlife Refuge (Ref. 54, pp. 1, 5). To determine the source of the lead contamination, numerous
investigations were conducted by EPA.
As documented in the Observed Release Section of this HRS documentation record, in December 1998,676
sediment samples, 42 soil samples, three waste samples, and eight aqueous samples were collected from
Hilliards Creek and tributaries to Hilliards Creek. Blue-stained material, believed to be paint, was observed
in the sediments of Hilliards Creek and in soil adjacent to the creek (Ref. 26, Table 1, p. 5). The report
documenting the November 1998 sampling event, concluded that significant concentrations of lead were in
the sediments of Hilliards Creek and its tributaries, and in the soil surrounding the creek (Ref. 26, p. 6). One
of the samples collected from the bank of the creek, which was noted as containing blue-stained material
(believed to be paint), contained Resource Conservation and Recovery Act (RCRA) hazardous concentrations
of lead (greater than 5 milligrams per liter) (Refs. 26, Table 1, pp. 5, 6; 27, p. 12). The NJDEP residential
direct contact soil cleanup criteria (RDCSCC) of 400 ppm was exceeded in 437 of the sediment and soil
samples (Ref. 26, p. 6). The concentrations of lead in the shallow and deep sediment samples did not vary
significantly. The highest concentrations of lead were detected in sediments collected from the portion of
Hilliards Creek within the property boundaries of Hilliards Creek Wildlife Refuge (Ref. 26, p. 7). Hilliards
Creek Wildlife Refuge is located on the west side of Gibbsboro-Clementon Road, approximately 1,200 feet
southwest of the Lucas plant (Ref. 97). During the investigation, analysts identified lead contamination in
Hilliards Creek extending from Hilliards Road upstream to a distance of 4,600 feet (Ref. 26, p. 8).
During the November 1998 investigation, a sediment sample was collected from Hilliards Creek containing
blue material or paint, and was analyzed for TAL metals. The following metals were detected in the
sediment sample: aluminum(l l,700ppm), arsenic (l,280ppm), chromium (29,300ppm), iron(47,300ppm),
142
-------
SWOF - Attribution
lead (68,000 ppm), and zinc (8,830 ppm). Analytical results forthe sample (W-l) containing blue material
collected from the hank of Hilliards Creek indicated aluminum (12,400 ppm), arsenic (759 ppm), barium
(2,870 ppm), chromium (38,500 ppm), and lead (65,000 ppm) (Refs. 26, p. 7 and Table 1, p, 5; 27, p. 11).
Two other samples containing blue-green stained material were collected from the flood plain of Hilliards
Creek downstream of the Lucas plant. These samples contained barium (up to 14,400 ppm), lead (up to
1,090 ppm), magnesium (up to 7,340 ppm), and mercury (up to 17.8 ppm) (Refs. 26, pp. 5, 7, 8; 27, p. 11,
Figure 2).
1999 Soil Investigation Hilliards Creek
In June 28,1999,155 soil samples were collected to define the extent of lead in the soil adjacent to Hilliards
Creek. The samples were analyzed on site using X-ray Fluorescence (XRF). Sixteen samples were analyzed
for TAL metals (Ref. 29, p. 2). Lead was detected in silt-rich soils in Hilliards Creek flood plain. Lead
concentrations decreased to a nondetectable level in areas up slope from the flood plain. The highest lead
concentrations were detected in samples containing blue-green clayey material (Ref. 29, p. 3).
1999 Health Consultation Hilliards Creek
In 1999, the Agency for Toxic Substances and Disease Registry (ATSDR) completed a health consultation
for Hilliards Creek. ATSDR evaluated the analytical data collected in 1998 where lead was detected at
221,900 ppm in a sediment sample collected in the Hilliards Creek Wildlife Refuge. ATSDR concluded that
an urgent health hazard exists to children and adults who use the refuge. The area where the sediment sample
was collected was expected to be visited frequently because a trail in the refuge brought visitors to the
sampling location (Ref. 55, pp 4, 8).
1999 Administrative Order of Consent Hilliards Creek
On September 30,1999, the EPA Region 2, Regional Administrator and Sherwin-Williams signed an AOC
for a removal action that required Sherwin-Williams to delineate the extent of contamination at accessible
areas along Hilliards Creek; prevent direct contact with the contamination by use of engineering controls in
accessible areas; obtain access; post signs where appropriate; and conduct site inspections on a quarterly
basis (Refs. 49, P. 1-1; 50, pp. 1-1, 1-2; 51, pp. 1, 2, 22, 23). The removal action under the AOC also
included sampling of Hilliards Creek and residential properties near Hilliards Creek to delineate the extent
of lead-contaminated soil and the installation of a fence around lead-contaminated soil adjacent to Hilliards
Creek (Ref. 51, pp. 9 through 14).
Between December 1999 and January 2000, sediment and soil samples were collected from 16 transects (T1
throughT15 andT17) across Hilliards Creek between Gibbsboro-Clementon Road and Hilliards Road. The
transects were spaced approximately 200 feet apart. Samples were collected at approximately 30-foot
intervals along each transect from each bank of Hilliards Creek and from the center of Hilliards Creek. The
surface soil samples collected from the banks of Hilliards Creek were collected from within the 100-year
flood plain of Hilliards Creek. The flood plain samples were collected to determine whether periodic
flooding transported contaminated sediments from Hilliards Creek to the flood plain of Hilliards Creek.
Additional samples were collected as needed to complete the horizontal and vertical delineation of lead
contamination, including four soil boring samples at various depths from the southern berm of the manmade
pond located off of Gibbsboro-Clementon Road (Ref. 51, pp. 5, 8).
143
-------
SWOF - Attribution
All samples were analyzed for lead (Ref. 51, p. 5). Approximately 25 percent of all samples were analyzed
for TAL metals plus cyanide, five percent for TCLP metals (including copper and zinc), and five percent for
TCLP VOC and BNA analyses. All sediment samples collected during the initial round of sampling were
submitted for pH, TOC, and grain size analyses (Ref. 51, p. 6). All samples were collected in accordance
with the November 1999 Work Plan for the Hilliards Creek Site, Gibbsboro, New Jersey and the December
1999 Work Plan Addendum (Refs. 51, p. 4; 68, 69).
No sediment sample designated to be background for all of Hilliards Creek was collected. However, a
transect (T17) was placed across Nicholson Branch, a tributary of Hilliards Creek. The transect included
the collection of surface and subsurface soil and sediment samples from the two flood plain banks and the
center of Nicholson Branch (Ref. 51, pp. 5, 8, and Figure 4). Nicholson Branch is similar in size to Hilliards
Creek, located within the same drainage area, and has similar soil/sediment types (Refs. 31, pp. 2-7 through
2-10; 6, Figure 2-7). The samples collected from transect 17 in Nicholson Branch are used to establish
background lead levels in sediment located within Hilliards Creek. A summary of analytical results for
sediment samples indicating concentrations of lead above three times the background concentration is
provided in the Tables 17 and 18. The background samples were analyzed for lead only (Ref. 51, Table 4c,
p. 14, Figure 4). Therefore, lead is the only metal evaluated.
144
-------
SWOF - Attribution
TABLE 17
INORGANIC DATA SUMMARY - HILLIARDS CREEK
SEDIMENT SAMPLES (0.0 TO 0.5 foot bgs)
1999 SHERWIN-WILLIAMS INVESTIGATION
Location ID
T17C
T01C
T02C
T03C
T03C2
T04C
T05C
T05C2
T08C
T09C
Field Sample
SS-T17C-
SS-T01C-
SS-T02C-
SD-T03C-
SD-T03C2-
SD-T04C-
SD-T05C-
SD-T05C2-
SD-T08C-
SD-T09C-0.0-
ID
0.0-005
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.0-0.5
0.5
Date Collected
12/13/1999
12/03/199
12/3/1999
12/2/1999
12/2/1999
12/2/1999
12/2/1999
12/3/1999
12/8/1999
12/09/199
Sample Type
Background
Release
Release
Release
Release
Release
Release
Release
Release
Release
Location
Nicholson
Hilliards
Hilliards
Hilliards
Hilliards
Hilliards
Hilliards
Hilliards
Hilliards
North of the
Branch
Creek -
Creek -
Creek
Creek
Creek
Creek
Creek - 700
Creek -
location where
West of
100 feet
wetland -
wetland -
wetland -
wetland -
feet west of
1,200 feet
Hilliards
Hilliard
west of
700 feet
700 feet
800 feet
825 feet
Hilliard
west of
Creek
Road
Hilliard
west of
west of
west of
west of
Road
Hilliard
discharges into
Road
Hilliard
Hilliard
Hilliard
Hilliard
Road
Kirkwood
Road
Road
Road
Road
Lake
Reference
51, Table
51, Table
51, Tables
51, Table
51, Table 4-
51, Table
51, Table
51, Table 4-
51, Table
51, Table 4-f,
4-c, p. 14,
4-f, p. 1,
4-f, p. 5,
4-f, p. 6,
f, p. 6,
4-f, p. 6,
4-f, p. 7,
f, p. 7,
4-f, p. 9,
p. 10, Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Figure 4
Lead (mu/ku)
2.9
194
206
1.970
502
3.350
106
6.270
2.150
266
145
-------
SWOF - Attribution
TABLE 17 (Continued)
INORGANIC DATA SUMMARY - HILLIARDS CREEK
SEDIMENT SAMPLES (0.0 to 5.0 foot bgs)
1999 SHERWIN-WILLIAMS INVESTIGATION
Location ID
T17C
T10C
T11C
T12C
T13C
T14C
T15C
Field Sample
ID
SS-T17C-0.0-0.5
SD-TlOC-0.0-0.5
SD-T1 lC-0.0-0.5
SD-T12C-0.0-0.5
SD-T13C-0.0-0.5
SD-T14C-0.0-0.5
SD-T15C-0.0-0.5
Date Collected
12/13/1999
12/9/1999
12/9/1999
12/9/1999
12/9/1999
12/9/1999
12/9/1999
Sample Type
Background
Release
Release
Release
Release
Release
Release
Location
Nicholson
Branch
Where Hilliards
Creek discharges
into Kirkwood
Lake
Kirkwood Lake,
200 feet west of
the dam
Kirkwood Lake,
300 feet west of
the dam
Kirkwood Lake,
400 feet west of
the dam
Kirkwood Lake,
600 feet west of
the dam
Hilliards Creek
wetland, 200 feet
southeast of the
Kirkwood dam
Reference
51, Table 4-c,
p. 14, Figure 4
51, Table 4-f,
p. 10, Figure 4
51, Table 4-f,
p. 11, Figure 4
51, Table 4-f,
p. 11, Figure 4
51, Table 4-f,
p. 12, Figure 4
51, Table 4-f,
p. 13, Figure 4
51, Table 4-f,
p. 13, Figure 4
Lead (miz/kiz)
2.9
1.530
788
906
210
854
32
Notes:
bgs
Below ground surface
C
Center
ID
Identification
mg/kg
Milligram per kilogram
SD
Sediment
SS
Soil Sample
T
Transect
146
-------
SWOF - Attribution
TABLE 18
INORGANIC DATA SUMMARY - HILLIARDS CREEK
SEDIMENT SAMPLES (1.5 to 2.0 feet bgs)
1999 SHERWIN-WILLIAMS INVESTIGATION
Location ID
T17C
T02C
T03C
T03C2
T07C
T09C
T11C
T12C
T13C
T14C
Field Sample
SS-T17C-
SS-T02C-
SD-T03C-
SD-T03C2-
SD-T07C-
SD-T09C-1.5-
SD-T11C-
SSD-T12C-
SSD-T13C-
SD-T14C-
ID
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
2.0
1.5-2.0
1.5-2.0
1.5-2.0
1.5-2.0
Date
12/13/1999
12/3/1999
12/2/1999
12/2/1999
12/8/1999
12/09/199
12/17/1999
12/9/1999
12/9/1999
12/9/1999
Collected
Sample Type
Background
Release
Release
Release
Release
Release
Release
Release
Release
Release
Location
Nicholson
Hilliards
Hilliards
Hilliards
Hilliards
North of the
Kirkwood
Kirkwood
Kirkwood
Kirkwood
Branch
Creek -
Creek
Creek
Creek
location where
Lake, 200
Lake, 300 ft
Lake, 400 ft
Lake, 600 ft
100 ft
wetland -
wetland -
wetland -
Hilliards Creek
ft west of
west of the
west of the
west of the
west of
700 ft west
800 ft west
1,000 ft west
discharges into
the dam
dam
dam
dam
Hilliards
of Hilliards
of Hilliards
of Hilliards
Kirkwood
Road
Road
Road
Road
Lake
Reference
51, Table
51, Table
51, Table
51, Table
51, Table
51, Table 4-c,
51, Table
51, Table
51, Table
51, Table
4-c, p. 14
4-c, p. 5
4-c,p. 6
4-c, p. 6
4-c,p. 8
p. 10
4-c, p. 11
4-c, p. 11
4-c, p. 12
4-c, p. 13
Lead (mu/ku)
3.7
144
519
289
112
39.3
69.8
30.4
641
116
Notes:
bgs Below ground surface
C Center
ft Foot
ID Identification
mg/kg Milligram per kilogram
SD Sediment
SS Soil Sample
T Transect
147
-------
SWOF - Attribution
Ten surface water samples also were collected from nine sampling locations where lead was detected at
elevated concentrations as compared to background (Ref. 51, p. 6, Figure 5). The samples were analyzed
for TAL metals (filtered and unfiltered), TOC, total dissolved solids (TDS), totals suspended solids, and
hardness. The samples were collected from a depth of approximately 2 inches below the top of the water
surface (Ref. 50, p. 6). No background surface water sample was collected (Ref. 51, Figure 5). To determine
whether the concentrations of hazardous substances detected in the surface water samples are three times
above the background concentration, surface water sample SW-09 collected from a tributary draining
Bridgewood Lake is used to establish background concentrations (Ref. 51, Figure 5). The tributary does not
receive surface water runoff from the Lucas plant, but does receive surface water runoff from two hazardous
waste sites, US Avenue Burn Site and Route 561 Dump Site (Ref. 6, Figure 2-1). As summarized in Table
19, concentrations of arsenic and lead were detected at three times above the background concentration in
surface water samples SW-07 and SW-08. Lead was detected in surface water sample SW-05 at
concentrations three times the background concentration as documented in the table below. The hardness,
TDS, TOC, and total suspended solids values are presented for water quality information and are not used
to establish an observed release of these values.
TABLE 19
SURFACE WATER SAMPLES FROM HILLIARDS CREEK
1999 SHERWIN-WILLIAMS INVESTIGATION
Location ID
SW-09
SW-05
SW-07
SW-08
Date Collected
12/22/1999
12/22/1999
12/22/1999
12/22/1999
Reference
51, p. 6, Table 2-a,
51, p. 6, Table 2-a,
51, p. 6, Table 2-a,
51, p. 6, Table 2-a,
Table 2-b, Figure 5
Table 2-b, Figure 5
Table 2-b, Figure 5
Table 2-b, Figure 5
Sample Type
Background
Release
Release
Release
Hardness (mg/L)
33,100
42,900
59,200
60,400
Total Dissolved
86
84
96
100
Solids (mg/L)
Total Organic
5.6
5.7
5.8
5.5
Carbon (mg/L)
Total Suspended
ND
ND
12
14
Solids (mg/L)
Metals (fig/L)
Arsenic
ND
ND
4
20.4
Lead
8.1
24.7
646
700
Notes:
Hg/L
Microgram per liter
ID
Identification
mg/L
Milligram per liter
ND
Not detected
SW
Surface Water
148
-------
SWOF - Attribution
In response to results of samples collected during investigations along Hilliards Creek, Sherwin-Williams
fenced areas of the Hilliards Creek Wildlife Preserve and Hilliards Creek to limit access to lead-contaminated
soil and sediment (Ref. 51, pp. 9, 10, 11).
June 2002 Investigation
In June 2002, Sherwin-Williams conducted a sampling investigation at Kirkwood Lake, the surface water
into which Hilliards Creek discharges, and residential properties adjacent to Kirkwood Lake (Ref. 49, pp.
2-1, Figure 2, Table 1). The investigation identified arsenic and lead contamination in Kirkwood Lake and
on one residential property (Ref. 49, pp. 3-7, 3-9, 3-10, 4-1, 4-2).
Historic Discharges into Hilliards Creek
Sherwin-Williams had a permit for discharging non-contact cooling water into Hilliards Creek from the
Lucas plant under a NJDEP National Pollution Discharge Elimination System (NPDES) permit. The
discharge ceased in August 1978 when the plant closed (Refs. 58; 59, p. 6).
A historic map of the Lucas plant indicates that hazardous substances stored and used in buildings on the
plant property may have been released to Hilliards Creek. The maps indicated that Hilliards Creek originated
at Silver Lake. Silver Lake discharged into an underground culvert that flowed under buildings located at
the plant and finally to an open ditch, Hilliards Creek, on the east side of Foster Avenue. Building floor
drains, a trench, a holding basin, and surface water run off from the plant were directed to the underground
culvert that discharged into Hilliards Creek (Refs. 6, Figure 2-4; 60, pp. 16, 25, 28, 29, 62). Hazardous
substances used and stored in buildings may have been released to Hilliards Creek through this pathway.
As indicated by historic maps, numerous types of hazardous substances were used in the plant buildings
(Refs. 6, Figure 2-4; 60).
There is also evidence that the surface impoundments (Source 3) leached their contents into Hilliards Creek
(Ref. 32, p. 3). Aerial photographs taken in 1973 show the presence of a pipeline extending from the north
bank of one of the surface impoundments (impoundment one) to a drainage channel (Hilliards Creek) that
runs through the center of the Lucas plant. An outfall from the western bank of the impoundment area
toward the drainage channel (Hilliards Creek) is visible (Ref. 7, p. 10).
On September 18,1915, Building 39 was almost completely destroyed by fire (Ref. 60, p. 67). On February
21, 1940 and July 30, 1949, fires occurred at the facility (warehouse No. 36), which ignited thousands of
gallons of drummed thinners, lacquer, and other flammable materials stored at the facility. During efforts
to extinguish the fires, hazardous substances were released to soil, ground water, and surface water (Refs.
32, p. 3; 60, p. 68).
On May 5, 1976, NJDEP inspectors observed that a feed pipe used for the transport of raw materials had
ruptured, causing an oil discharge to the primary settling lagoon (Source 3) and Hilliards Creek (Ref. 32, p.
3). The reference to the release does not indicate the exact type of the material discharged. This discharge
may have released contaminants to Hilliards Creek.
In 1983, a seep (Source 1) was observed in the parking lot north of Building 67 between Buildings 67 and
50, flowing into Hilliards Creek (Refs. 32, p. 5; 65, pp. 1, 2, 3). The seep was observed on many occasions
during the construction of the new office complex that now occupies the Lucas plant property. Two UST s,
149
-------
SWOF - Attribution
one for oil and another for solvent, were located in the area of the seep. There also was a loading pad for
railroad cars in this area (Ref. 65, p. 1). The loading pad and the USTs may have been one of the sources
of the seep. The seep flowed overland to a storm water catch basin in the parking lot and then discharged
into Hilliards Creek (Refs. 32, p. 5; 65, pp. 1, 2, 3). Analytical results for a sample of the seep is presented
in the waste characteristics section for Source 1 in this HRS documentation record.
On February 7, 1985, NJDEP personnel sampled Hilliards Creek and the seep (Source 1) discharging into
Hilliards Creek (Ref. 32, p. 5). Analytical results for the seep sample indicated the presence of 1,2,4-
trimethylbenzene, 1,3,5-trimethylbenzene, naphthalene, xylenes, ethylbenzene, cumene, and
tetrachloroethene (Ref. 32, pp. 6, 7). Analytical results for creek samples indicated the presence of benzene,
ethylbenzene, 1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene, xylenes, and toluene (Ref. 32, p. 6).
On May 11, 1987, NJDEP personnel witnessed Paint Works's employees (persons employed by the Paint
Works Corporate Associates I who purchased the Lucas plant from Sherwin-Williams) pumping hazardous
substances into Hilliards Creek. On June 11,1987, NJDEP personnel witnessed hazardous substances being
discharged to Hilliards Creek through a ditch dug by Paint Works's employees. On June 4, 1987, NJDEP
personnel observed Paint Works' fill in a section of Hilliards Creek with contaminated soils (Ref. 32, p. 8).
The reference documentation for the above releases does not identify the hazardous substances released.
In 1994, during investigations at the US Avenue Burn Site, a NJDEP representative interviewed a resident
of 25 US Avenue. The resident's interview indicated that Hilliards Creek was commonly known as the Paris
Green ditch where the washout from the Paint Works facility ran different colors on different days (Ref. 59,
Appendix BBB, pp. BBB3, BBB4). Another residence of Gibbsboro indicated that during the 1950s, he
observed a rainbow sheen across Hilliards Creek and he soaked cattails in the material seeping into the creek
in order to make torches (Ref. 64, p. 8).
On February 19,1988 and February 25,1988, NJDEP observed a seep (Source 1) discharging into Hilliards
Creek (Refs. 36; 37). On several occasions in 2002, as documented in the source characterization section
for Source 1, seeps were observed flowing into the Hilliards Creek at the point where the storm sewer north
of Building 67 discharges into the creek (Refs. 72, pp. 2, 4; 73, pp. 2, 4). As documented in the source
characterization section for Source 1 and Table 11, arsenic, lead, benzo(a)pyrene, bis(2-ethylhexyl)phthalate,
and chrysene were detected in seep samples and in Hilliards Creek sediment samples at concentrations
meeting the criteria for an observed release (Ref. 1, Table 2-3).
On March 30, 1989, NJDEP received a complaint of an illegal discharge of white paint solids into Hilliards
Creek from Academy Paints and issued a notice of violation to Academy Paints (Refs. 34; 35).
On April 9,2002, free-phase product from the seep (Source 1) was observed in the storm water system catch
basin and inlet, in the rip-rap, and in Hilliards Creek (Ref. 48, p. 2-3). The product was characterized as
waste petroleum distillates (Ref. 48, Appendix A). The free product was composed of benzene,
ethylbenzene, xylene, naphthalene, and 2-methylnaphthalene (Ref. 31, p. 4-25).
Arsenic, lead, and SVOCs have been detected in soil samples collected from sources on the Lucas plant
property (documented in the waste characterization section of this HRS documentation record), and surface
water runoff from the sources are not contained (as documented in the source description section of this HRS
documentation record). Surface water carried metals and SVOC-contaminated soil into Hilliards Creek as
documented in Section 4.0 of this documentation record (Ref. 31, p. 6-9).
150
-------
SWOF - Attribution
Additionally, lead and SVOCs have been detected in product samples collected from Source 1 (Refs. 76, pp.
12,13, 19, 20; 77, p. 82). Product from Source 1 has been observed discharging into Hilliards Creek (Refs.
10, pp. 1, 2; 31, pp. 3-3, 3-22; 32, p. 5; 65, pp. 1, 2, 3; 36; 37).
Contaminant Sources Associated with Site Operations
Historic illustrations showing areas where white lead grinding operations were conducted do not show any
air emission controls on the grinding equipment (Ref. 60, pp. 42,43,44,45). During the grinding operations,
lead would have been released to air and may have been deposited in Hilliards Creek and surrounding areas.
Similarly, many operations shown in the historic illustrations like boiling and cooling varnish, mixing
varnish, drum storage areas, latex storage, and solvent transport may have released lead and other hazardous
substances (Ref. 5). Many of the historic illustrations show equipment on wooden floors or directly on the
ground surface (Ref. 60,pp. 33, 35 through 41,46, 51,52, 53, 55). The historic descriptions of the buildings
indicate that the buildings did not have containment structures and were not constructed to prevent spills
from percolating into the underlying soil (Ref. 60, pp. 90, 91, 94 through 108).
Historic reports indicate that the varnish operation produced air emissions and the lacquer and paint
operations produced highly toxic liquid waste. Arsenic wastewater produced from the color works was
pumped to an open field outside Gibbsboro in the 1930s (Ref. 60, p. 69). Some of the residents recall that
the field frequently caught fire (Ref. 60, pp. 69,71). Residents also recall a time when Hilliards Creekwould
catch fire when solvents on its surface ignited (Ref. 60, p. 71). To resolve this problem, Sherwin-Williams
added a scrubber to the alkyd plant stack and contained wastewater in pits behind old Number 36 platform
(Ref. 60, p. 71).
Operations in the area of Tank Farm B (Source 4) are a probable cause of the soil contamination in this area.
Hazardous substances may have leaked or released during the transportation of the tank contents by tank cars
to the production facilities or from a system of pipes installed in 1911 to simplify the transportation process,
former ASTs and USTs, an existing septic system, and historical use of process chemicals (loading and
unloading) within the area (Refs. 59, Appendix n, p. 115; 60, p. 46). The area of Tank Farm B was referred
to as oil hill (Ref. 60, p. 46). The tanks contained oils, mineral spirits, and xylene (Ref. 31, Table 2-2).
In September 1987 and February 1988, NJDEP determined that the analysis of seep (Source 1) samples
indicated that the constituents in Source 1 were similar to the materials used and stored at the Sherwin-
Williams facility (Ref. 38, pp. 1 through 3). The seeps (free-phase product) may have resulted from leaks
from ASTs containing mineral spirits 66-2 and 802-15 alkyd resin, a pipe extending from the maintenance
shop in Building 50, a former gasoline station, an existing septic system, or the handling of process chemicals
during operations (Refs. 18, pp. 3-5, 4-1; 59 Appendix II, p. 115). A surface spill of motor oil also was
indicated as a source of contamination (Ref. 18, pp. 3-5, 4-1).
Contaminated soil on the plant property may be due to the storage of raw materials in Buildings 55 and 58
and improper handling of materials during transfer, leaking transfer piping, leaking drums and tanks, spills
during maintenance of pipes, spills during maintenance of pipes, pumps and tanks, spills during drum
cleaning activities, discharge of wastes to surface impoundments, and leaks due to improper storage of
drummed materials (Ref. 32, p. 9, Figure 2-2).
151
-------
SWOF - Attribution
The reworking of the parking lot adjacent to Building 67 included the excavation of the cut-bank in the
northeastern corner of the parking lot to provide an additional area for parking. This reworking allowed free-
phase product and ground water to seep at the ground surface (Ref. 31, p. 6-3).
Analytical results for soil samples collected from the source areas indicated the presence of numerous
SVOCs, including those SVOCs detected in the release to surface water and sediment samples collected from
Hilliards Creek as documented in this section of the HRS documentation record (Refs. 31, Table 4-5; 78, p.
13). Surface water run off from the areas of contaminated soil, Sources 2, 3, and 4, would carry the
contaminated soil to Hilliards Creek.
Ground Water Contaminant Releases to Surface Water
Locally, Hilliards Creek acts as a discharge zone for shallow ground water (Ref. 31, p. 4-2). Therefore, any
shallow ground water contamination associated with the facility would eventually discharge into Hilliards
Creek. As discussed in the observed release by direct observation via overland flow section earlier in this
HRS Documentation Record and later in the Ground Water to Surface Water section of this HRS
Documentation Record, the ground water is in direct contact with free product underneath the paint works
area, and this free product and soils in the free product source area contain lead, arsenic, and SVOCs.
Similar types of wastes have been observed in the Route 561 Dump Site and in soil near Hilliards Creek and
in sediments of Hilliards Creek including blue and bluish-green staining or blue and bluish-green stained soil
and sediment (Ref. 59, Appendix Z, p. Zl; Appendix FF, p. FF1; Appendix GG, p. GG1).
In summary, lead, arsenic and several SVOCs are clearly associated with on-site sources. They are found
in observed releases by direct observation. They are found in significantly higher concentrations downstream
of the PPEs for the site sources, and historic documentation supports that these substances have been released
to Hilliards Creek numerous times. Although there may be other sources in the Hilliard's Creek Watershed,
it is clear that the significant increase in the release substances can be at least in part attributed to site
releases.
Observed Release Hazardous Substances:
Arsenic
Benzo(a)anthracene
Benzo(b)pyrene
Benzo(b)fluoranthene
B enzo(g,h,i)p erylene
Benzo(k)fluoranthene
Bis-2(ethylhexyl)phthalate
Chrysene
Fluoranthene
Lead
Phenanthrene
152
-------
SWOF/Drinking - Waste Characteristics
4.1.2.2 WASTE CHARACTERISTICS
4.1.2.2.1 Toxicity/Persistence
For each hazardous substance detected in a source with a containment value greater than zero, a toxicity
factor value, a persistence factor value, and a combined toxicity/persistence factor value are assigned (Ref.
1, Section 4.1.2.2.1).
TABLE 20
TOXICITY/PERSISTENCE FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Toxicity
Persistence
Toxicity/
Persistence
Source
Factor
Factor
Factor
Hazardous Substance
Number
Value
Value*
Value
Reference
Acetone
1,4
1
0.07
0.07
2, p. BI-1
Aluminum
1
0
1
0
2, p. BI-1
Antimony
2
10,000
1
10,000
2, p. BI-1
Arsenic
1,2,3,4
10,000
1
10,000
2, p. BI-1
Barium
1,2,3,4
10,000
1
10,000
2, p. BI-1
Benzene
1
1,000
0.4
400
2, p. BI-2
Benzo(a)anthracene
1,4
1,000
1
1,000
2, p. BI-2
Benzo(a)pyrene
1,4
10,000
1
10,000
2, p. BI-2
Benzoic acid
3
--
--
--
2, p. BI-2
Benzo(b)fluoranthene
1,4
--
--
--
2, p. BI-2
Benzo(k)fluoranthene
1,4
100
1
100
2, p. BI-2
Beryllium
2
10,000
1
10,000
2, p. BI-2
Bis (2-ethylhexyl) phthalate
1
100
1
100
2, p. BI-2
2-Butanone
1,2,4
--
--
--
2, p. BI-2
Cadmium
1,2,3
10,000
1
10,000
2, p. BI-2
Carbon disulfide
3
10
0.4
4
2, p. BI-3
4-Chloroaniline
1
--
--
--
2, p. BI-3
Chlorobenzene
1
100
0.0007
0.07
2, p. BI-3
Chloroform
4
100
0.4
40.0
2, p. BI-3
Chromium
1,2,3,4
10,000
1
10,000
2, p. BI-3
Chrysene
1,4
10
1
10
2, p. BI-3
Cobalt
2,4
10
1
10
2, p. BI-3
Copper
1,2,3
0
1
0
2, p. BI-3
Cyanide
4
100
1
100
2, p. BI-4
1,2-Dichloroethene
1,2
100
0.4
40
2, p. BI-4
2,4-Dimethylphenol
1
100
1
100
2, p. BI-5
Di-n-butyl phthalate
4
10
1
10
2, p. BI-4
153
-------
SWOF/Drinking - Waste Characteristics
TABLE 20 (Continued)
TOXICITY/PERSISTENCE FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Toxicity/
Toxicity
Persistence
Persistence
Source
Factor
Factor
Factor
Hazardous Substance
Number
Value
Value*
Value
Reference
Ethylbenzene
1,2,3,4
10
7x10"4
0.007
2, p. BI-6
Fluoranthene
1,2
--
--
--
2, p. BI-6
2-Hexanone
4
--
--
--
2, p. BI-8
Iron
1
1
1
1
2, p. BI-8
Lead
1,2,3,4
10,000
1
10,000
2, p. BI-8
Magnesium
1,2,4
--
--
--
2, p. BI-8
Manganese
1
10,000
1
10,000
2, p. BI-8
Mercury
1,2,3,4
10,000
1
10,000
2, p. BI-8
2-Methylnaphthalene
1,2
0
0.4
0
2, p. BI-9
Naphthalene
1,2
1,000
0.4
400
2, p. BI-9
Nickel
1,2,3
10,000
1
10,000
2, p. BI-9
Pentachlorophenol
1,3
100
1
100
2, p. BI-9
Phenanthrene
1,4
0
0.4
0
2, p. BI-9
Pyrene
1,4
100
1
100
2, p. BI-10
Selenium
1
100
1
100
2, p. BI-10
Silver
1
100
1
100
2, p. BI-10
T etrachloroethene
1,2
100
0.4
40
2, p. BI-10
Toluene
1,4
10
0.07
0.7
2, p. BI-11
1,1,1 -Trichloroethane
4
1
0.4
0.4
2, p. BI-11
1,1,2-Trichloroethane
1,4
1,000
0.4
400
2, p. BI-11
Trichloroethene
1,2,4
10,000
0.4
4,000
2, p. BI,
B2-1
1,2,4-Trimethylbenzene
1
--
--
--
2, p. BI-11
1,3,5-Trimethylbenzene
1
--
--
--
Vanadium
1
100
1
100
2, p. BI-11
Xylene
1,2,3,4
100
0.4
40
2, p. BI-12
Zinc
1,2,3,4
10
1
10
2. d. BI-12
Notes:
River persistence values are assigned.
Not listed in the SCDM.
Toxicity/Persistence Factor Value: 10,000
(Ref. 1, Table 4-12)
154
-------
SWOF/Drinking - Hazardous Waste Quantity
4.1.2.2.2 Hazardous Waste Quantity
The source hazardous waste quantity (HWQ) values for each of the four sources is greater than zero. As
documented in Section 4.1.4.3, wetlands are subject to Level I and II concentrations; therefore, a default
value of 100 is assigned for the HWQ value (Ref. 1, Section 2.4.2.2, Table 2-6).
155
Hazardous Waste Quantity Factor Value: 100
-------
SWOF/Drinking - Waste Characteristics Factor Category Value
4.1.2.2.3 Waste Characteristics Factor Category Value
The waste characteristics factor value is determined from the product of the toxicity/persistence and HWQ
factor values, and is subject to a maximum product of 1 x 108 (Ref. 1, Table 2-7). Numerous hazardous
substances listed in Table 20 have a toxicity/persistence value of 10,000 including benzo(a)pyrene,
manganese, arsenic, lead, and mercury.
10,000 x 100 = 1x10s
Toxicity/persistence factor value: 10,000
Waste characteristics product: lx 106
Waste Characteristics Factor Category Value: 32
(Ref. 1, Table 2-7)
156
-------
SWOF/Food Chain - Toxicity/Persistence/Bioaccumulation
4.1.3.2 WASTE CHARACTERISTICS
4.1.3.2.1 Toxicity/Persistence/Bioaccumulation
The toxicity, persistence, and bioaccumulation factor values associated with hazardous substances
detected in the sources at the Sherwin-Williams/Hilliards Creek are summarized in Table 21.
TABLE 21
TOXICITY/PERSISTENCE/BIOACCUMULATION FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Toxicity/
Human Food
Toxicity/
Persistence
Chain
Persistence/
Source
Factor Value
Bioaccumulation
Bioaccumulation
Hazardous Substance
Number
(Table 16)
Value*
Factor Value
Reference
Acetone
1,4
0.07
0.5
0.035
2, p. BI-1
Aluminum
1
0
5,000
0
2, p. BI-1
Antimony
2
10,000
5
50,000
2, p. BI-1
Arsenic
1,2,3,4
10,000
5
50,000
2, p. BI-1
Barium
1,2,3,4
10,000
500
5xl06
2, p. BI-1
Benzene
1
400
5,000
20,000
2, p. BI-2
Benzo(a)anthracene
1,4
1,000
50,000
5xl07
2, p. BI-2
Benzo(a)pyrene
1,4
10,000
50,000
5xl08
2, p. BI-2
Benzoic acid
3
-
-
-
2, p. BI-2
B enzo(b) fluoranthene
1,4
-
-
-
2, p. BI-2
B enzo(k) fluoranthene
1,4
100
50,000
5xl06
2, p. BI-2
Beryllium
2
10,000
50
5xl05
Bis (2-ethyl hexyl)
1
100
50,000
5xl06
2, p. BI-2
phthalate
2-Butanone
1,2,4
-
-
-
2, p. BI-2
Cadmium
1,2,3
10,000
5,000
5xl07
2, p. BI-2
Carbon disulfide
3
4
500
2,000
2, p. BI-2
4-Chloroaniline
1
-
-
-
2, p. BI-2
Chlorobenzene
1
0.07
50
3.5
2, p. BI-3
Chloroform
4
40
5
200
2, p. BI-3
Chromium
1,2,3,4
10,000
500
5xl06
2, p. BI-3
Chrysene
1,4
10
5
50
2, p. BI-3
Cobalt
2,4
10
5,000
50,000
2, p. BI-3
Copper
1,2,3
0
500
0
2, p. BI-3
Cyanide
4
0
0.5
50
2, p. BI-3
1,2-Dichloroethene
1,2
40
50
2,000
2, p. BI-5
2,4-Dimethylphenol
1
100
500
5xl04
2, p. BI-4
Di-n-butyl Phthalate
4
10
5,000
50,000
2, p. BI-5
157
-------
SWOF/Food Chain - Toxicity/Persistence/Bioaccumulation
TABLE 21 (Continued)
TOXICITY/PERSISTENCE/BIOACCUMULATION FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Toxicity/
Human Food
Toxicity/
Persistence
Chain
Persistence/
Source
Factor Value
Bioaccumulation
Bioaccumulation
Hazardous Substance
Number
(Table 16)
Value*
Factor Value
Reference
Ethylbenzene
1,2,3,4
0.7
50
3.5
2, p. BI-4
Fluoranthene
1,4
-
-
-
2, p. BI-4
2-Hexanone
4
-
-
-
2, p. BI-7
Iron
1
1
5,000
5,000
2, p. BI-8
Lead
1,2,3,4
10,000
5
50,000
2, p. BI-8
Magnesium
1,2,4
-
-
-
2, p. BI-8
Manganese
1
10,000
50,000
5xl08
2, p. BI-8
Mercury
1,2,3,4
10,000
50,000
5xl08
2, p. BI-8
2 -Methylnaphthalene
1,2
0
50,000
0.0
2, p. BI-9
Naphthalene
1,2
400
50,000
2xl06
2, p. BI-9
Nickel
1,2,3
10,000
0.5
5,000
2, p. BI-9
Pentachlorophenol
1,3
100
50,000
5xl06
2, p. BI-9
Phenanthrene
1,4
0
5,000
0.0
2, p. BI-9
Pyrene
1,4
100
50,000
5xl06
2, p. BI-9
Selenium
1
100
50
5,000
2, p. BI-10
Silver
1
100
50
5,000
2, p. BI-10
T etrachloroethene
1,2
40
50
2,000
2, p. BI-10
Toluene
1,4
0.7
50
3.5
2, p. BI-11
1,1,1 -Trichloroethane
4
0.4
5
2
2, p. BI-11
1,1,2-Trichloroethane
1,4
400
50
20,000
2, p. BI-11
Trichloroethene
1,2,4
4,000
50
2xl05
2, p. BI,
B2-1
1,2,4-
1
—
—
—
2, p. BI-11
Trimethylbenzene
1,3,5-
1
—
—
—
2, p. BI-11
Trimethylbenzene
Vanadium
1
100
500
50,000
2, p. BI-11
Xylenes
2,4
40
50
200
2, p. BI-12
Zinc
1.2.3.4
10
5
50
2. d. BI-12
158
-------
SWOF/Food Chain - Toxicity/Persistence/Bioaccumulation
TABLE 21 (Continued)
TOXICITY/PERSISTENCE/BIOACCUMULATION FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Notes:
* Fresh-water bioaccumulation values are assigned.
- Not Available.
Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 108
(Ref. 1, Table 4-16)
159
-------
SWOF/Food Chain - Hazardous Waste Quantity
4.1.3.2.2 Hazardous Waste Quantity
The source HWQ values for each of the four sources is greater than zero. As documented in Section 4.1.4.3,
wetlands are subject to Level I and II concentrations; therefore, a minimum value of 100 is assigned for the
HWQ value (Ref. 1, Section 2.4.2.2, Table 2-6).
160
Hazardous Waste Quantity Factor Value: 100
-------
SWOF/Food Chain - Waste Characteristics Factor Category Value
4.1.3.2.3 Waste Characteristics Factor Category Value
The waste characteristic factor value is the product of the highest toxicity/persistence factor value and 11W Q
value, multiplied by the highest bioaccumulation factor value for the same hazardous substance (Ref. 1, Section
4.1.3.2.3). The hazardous substances with the highest toxicity/persistence factorvalue and bioaccumulation
factor value include benzo(a)pyrene, manganese, and mercury.
10,000 x 100 = 1 x 106
Toxicity/persistence factorvalue
X hazardous waste quantity factor value: 1 x 106
1 X lo6 X 50,000 = 5 x 1010
(Toxicity/persistence X hazardous waste quantity)
X bioaccumulation potential factorvalue: 5 x 1010
Waste Characteristics Factor Category Value: 320
(Ref. 1, Table 2-7)
161
-------
SWOF/Food Chain - Targets
4.1.3.3 HUMAN FOOD CHAIN THREAT - TARGETS
Actual Human Food Chain Contamination
Although aqueous and sediment samples document an observed release to the surface water migration pathway,
actual food chain contamination is not scored because no fisheries are documented within the areas of the
observed release (Ref. 1, Section 4.1.3.3).
4.1.3.3.1 Food Chain Individual
As documented in Section 4.1.2.1.1 of this HRS documentation record, an observed release of hazardous
substances having a bioaccumulation factor value of 500 or greater is documented at the Hilliards Creek
watershed and there is a fishery, Kirkwood Lake, within the 15-mile downstream TDL. The food chain
individual factor is assigned a value of 20 (Refs. 1 [Section 4.1.3.3.1]; 52, p. 5).
Food Chain Individual Factor Value: 20
(Ref. 1 [Section 4.1.3.3.1])
4.1.3.3.2.3 Potential Human Food Chain Contamination
Kirkwood Lake is the only fishery identified within the 15-mile downstream TDL. The value for the potential
human food chain contamination factor for Kirkwood Lake is assigned a value of greater than zero because
information related to annua! production of the lake has not been documented. However, since the lake is a
fishery, the production value would be greater than zero (Ref. 52, p. 5).
Potential Human Food Chain Contamination Factor Value: >0
(Ref. 1 [Section 4.1.3.3.2.3])
162
-------
SWOF/Environment - Toxicity/Persistence/Bioaccumulation
4.1.4 ENVIRONMENTAL THREAT
4.1.4.2 Waste Characteristics
4.1.4.2.1 Ecosystem Toxicitv/Persistence/Bioaccumulation
Table 22 presents the ecosystem toxicity/persistence/bioaccumulation factor values for hazardous substances
detected in sources with a containment value greater than zero.
TABLE 22
ECOSYSTEM TOXICITY/PERSISTENCE
FACTOR VALUES
SHERWIN- WILLIAMS/HILLIARDS CREEK
Source
Ecosystem
Toxicity
Persistence
Ecosystem
Toxicity/
Persistence
Hazardous Substance
Number
Value*
Value**
Factor Value
Reference
Acetone
1,4
100
0.07
7
2, p. BI-1
Aluminum
1
100
1.0
100
2, p. BI-1
Antimony
2
100
1.0
100
2, p. BI-1
Arsenic
1,2,3,4
10
1.0
10
2, p. BI-1
Barium
1,2,3,4
1
1.0
1
2, p. BI-1
Benzene
1
1,000
0.4
400
2, p. BI-2
Benzo(a)anthracene
1,4
10,000
1.0
10,000
2, p. BI-2
Benzo(a)pyrene
1,4
10,000
1.0
10,000
2, p. BI-2
Benzo(b)fluoranthene
1,4
-
-
-
2, p. BI-2
Benzoic acid
3
-
-
-
2, p. BI-2
Benzo(k)fluoranthene
1,4
0
1.0
0
2, p. BI-2
Beryllium
2
0
1.0
0
2, p. BI-2
Bis (2-ethylhexyl)
1
1,000
1.0
1,000
2, p. BI-2
phthalate
2-Butanone
1,2,4
-
-
-
2, p. BI-2
Cadmium
1,2,3
10,000
1.0
10,000
2, p. BI-2
Carbon disulfide
3
100
0.4
40
2, p. BI-2
4-Chloroaniline
1
-
-
-
2, p. BI-3
Chlorobenzene
1
10,000
0.0007
7
2, p. BI-3
Chloroform
4
100
0.4
40
2, p. BI-3
Chromium
1,2,3,4
10,000
1.0
10,000
2, p. BI-3
Chrysene
1,4
1,000
1.0
1,000
2, p. BI-3
Cobalt
2,4
0
1.0
0
2, p. BI-3
Copper
1,2,3
1,000
1.0
1,000
2, p. BI-3
Cyanide
4
1,000
1.0
1,000
2, p. BI-3
163
-------
SWOF/Environment - Toxicity/Persistence/Bioaccumulation
TABLE 22 (Continued)
ECOSYSTEMTOXICITY/PERSISTENCE
FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Hazardous Substance
Source
Number
Ecosystem
Toxicity
Value*
Persistence
Value**
Ecosystem
Toxicity/
Persistence
Factor Value
Reference
1,2-Dichloroethene
1,2
1
0.4
0.4
2, p. BI-5
2,4-Dimethylphenol
1
100
1.0
100
2, p. BI-4
Di-n-butyl phthalate
4
1,000
1.0
1,000
2, p. BI-5
Ethylbenzene
1,2,3,4
100
0.0007
0.07
2, p. BI-4
Fluoranthene
1,4
-
-
-
2, p. BI-4
2-Hexanone
4
-
-
-
2, p. BI-7
Iron
1
10
1.0
10
2, p. BI-8
Lead
1,2,3,4
1,000
1.0
1,000
2, p. BI-8
Magnesium
1,2,4
-
-
-
2, p. BI-8
Manganese
1
0
1.0
0
2, p. BI-8
Mercury
1,2,3,4
10,000
1.0
10,000
2, p. BI-8
2-Methylnaphthalene
1,2
100
0.4
40
2, p. BI-8
Naphthalene
1,2
1,000
0.4
400
2, p. BI-9
Nickel
1,2,3
100
1.0
100
2, p. BI-9
Pentachlorophenol
1,3
100
1.0
100
2, p. BI-9
Phenanthrene
1,4
10,000
0.4
4,000
2, p. BI-9
Pyrene
1,4
10,000
1.0
10,000
2, p. BI-9
Selenium
1
1,000
1.0
1,000
2, p. BI-10
Silver
1
10,000
1.0
10,000
2, p. BI-10
T etrachloroethene
1,2
0
0.4
0
2, p. BI-10
Toluene
1,4
100
0.1
70
2, p. BI-11
1,1,1 -Trichloroethane
4
10
0.4
4
2, p. BI-11
1,1,2-Trichloroethane
1,4
100
0.4
40
2, p. BI-11
Trichloroethene
1,2,4
100
0.4
40
2, p. BI, B2-1
1,2,4-
Trimethylbenzene
1
—
—
—
2, p. BI-11
1,3,5-
Trimethylbenzene
1
—
—
—
2, p. BI-11
Vanadium
1,4
0
1.0
0
2, p. BI-11
Xylenes
1,2,3,4
100
0.4
40
2, p. BI-12
Zinc
1.2.3.4
10
1.0
10
2. p. BI-12
164
-------
SWOF/Environment - Toxicity/Persistence/Bioaccumulation
TABLE 22 (Continued)
ECOSYSTEMTOXICITY/PERSISTENCE
FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Notes:
* Fresh-water ecotoxicities are assigned.
** Persistence values for river.
- Not Available.
165
-------
SWOF/Environment - Toxicity/Persistence/Bioaccumulation
TABLE 23
ECOSYSTEM TOXICITY/PERSISTENCE/BIOACCUMULATION
FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Ecosystem
Ecosystem
Toxicity/
Toxicity/
Persistence
Ecosystem
Persistence/
Source
Factor
Bioaccumulation
Bioaccumulation
Hazardous Substance
Number
Value
Value *
Value
Reference
Acetone
1,4
7
0.5
3.5
2, p. BI-1
Aluminum
1
100
50,000
5xl05
2, p. BI-1
Antimony
2
100
5
500.0
2, p. BI-1
Arsenic
1,2,3,4
10
5,000
5x104
2, p. BI-1
Barium
1,2,3,4
1
500
500.0
2, p. BI-1
Benzene
1
400
5,000
2xl07
2, p. BI-2
Benzo(a)anthracene
1,4
10,000
50,000
5xl08
2, p. BI-2
Benzo(a)pyrene
1,4
10,000
50,000
5xl08
2, p. BI-2
Benzo(b)fluoranthene
1,4
-
-
-
2, p. BI-2
Benzoic acid
3
-
-
-
2, p. BI-2
Benzo(k)fluoranthene
1,4
0
50,000
0.0
2, p. BI-2
Beryllium
2
0
50
0.0
2, p. BI-2
Bis (2-ethyl hexyl)
1
1,000
50,000
5xl07
2, p. BI-2
phthalate
2-Butanone
1,2,4
-
-
-
2, p. BI-2
Cadmium
1,2,3
10,000
50,000
5xl08
2, p. BI-2
Carbon disulfide
3
40
500
2xl04
2, p. BI-2
4-Chloroaniline
1
-
-
-
2, p. BI-3
Chlorobenzene
1
7
5,000
35,000.0
2, p. BI-3
Chloroform
4
40
500
2xl04
2, p. BI-3
Chromium
1,2,3,4
10,000
500
5xl06
2, p. BI-3
Chrysene
1,4
1,000
5,000
5xl06
2, p. BI-3
Copper
1,2,3
1,000
5,000
5xl06
2, p. BI-3
Cyanide
4
1,000
0.5
500.0
2, p. BI-3
1,2-Dichloroethene
1,2
0.4
50
20.0
2, p. BI-5
2,4-Dimethylphenol
1
100
500
5x104
2, p. BI-4
Di-n-butyl phthalate
4
1,000
5,000
5xl06
2, p. BI-4
Ethylbenzene
1,2,3,4
0.07
50
3.5
2, p. BI-6
Fluoranthene
1,4
-
-
-
2, p. BI-6
2-Hexanone
4
-
-
-
2, p. BI-8
Iron
1
10
5,000
5xl05
2, p. BI-8
166
-------
SWOF/Environment - Toxicity/Persistence/Bioaccumulation
TABLE 23 (Continued)
ECOSYSTEM TOXICITY/PERSISTENCE/BIOACCUMULATION
FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Ecosystem
Toxicity/
Persistence
Ecosystem
Ecosystem
Toxicity/
Persistence/
Source
Factor
Bioaccumulation
Bioaccumulation
Hazardous Substance
Number
Value
Value *
Value
Reference
Lead
1,2,3,4
1,000
50,000
5xl07
2, p. BI-8
Magnesium
1
-
-
-
2, p. BI-8
Manganese
1
0
50,000
0.0
2, p. BI-8
Mercury
1,2,3,4
10,000
50,000
5xl08
2, p. BI-8
2-Methylnaphthalene
1,2
40
50,000
2xl06
2, p. BI-8
Naphthalene
1,2
400
50,000
2xl07
2, p. BI-9
Nickel
1,2,3
100
500
5x104
2, p. BI-9
Pentachlorophenol
1,3
100
50,000
5xl06
2, p. BI-9
Phenanthrene
1,4
4,000
50,000
2xl08
2, p. BI-9
Pyrene
1,4
10,000
50,000
5xl08
2, p. BI-9
Selenium
1
1,000
500
5xl05
2, p. BI-10
Silver
1
10,000
50
5xl05
2, p. BI-10
T etrachloroethene
1,2
0
50
0
2, p. BI-10
Toluene
1,4
70
5,000
35,000
2, p. BI-11
1,1,1 -T richloroethane
4
4
5
20
2, p. BI-11
1,1,2-Trichloroethane
1,4
40
50
2,000
2, p. BI-11
Trichloroethene
1,2,4
40
50
200
2, p. BI-11
1,2,4-
1
—
—
—
2, p. BI-11
T rimethylb enzene
1,3,5-
1
—
—
—
2, p. BI-11
Trimethylbenzene
Vanadium
1
0
500
0
2, p. BI-11
Xylenes
1,2,3,4
40
50
2,000
2, p. BI-12
Zinc
1.2.3.4
10
50.000
5x104
2. o. BI-12
Notes:
* Fresh-water environmental bioaccumulation values are assigned.
- Not Available.
Ecosystem Toxicity/Persistence/Bioaccumulation Potential Factor Value: 5 x 108
167
-------
SWOF/Environmental - Hazardous Waste Quantity
4.1.4.2.2 Hazardous Waste Quantity
The source HWQ values for each of the four sources is greater than zero. As documented in Section 4.1.4.3,
wetlands are subject to Level I and II concentrations; therefore, a minimum value of 100 is assigned for the
HWQ value (Ref. 1, Section 2.4.2.2, Table 2-6).
168
Hazardous Waste Quantity Factor Value =100
-------
S WO F/Knv iron mental - Waste Characteristics Factor Category Value
4.1.4.2.3 Waste Characteristics Factor Category Value
The waste characteristics factor category value is determined by taking the product of the highest ecosystem
toxicity/persistence factor value and the HWQ value and multiplying the product by the highest ecosystem
bioaccumulation factor value (Ref. 1, Section 4.1.4.2.3). The hazardous substances with the highest values
include benzo(a)anthracene; benzo(a)pyrene; cadmium; mercury; and pyrene.
10,000 x 100 = 1 x 106
Ecosystem toxicity/persistence factor value
x Hazardous waste quantity factor value: 1 x 106
1 x 106 x 50,000 = 5 x 1010
(Ecosystem toxicity/persistence X hazardous waste quantity)
x ecosystem bioaccumulation potential factor value: 5 x 1010
Waste Characteristics Factor Category Value: 320
(Ref. 1, Table 2-7)
169
-------
SWOF/Environment - Targets
4.1.4.3 ENVIRONMENTAL THREAT - TARGETS
Level I Concentrations
Actual environmental contamination has been documented in the wetland of Hilliards Creek and in Hilliards
Creek, as documented in Section 4.1.1.1 of this documentation record. The sampling locations and wetland
are shown on Reference 97. The wetland is identified on Reference 93, Wetland Inventory Map, and
electronically transposed onto Reference 97 for clarity. The wetland is a palustrine forested broad-leaved
deciduous and needle-leaved evergreen, and palustrine scrub/shrub and emergent wetland (Ref. 93). The Level
I samples listed below are documented in an observed release to Hilliards Creek in Table 12 of this
documentation record.
Sample ID:
Sample Medium:
Location:
References:
HC-SW-22
Aqueous
Hilliards Creek, approximately 4,389 feet downstream of the PPE-1.
9; 84, Figure 1; 97
Sample ID:
Sample Medium:
Location:
References:
HC-SW-34
Aqueous
Hilliards Creek, approximately 5,800 feet downstream of the PPE-1.
9; 84, Figure 1; 97
Sample ID:
Sample Medium:
Location:
References:
HC-SW-35
Aqueous
Hilliards Creek, approximately 6,100 feet downstream of the PPE-1.
9; 84, Figure 1; 97
Sample ID:
Sample Medium:
Location:
References:
HC-SW-39
Aqueous
Hilliards Creek, approximately 6,500 feet downstream of the PPE-1.
9; 84, Figure 1; 97
The concentrations of hazardous substances detected in surface water samples documenting an observed release
to surface water and the corresponding benchmark are listed in Table 24. The concentrations of hazardous
substances detected in the samples are documented in Table 12. The environmental benchmarks are EPA's
ambient water quality criteria (AWQC), as presented in National Recommended Water Quality Criteria: 2002
(EPA-822-R-02-047) (Ref. 1, Table 4-22). To use the AWQC, the criteria are adjusted in relation to the
hardness of the aqueous sample. Reference 95 provides the AWQC for each aqueous sample adjusted for the
sample-specific hardness values (Refs. 2, p. 28; 95). The AWQC provide criteria maximum concentrations
(CMC) and criteria continuous concentrations (CCC) (Ref. 2, pp. BII-1, BII-8). Therefore, CMC and CCC for
each aqueous sample are calculated to determine the sample-specific CMC and CCC with consideration of the
hardness value for the sample. The CCC is the chronic benchmark and is used to determine actual
contamination in accordance with Reference 1, Table 4-22.
170
-------
SWOF/Environment - Targets
TABLE 24
BENCHMARK CONCENTRATIONS - LEVEL I SENSITIVE ENVIRONMENTS
Sample ID
Hazardous
Substance
Hazardous
Substance
Concentration
(Hg/L )*
Benchmark
Concentration
(Hg/L) (Refs. 2,
p. BII-8; 95)
Benchmark
(Refs. 2; 95)
HC-SW-22
Lead
15
1.02
AWQC-CCC
HC-SW-34
Lead
29
2.8
AWQC-CCC
HC-SW-35
Lead
12.4
1.12
AWQC-CCC
HC-SW-39
Lead
24.1
6.43
AWQC-CCC
Notes:
* The concentration cited represents dissolved metals because the surface water samples were filtered
(Ref. 84, p. 6).
fxg/L Microgram per liter
AWQC Ambient Water Quality Criteria
HC Hilliards Creek
CCC Criteria Continuous Concentration
SW Surface water
Most Distant Level I Sample
Sample ID:
Sample Medium:
Location:
References:
HC-SW-39 (aqueous sample)
Aqueous
Hilliards Creek, approximately 5,708 feet downstream of the PPE -3.
9; 84, Figure 1; 97
Level II Concentrations
The locations of the Level II wetland sediment sampling locations outside of the area of Level I wetland
concentrations is documented below (Ref. 1, Section 4.1.4.3.1.2).
Sample ID:
Sample Medium:
Location:
References:
HC-SD-41
Sediment
Wetland between Cooper River and Hilliards Creek, approximately 389 feet
downstream of HC-SW-39.
9; 84, Figure 1; 97
171
-------
SWOF/Environment - Targets
Sample ID:
Sample Medium:
Location:
References:
Sample ID:
Sample Medium:
Location:
References:
Sample ID:
Sample Medium:
Location:
References:
Sample ID:
Sample Medium:
Location:
References:
Sample ID:
Sample Medium:
Location:
References:
Most Distant Level II Sample
HC-SD-43
Sediment
Wetland adjacent to Hilliards Creek, approximately 6,900 feet downstream of the
PPE-3.
9; 84, Figure 1; 97
HC-SD-44
Sediment
Wetland adjacent to Hilliards Creek, approximately 6,600 feet downstream of the
PPE-3.
9; 84, Figure 1; 97
HC-SD-45
Sediment
Wetland adjacent to Hilliards Creek, approximately 6,600 feet downstream of the
PPE-3.
9; 84, Figure 1; 97
HC-SD46
Sediment
Wetland adjacent to Hilliards Creek, approximately 6,200 feet downstream of the
PPE-3.
9; 84, Figure 1; 97
HC-SD-48
Sediment
Wetland adjacent to Hilliards Creek, approximately 6,500 feet downstream of the
PPE-3.
9; 84, Figure 1; 97
Sample ID:
Sample Medium:
Location:
Reference:
HC-SD-43 (sediment sample)
Sediment
Hilliards Creek, approximate 389 feet downstream of the HC-SW-39.
9; 84, Figure 1; 97
172
-------
SWOF/Environment - Targets
4.1.4.3.1 Sensitive Environments
4.1.4.3.1.1 Level I Concentrations
Sensitive Environments
Sensitive environments other than wetland have not been identified within the 15-mile downstream target
distance.
Wetlands
The wetland areas were identified from Reference 93, Wetland Inventory Map. The wetland is a palustrine
forested broad-leaved deciduous and needle-leaved evergreen, and palustrine scrub/shrub and emergent wetland
(Ref. 93). The sampling locations identified in the Level I Concentrations section above are within this
wetland (Ref. 97). The wetlands subject to Level I concentrations are those wetlands located between PPE-1
and the most distance downstream Level I sampling location (HC-SW-39) (Ref. 1, Section 4.1.1.2).
The total length of wetlands from PPE-1 to the most downstream sampling location (HC-SW-39) containing
Level I concentrations is estimated to be 5,708 feet (Refs. 93; 97). Since wetlands are located on both sides
of Hilliards Creek, the total length of wetlands subject to Level I concentrations is two times 5,708 feet or
11,416 feet or 2.16 miles (Ref. 1, Section 4.1.4.3.1.1). The wetland frontage is summarized in Table 25.
TABLE 25
LEVEL I WETLAND FRONTAGE
Wetland
Wetland Frontage
Reference
Palustrine emergent, palustrine
forested, palustrine scrub/shrub
2.16 mile
93; 97
Total Level I Wetland Frontage: 2.16 mi.
The wetland ratings value for 2.16 miles is obtained from Reference 1, Table 4-24 and is 75.
Level I Wetland Value: 75
(Ref. 1, Table 4-24)
For wetlands subject to Level I concentrations, the wetland value (75) is multiplied by 10 (Ref. 1, Section
4.1.4.3.1.1).
Level I Concentrations Factor Value: 750 (Ref. 1, Section 4.1.4.3.1.1)
173
-------
SWOF/Hnvironmcnt - Level II Concentrations
4.1.4.3.1 Sensitive Environments
4.1.4.3.1.2 Level II Concentrations
Sensitive Environments
Sensitive environments other than wetlands have not been identified within the 15-mile downstream target
distance.
Wetlands
The wetland length subj ect to Level II concentrations is located between surface water sampling location HC-
SW-39 (most distance Level I concentration) and sediment sampling location HC-SD-43, the most distant Level
II sediment sampling location. That length is estimated to be 778 feet or 0.15 mile as measured on Reference
97 (Refs. 93; 97) and includes the length of wetlands on both the north and south banks of Hilliards Creek (Ref.
1, Section 4.1.4.3.1.1). The Level II wetland frontage is summarized in Table 26.
TABLE 26
LEVEL II WETLAND FRONTAGE
Wetland
Wetland Frontage
Reference
Palustrine emergent, palustrine
forested, palustrine scrub/shrub
0.15 mile
93; 97
Total Level I Wetland Frontage: 0.15 mile
The wetland ratings value for 0.15 mile of wetland frontage is obtained from Ref. 1, Table 4-24 and is 25.
Level II Wetland Value: 25
(Ref. 1, Table 4-24)
Level II Concentrations Factor Value: 25 (Ref. 1, Section 4.1.4.3.1.2)
174
-------
SWOF/Hnvironmcnt - Potential Contamination
4.1.4.3.1.3 Potential Contamination
Sensitive Environments
Sensitive environments potentially exposed to contaminants from the Sherwin-Williams/Hilliards Creek are
not evaluated because the presence of sensitive environments other than wetlands subject to Level I and II
concentrations have not been identified.
Potential Contamination Factor Value (SP): NE
175
-------
Ground Water (GW) to Surface Water (SW)
General Considerations
4.2
GROUND WATER TO SURFACE WATER MIGRATION
The ground water to surface water migration component is included to evaluate the threats that result from
migration of hazardous substances from a source to surface water via ground water (Ref. 1, Section 4.2).
Surface water eligible for evaluation in the ground water to surface water migration pathway includes those
surface waters within 1 mile of the sources. Additionally, no aquifer discontinuity can be located between
the sources and the surface waters, and the top of the uppermost aquifer must be at or above the bottom of
the surface water (Ref. 1, Section 4.2.1.1). Eligible surface water bodies include Hilliards Creek, Silver
Lake, White Sand Branch, Haney Run Brooke, and Bridgewood Lake (Ref. 9). The threats posed to Silver
Lake, White Sand Branch, Haney Run Brooke, and Bridgewood Lake are not evaluated. Only the threats
posed to Hilliards Creek are evaluated because the Hilliards Creek migration pathway yields the highest
ground water to surface water migration score. An observed release to Hilliards Creek can be documented
and fisheries and actual contamination of wetlands are associated with the migration pathway, as documented
in the sections below (Refs. 9; 31, Figures 2-2 and 3-2). Evaluation of the other eligible surface water bodies
does not change the site score. Hilliards Creek, as documented in Section 4.0 of this HRS documentation
record, is the primary surface water body threatened by releases from the Lucas plant. Available
documentation indicates that a release of lead to Bridgewood Lake may have occurred from the plant.
However, background samples were not collected to document background conditions. Additionally
Bridgewood Lake is not a fishery and the wetlands associated with the lake do not meet the minimum
frontage requirements of 0.1 mile for HRS evaluation. As a result, the target value for Bridgewood Lake is
very low.
Free-phase product in ground water and ground water seeps enter a storm sewer north of Building 67 when
the water table is high, indicating that there is no aquifer discontinuity and that the top of the uppermost
aquifer is at or above the bottom of Hilliards Creek (Refs. 6, p. 3-47; 18, p. 2-3). Locally, Hilliards Creek
acts as a discharge zone for the shallow aquifer (Ref. 31, pp. 4-2, 6-2).
4.2.1.2 Hazardous Substance Migration Path for Ground Water to Surface Water
The ground water to surface water migration pathway is restricted to the ground water segment in the
uppermost aquifer between the source and nearby surface water bodies. The surface water in-water segment
begins at the PPE from the uppermost aquifer to the surface water. The location of the PPE is the point of
the surface water that yields the shortest straight-line distance, within the aquifer boundary, from the sources
with a containment factor value of greater then 0 to surface water. As documented in the source section of
this HRS documentation record, the four sources evaluated have a containment factor value of greater than
0. The shortest distance from Source 1 to Hilliards Creek is the point at which the storm sewer north of
Building 67 discharges into Hilliards Creek, the same location as PPE-1 evaluated in the overland component
of the surface migration pathway (Refs. 10, pp. 1, 2, 3; 31, p. 34; 32, pp. 5, 6; 65, pp. 1, 2, 3; 97). Source
1 includes the sampling location MW-14 (see Section 2.4 of this documentation record for Source 1). The
shortest straight-line distance from Source 1 to Hilliards Creek is measured from MW-14. The shortest
4.2.1
General Considerations
4.2.1.1
Eligible Surface Water
176
-------
Ground Water (GW) to Surface Water (SW)
General Considerations
distance to surface water from Source 2 is measured from the location of the contaminated soil sample (TB-
73) adjacent to the pump house, which is located adjacent to Hilliards Creek (Ref. 31, Figure 3-2) and is
shown in Reference 97 as PPE-3. The shortest straight line distance from Source 3 to Hilliards Creek is
obtained by traveling the distance from the lagoons along the pipeline that extends from the lagoons into a
drainage channel (Hilliards Creek), the same location as PPE-2 evaluated in the overland component of the
surface migration pathway (Ref. 97). The pipeline makes the shortest straight line distance to surface water
from Source 3 (Ref. 7, pp. 10, 11). The shortest straight-line distance from Source 4, Former Tank Farm B,
to Hilliards Creek is obtained from measuring at sampling location MW-17(Ref. 31, Figure 3-2) as shown
on Reference 98 as PPE-4. A summary of the PPEs is presented in the table below and illustrated on
Reference 98.
TABLE 27
SUMMARY OF GROUND WATER TO SURFACE WATER
PROBABLE POINTS OF ENTRY
Source
Number
PPE
Number
Location of Shortest Distance Measurement
1
1
Measured from sampling location MW-14 (see Reference 31, Figure 3-2)
2
2
Measured from sampling location TB-73 (see Reference 31, Figure 3-2)
3
3
Measured from the western bank of the lagoons, along the pipeline, to
Hilliards Creek as shown in aerial photographs (See Reference 7, pp. 10,
11)
4
4
Measured from sampling location MW-17 (see Reference 31, Figure 3-2)
Notes:
MW Monitoring well
PPE Probable point of entry
TB Test boring
4.2.2.1.1 Observed Release to Ground Water
In this section, an observed release to the uppermost aquifer is established as specified in Section 3.1.1 of
Reference 1.
Regional Geology
The Lucas plant is located within the Atlantic Coastal Plain Physiographic Province. The Atlantic Coastal
Plain geology within Camden County is characterized by unconsolidated and semiconsolidated sediments
of Cretaceous through Quaternary ages consisting of alternating sand, silts, and clays. The sediments dip
gently to the southeast and thicken from approximately 40 feet at the Delaware River to over 2,900 feet at
the Camden-Atlantic County boundary. Below these unconsolidated sediments is pre-Cretaceous-age
bedrock (Ref. 109, pp. 1, 9).
177
-------
Ground Water (GW) to Surface Water (SW)
General Considerations
The Lucas plant is underlain by Pleistocene age sands of the Pennsauken Formation. The Pennsauken
Formation outcrops in irregular patches in Gibbsboro and ranges in thickness from a few feet to
approximately 30 feet. The Pennsauken Formation consists of medium- to coarse-grained quartzose sand,
gravel, and clay (Refs. 109, pp. 82, 83, 84; 31, p. 2-11, Appendix C).
The Kirkwood Formation underlies the Pennsauken Formation. The Kirkwood Formation consists of sand,
silt, and clay and reaches a thickness of approximately 80 feet in the vicinity of the Lucas plant (Refs. 109,
pp. 82, 83, 84; 31, p. 2-11).
Regional Hvdrogeology
The major freshwater aquifers in Camden County are sands and gravel of Cretaceous and Tertiary ages. The
Pennsauken and Kirkwood Formations are not typically used for potable water supply in Camden County.
The sands of the Pennsauken Formation and the upper section of the Kirkwood Formation form the shallow
subsurface of the Lucas plant and sources areas. These formations are approximately 20 to 30 feet thick in
the area of the plant and source areas and are generally hydraulically connected and form an unconfined
(water table) aquifer (Refs. 109, pp. 1, 9, 10, 22, 84; 31, p. 2-12 and Appendix C).
Aquifer Description
Ground water underlying the Lucas plant and sources at the plant occurs in two distinct zones: the shallow
zone (30 to 40 feet thick) and a deeper zone (total thickness unknown). The two zones are separated by a
silt unit (Ref. 31, p. 4-2). However, since releases of hazardous substances have been documented in both
zones, the two zones exchange water and are therefore interconnected and considered one aquifer, the
shallow aquifer (Refs. 1, Section 3.0.1; 31, pp. ES-l,ES-2, 5-8, 6-2, 6-6). The shallow aquifer is the aquifer
evaluated.
Shallow Aquifer (Stratum Name: Pennsauken and Kirkwood Formation)
The shallow aquifer is composed of reworked native soils, silty sand, and silt and is approximately 40 feet
thick (Ref. 31, p. 4-1). The saturated thickness of this aquifer is approximately 30 to 40 feet. Depth to
ground water is between 1 to 15 feet bgs. Ground water elevations indicate that the shallow zone flows from
the northeast to the southwest towards Hilliards Creek (Ref. 31, p. 4-2, Figure 4-7). Locally, Hilliards Creek
acts as a discharge zone for the shallow aquifer (Ref. 31, p. 4-2).
Free-phase product, composed of benzene, ethylbenzene, xylene, naphthalene, and 2-methyl naphthalene,
has been identified in the shallow aquifer (Ref. 31, p. ES-6).
178
-------
GW to SW Component - Observed Release
Direct Observation
Free-phase product has been identified at nine monitoring locations: MW-11, MW-13, MW-21, MW-26,
MW-27, WP-1, WP-3, WP-12, and WP-14. The estimated thickness of the free-phase product is between
0.22 and 0.42 foot (Ref. 31, p. 4-18). The presence offree-phase product in the monitoring wells documents
hazardous substances in direct contact with the ground water. Hazardous substances associated with the free-
phase product include 2-methylnaphthalene 4-chloroaniline, naphthalene, chlorobenzene , ethylbenzene,
xylene, benzene, benz(a)pyrene, chrysene, fluoranthene, naphthalene, cumene, tetrachlorothylene, 1,2, 4-
trimethylbenzene, 1,3,5-trimethylbenzene, aluminum, arsenic, barium, chromium, copper, iron, lead,
magnesium, manganese, and zinc (Ref. 31, pp. 3-3, 3-15, 3-17, Figure 3-2, Table 4-20; Ref.. 32, pp. 6, 7;
Ref. 77, pp. 1,2, 75, 76; Ref. 78, pp. 1 through 4, 13, 15, 16; Ref. 79, p. 28). See Section 2.2.1 for additional
information.
During sampling events from June 1993 through October 1993, three well points (WP-1, WP-2, and WP-3)
were installed to delineate the free-phase product ground water plume detected in MW-13 (Ref. 31, pp. 3-3,
3-15). Samples of free-phase product were collected from the MW-11 (located on the southern end of Tank
Farm A) and MW-13 (located east of Building 67) (Ref. 31, p. 3-17, Figure 3-2). Analytical results forthe
product sample collected from MW-11 on August 6, 1993 indicated the presence of 2-methylnaphthalene
(360 milligrams per liter [mg/L]), 4-chloroaniline (320 mg/L), naphthalene (930 mg/L), chlorobenzene (100
mg/L), ethylbenzene (at an estimated concentration of520 mg/L), and xylene (at 4,600 mg/L) (Ref. 31, Table
4-20). The product sample collected from MW-13 on August 6, 1993 contained 2-methylnaphthalene (1,800
mg/L), naphthalene (6,200 mg/L), benzene (at 110 mg/L), ethylbenzene (1,200 mg/L), and xylene (2,100
mg/L) (Ref. 31, Table 4-20).
During sampling events from July 1995 through August 1995, 45 hand-augered borings were located
throughout the seep area to attempt to delineate the extent of free-phase product through photoionization
detector (PID) field screening and visual observation. No samples were collected from these locations (Ref.
31, pp. 3-3,3 -18). Additional monitoring wells were installed, and two rounds of ground water samples were
collected (Ref. 31, p. 3-19). On July 14, 1995, samples of the free-phase product were collected from the
MW-11 (located on the southern end of Tank Farm A), MW-13 (located east of Building 67), and MW-21
(southeast of Building 67) (Ref. 31, p. 3-17, Figure 3-2). Anaytical results forthe product sample collected
from MW-11 indicated the presence of naphthalene (at an estimated concentration of 600 mg/L),
ethylbenzene (66 mg/L), and xylene (2,500 mg/L). The product sample collected from MW-13 contained
naphthalene (at 3,200 mg/L), benzene (at 570 mg/L), ethylbenzene (at 1,400 mg/L), and xylene (at 7,500
mg/L). Analytical results forthe product sample collected from MW-26 indicated 2-methylnaphthalene (at
an estimated concentration of460 mg/L), naphthalene (1,600 mg/L), and xylene (420 mg/L) (Ref. 31, Table
4-20).
On April 10, 2002, samples of the free-phase product were collected and analyzed for VOCs, petroleum
products, and fingerprinted (Ref. 75, pp. 2,4,5). The concentrations of hazardous substances detected in the
product samples are in the units of micrograms per kilogram (j^ig/kg) indicating that the samples were
analyzed as a solid. Analytical results for the samples indicated the presence of benzene (up to 240,000
(ig/kg), ethylbenzene (up to 4,600,000 (ig/kg), xylene (up to 26,000,000 (ig/kg), naphthalene (up to 1,800,000
(ig/kg), 2-methylnaphthalene (up to an estimated concentration of400,000 |_ig/kg). and numerous TICs (Ref.
75, pp. 6, 7, 8).
179
-------
GW to SW Component - Observed Release
Chemical Analysis
Aquifer being evaluated: Shallow Aquifer
An observed release to ground water is documented by ground water samples collected from monitoring wells
located on the Lucas plant during RI activities. The background ground water samples are selected based on
whether the background and release ground water samples were collected within the same screened interval
and period of time, and whether the samples were analyzed for the same hazardous substances. All ground
water samples collected during the RI from 1990 to 1997 were analyzed by Weston Analytics Division, a
New Jersey-certified laboratory. All samples collected from 1998 to 2000 were analyzed by Severn-Trent
Laboratories (STL), a New Jersey-certified laboratory (Ref. 31, p. 3-37). Reference 111 provides a Quality
Assurance Project Plan used by Sherwin-Williams' environmental consultant. The plan provides analytical
methods, quantitation limits, and detection limits for some of the investigations conducted by Sherwin-
Williams' (Ref. 111). It is likely that these same methods were used for analyzing the samples summarized
in this section. Analytical data sheets from the laboratories and detection limits are not provided in the RI;
however, the RI report states that the analytical data are valid. The analytical results used to document an
observed release to ground water are considered usable and of known quality (Ref. 31, p.
3-38). Table 3-1 of Reference 31 provides a summary of the analytical suite for the ground water samples.
The tables presenting the analytical results in the RI report provide only concentrations detected (Ref. 31,
Tables 4-9, 4-11, 4-14). Tables 4-9, 4-11, and 4-14 of Reference 31 provide a summary of the hazardous
substances detected in ground water samples. When concentrations of metals are reported in Tables 4-9,
4-11, and 4-14 of Reference 31 as soluble, the reported concentration is for dissolved metal. The dissolved
metals concentrations are not used to document an observed release to ground water.
Background Concentrations:
Ground water investigations conducted at the Lucas plant have determined that the free-phase product plume
in the shallow aquifer is limited to the east of Hilliards Creek (Ref. 31, p. ES-4). The RI activities
determined, based on ground water elevations, the shallow aquifer flows from the northeast to the southwest
towards Hilliards Creek (Ref. 31, p. 4-2, Figure 4-7) and is divided into a shallow and deep zone (Ref. 31,
p. 4-2). Therefore, background well selection is based on whether the wells are screened within the same
relative depth of the shallow aquifer. The RI activities did not establish a location of a background well.
Therefore, wells installed on the Lucas Plant were reviewed to identify potential background well sampling
locations. The RI activities included the installation of monitoring wells at biased locations or locations
where contamination was expected to be located based site use history or previous sampling activities.
Therefore, the majority of the monitoring wells located on the Lucas plant were installed in areas of potential
contamination. No monitoring well located outside the influence of potential sources of contamination on
179 a
-------
GW to SW Component - Observed Release
the Lucas plant was identified that could be used to establish background concentrations for the shallow zone
of aquifer on the east side of Hilliards Creek. The analytical data for ground water samples collected from
monitoring well (MW) 14, indicate that the ground water contamination from the Lucas plant has not
contaminated the ground water at MW-14. Although MW-14 is located on the Lucas plant in areas of known
contamination, the well is used to establish background concentrations for the shallow zone of the aquifer on
the east side of Hilliards Creek because analytical data indicate that operations at the Lucas plant have not
released hazardous substances to the well, as documented in the sections below. MW-14 is located north of
Building 67 (Ref. 31, Figure 3-2). Ground water samples were collected from MW-14 during four separate
sampling activities (Ref. 31, Table 3-1, p. 3). As documented in the section below, during each sampling
activity, no significant concentrations of hazardous substances were detected in the ground water samples.
MW-20 is also used to establish background SVOC and VOC concentrations for the shallow zone of the
aquifer on the east side of Hilliards Creek for the 1993 sampling activity. The monitoring well is screened
in the shallow zone of the aquifer and is located on the northwest side of Building 55 (Ref. 31, Table 4-1, p.
2 and Figure 3-2). The ground water samples collected from MW-20 were analyzed for SVOCs and VOCs
(Ref. 31, Table 3-1). MW-28, located northeast of the Lucas plant, is also used to establish background
concentrations for the shallow zone of the aquifer on the east side of Hilliards Creek (Ref. 31, Figure 3-2).
MW-28 is screened in the shallow portion of the aquifer (Ref. 31, Table 4-1, p. 2). Ground water samples
were collected from the well in 1993 and analyzed for SVOCs and VOCs and in 1995 and analyzed for
inorganic compounds (Ref. 31, Table 3-1).
Other background ground water samples for the shallow zone of the aquifer were collected from 47
Hydropunch™ sampling locations (SGW-200 sample identification sequence), excluding SGW-278, SGW-
280, and SGW-300, for screening analyses. Thirty-nine shallow ground water-screening samples were
collected from the Hydropunch™ locations and analyzed for BTEX. Analytical data for the SGW sampling
locations SGW-200; SGW-204; SGW- 210; and SGW-286 are presented to illustrate that the BTEX
compounds detected in the shallow zone of the aquifer on the east side of Hilliards Creek are not migrating
from a source northeast of the Lucas plant (ground water flows from the northeast to the southwest) (Ref. 31,
p. 4-7, Figure 4-7). The Lucas plant is the only potential source of the BTEX ground water contamination.
MW-16 is used to establish background concentrations for shallow zone of the aquifer on the west side of
Hilliards Creek and is located in the area of Tank Farm B (Ref. 31, Table 3-1, p. 2, and Figure 3-2). Although
Tank Farm B (Source 4) is a potential source of ground water contamination, analytical results for samples
collected from MW-16 have not indicated significant concentrations of hazardous substances (Ref. 31, Table
4-9). The only contaminant detected in ground water samples collected from MW-16 at significant
concentrations is lead, up to 10 j^ig/L. This may reflect ground water contamination from Tank Farm B (Ref.
31, Table 4-9).
Two monitoring wells are used to establish background concentrations for the deep zone of the aquifer, MW-
32 and MW-34 (Ref. 31, Table 3-1, p. 2). MW-32 is located on the east side of Hilliards Creek in the eastern
section of the Lucas plant, near the gasoline station, upgradient of the source areas. MW-34 is located on the
east side of Hilliards Creek in the far northeastern portion of the Lucas plant upgradient of source areas.
Monitoring well locations are shown in Reference 31, Figure 3-2.
Based on similar screened intervals, dates of collection, analytical and collection procedures, and analytical
180
-------
GW to SW Component - Observed Release to Ground Water
parameters, the samples collected from MW-14, MW-16, MW-20, MW-28, MW-32, and MW-34 are
considered to be adequate background samples. Ground water samples collected from Hydropunch™
background sampling locations are presented to illustrate that no source of BTEX contamination is located
northeast of the Lucas plant. Although the ground water samples were collected for screening purposes only
and were not collected from completed monitoring wells, presentation of these background concentrations
provides additional evidence that the Lucas plant is the source of BTEX contamination in groundwater.
There are numerous instances where analytical results from the analysis of the samples are not provided in
the RI summary of detections tables. For example, in the years 1999 and 2000, ground water samples were
collected from MW-32 and analyzed for VOCs and SVOCs (Ref. 31, Table 3-1). Analytical results for
samples collected on those dates are not provided in the summary of detections tables presented in the RI
(Ref. 31, Table 4-11). It is likely that the results were notrecorded because no hazardous substances were
detected in the ground water samples collected on those dates.
No background ground water sample analytical results were identified in the RI for years 1999 and 2000.
Therefore, data for groundwater samples collected from the date closest to the years 1999 and 2000 are used
to establish background concentrations. In many cases, background ground water samples were collected
a year or more before the release ground water sample was collected. Although the background samples used
were collected up to a year or more before the release ground water samples, the background samples used
are considered adequate because the hazardous substances detected in the release ground water samples are
not naturally occurring, are established as being present in the shallow aquifer underlying the Lucas plant,
and are at least partially attributable to the Lucas plant.
The construction details for the background monitoring wells are summarized in Table 28. As shown in
Table 28, MW-32 and MW-34 are screened at a greater depths than MW-14, MW-16, MW-20, and MW-28.
MW-14, MW-20, andMW-28 are used to establish background conditions for the shallow zone ofthe aquifer
located on the east side of Hilliards Creek. MW-16 is used to establish background conditions for the
shallow zone of the aquifer on the west side of Hilliards Creek. MW-32 and MW-34 are used to establish
background conditions for the deep zone of the aquifer on the east side of Hilliards Creek. Background
ground water samples are compared to release ground water samples collected from monitoring wells
screened within the same relative interval. Ground water samples collected from Hydropunch™ sampling
locations SWG-200; SWG-204; SWG-210; SWG-212; and SWG-286 are used to illustrate that no BTEX
source is located northeast of the plant on east side of Hilliards Creek. No construction information for
Hydropunch™ wells is available (Ref. 31, p. 3-14).
181
-------
GW to SW Component - Observed Release to Ground Water
TABLE 28
BACKGROUND MONITORING WELL CONSTRUCTION DETAILS
Monitoring Well ID
Depth (ft msl)
Screened
Interval (ft msl)
Reference
MW-14
74.28
85.28-74.28
31, Appendix C, p. 21
MW-16
78.60
88.60-78.60
31, Appendix C, p. 25
MW-20
58.19
68.19 - 58.19
31, Appendix C, p. 52
MW-28
84.57
104.57-84.57
31, Table 4-1, p. 2
MW-32
25.13
30.13 - 25.13
31, Appendix C, p. 117
MW-34
17.21
27.1 - 17.21
31, Appendix C, p. 137
SGW-200
shallow
NA
31, p. 3-14
SGW-204
shallow
NA
31, p. 3-14
SGW-210
shallow
NA
31, pp. 3-14
SGW-212
shallow
NA
31, pp. 3-14
SGW-286
shallow
NA
31, pp. 3-14
Notes:
ft Foot
ID Identification
MW Monitoring well
msl Mean sea level
NA Not Available
SGW These samples are not used for documenting background or release concentrations. They are used
to show background concentrations for other shallow ground water monitoring (SGW) locations that
are presented in the release sample tables. The SGW locations are presented to illustrate that BTEX
are not migrating from northeast of the Lucas plant.
Table 29 summarizes the analytical parameters for ground water samples collected from MW-14; MW-16;
MW-20; MW-28; MW-32; MW-34; SGW-200; SGW-204; SGW-210; SGW-212; and SGW-286. The
reference documentation does not describe the analytical methods used to analyze the ground water samples
or the detection limits (Ref. 31, Table 3-1, pp. 4, 8). Table 29 presents the analytical parameters exactly as
they appear in Reference 31, Table 3-1. Table 3-1 of Reference 31 indicates that ground water samples
collected from MW-34 were analyzed for VOCs on February 3, 1999; March, 24, 1999; and January 14,
2000. However, the VOC analytical results for MW-34 are not provided in the summary of detections tables
in the RI report (Ref. 31, Table 4-11). Because the summary of VOC detections for MW-34 is missing from
the RI, MW-32 is used to establish background concentrations for VOCs in ground water collected from
182
-------
GW to SW Component - Observed Release to Ground Water
within the same relative screened interval and dates. Because Table 4-11 of Reference 31 provides only a
summary of detections, it is likely that no VOCs were detected in ground water samples collected from MW-
34 and therefore, no analytical results were provided in Table 4-11 of Reference 31 for MW-34.
The rational or purpose for selecting the locations of the monitoring wells used to establish background
conditions for the Lucas plant is not provided in the RI. The text of the RI does not discuss MW-32 and
MW-34. However, the RI does discuss the purpose for some of the monitoring well locations. The RI
indicates that from August 1991 through January 1992, during Phase I of the RI (Ref. 31, p. 3-3), MW-14
was installed in the ground water seep area to define ground water flow direction and to monitor ground
water conditions (Ref. 31, pp. 3-1, 3-11). Ground water samples were collected from MW-14 and analyzed
for PP VOA+15, PPbase neutral acids (BNA), phenols, lead, barium, and chromium (Ref. 31, p. 3-31). A
list of PP VOA and BNAs is provided in Reference 96. During Phase II of the RI a ground water sample was
collectedfromMW-14 and analyzed for lead (Ref. 31, p. 3-17). According to the RI, ground water samples
were collected from MW-28 for the purpose of characterizing specific water qualify parameters required for
remedial design options (Ref. 31, p. 3-19). The RI also indicates that MW-16 was installed in the vicinity
of the former Tank Farm B during Phase I ofthe RI (Ref. 31, pp. 3-1, 3-3,3-31). Groundwater samples were
collected from MW-16 and analyzed for PP VOA+15, PP base neutral acids (BNA), phenols, lead, barium,
and chromium (Ref. 31, p. 3-31). From June 1993 through October 1993, during Phase II ofthe RI(Ref. 31,
p. 3-3), ground water samples were collected from MW-16 and analyzed for VOC+10, SVOC+20, and lead
(Ref. 31, p. 3-32). From July 1998 through January 2000, during Phase V of the RI (Ref. 31, p. 3-3), ground
water samples were collected from MW-16 to confirm the presence of PCP based on previous analytical
results (Ref. 31, p. 3-33). MW-20 was installed at greater depths in the water table aquifer (Ref. 31, p. 3-15).
The concentrations of hazardous substances detected in ground water samples collected from MW-14; MW-
16; MW-20; MW-28; MW-32; MW-34; SGW-200; SGW-204; SGW-210; SGW-212; and SGW-286 are
summarized in Table 30. In many cases, hazardous substances listed in Table 30 do not appear in the
summary of detections tables (Ref. 31, Tables 4-9, 4-11, and 4-14) used to prepare Table 30. Since the
hazardous substance is not detected, the hazardous substance is not listed in the summary of detections tables.
Not all hazardous substances analyzed for are listed in the summary of detections tables presented in the RI
(Ref. 31, Tables 4-9, 4-11, and 4-14). In some cases, no analytical results are presented in the tables
indicating the none of substances analyzed for were detected. In many cases, a blank space appears in the
cell of the summary of detections tables. A blank cell indicates that the hazardous substance was not
detected. The detection limit followed by the laboratory data qualifier is not used to denote "not detected,"
as is most commonly practiced. The analytical results for the analysis of ground water collected from MW-
28 on August 5, 1993 for SVOCs and VOCs, on September 9,1993 for VOC, and July 14, 1995 for metals
are provided in Table 3-11 (Ref. 31, Table 3-1, p. 3 and Table 4-11, pp. 7,20,26). Because analytical results
are not provided in the summary table, no concentrations of hazardous substances were detected in the
ground water samples. The summary table only provides a summary of detections.
183
-------
GW to SW Component - Observed Release to Ground Water
TABLE 29
SUMMARY OF SAMPLING AND ANALYSIS FOR BACKGROUND
MONITORING WELLS
Sample ID
Collection
Date
Parameters
Reference
Ground Water Samples from MW-14 (shallow well)
014-M003
08/04/1991
Metals
Semivolatiles
Volatiles
31, Table 3-1 (p. 3)
014-M001
12/04/1991
Metals
Semivolatiles
Volatiles
31, Table 3-1 (p. 3)
014-M002
01/01/1992
Metals
Semivolatiles
Volatiles
31, Table 3-1 (p. 3)
014-M004
09/10/1993
Metals
Semivolatiles
Volatiles
31, Table 3-1 (p. 3)
MW14-
GW4
11/11/1996
Metals
31, Table 3-1 (p. 3)
Ground Water Samples from MW-16 (shallow well)
016-M001
12/5/1991
Metals
Semivolatiles
Volatiles
31, pp. 3-31, 3-32,
Table 3-1 (p. 8)
016-M002
01/07/1992
Metals
Semivolatiles
Volatiles
31, pp. 3-31, 3-32,
Table 3-1 (p. 8)
016-M003
08/05/1993
Metals
Semivolatiles
Volatiles
31, pp. 3-31, 3-32,
Table 3-1 (p. 8)
016-M004
09/08/1993
Metals
Semivolatiles
Volatiles
31, pp. 3-31, 3-32,
Table 3-1 (p. 8)
184
-------
GW to SW Component - Observed Release to Ground Water
TABLE 29 (Continued)
SUMMARY OF SAMPLING AND ANALYSIS FOR BACKGROUND
MONITORING WELLS
Sample ID
Collection
Date
Parameters
Reference
016-M203
08/05/1993
Semivolatiles
Volatiles
31, pp. 3-31, 3-32,
Table 3-1 (p. 8)
Ground Water Samples from MW-20 (shallow well)
020-M003
08/09/1993
Semivolatiles
Volatiles
31, Table 3-1 (p. 3)
020-M004
09/08/1993
Semivolatiles
Volatiles
31, Table 3-1 (p. 3)
Ground Water Samples from MW-28 (shallow well)
028-M003
08/05/1993
Semivolatiles
Volatiles
31, Table 3-1 (p. 4)
028-M004
09/09/1993
Semivolatiles
Volatiles
31, Table 3-1 (p. 4)
028-M005
07/14/1995
Inorganics
31, Table 3-1 (p. 4)
Ground Water Samples from MW-32 (deep well)
MW32-
GW4
11/05/1996
Inorganics
Metals
Semivolatiles
Volatiles
31, Table 3-1 (p. 4)
GW5-
MW32
01/22/1997
Inorganics
Metals
Semivolatiles
Volatiles
31, Table 3-1 (p. 4)
MW-32
02/04/1999
Inorganics
Metals
Semivolatiles
Volatiles
31, Table 3-1 (p. 4)
185
-------
GW to SW Component - Observed Release to Ground Water
TABLE 29 (Continued)
SUMMARY OF SAMPLING AND ANALYSIS FOR BACKGROUND
MONITORING WELLS
Sample ID
Collection
Date
Parameters
Reference
Ground Water Samples from MW-32 (deep well) (Continued)
MW-32
1/14/2000
Inorganics
Metals
Semivolatiles
Volatiles
31, Table 3-1 (p. 4)
Ground Water Samples from MW-34 (deep well)
MW-34
2/3/1999
Inorganics
Metals
Semivolatiles
Volatiles
31, Table 3-1 (p. 4)
MW-34
3/24/1999
Inorganics
Metals
Semivolatiles
Volatiles
31, Table 3-11 (p. 4)
MW-34
1/14/2000
Inorganics
Metals
Semivolatiles
Volatiles
31, Table 3-11 (p. 4)
Hydropunch™ ground water samples (shallow ground water)
SGW-200
06/22/1993
BTEX (benzene, toluene, ethyl benzene,
xylene)
31, Table 3-11 (p. 2)
SGW-204
06/22/1993
BTEX
31, Table 3-11 (p. 2)
SGW-210
06/22/1993
BTEX
31, Table 3-11 (p. 2)
SGW-212
06/22/1993
BTEX
31, Table 3-11 (p. 2)
SGW-286
06/22/1993
BTEX
31, Table 3-11 (p. 2)
186
-------
GW to SW Component - Observed Release to Ground Water
TABLE 29 (Continued)
SUMMARY OF SAMPLING AND ANALYSIS FOR BACKGROUND
MONITORING WELLS
Notes:
BTEX benzene, toluene, ethylbenzene, and xylene
GW Ground water
ID Identification
MW Monitoring well
SGW Shallow ground water
187
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30
BACKGROUND CONCENTRATIONS
MW ID
Field Sample ID
Hazardous
Substance
Cone.
(Mg/L)
Q
Detection
Limits
(^g/L)
Date
Reference
MW-14
Volatile Organic Compounds
08/04
31, Table 4-11
(014-M003)
Acetone
12
B
10
/1991
(pp. 4, 16, 25);
112, pp. 2, 3,
4, 5
2-Butanone
ND
10
Benzene
3 (4.94)*
J
10
Carbon disulfide
ND
10
Chlorobenzene
ND
10
Chloroform
ND
10
1,1 -Dichloroethane
ND
10
Ethylbenzene
ND
10
Methylene chloride
26
B
10
Styrene
ND
10
Toluene
ND
10
Total 1,2-dichloroethene
5(50)*
J
10
Vinyl chloride
ND
10
Xylene (total)
ND
10
Semivolatile Organic Compounds
Acenaphthene
ND
10
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
4-Methylphenol
ND
10
2-Methylnaphthalene
ND
10
Naphthalene
ND
10
4-Nitrophenol
ND
25
Pentachlorophenol
ND
25
Phenol
ND
10
2,4,5-Trichlorophenol
ND
25
Metals
188
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
MW ID
Field Sample ID
Hazardous
Substance
Cone.
(Mg/L)
Q
Detection
Limits
(^g/L)
Date
Reference
Lead
2.4
3
MW-14
Volatile Organic Compounds
12/04
31, Table 4-11
(014-M001)
Acetone
12
B
10
/1991
(pp. 4, 16, 25);
112, pp. 2, 3,
4, 5
2-Butanone
ND
10
Benzene
3 (4.94)*
J
10
Carbon disulfide
ND
10
Chlorobenzene
ND
10
Chloroform
ND
10
1,1 -Dichloroethane
ND
10
Ethylbenzene
ND
10
Methylene chloride
26
B
10
Styrene
ND
10
Toluene
ND
10
Total-1,2-dichloroethene
5(50)*
J
10
Vinyl chloride
ND
10
Xylene (total)
ND
10
Semivolatile Organic Compounds
Acenaphthene
ND
10
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
4-Methylphenol
ND
10
2-Methylnaphthalene
ND
10
Naphthalene
ND
10
4-Nitrophenol
ND
25
Pentachlorophenol
ND
25
Phenol
ND
10
2,4,5-Trichlorophenol
ND
25
189
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
Detection
MW ID
Hazardous
Cone.
Limits
Field Sample ID
Substance
(Mg/L)
Q
(^g/L)
Date
Reference
Metals
Lead
2.4
3
MW-14
Volatile Organic Compounds
01/08
31, Table 4-11
(014-M002)
Acetone
47
B
10
/1992
(pp. 4, 16, 25);
112, pp. 2, 3,
4, 5
2-Butanone
ND
10
Benzene
3 (4.94)*
J
10
Carbon disulfide
ND
10
Chlorobenzene
ND
10
Chloroform
ND
10
1,1 -Dichloroethane
ND
10
Ethylbenzene
ND
10
Methylene chloride
27
10
Styrene
ND
10
Toluene
ND
10
Total 1,2-dichloroethene
5(50)*
J
10
Vinyl chloride
ND
10
Xylene (total)
ND
10
Semivolatile Organic Compounds
Acenaphthene
ND
10
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
4-Methylphenol
ND
10
2-Methylnaphthalene
ND
10
Naphthalene
ND
10
4-Nitrophenol
ND
25
Pentachlorophenol
ND
25
Phenol
ND
10
190
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
MW ID
Field Sample ID
Hazardous
Substance
Cone.
(Mg/L)
Q
Detection
Limits
(^g/L)
Date
Reference
2,4,5-Trichlorophenol
ND
25
Metals
Lead
ND
3
MW-14
Volatile Organic Compounds
09/10
31, Table 4-11
(014-M004)
Acetone
20
B
10
/1993
(pp. 4, 16, 25);
112, pp. 2, 3,
4, 5
2-Butanone
ND
10
Benzene
ND
10
Carbon disulfide
ND
10
Chlorobenzene
ND
10
Chloroform
ND
10
1,1 -Dichloroethane
ND
10
Ethylbenzene
ND
10
Methylene chloride
11
B
10
Styrene
ND
10
Toluene
ND
10
Total 1,2-dichloroethene
5(50)*
J
10
Vinyl chloride
ND
10
Xylene (total)
ND
10
Semivolatile Organic Compounds
Acenaphthene
ND
10
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
4-Methylphenol
ND
10
2-Methylnaphthalene
ND
10
Naphthalene
ND
10
4-Nitrophenol
ND
25
Pentachlorophenol
ND
25
191
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
Detection
MW ID
Hazardous
Cone.
Limits
Field Sample ID
Substance
(Mg/L)
Q
(^g/L)
Date
Reference
Phenol
ND
10
2,4,5-Trichlorophenol
ND
25
Metals
Lead
4.4
3
MW-16
Volatile Organic Compounds
12/05
31, pp. 3-31,
016-M001
Acetone
14
B
10
/1991
Table 3-1 (p.
8), Table 4-9
(PP. 1, 3, 5);
2-Butanone
ND
10
Benzene
ND
10
112, pp. 2, 3,
4, 5
Carbon disulfide
ND
10
Chlorobenzene
ND
10
Chloroform
ND
10
1,1 -Dichloroethane
ND
10
Ethylbenzene
ND
10
Methylene chloride
12
B
10
Styrene
ND
10
Toluene
ND
10
Total-1,2-dichloroethene
ND
10
Vinyl chloride
ND
10
Xylene (total)
ND
10
Semivolatile Organic Compounds
Acenaphthene
ND
10
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
4-Methylphenol
ND
10
2-Methylnaphthalene
ND
10
Naphthalene
ND
10
4-Nitrophenol
ND
25
192
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
Detection
MW ID
Hazardous
Cone.
Limits
Field Sample ID
Substance
(Mg/L)
Q
(^g/L)
Date
Reference
Pentachlorophenol
ND
25
Phenol
ND
10
2,4,5-Trichlorophenol
ND
25
Metals
Lead
10
3
MW-16
Volatile Organic Compounds
01/07
31, pp. 3-31,
016-M002
Acetone
ND
10
/1992
Table 3-1 (p.
8), Table 4-9
(PP. 1,3,5);
2-Butanone
ND
10
Benzene
ND
10
112, pp. 2, 3, 5
Carbon disulfide
ND
10
Chlorobenzene
ND
10
Chloroform
ND
10
1,1 -Dichloroethane
ND
10
Ethylbenzene
ND
10
Methylene chloride
8
10
Styrene
ND
10
Toluene
ND
10
Total-1,2-dichloroethene
ND
10
Vinyl chloride
ND
10
Xylene (total)
ND
10
Semivolatile Organic Compounds
Acenaphthene
ND
10
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
4-Methylphenol
ND
10
2-Methylnaphthalene
ND
10
Naphthalene
ND
10
193
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
MW ID
Field Sample ID
Hazardous
Substance
Cone.
(Mg/L)
Q
Detection
Limits
(^g/L)
Date
Reference
4-Nitrophenol
ND
25
Pentachlorophenol
2 (20.24)*
J
25
Phenol
ND
10
2,4,5-Trichlorophenol
ND
25
Metals
Lead
3
3
MW-16
Volatile Organic Compounds
08/05
31, pp. 3-32,
016-M003
Acetone
ND
10
/1993
Table 3-1 (p.
8), Table 4-9
(PP. 1, 3, 5);
2-Butanone
ND
10
Benzene
ND
10
112, pp. 1,2,
3,4,5
Carbon disulfide
ND
10
1,1 -Dichloroethane
ND
10
Ethylbenzene
ND
10
Methylene chloride
ND
10
Styrene
ND
10
Toluene
ND
10
Total-1,2-dichloroethene
ND
10
Vinyl chloride
ND
10
Xylene (total)
ND
10
Semivolatile Organic Compounds
Acenaphthene
ND
10
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
2-Methylnaphthalene
ND
10
4-Methylphenol
ND
10
Naphthalene
ND
10
4-Nitrophenol
ND
25
Pentachlorophenol
ND
25
194
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
MW ID
Field Sample ID
Hazardous
Substance
Cone.
(Mg/L)
Q
Detection
Limits
(^g/L)
Date
Reference
Phenol
ND
10
2,4,5-Trichlorophenol
ND
25
Metals
Lead
5
3
MW-20
Volatile Organic Compounds
08/09
31, Table 4-11
(020-M003)
Acetone
14
B
10
/1993
(p. 5); 112, pp.
2, 3,4, 5
2-Butanone
ND
10
Benzene
2 (3.28)*
J
10
Carbon disulfide
ND
10
Chlorobenzene
ND
10
Chloroform
ND
10
1,1 -Dichloroethane
ND
10
Ethylbenzene
ND
10
Methylene chloride
ND
10
Styrene
ND
10
Toluene
ND
10
Total-1,2-dichloroethene
8(80)*
J
10
Vinyl chloride
ND
10
Xylene (total)
ND
10
Semivolatile Organic Compounds
Acenaphthene
ND
10
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
4-Methylphenol
ND
10
2-Methylnaphthalene
ND
10
Naphthalene
ND
10
4-Nitrophenol
ND
25
195
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
MW ID
Field Sample ID
Hazardous
Substance
Cone.
(Mg/L)
Q
Detection
Limits
(^g/L)
Date
Reference
Pentachlorophenol
ND
25
Phenol
ND
10
2,4,5-Trichlorophenol
ND
25
MW-20
Volatile Organic Compounds
09/08
31, Table 4-11
(020-M004)
Acetone
12
B
10
/1993
(p. 5); 112, pp.
2, 3,4, 5
2-Butanone
ND
10
Benzene
4 (6.56)*
J
10
Carbon disulfide
ND
10
Chlorobenzene
ND
10
Chloroform
ND
10
1,1 -Dichloroethane
ND
10
Ethylbenzene
3 (30)*
J
10
Methylene chloride
ND
10
Styrene
ND
10
Toluene
ND
10
Total-1,2-dichloroethene
3 (30)*
J
10
Vinyl chloride
ND
10
Xylene (total)
ND
10
Semivolatile Organic Compounds
Acenaphthene
ND
10
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
4-Methylphenol
ND
10
2-Methylnaphthalene
ND
10
Naphthalene
ND
10
4-Nitrophenol
ND
25
Pentachlorophenol
ND
25
196
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
Detection
MW ID
Hazardous
Cone.
Limits
Field Sample ID
Substance
(Mg/L)
Q
(^g/L)
Date
Reference
Phenol
ND
10
2,4,5-Trichlorophenol
ND
25
MW-28
Volatile Organic Compounds
08/05
31, Table 3-1
(028-M003)
Acetone
ND
10
/1993
(p. 4), Table
4-11 (pp. 7,
20) See
2-Butanone
ND
10
Benzene
ND
10
comments in
the notes at
the end the of
Carbon disulfide
ND
10
Chlorobenzene
ND
10
the table.; 112,
Chloroform
ND
10
pp. 1, 2, 3, 4,
•s
1,1 -Dichloroethane
ND
10
Ethylbenzene
ND
10
Methylene chloride
ND
10
Styrene
ND
10
Toluene
ND
10
Total-1,2-dichloroethene
ND
10
Vinyl chloride
ND
10
Xylene (total)
ND
10
Semivolatile Organic Compounds
Acenaphthene
ND
10
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
2-Methylphenol
ND
10
2-Methylnaphthalene
ND
10
Naphthalene
ND
10
Pentachlorophenol
ND
25
Phenol
ND
10
2,4,5-Trichlorophenol
ND
25
197
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
MW ID
Field Sample ID
Hazardous
Substance
Cone.
(Mg/L)
Q
Detection
Limits
(^g/L)
Date
Reference
MW-28
Volatile Organic Compounds
09/09
31, Table 3-1
(028-M004)
Acetone
ND
10
/1993
(p.4), Table 4-
11
(PP. 7, 20)
2-Butanone
ND
10
Benzene
ND
10
See comments
in the notes at
the end the of
Carbon disulfide
ND
10
Chlorobenzene
ND
10
the table.; 112,
Chloroform
ND
10
pp. 1, 2, 3, 4,
5
1,1 -Dichloroethane
ND
10
Ethylbenzene
ND
10
Methylene chloride
ND
10
Styrene
ND
10
Toluene
ND
10
Total-1,2-dichloroethene
ND
10
Vinyl chloride
ND
10
Xylene (total)
ND
10
Semivolatile Organic Compounds
Acenaphthene
ND
10
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
4-Methylphenol
ND
10
2-Methylnaphthalene
ND
10
Naphthalene
ND
10
4-Nitrophenol
ND
25
Pentachlorophenol
ND
25
Phenol
ND
10
2,4,5-Trichlorophenol
ND
25
198
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
MW ID
Field Sample ID
Hazardous
Substance
Cone.
(Mg/L)
Q
Detection
Limits
(^g/L)
Date
Reference
MW-28
028-MOO 5
Metals
07/14
/1995
31, Table 3-11
(p. 4) and
Table 4-11 (p.
26) See
comments in
the notes at
the end the of
the table.;
112, p. 5
Lead
ND
3
MW-32
MW32-GW4
Volatile Organic Compounds
11/05
/1996
31,Table 4-11
(PP. 8, 19);
112, pp., 2, 3,
4, 5
Acetone
0.3
BJ
10
2-Butanone
ND
10
Benzene
ND
10
Carbon disulfide
ND
10
1,1 -Dichloroethane
ND
10
Ethylbenzene
ND
10
Methylene chloride
0.6
BJ
10
Styrene
ND
10
Toluene
ND
10
Total 1,2-dichloroethene
ND
10
Vinyl chloride
ND
10
Xylene
ND
10
Semivolatile Organic Compounds
Acenaphthene
ND
10
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
2-Methylnaphthalene
ND
10
4-Methylphenol
ND
10
Naphthalene
ND
10
199
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
MW ID
Field Sample ID
Hazardous
Substance
Cone.
(Mg/L)
Q
Detection
Limits
(^g/L)
Date
Reference
Pentachlorophenol
ND
25
Phenol
ND
10
2,4,5-Trichlorophenol
ND
25
MW-32
Volatile Organic Compounds
01/22
31, Table 4-11
GW5-MW32
Acetone
22
10
/1997
(p. 8); 112, pp.
2, 3,4, 5
2-Butanone
ND
10
Benzene
ND
10
Benzoic Acid
50
Carbon disulfide
ND
10
Cresol (ortho)
10
1,1 -Dichloroethane
ND
10
Ethylbenzene
ND
10
Methylene chloride
1
BJ
10
Styrene
ND
10
Toluene
ND
10
Total-1,2-dichloroethene
ND
10
Trichloroethene
10
Vinyl chloride
ND
10
Xylene (total)
ND
10
MW-32
Semivolatile Organic Compounds
01/14
31 Table 4-11
MW-32
Acenaphthene
ND
10
/2000
(p. 19); 112,
pp. 2, 3, 4, 5
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
2-Methylphenol
ND
10
Naphthalene
ND
10
Pentachlorophenol
ND
25
Phenol
ND
10
200
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
MW ID
Field Sample ID
Hazardous
Substance
Cone.
(Mg/L)
Q
Detection
Limits
(^g/L)
Date
Reference
2,4,5-Trichlorophenol
ND
25
MW-34
Semivolatile Organic Compounds
02/03
31 Table 4-11
MW-34
Acenaphthene
ND
10
/1999
(p. 19); 112,
pp. 2, 3, 4, 5
Benzoic acid
ND
50
2-Chloronaphthalene
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
4-Methylphenol
ND
10
2-Methylnaphthalene
ND
10
Naphthalene
ND
10
Pentachlorophenol
ND
25
Phenol
ND
10
MW-34
Semivolatile Organic Compounds
03/24
31, Table 4-11
MW-34
Acenaphthene
ND
10
/1999
(p. 19); 112,
pp. 2, 3, 4, 5
Benzoic acid
ND
50
2-Chlorophenol
ND
10
Cresol
ND
10
Dibenzofuran
ND
10
2,4-Dimethylphenol
ND
10
Fluorene
ND
10
4-Methylphenol
ND
10
2-Methylnaphthalene
ND
10
Naphthalene
ND
10
Pentachlorophenol
ND
25
Phenol
ND
10
Vinyl Chloride
ND
10
201
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
MW ID
Field Sample ID
SGW-200
Hazardous
Substance
Cone.
(Mg/L)
Q
Detection
Limits
(^g/L)
10
10
10
10
Date
06/22
/1993
Reference
3, Table 4-11
(p. 10); 112,
pp. 2,3,4,5
BTEX
Benzene
ND
Toluene
ND
Ethyl benzene
ND
Xylene
1.2
SGW-204
BTEX
06/22
/1993
3, Table 4-11
(p. 10); 112,
p. 2
Benzene
0.16
(0.26)*
J
10
Toluene
ND
10
Ethyl benzene
ND
10
Xylene
1.2
10
SGW-210
BTEX
06/22
/1993
3, Table 4-11
(p. 11); 112,
pp. 2
Benzene
0.36
(0.59)
J
10
Toluene
ND
10
Ethyl benzene
ND
10
Xylene
0.48
(4.8)*
J
10
SGW-212
BTEX
06/23
/1993
3, Table 4-11
(p. 11) No
BTEX
detected.
Therefore,
analytical
results are not
presented in
Table 4-11;
112, pp. 2
Benzene
ND
10
Toluene
ND
10
Ethyl benzene
ND
10
Xylene
ND
10
SGW-286
BTEX
06/29
/1993
3, Table 4-11
(p. 13); 112,
pp. 2
Benzene
0.15
(0.25)*
J
10
Toluene
1.7
10
Ethyl benzene
0.45 (4.5)*
J
10
202
-------
GW to SW Component - Observed Release to Ground Water
TABLE 30 (Continued)
BACKGROUND CONCENTRATIONS
Detection
MW ID
Hazardous
Cone.
Limits
Field Sample ID
Substance
(Mg/L)
Q
(^g/L)
Date
Reference
Xylene
3.3
10
Notes:
() Adjusted concentration ID
B Detected in the laboratory blank J
BTEX Benzene, toluene, ethylbenzene, xylene MW
Cone. Concentration S
(ig/L Microgram per liter
GW Ground Water
Q Data qualifier
Notes (Continued):
Identification
Estimated concentration
Monitoring well
Shallow
"Adjusted concentration: The benzene, 1,2-dichloroethene (total), and pentachlorophenol concentrations
qualified with a "J" data qualifier are adjusted in accordance with Reference 81. The reason for the "J"
qualifiers is unknown; therefore, the samples are conservatively adjusted to reflect an unknown bias. The
concentration is adjusted by multiplying the concentration by the appropriate adjustment factor (Ref. 81,
Exhibit 2). The adjustment factor for benzene is 1.64,1,2-dichloroethene (total) is 10, and pentachlorophenol
is 10.12 (Ref. 81, p. 15).
No analytical results are presented in Table 4-11 for ground water samples collected from MW-28 on August
5, 1993 for VOC and SVOC analysis; on September 9, 1993 for VOC analysis; and on July 14, 1995 for
inorganic analysis because Table 4-11 provides a summary of detections. Therefore, these substances were
not reported (Ref. 31, Table 3-1, p. 4).
203
-------
GW to SW Component - Observed Release to Ground Water
Release Samples:
Numerous monitoring wells were installed at the Lucas plant in the areas of the sources during the RI (see
Reference 31, Figure 3-2). The construction details and locations ofthe monitoring wells used to document
an observed release to ground water are summarized in Table 31. The construction details were obtained
from borehole logs in Appendix C of Reference 31. In some instances, borehole logs are not provided in
reference documentation. However, Table 4-1 in Reference 31 provides the screened interval for the
monitoring wells in feet below mean sea level (msl). Concentrations of hazardous substances detected in
the release ground water samples are summarized in Table 32.
TABLE 31
RELEASE MONITORING WELL CONSTRUCTION DETAILS
MW ID
Location
Depth
(ft msl)
Screened
Interval
(ft msl)
Reference
MW-1*
South of shed and east of Tank
Farm A
79.80
99.80 - 79.80
31, p. 3-8, Table 4-1, p.
1 and Appendix C,
p.230
MW-2
Northwest of Lagoon Area
79.80
99.80 - 79.80
31, Table 4-1, p. 1,
Appendix C, p. 5
MW-3*
South of Building 67
70.69
80.69 - 70.69
31, Table 4-1, p. 1
MW-4*
Southeast portion of Lagoon Area
67.88
77.88 - 67.88
31, Table 4-1, p. 1
MW-6
North of the Lagoon Area
78.10
82.10 - 78.10
31, Table 4-1, p. 1
MW-11
Tank Farm A
82.68
92.68 - 82.68
31, Appendix C, p. 8
MW-12
Northwest of Tank Farm A
82.07
92.07 - 82.07
31, Appendix C, p. 11
MW-13
West of Building 67
76
86-76
31, Appendix C, p. 14
MW-15
Northwest of Building 55
78.24
88.24 - 78.24
31, Appendix C, p. 24
MW-18
South of Tank Farm B
76.63
86.63 - 76.63
31, Table 4-1, p. 2
MW-19
Northwest of Tank Farm A
65.84
75.84 - 65.84
31, Appendix C, p. 47
MW-21
Southeast of Building 67
76.85
86.85 - 76.85
31, Appendix C, p. 56
MW-22
Southeast of Building 67
55.66
65.66 - 55.66
31, Appendix C, p. 63
MW-23
South of Lagoon area
73.65
83.65 - 73.65
31, Appendix C, p. 66
MW-24
Northeast of Building 58
84.87
94.87 - 84.87
31, Appendix C, p. 69
204
-------
GW to SW Component - Observed Release to Ground Water
TABLE 31 (Continued)
RELEASE MONITORING WELL CONSTRUCTION DETAILS
MW ID
Location
Depth
(ft msl)
Screened
Interval
(ft msl)
Reference
MW-25
Northeast of shed and Tank Farm A
85.09
95.09 - 85.09
31, Appendix C, p. 73
MW-30
Northwest of T ank Farm A
37.91
42.91- 37.91
31, Appendix C, p. 95
MW-33
Southeast of Building 67
35.42
40.42 - 35.42
31, Appendix C, p. 127
MW-3 5
Southeast of Building 55
17.53
27.53 - 17.53
31, Appendix C, p. 147
MW-36
Northeast of Lagoon Area
14.19
25.19- 14.19
31, Appendix C, p. 163
MW-41*
South of Lagoon Area
9.83
19.83 - 9.83
31, p. 3-29, Table 4-1,
p. 6
Notes:
ft Foot
ID Identification
msl Below mean sea level
MW Monitoring well
The borehole logs forMW-1, MW-3, MW-4, andMW-41 were not in the reference documentation.
However, Table 4-1 of Reference 31 summarizes the screened interval for the monitoring wells.
Release Concentrations
The concentrations of hazardous substances meeting the criteria for documenting an observed release to
ground water are summarized in Table 32.
205
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
(Mg/L)
Q
Adjust
ed
Cone.
(HS/L)
Detec-
tion
Limit
(HS/L)
Date
Rcfcrcnct
MW-1
001-MOO 1
(Background: MW-14,
014-M001)
Volatile Organic Compounds
12/03/1991
31,
Table 4-
11,
pp. 3, 15;
112 pp. 1,
2, 3, 4, 5
Ethylbenzene
250
J
25
10
Xylene
1,800
-
-
10
Semi-Volatile Organic Compounds
Naphthalene
1,900
-
-
10
MW-1
001-M002
(Background: MW-14,
014-M002)
Volatile Organic Compounds
01/07/1992
31,
Table 4-
11,
pp. 3, 15;
112 pp. 1,
2, 3, 4, 5
Ethylbenzene
410
-
-
10
Total 1,2-dichloroethene
630
-
-
10
Xylene
2,300
-
-
10
Semivolatile Organic Compounds
2-Methylnaphthalene
810
-
-
10
Naphthalene
5,200
-
-
10
MW-1
001-M003
(Background: MW-14,
014-M004; MW-20, 020-
M003; MW-28, 028-M003)
Volatile Organic Compounds
08/05/1993
31,
Table 4-
11,
pp. 3, 15;
112 pp. 1
2, 3, 4, 5
Total 1,2-dichloroethene
410
J
174
10
Ethylbenzene
240
J
24
10
Xylene
950
J
45
10
Semivolatile Organic Compounds
2-Methylnaphthalene
35
-
-
10
Naphthalene
1,100
-
-
10
MW-1
001-M004
(Background: MW-14,
014-M004; MW-20, 020-
M004; MW-28, 028-M004)
Volatile Organic Compounds
09/09/1993
31,
Table 4-
11,
pp. 3, 15;
112 pp. 1,
2, 3, 4, 5
Ethylbenzene
240
-
-
10
Total 1,2-dichloroethene
490
-
-
10
Xylene
830
-
-
10
Semivolatile Organic Compounds
2-Methylnaphthalene
72
-
-
10
Naphthalene
670
-
-
10
206
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
(Mg/L)
Q
Adjust
ed
Cone.
(HS/L)
Detec-
tion
Limit
(HS/L)
Date
Rcfcrcnct
MW-2
002-MOO 1
(Background: MW-14,
014-M001)
Volatile Organic Compounds
12/04/1991
31,
Table 4-
14,
p. 1; 112
pp. 1, 2, 3
4, 5
Carbon disulfide
16
-
-
10
Ethylbenzene
35
-
-
10
Xylene
170
-
-
10
MW-2
002-M002
(Background: MW-14,
014-M002)
Volatile Organic Compounds
01/07/1992
31,
Table 4-
14,
p. 1; 112
pp. 1, 2, 3
4, 5
Carbon disulfide
10
-
-
10
Ethyl benzene
7
-
-
10
Xylene
10
-
-
10
MW-2
002-M003
(Background: MW-14,
014-M004; MW-20, 020-
M004; MW-28, 028-M004)
Volatile Organic Compounds
09/23/1993
31,
Table 4-
14,
pp. 1, 4;
112 pp. 1,
2, 3, 4, 5
Xylene
140
-
-
10
Semivolatile Organic Compounds
2-Chloronaphthalene
28
-
-
10
4-Methylphenol
10
-
-
10
Phenol
17
-
-
10
MW-2
002-M004
(Background: MW-14,
014-M004; MW-20, 020-
M004; MW-28, 028-M004)
Semivolatile Organic Compounds
10/07/1993
31,
Table 4-
14,
p. 4; 112
pp. 1, 2, 3
4, 5
Phenol
13
~
~
10
MW-3
003-M004
(Background: MW-14, 014-
M002)
Metals
01/08/1992
31,
Table 4-
14,
p. 7; 112,
Lead
5.1
-
-
3
MW-3
003-M004
(Background: MW-14, 014-
M004)
Metals
10/07/1993
31, P- 5
Table 4-
14,
p. 7; 112,
p. 5
Lead
25
"
"
3
207
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
(fig/L)
Q
Adjust
ed
Cone.
(fig/L)
Detec-
tion
Limit
(fig/L)
Date
Referenct
MW-4
004-M2031
(Background: MW-14,
014-M004)
Volatile Organic Compounds
08/04/1993
31,
Table 4-
14,
p. 2
2-Butanone
12
-
-
10
MW-4
004-M003
(Background: MW-14, 014-
M004)
Metals
09/23/1993
31,
Table 4-
14,
p. 8; 112,
n ^
Lead
22
-
-
3
MW-4
004-M004
(Background: MW-14,
014-M004)
Metals
10/07/1993
31,
Table 4-
14,
p. 8; 112,
p. 5
Lead
23
-
-
3
MW-6
006-M004
(Background: MW-14, 014-
M004)
Metals
10/07/1993
31,
Table 4-
14,
p. 9; 112,
p. 5
Lead
41
-
-
3
MW -11
011-M001
(Background: MW-14,
014-M001)
Volatile Organic Compounds
12/03/1991
31,
Table 4-
11,
pp. 3, 16;
112 pp. 1.
2, 3, 4, 5
Benzene
120
-
-
10
Ethylbenzene
270
-
-
10
Total 1,2-dichloroethene
46
-
-
10
Xylene
810
-
-
10
Semivolatile Organic Compounds
Naphthalene
350
-
-
10
MW-11
011-M002
(Background: MW-14,
014-M002)
Volatile Organic Compounds
01/07/1992
31,
Table 4-
11,
p. 3; 112
pp. 1, 2, 3
__l £
Ethylbenzene
500
-
-
10
Total 1,2-dichloroethene
110
-
-
10
Xylene
2,100
-
-
10
208
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
0»g/L)
Q
Adjust
ed
Cone.
0»g/L)
Detec-
tion
Limit
0»g/L)
Date
Referenct
MW-12
012-M001
(Background: MW-14,
014-M001)
Volatile Organic Compounds
12/03/1991
31,
Table 4-
11,
p. 3; 112
pp. 1, 2, 3
4, 5
Benzene
370
-
-
10
Ethylbenzene
790
-
-
10
Xylene
3,400
-
-
10
MW-12
012-M002
(Background: MW-14,
014-M002)
Volatile Organic Compounds
01/07/1992
31,
Table 4-
11,
pp. 3, 16;
112 pp. 1.
2, 3, 4, 5
Benzene
270
-
-
10
Ethylbenzene
870
-
-
10
Xylene
3,400
-
-
10
Semivolatile Organic Compounds
Naphthalene
290
-
-
10
MW-12
012-M003
(Background: MW-14,
014-M004; MW-20, 020-
M003; MW-28, 028-M003)
Volatile Organic Compounds
08/05/1993
31,
Table 4-
11,
pp. 3, 16;
112 pp. 1.
2, 3, 4, 5
Benzene
610
-
-
10
Ethylbenzene
1,400
-
-
10
Toluene
10
-
-
10
Xylene
670
-
-
10
Semivolatile Organic Compounds
2,4-Dimethylphenol
46
-
-
10
MW-12
012-M003
Naphthalene
75
"
"
10
08/05/1993
31,
Table 4-
11,
pp. 3, 16;
112 pp. 1.
2, 3, 4, 5
Phenol
10
"
"
10
MW-12
MW12-GW 4
(Background: MW-14, 014-
M004; MW-32, MW32-
GW4)*
Volatile Organic Compounds
11/05/1996
31,
Table 4-
11,
p. 4; 112
pp. 1, 2, 3
4, 5
Benzene
540
-
-
10
Ethylbenzene
540
-
-
10
Toluene
130
-
-
10
Vinyl chloride
210
-
-
10
Xylene
750
-
-
10
209
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
0»g/L)
Q
Adjust
ed
Cone.
0»g/L)
Detec-
tion
Limit
0»g/L)
Date
Referenct
MW-13
013-M001
(Background: MW-14, 014-
M001)
Volatile Organic Compounds
12/04/1991
31,
Table 4-
11,
pp. 4, 16;
112 pp. 1.
2, 3, 4, 5
Acetone
9,500
-
-
10
Benzene
1,800
-
-
10
2-Butanone
110
-
-
10
Ethylbenzene
1,500
-
-
Xylene
10,000
-
-
10
Semivolatile Organic Compounds
2 -Methylnaphthalene
120
-
-
10
Naphthalene
800
-
-
10
MW-13
013-M002
(Background: MW-14,
014-M002)
Volatile Organic Compounds
01/08/1992
31,
Table 4-
11,
pp. 4, 16;
112 pp. 1.
2, 3, 4, 5
Benzene
3,200
-
-
10
Ethylbenzene
2,700
-
-
10
Methylene chloride
1,600
-
-
10
Styrene
660
-
-
10
Xylene
12,000
-
-
10
Semivolatile Organic Compounds
Naphthalene
1,800
-
-
MW -15
015-M001
(Background: MW-14,
014-M001)
Volatile Organic Compounds
12/04/1991
12/04/1991
31,
Table 4-
11,
pp. 4, 17;
112 pp. 1.
2, 3, 4, 5
Benzene
350
-
-
10
Ethylbenzene
510
-
-
10
Vinyl chloride
53
-
-
10
Xylene
54
-
-
10
Semivolatile Organic Compounds
Naphthalene
59
-
-
10
210
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
(Mg/L)
Q
Adjust
ed
Cone.
(HS/L)
Detec-
tion
Limit
(HS/L)
Date
Rcfcrcnct
MW-15
015-M002
(Background: MW-14,
014-M002)
Volatile Organic Compounds
01/08/1992
31,
Table 4-
11,
pp. 4, 17;
112 pp. 1,
2, 3, 4, 5
Benzene
220
-
-
10
Ethylbenzene
390
-
-
10
Semivolatile Organic Compounds
Naphthalene
66
-
-
10
MW-15
015-M003
(Background: MW-14,
MW14-M004; MW-20,
020-M003; MW-28, 028-
M003)
Volatile Organic Compounds
08/05/1993
31,
Table 4-
11,
pp. 4, 17;
112 pp. 1,
2, 3, 4, 5
Benzene
130
-
-
10
2-Butanone
10
-
-
10
Ethylbenzene
160
-
-
10
Toluene
10
-
-
10
Vinyl chloride
100
-
-
10
Xylene
14
-
-
10
Semivolatile Organic Compounds
Naphthalene
43
-
-
10
MW-15
015-M004
(Background: MW-14,
014-M004; MW-20, 020-
M004; MW-28, 028-M004)
Volatile Organic Compounds
09/10/1993
31,
Table 4-
11,
pp. 5, 17;
112 pp. 1,
2, 3, 4, 5
Benzene
74
-
-
10
Ethylbenzene
140
-
-
10
Total 1,2-dichloroethene
62
-
-
10
Vinyl chloride
18
-
-
10
MW-15
MW15-GW4
(Background Sample:
MW-14, 014-M004; MW-
32, MW32-GW4)*
Volatile Organic Compounds
11/06/1996
31,
Table 4-
11,
p. 5; 112
pp. 1, 2, 3
4, 5
Benzene
100
-
-
10
Ethylbenzene
120
-
-
10
Toluene
5
-
-
10
Vinyl chloride
39
-
-
10
Xylene
15
-
-
10
MW-18
018-M001
(Background: MW-16,
MW16-M001)
Metals
12/05/1991
31,
Table 4-9,
p. 5; 112,
p. 5
Lead
30
-
-
3
211
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
(Mg/L)
Q
Adjust
ed
Cone.
(HS/L)
Detec-
tion
Limit
(HS/L)
Date
Rcfcrcnct
MW-18
018-M002
(Background: MW-16,
MW16-M002)
Metals
01/07/1992
31,
Table 4-9,
p. 6; 112,
p. 5
Lead
50
-
-
3
MW-18
018-M003
(Background: MW-16,
MW16-M003)
Metals
08/05/1993
31,
Table 4-9,
p. 6; 112,
p. 5
Lead
240
-
-
3
MW-18
018-M004
(Background: MW-16,
MW 16-M004)
Metals
09/08/1993
31,
Table 4-9;
p. 6; 112,
p. 5
Lead
180
-
-
3
MW-19
012-M004
(Background: MW-14,
014-M004; MW-20, 020-
M004; MW-28, 028-M004)
Volatile Organic Compounds
09/09/1993
31,
Table 4-
11,
pp. 5, 17;
112 pp. 1,
2, 3, 4, 5
Benzene
260
-
-
10
Ethylbenzene
790
-
-
10
Toluene
300
-
-
10
Xylene
2,500
-
-
10
Semivolatile Organic Compounds
2-Methylnaphthalene
13
-
-
10
2,4-Dimethylphenol
11
-
-
10
Naphthalene
120
-
-
10
MW-19
019-M003
(Background: MW-14,
014-M004; MW-20, 020-
M003; MW-28, 028-M003)
Volatile Organic Compounds
08/09/1993
31,
Table 4-
11,
p. 5; 112
pp. 1, 2, 3
4, 5
Benzene
270
-
-
10
Ethylbenzene
750
-
-
10
Toluene
310
-
-
10
Xylene
2,000
-
-
10
212
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
(fig/L)
Q
Adjust
ed
Cone.
(fig/L)
Detec-
tion
Limit
(fig/L)
Date
Referenct
MW-19
019-M004
(Background: MW-14,
014-M004; MW-20, 020-
M004; MW-28, 028-M004)
Volatile Organic Compounds
09/09/1993
31,
Table 4-
11,
pp. 5, 19;
112 pp. 1.
2, 3, 4, 5
Benzene
480
-
-
10
Ethylbenzene
1,800
-
-
10
Xylene
1,400
-
-
10
Semivolatile Organic Compounds
2,4-Dimethylphenol
44
-
-
10
2 -Methylnaphthalene
11
-
-
10
Naphthalene
120
-
-
10
MW-21
021-M001
(Background: MW-14,
014-M004; MW-20,
MW20-M003; MW-28,
MW 28-M003)
Volatile Organic Compounds
08/04/1993
31,
Table 4-
11,
pp. 5, 17;
112 pp. 1.
2, 3, 4, 5
Benzene
71
-
-
10
Ethylbenzene
37
-
-
10
Xylene
150
-
-
10
Semivolatile Organic Compounds
2,4-Dimethylphenol
11
-
-
10
2 -Methylnaphthalene
28
-
-
10
Naphthalene
360
-
-
10
MW-21
021-M004
(Background: MW-14,
014-M004; MW-20, 020-
M004; MW-28, 028-M004)
Volatile Organic Compounds
09/08/1993
31,
Table 4-
11,
PP. 5, 17;
112 pp. 1.
2, 3, 4, 5
Benzene
86
-
-
10
Ethylbenzene
38
-
-
10
Xylene
240
-
-
10
Semivolatile Organic Compounds
Naphthalene
130
-
-
10
MW-22
022-M003
(Background: MW-14,
014-M004; MW-20, 020-
M003; MW-28, 028-M003)
Volatile Organic Compounds
08/09/1993
31,
Table 4-
11,
p. 5; 112
pp. 1, 2, 3
4, 5
Benzene
45
"
"
10
213
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
0»g/L)
Q
Adjust
ed
Cone.
0»g/L)
Detec-
tion
Limit
0»g/L)
Date
Referenct
MW-22
022-M004
(Background: MW-14,
014-M004; MW-20, 020-
M004; MW-28, 028-M004)
Volatile Organic Compounds
09/08/1993
31,
Table 4-
11,
p. 6; 112
pp. 1, 2, 3
4, 5
Benzene
51
-
-
10
1,2-dichloroethane
61
-
-
10
MW-23
023-M001
(Background: MW-14,
014-M004; MW-20, 020-
M004; MW-28, 028-M004)
Volatile Organic Compounds
09/23/1993
31,
Table 4-
14,
pp. 1,4;
112 pp. 1.
2, 3, 4, 5
Carbon disulfide
23
-
-
10
Xylene
120
-
-
10
Semivolatile Organic Compounds
4-Methylphenol
10
-
-
10
Pentachlorophenol
1,400
-
-
25
MW-23
023-M004
(Background: MW-14,
014-M004; MW-20, 020-
M004; MW-28, 028-M004)
Semivolatile Organic Compounds
10/23/1993
31,
Table 4-
14,
p. 4; 112
pp. 1, 2, 3
4, 5
2,4-Dichlorophenol
11
"
-
10
Pentachlorophenol
1,900
"
-
25
MW-23
MW-1011
(Background: MW-34,
MW-34)*
Semivolatile Organic Compounds
02/04/1999
31,
Table 4-
14,
p. 4; 112
Pentachlorophenol
94
-
-
25
MW-23
MW-23
(Background: MW-32,
MW-34)*
Semivolatile Organic Compounds
02/04/1999
PP-il,2' 3
Takll 4-
14,
p. 4
Pentachlorophenol
110
-
-
25
MW-23
MW-23
(Background: MW-32,
MW-34)*
Semivolatile Organic Compounds
02/15/2000
31,
Table 4-
14,
p. 4; 112
pp. 1, 2, 3
4, 5
Pentachlorophenol
69
"
-
25
214
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
(Mg/L)
Q
Adjust
ed
Cone.
(HS/L)
Detec-
tion
Limit
(HS/L)
Date
Rcfcrcnct
MW-23
MW-23-GW4
(Background: MW-32,
MW32-GW4)*
Semivolatile Organic Compounds
11/07/1996
31,
Table 4-
14,
p. 4
Benzoic acid
1,700
D
-
50
MW-24
024-M003
(Background: MW-14,
014-M004; MW-20, 020-
M004; MW-28, 028-M004)
Volatile Organic Compounds
08/05/1993
31,
Table 4-
11,
pp. 6, 18;
112 pp. 1,
2, 3, 4, 5
Benzene
74
-
-
10
Ethylbenzene
77
-
-
10
Styrene
330
-
-
10
Toluene
300
-
-
10
Xylene
1,200
-
-
10
Semivolatile Organic Compounds
Acenaphthene
84
-
-
10
Dibenzofuran
68
-
-
10
Fluorene
38
-
-
10
2-Methylnaphthalene
410
-
-
10
Naphthalene
1,500
-
-
10
4-Nitrophenol
72
-
-
25
MW-24
024-M004
(Background: MW-14,
014-M004; MW-20, 020-
M004; MW-28, 028-M004)
Volatile Organic Compounds
09/09/1993
31,
Table 4-
14,
pp. 6, 18;
112 pp. 1,
2, 3, 4, 5
Benzene
130
-
-
10
Ethylbenzene
77
-
-
10
Styrene
370
-
-
10
Toluene
340
-
-
10
Xylene
1,300
-
-
10
Semivolatile Organic Compounds
Acenaphthene
32
-
-
10
Dibenzofuran
28
-
-
10
Fluorene
15
-
-
10
2 -Methy lnaphthalene
190
-
-
10
Naphthalene
1,100
-
-
10
215
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
(Mg/L)
Q
Adjust
ed
Cone.
(HS/L)
Detec-
tion
Limit
(HS/L)
Date
Rcfcrcnct
MW-24
024-M104
(Background: MW-14,
014-M004; MW-20, 020-
M004; MW-28, 028-M004)
Volatile Organic Compounds
09/09/1993
31,
Table 4-
11,
pp. 6, 18;
112 pp. 1,
2, 3, 4, 5
Benzene
130
-
-
10
Toluene
320
-
-
10
Xylene
1,200
-
-
10
Semivolatile Organic Compounds
Acenaphthene
30
-
-
10
Dibenzofuran
26
-
-
10
Fluorene
14
-
-
10
2 -Methy lnaphthalene
170
-
-
10
Naphthalene
770
-
-
10
MW-25
025-M003
(Background: MW-14,
016-M004; MW-20, 020-
M003; MW-28, 028-M003)
Volatile Organic Compounds
08/05/1993
31,
Table 4-
14,
pp. 6, 18;
112 pp. 1,
2, 3, 4, 5
1,1 -Dichloroethane
13
-
-
10
Semivolatile Organic Compounds
Pentachlorophenol
180
-
-
25
MW-25
025-M004
(Background Sample:
MW-14, 014-M004; MW-
20, 020-M004; MW-28,
028-M004)
Volatile Organic Compounds
09/09/1993
31,
Table 4-
11,
p. 6; 112
pp. 1, 2, 3
4, 5
1,1 -Dichloroethane
14
~
~
10
MW-30
GW5-MW30
(Background: MW-32,
GW5-MW32)
Volatile Organic Compounds
01/22/1997
31,
Table 4-
11,
pp. 7, 19;
112 pp. 1,
2, 3, 4, 5
Acetone
850
-
-
10
Benzene
5,000
-
-
10
Toluene
330
-
-
10
Total 1,2-dichloroethene
120
-
-
10
Xylene
48
-
-
10
Semivolatile Organic Compounds
Benzoic acid
10,000
-
-
50
Cresol (ortho)
61
-
-
10
216
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
(Mg/L)
Q
Adjust
ed
Cone.
(HS/L)
Detec-
tion
Limit
(HS/L)
Date
Rcfcrcnct
4-Methylphenol
220
-
-
10
Phenol
530
-
-
10
MW-30
GW5-MW531
(Background: MW-32,
GW5-MW32)
Volatile Organic Compounds
01/22/1997
31,
Table 4-
11,
pp. 7, 19;
112 pp. 1,
2, 3, 4, 5
Benzene
5,400
-
-
10
Toluene
390
-
-
10
Total 1,2-dichloroethene
130
-
-
10
Xylene
53
-
-
10
Semivolatile Organic Compounds
Benzoic acid
15,000
-
-
50
Cresol (ortho)
63
-
-
10
4-Methylphenol
210
-
-
10
Phenol
750
-
-
10
MW-30
MW-30
(Background: MW-32,
MW-34)
Volatile Organic Compounds
02/03/1999
31,
Table 4-
11,
pp. 7, 19;
112 pp. 1,
2, 3, 4, 5
Acetone
540
-
-
10
Benzene
5,000
-
-
10
Toluene
380
-
-
10
Total 1,2-dichloroethene
79
-
-
10
Xylene
28
-
-
10
Semivolatile Organic Compounds
Benzoic acid
12,000
-
-
50
Cresol (ortho)
47
-
-
10
4-Methylphenol
190
-
-
10
Phenol
610
-
-
10
217
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
(Mg/L)
Q
Adjust
ed
Cone.
(HS/L)
Detec-
tion
Limit
(HS/L)
Date
Rcfcrcnct
MW-30
MW-30-GW4
(Background: MW-32,
MW32-GW4)
Volatile Organic Compounds
11/05/1996
31,
Table 4-
11,
pp. 8, 19;
112 pp. 1,
2, 3, 4, 5
Benzene
4,900
-
-
10
Toluene
270
-
-
10
Semivolatile Organic Compounds
Benzoic acid
10,000
-
-
50
4-Methylphenol
120
J
12
10
Phenol
430
J
122
10
MW-30
MW50-GW41
MW-30-GW4
(Background: MW-32,
MW32-GW-4)
Volatile Organic Compounds
11/05/1996
31,
Table 4-1:
p. 8; 112
pp. 1, 2, 3
4, 5
Benzene
5,500
-
-
10
Phenol
420
J
119
10
Toluene
300
-
-
10
Total 1,2-dichloroethene
120
J
12
10
Semivolatile Organic Compounds
Benzoic acid
9,400
-
-
50
4-Methylphenol
110
J
11
10
MW-33
MW-33-GW4
(Background: MW-32,
MW32-GW4)
Volatile Organic Compounds
11/06/1996
31,
Table 4-
11,
p. 8; 112
pp. 1, 2, 3
4, 5
Benzene
430
D
-
10
Total 1,2-dichloroethene
32
-
-
10
Semivolatile Organic Compounds
Phenol
10
-
-
10
MW-33
GW5-MW33
(Background: MW-32,
GW5-MW32)
Volatile Organic Compounds
01/22/1997
31,
Table 4-
11,
p. 8; 112
pp. 1, 2, 3
4, 5
Acetone
6
-
-
10
Benzene
570
-
-
10
Xylene
30
-
-
10
218
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
0»g/L)
Q
Adjust
ed
Cone.
0»g/L)
Detec-
tion
Limit
0»g/L)
Date
Referenct
MW-33
MW-13
(Background: MW-32)
Volatile Organic Compounds
02/05/1999
31,
Table 4-
11,
p. 8; 112
pp. 1, 2, 3
4, 5
Benzene
420
"
"
10
MW-33
MW-33
(Background: MW-32)
Volatile Organic Compounds
01/13/2000
31,
Table 4-
11,
p. 8; 112
pp. 1, 2, 3
4, 5
Benzene
570
"
"
10
MW-35
MW-1001
(Background: MW-32,
MW-34)
Volatile Organic Compounds
02/03/1999
31,
Table 4-
11,
p. 9; 112
pp. 1, 2, 3
4, 5
Benzene
80
-
-
10
Ethylbenzene
18
-
-
10
Xylene
49
-
-
10
MW-35
MW-35
(Background: MW-32,
MW-34)
Volatile Organic Compounds
02/03/1999
31,
Table 4-
11,
p. 9; 112
pp. 1, 2, 3
4, 5
Benzene
78
-
-
10
Ethylbenzene
18
-
-
10
Xylene
49
-
-
10
MW-35
MW-35
(Background: MW-32,
MW-34)
Volatile Organic Compounds
03/24/1999
31,
Table 4-
11,
p. 9; 112
pp. 1, 2, 3
4, 5
Benzene
96
-
-
10
Ethylbenzene
16
-
-
10
Xylene
38
-
-
10
MW-35
MW-35
(Background: MW-32,
MW-34)
Volatile Organic Compounds
01/14/2000
31,
Table 4-
11,
p. 9; 112
pp. 1, 2, 3
4, 5
Ethylbenzene
10
-
-
10
Xylene
11
-
-
10
219
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
(fig/L)
Q
Adjust
ed
Cone.
(fig/L)
Detec-
tion
Limit
(fig/L)
Date
Referenct
MW-35
MW-35D1
(Background: MW-32,
MW-34)
Volatile Organic Compounds
01/14/2000
31,
Table 4-
11,
p. 9; 112
pp. 1, 2, 3
4, 5
Benzene
100
"
"
10
MW-36
MW-36
(Background Sample:
MW-32, MW-34)
Volatile Organic Compounds
02/03/1999
31,
Table 4-
11,
p. 9; 112
pp. 1, 2, 3
4, 5
Benzene
150
"
"
10
MW-36
MW-36
(Background: MW-32,
MW-34)
Volatile Organic Compounds
03/24/1999
31,
Table 4-
11,
p. 9; 112
pp. 1, 2, 3
4, 5
Benzene
73
"
"
10
MW-36
MW-36
(Background: MW-32,
MW-34)
Volatile Organic Compounds
01/13/2000
31,
Table 4-
11,
p. 9; 112
pp. 1, 2, 3
4, 5
Benzene
140
"
"
10
MW-36
MW-36DUP1
(Background: MW-32,
MW-34)
Volatile Organic Compounds
03/24/1999
31,
Table 4-
11,
p. 9; 112
pp. 1, 2, 3
4, 5
Benzene
68
"
"
10
MW-41
MW-41-12/8/99
(Background: MW-32,
MW-34)
Volatile Organic Compounds
12/08/1999
31,
Table 4-
11,
pp. 10, 23
112 pp. 1.
2, 3, 4, 5
Benzene
720
-
-
10
Semivolatile Organic Compounds
Phenol
110
-
-
220
-------
GW to SW Component - Observed Release to Ground Water
TABLE 32 (Continued)
RELEASE GROUND WATER SAMPLE CONCENTRATIONS
OF HAZARDOUS SUBSTANCES
MW ID
Field Sample ID
Hazardous Substance
Cone.
0»g/L)
Q
Adjust
ed
Cone.
0»g/L)
Detec-
tion
Limit
0»g/L)
Date
Referenct
MW-41
MW-41
(Background: MW-32,
MW-34)
Volatile Organic Compounds
10
01/13/2000
31,
Table 4-
11,
pp. 10, 22
112 pp. 1.
2, 3, 4, 5
Benzene
900
-
-
10
Semivolatile Organic Compounds
Phenol
36
-
-
10
Notes:
1 Duplicate sample
fxg/L Microgram per liter
- Not applicable
Cone. Concentration
D Diluted
GW Ground water
ID Identification
J Estimated value
MW Monitoring well
Q Data qualifier
* On some sampling dates, background shallow ground water samples were not collected from the
aquifer. Therefore, the deep background ground water samples are used to establish background
concentrations.
Notes (Continued):
Adjusted concentrations - Concentrations with the data qualifier J, estimated value, are divided by the
adjustment factor value in Reference 81. The reason the data were J qualified is not known. Therefore, the
bias was considered high. For release concentrations that have a high bias, the concentration is divided by
the adjustment factor (Ref. 81, Exhibit 3). The adjustment factors used include ethylbenzene (10), total 1,2-
dichloroethene (10), xylene (10), 4-methylphenol (10), and phenol (3.53) (Ref. 81, pp. 11, 12).
221
-------
Attribution
Attribution:
The hazardous substances detected in the release ground waters samples are attributable to sources located
on the Lucas plant (see Section 2.4 of this documentation record) and to operations conducted at the Lucas
plant as documented in the introduction section and attribution section (Section 4.0) of this documentation
record.
Lead was used extensively at the Lucas plant (Refs. 13, p. 3; 31, p. 2-3; 60, pp. 6, 8, 10, 12, 22, 26). The
presence of lead within ground water and in Hilliards Creek extending from the Lucas plant to Hilliards Road
indicates that overtime operations at the Lucas plant have released lead to ground water and surface water.
As documented in Section 4.0 of this HRS documentation record, other than waste disposal areas used by
the Lucas plant, no other significant sources of lead have been identified in the Hilliards Creek watershed.
Potential sources of ground water contamination in the area surrounding the Lucas plant are discussed in the
attribution and land use surrounding Hilliards Creek sections (see Section 4.0).
Lead has been detected in soil samples collected from sources on the Lucas plant property, as documented
in the waste characterization section (Section 2.4) of this HRS documentation record, and ground water and
surface water sediment and aqueous samples at concentrations exceeding three times the background
concentration (see Sections 4.1.2.1.1 and 4.2.2.1.1 of this HRS documentation record).
Additionally, lead has been detected in product samples collected from the ground water underlying Source
1 (Refs. 76, pp. 12, 13, 19, 20; 77, p. 82). The product has been observed to discharge into Hilliards Creek
(Refs. 10, pp. 1, 2; 31, pp. 3-3, 3-22; 32, p. 5; 65, pp. 1, 2, 3; 36; 37).
Analytical results for free-phase product samples collected from Source 1 indicated the presence of 2-
methylnaphthalene; 4-chloroaniline; naphthalene; benzene; chlorobenzene; ethylbenzene; and xylene (Ref.
31, Table 4-20 and Section 2.4.1 of this HRS documentation for Source 1). These same hazardous
substances were detected in the observed release samples as documented in Section 4.2 of this HRS
documentation record.
Many of the hazardous substances detectedin the observe release to ground water samples were also detected
in source samples including acetone (Sources 1,2, and 4); benzene (Source 1); benzoic acid (Source 3); 2-
butanone (Sources 1 and 2); carbon disulfide (Sources 1 and 3); chlorobenzene (Source 1); chloroform
(Source 4); 1,2-dichloroethene (Sources 1 and 2); 2,4-dimethylphenol (Source 1); ethylbenzene (Sources 1,
2, 3, and 4); lead (Sources 1, 2, 3, and 4); 2-methylnapthalene (Source 1); naphthalene (Sources 1 and 2);
pentachlorophenol (Source 3); toluene (Sources 1 and 4); and xylene (Sources 1,2, and 4). Refer to Section
2.4.1 of this HRS documentation record for the source sample documentation and Section 4.2 of this HRS
documentation record for the ground water sample documentation.
Some of the hazardous substances detected in the ground water observed release samples were not detected
in the source samples including acenaphthene; 2-chloronaphthalene; cresol; dibenzofuran; 1,1 -
dichloroethane; fluorene; 2-methylnaphthalene; 4-methyl phenol; phenol; styrene; tetrachloroethylene; total
1,2-dichloroethene; 2,4,5-trichlorophenol; and vinyl chloride. However, many of these hazardous substances
can be attributed to operations conducted at the Lucas plant. PAHs, such as acenaphthene and fluorene are
common constituents of petroleum products such as was used at the Lucas plant (Refs. 10, p. 9; 105, pp. 2,
4). Cresols are used in paint (Ref. 107, p. 75). 1,2-Dichloroethane is used for varnish and finish removers
222
-------
Attribution
(Ref. 108, p. 51). There is no record of the use of the following hazardous substances at the Lucas plant:
2-chloronaphthalene; dibenzofuran; 2-methylnaphthalene; 4-methyl phenol; phenol; styrene;
tetrachloroethylene; total 1,2,-dichloroethene; 2,3,4-trichlorophenol; and vinyl chloride. Therefore, these
hazardous substances are not used in the observed release to ground water.
Hazardous Substances Attributable to the Site and Documented in the Observed Release to Ground
Water and Surface Water:
Lead
223
-------
GW to SW Component\Drinking Water - Waste Characteristics
4.2.2.2 WASTE CHARACTERISTICS
4.2.2.2.1 Toxicity/Persistence
For each hazardous substance detected in a ground water sample meeting the criteria for an observed release
and in a source with a containment value of greater than zero, a toxicity, a mobility, persistence factor, and
a combined toxicity/mobility/persistence factor value are assigned (Ref. 1, Section 4.2.2.2.1).
TABLE 33
TOXICITY/MOBILITY/PERSISTENCE FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Hazardous Substance
Source
Number
Toxicity
Factor
Value
Mobility
Factor
Value**
Persistence
Factor
Value*
Toxicity/
Persistence/
Mobility
Factor Value
Reference
Acetone
1, 4
1
1.0
0.1
0.07
2, p. BI-1
Aluminum
1
0
1.0
1.0
0.0
2, p. BI-1
Antimony
2
10,000
lxl 0"2
1.0
100.0
2, p. BI-1
Arsenic
1, 2, 3, 4
10,000
lxl 0"2
1.0
100.0
2, p. BI-1
Barium
1, 2, 3, 4
10,000
lxl 0"2
1.0
100.0
2, p. BI-1
Benzene
1
1,000
1.0
0.4
400.0
2, p. BI-2
Benzo(a)anthracene
1, 4
1,000
2xl0"9
1.0
2xl0"6
2, p. BI-2
Benzo(a)pyrene
1, 4
10,000
2xl0"9
1.0
2xl0"5
2, p. BI-2
Benzoic Acid
3
--
--
--
--
2, p. BI-2
B enzo (b) fluoranthene
1, 4
--
--
--
--
2, p. BI-2
Benzo(k)fluoranthene
1, 4
100
2xl0"9
1.0
2xl0"7
2, p. BI-2
Beryllium
2
10,000
lxl 0"2
1.0
100.0
2, p. BI-2
Bis(2 -ethylhexyl)
phthalate
1
100
2xl0"7
1.0
2xl0"5
2, p. BI-2
2-Butanone
1, 2, 4
--
--
--
--
2, p. BI-2
Cadmium
1, 2, 3
10,000
lxlO"2
1.0
100.0
2, p. BI-2
Carbon disulfide
3
10
1.0
0.4
4.0
2, p. BI-3
4-Chloroaniline
1
--
--
--
--
2, p. BI-3
Chlorobenzene
1
100
1.0
0.0007
0.1
2, p. BI-3
Chloroform
4
100
1.0
0.4
40.0
2, p. BI-3
Chromium
1, 2, 3, 4
10,000
lxlO"2
1.0
100.0
2, p. BI-3
Chrysene
1, 4
10
2xl0"9
1.0
2xl0"8
2, p. BI-3
Cobalt
2, 4
10
lxlO"2
1.0
0.1
2, p. BI-3
Copper
1, 2, 3
0
lxlO"2
1.0
0
2, p. BI-3
Cyanide
4
100
1.0
1.0
100.0
2, p. BI-4
1,2-Dichloroethene
1,2
100
1.0
0.4
40.0
2, p. BI-5
2,4 -Dimethylphenol
1
100
1.0
1.0
100.0
2, p. BI-5
Di-n-b utyl-phthalate
4
10
1.0
1.0
10.0
2, p. BI-4
224
-------
GW to SW Component\Drinking Water - Waste Characteristics
TABLE 33
TOXICITY/MOBILITY/PERSISTENCE FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Hazardous Substance
Source
Number
Toxicity
Factor
Value
Mobility
Factor
Value**
Persistence
Factor
Value*
Toxicity/
Persistence/
Mobility
Factor Value
Reference
Ethylbenzene
1, 2, 3, 4
10
1.0
7xl0"4
7xl0"3
2, p. BI-6
Fluoranthene
1, 4
-
-
-
-
2, p. BI-6
2-Hexanone
4
-
-
-
-
2, p. BI-8
Iron
1
1
lxlO"2
1.0
lxl 0"2
2, p. BI-8
Lead
1, 2, 3, 4
10,000
1.0
1.0
10,000.0
2, p. BI-8
Magnesium
1, 2, 4
-
-
-
-
2, p. BI-8
Manganese
1
10,000
lxlO"2
1.0
100.0
2, p. BI-8
Mercury
1, 2, 3, 4
10,000
lxl 0"2
1.0
100.0
2, p. BI-8
2 - Methylnaphthalene
1, 2
0
1.0
0.4
0.0
2, p. BI-9
Naphthalene
1, 2
1,000
1.0
0.4
400.0
2, p. BI-9
Nickel
1, 2, 3
10,000
lxl 0"2
1.0
100.0
2, p. BI-9
Pentachlorophenol
1, 3
100
1.0
1.0
100.0
2, p. BI-9
Phenanthrene
1, 4
0
lxlO"5
0.4
0.0
2, p. BI-9
Pyrene
1, 4
100
2xl0"5
1.0
2xl0"3
2, p. BI-10
Selenium
1
100
1.0
1.0
100.0
2, p. BI-10
Silver
1
100
1.0
1.0
100.0
2, p. BI-10
T etrachloroethene
1, 2
100
1.0
0.4
40.0
2, p. BI-10
Toluene
1, 4
10
1.0
7 x 10"2
0.7
2, p. BI-11
1,1,1 -Trichloroethane
4
1
1.0
0.4
0.4
2, p. BI-11
1,1,2 -Trichloroethane
1, 4
1,000
1.0
0.4
400.0
2, p. BI-11
T richloroethene
1, 2, 4
10,000
1.0
0.4
4,000.0
2, pp. BI, B2-1
1,2,4-Trimethylbenzene
1
-
-
-
-
2, p. BI-11
1,3,5 -Trimethylbenzene
1
-
-
-
-
2, p. BI-11
Vanadium
1
100
lxlO"2
1.0
1.0
2, p. BI-11
Xylene
1, 2, 3, 4
100
1.0
0.4
40.0
2, p. BI-12
Zinc
1, 2, 3, 4
10
lxlO"2
1.0
0.1
2, p. BI-12
Notes:
* River persistence values are assigned.
** Mobility factor values are 1 for hazardous substances for which an observed release to ground water has
been documented. All hazardous substances are assumed to be deposited as a solid.
- Not listed in the SCDM.
Toxicity/Mobility/Persistence Factor Value: 10,000 (Ref. 1, Table 4-26)
225
-------
GW to SW Component\Drinking Water - Waste Characteristics
4.2.2.2.2 Hazardous Waste Quantity
The source hazardous waste quantity (HWQ) values for each of the four sources is greater than zero. As
documented in Section 4.1.4.3, wetlands are subject to Level I and II concentrations; therefore, a default
value of 100 is assigned for the HWQ factor value (Ref. 1, Section 2.4.2.2, Table 2-6).
226
Hazardous Waste Quantity Factor Value: 100
-------
GW to SW Component/Drinking - Waste Characteristics Factor Category Value
4.2.2.2.3 Waste Characteristics Factor Category Value
The waste characteristics factor value is determined from the product of the toxicity/mobility/persistence
value for lead and nickel (10,000) and HWQ factor values, and is subject to a maximum product of 1 x 108
(Ref. 1, Table 2-7).
10,000 x 100 = 1x10s
Toxicity/Persistence Factor Value: 10,000
Waste Characteristics Product: lx 106
Waste Characteristics Factor Category Value: 32
(Ref 1, Table 2-7)
227
-------
GW to SW Food Chain - Toxicity/Mobility/Persistence/Bioaccumulation
4.2.3.2 WASTE CHARACTERISTICS
4.2.3.2.1 Toxicity/Mobility/Persistence/Bioaccumulation
The toxicity, mobility, persistence, and bioaccumulation factor values associated with hazardous
substances detected in the sources at the Sherwin-Williams/Hilliards Creek are summarized in Table 34.
TABLE 34
TOXICITY/MOBILITY/PERSISTENCE/BIOACCUMULATION FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Hazardous Substance
Source
Number
Toxicity/
Mobility/
Persistence
Factor Value
(Table 33)
Human Food
Chain
Bioaccumulation
Value*
Toxicity/
Persistence/
Mobility/
Bioaccumulation
Factor Value
Reference
Acetone
1, 4
0.07
0.5
0.035
2, p. BI-1
Aluminum
1
0.0
50.0
0.0
2, p. BI-1
Antimony
2
100.0
5.0
500.0
2, p. BI-1
Arsenic
1, 2, 3, 4
100.0
5.0
500.0
2, p. BI-1
Barium
1, 2, 3, 4
100.0
500.0
50,000.0
2, p. BI-1
Benzene
1
400.0
5,000.0
2xl06
2, p. BI-2
Benzo(a)anthracene
1, 4
2xl0"6
50,000.0
0.1
2, p. BI-2
Benzo(a)pyrene
1, 4
2xl0"5
50,000.0
1.0
2, p. BI-2
Benzoic acid
3
--
--
--
2, p. BI-2
Benzo(b)fluoranthene
1, 4
--
--
--
2, p. BI-2
Benzo(k)fluoranthene
1, 4
2xl0"7
50,000.0
0.01
2, p. BI-2
Beryllium
2
100.0
50.0
5,000.0
2, p. BI-2
Bis (2-ethylhexyl)
phthalate
1
2xl0"5
50,000.0
1.0
2, p. BI-2
2-Butanone
1, 2, 4
--
--
--
2, p. BI-2
Cadmium
1, 2, 3
100.0
5,000.0
5xl05
2, p. BI-2
Carbon disulfide
3
4.0
500.0
2,000.0
2, p. BI-2
4-Chloroaniline
1
--
--
--
2, p. BI-3
Chlorobenzene
1
0.07
50.0
3.5
2, p. BI-3
Chloroform
4
40.0
5.0
200.0
2, p. BI-3
Chromium
1, 2, 3, 4
100.0
500.0
50,000.0
2, p. BI-3
Chrysene
1, 4
2xl0"8
5.0
1 x 10 "7
2, p. BI-3
Cobalt
2, 4
0.1
5,000.0
500.0
2, p. BI-3
Copper
1, 2, 3
0
500.0
0
2, p. BI-3
Cyanide
4
100.0
0.5
50.0
2, p. BI-3
1,2-Dichloroethene
1,2
40.0
50.0
2,000.0
2, p. BI-5
2,4-Dimethylphenol
1
100.0
500.0
50,000.0
2, p. BI-5
Di-n-butyl phthalate
4
10.0
5,000.0
50,000.0
2, p. BI-5
228
-------
GW to SW Food Chain - Toxicity/Mobility/Persistence/Bioaccumulation
TABLE 34 (Continued)
TOXICITY/MOBILITY/PERSISTENCE/BIOACCUMULATION FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Toxicity/
Toxicity/
Mobility/
Human Food
Persistence/
Persistence
Chain
Mobility/
Source
Factor Value
Bioaccumulation
Bioaccumulation
Hazardous Substance
Number
(Table 33)
Value*
Factor Value
Reference
Ethylbenzene
1, 2, 3, 4
0.007
50.0
0.35
2, p. BI-4
Fluoranthene
1, 4
-
-
-
2, p. BI-6
2-Hexanone
4
-
-
-
2, p. BI-8
Iron
1
0.01
5,000.0
50.0
2, p. BI-8
Lead
1, 2, 3, 4
10,000.0
5.0
50,000.0
2, p. BI-8
Magnesium
1, 2, 4
-
-
-
2, p. BI-8
Manganese
1
100.0
50,000.0
5xl06
2, p. BI-8
Mercury
1, 2, 3, 4
100.0
50,000.0
5xl06
2, p. BI-8
2-Methylnaphthalene
1, 2
0.0
50,000.0
0.0
2, p. BI-9
Naphthalene
1, 2
400.0
50,000.0
2xl07
2, p. BI-9
Nickel
1, 2, 3
100.0
0.5
50.0
2, p. BI-9
Pentachlorophenol
1, 3
100.0
50,000.0
5xl06
2, p. BI-9
Phenanthrene
1, 4
0.0
5,000.0
0.0
2, p. BI-9
Pyrene
1, 4
2xl0"3
50,000.0
500.0
2, p. BI-9
Selenium
1
100.0
50.0
5,000.0
2, p. BI-10
Silver
1
100.0
50.0
5,000.0
2, p. BI-10
T etrachlorothene
1, 2
40.0
50.0
2,000.0
2, p. BI-10
Toluene
1, 4
0.7
50.0
200.0
2, p. BI-11
1,1,1 -Trichloroethane
4
0.4
5.0
2.0
2, p. BI-11
1,1,2-Trichloroethane
1, 4
400.0
50.0
2,000.0
2, p. BI-11
Trichloroethene
1, 2, 4
4,000.0
50.0
2xl05
2, p. BI,
B2-1
1,2,4-Trimethylbenzene
1
-
-
-
2, p. BI-11
1,3,5-Trimethylbenzene
1
-
-
-
2, p. BI-11
Vanadium
1
1.0
500.0
500.0
2, p. BI-11
Xylenes
1, 2, 3, 4
40.0
50.0
2,000.0
2, p. BI-12
Zinc
1 3 4
0 1
5 0
0 5
n BT-1?
Notes:
* Fresh-water bioaccumulation values are assigned.
- Not listed in the SCDM.
Toxicity/Mobility/Persistence/Bioaccumulation Factor Value: 2 x 107
(Ref. 1, Table 4-26)
229
-------
GW to SW/Food Chain - Hazardous Waste Quantity
4.2.3.2.2 Hazardous Waste Quantity
The source HWQ values for each of the four sources is greater than zero. As documented in Section
4.1.4.3, wetlands are subject to Level I and II concentrations; therefore, a default value of 100 is assigned
for the HWQ factor value (Ref. 1, Section 2.4.2.2, Table 2-6).
230
Hazardous Waste Quantity Factor Value: 100
-------
GW to SW/Food Chain - Waste Characteristics Factor Category Value
4.2.3.2.3 Waste Characteristics Factor Category Value
The waste characteristic factor category value is the product of the highest toxicity/mobility/persistence
factor value for naphthalene (400) and HWQ factor value, multiplied by the highest bioaccumulation
factor value 50,000 for naphthalene(Ref. 1, Section 4.2.3.2.3).
400 x 100 = 40,000
Toxicity/persistence factor value
x hazardous waste quantity factor value: 1 x 105
40,000 x 50,000 = 2 x io9
(Toxicity/persistence x hazardous waste quantity)
x bioaccumulation potential factor value: 2 x 109
Waste Characteristics Factor Category Value: 180
(Ref. 1, Table 2-7)
231
-------
GW to SW Component/Food Chain - Targets
4.2.3.3 HUMAN FOOD CHAIN THREAT - TARGETS
Actual Human Food Chain Contamination
Although aqueous and sediment samples document an observed release to the Hilliards Creek, actual
food chain contamination is not scored because no fisheries are documented within the areas of the
observed release (Ref. 1, Section 4.2.3.3).
4.2.3.3.1 Food Chain Individual
No hazardous substance having a bioaccumulation factor value of greater than 500 was detected in both
the observe release to ground water and in the observed release to surface water. Lead was the only
hazardous substance detected in both the observed release to surface water and groundwater migration
pathways. The food chain individual factor is assigned a value of 0 (Ref. 1, Section 4.1.3.3.1).
232
Food Chain Individual Factor Value: 0
(Ref. 1 [Section 4.1.3.3.1])
-------
GW to SW Component/Environmental Threat
4.2.4 ENVIRONMENTAL THREAT
4.2.4.2 Waste Characteristics
4.2.4.2.1 Ecosystem Toxicitv/Mobilitv/Persistence/Bioaccuimilation
The ecosystem toxicity/mobility/persistence/bioaccumulation factor values for hazardous substances
detected in sources with a containment value greater than zero are summarized in Tables 35 and 36.
TABLE 35
ECOSYSTEM TOXICITY/MOBILITY/PERSISTENCE
FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Hazardous Substance
Source
Number
Ecosystem
Toxicity
Value*
Mobility
Value**
Persistence
Value***
Ecosystem
Toxicity/
Persistence
Factor Value
Reference
Acetone
1, 4
100
1.0
0.1
7.0
2, p. BI-1
Aluminum
1
100
1.0
1.0
100
2, p. BI-1
Antimony
2
100
1 x 10"2
1.0
1.0
2, p. BI-1
Arsenic
1, 2, 3, 4
10
1 x 10"2
1.0
0.1
2, p. BI-1
Barium
1, 2, 3, 4
1
1 x 10"2
1.0
0.1
2, p. BI-1
Benzene
1
1,000
1.0
0.4
400.0
2, p. BI-2
Benzo(a)anthracene
1, 4
10,000
2xl0"9
1.0
2xl0"5
2, p. BI-2
Benzo(a)pyrene
1, 4
10,000
2xl0"9
1.0
2xl0"5
2, p. BI-2
Benzoic acid
3
--
--
--
--
2, p. BI-2
Benzo(b)fluoranthene
1, 4
--
--
--
--
2, p. BI-2
Benzo(k)fluoranthene
1, 4
0
1 x 10"4
1.0
0.0
2, p. BI-2
Beryllium
2
0
1 x 10"2
1.0
0.0
2, p. BI-2
Bis(2 -ethylhexyl)phthalate
1
1,000
2xl0"7
1.0
2xl0"4
2, p. BI-2
2-Butanone
1, 2, 4
-
-
-
-
2, p. BI-2
Cadmium
1, 2, 3
10,000
1 x 10"2
1.0
100
2, p. BI-2
Carbon disulfide
3
100
1.0
0.4
40
2, p. BI-2
Chlorobenzene
1
10,000
1.0
0.0007
7.0
2, p. BI-2
Chloroform
4
100
1.0
0.40
40
2, p. BI-3
Chromium
1, 2, 3, 4
10,000
1 x 10"2
1.0
100
2, p. BI-3
Chrysene
1, 4
1,000
2xl0"9
1.0
2xl0"6
2, p. BI-3
Cobalt
2, 4
0
1 x 10"2
1.0
0.0
2, p. BI-3
Copper
1,2, 3
1,000
1 x 10"2
1.0
10
2, p. BI-3
Cyanide
4
1,000
1.0
1.0
1,000
2, p. BI-3
1,2-Dichloroethene
1,2
1
1 x 10"2
0.4
4xl0"3
2, p. BI-4
2,4-Dimethylphenol
1
100
1 x 10"2
0.4
0.4
2, p. BI-4
Di-n-butyl phthalate
4
1,000
2xl0"5
1.0
2x 10"2
2, p. BI-5
233
-------
GW to SW Component/Environmental Threat
TABLE 35 (Continued)
ECOSYSTEM TOXICITY/MOBILITY/PERSISTENCE
FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Hazardous Substance
Source
Number
Ecosystem
Toxicity
Value*
Mobility
Value**
Persistence
Value***
Ecosystem
Toxicity/
Persistence
Factor Value
Reference
Ethylbenzene
1, 2, 3, 4
100
1 x 10"2
0.0007
0.07
2, p. BI-6
Fluoranthene
1, 4
--
--
--
--
2, p. BI-6
2-Hexanone
4
--
--
--
--
2, p. BI-8
Iron
1
10
1 x 10"2
1.0
0.1
2, p. BI-8
Lead
1, 2, 3, 4
1,000
1.0
1.0
1,000
2, p. BI-8
Manganese
1
0
1 x 10"2
1.0
0.0
2, p. BI-8
Mercury
1, 2, 3, 4
10,000
1 x 10"2
1.0
100
2, p. BI-8
2-Methylnaphthalene
1, 2
100
2xl0"3
0.4
0.1
2, p. BI-8
Naphthalene
1, 2
1,000
1.0
0.4
400
2, p. BI-9
Nickel
1, 2, 3
100
1 x 10"2
0.4
0.4
2, p. BI-9
Pentachlorophenol
1, 3
100
1.0
1.0
100
2, p. BI-9
Phenanthrene
1, 4
10,000
2xl0"5
0.04
0.1
2, p. BI-9
Pyrene
1, 4
10,000
2xl0"5
1.0
0.2
2, p. BI-9
Selenium
1
1,000
1.0
1.0
1,000
2, p. BI-10
Tetrachloroethene
1, 2
0
1.0
0.40
0.0
2, p. BI-10
Toluene
1, 4
100
1.0
0.07
7.0
2, p. BI-11
1,1,2-Trichloroethane
1, 4
100
1.0
0.4
40
2, p. BI-11
Trichloroethene
1, 2, 4
100
1.0
0.4
40
2, p. BI,
B2-1
1,2,4-Trimethylbenzene
1
--
--
--
--
2, p. BI-11
1,3,5 - T rimethylb enzene
1
--
--
--
--
2, p. BI-11
Vanadium
1
0
1 x 10"2
1.0
0.0
2, p. BI-11
Xylenes
1, 2, 3, 4
100
1.0
0.4
40
2, p. BI-12
Zinc
1.2.3.4
10
1.0
0.4
4.0
2. p. BI-12
Notes:
* Fresh water ecotoxicities are assigned.
** Mobility factor value of 1 assigned to those hazardous substances for which an observed release
to ground water is documented.
*** Persistence values for river.
- Not listed in the SCDM.
234
-------
GW to SW Component/Environmental Threat
TABLE 36
ECOSYSTEM TOXICITY/MOBILITY/PERSISTENCE AND BIOACCUMULATION
FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Hazardous Substance
Source
Number
Ecosystem
Toxicity/
Mobility/
Persistence
Factor Value
(Table 35)
Bioaccumulation
Factor Value*
Ecosystem
Toxicity/
Persistence/
Bioaccumulation
Factor Value
Reference
Acetone
1, 4
7.0
0.5
3.5
2, p. BI-1
Aluminum
1
100
5,000
5xl05
2, p. BI-1
Antimony
2
1.0
5
5
2, p. BI-1
Arsenic
1, 2, 3, 4
0.1
5,000
500
2, p. BI-1
Barium
1, 2, 3, 4
0.1
500
50
2, p. BI-1
Benzene
1
400
5,000
2xl06
2, p. BI-2
Benzo(a)anthracene
1, 4
2xl0"5
50,000
1.0
2, p. BI-2
Benzo(a)pyrene
1, 4
2xl0"5
50,000
1.0
2, p. BI-2
Benzoic acid
3
--
--
--
2, p. BI-2
B enzo (b ) fluoranthene
1, 4
--
--
--
2, p. BI-2
B enzo (k) fluoranthene
1, 4
0.0
50,000
0.0
2, p. BI-2
Beryllium
2
0.0
50
0.0
2, p. BI-2
Bis(2 -ethylhexyl)
phthalate
1
2xl0"4
50,000
10
2, p. BI-2
2-Butanone
1, 2, 4
-
-
-
2, p. BI-2
Cadmium
1, 2, 3
100
50,000
5xl06
2, p. BI-2
Carbon disulfide
3
40
500
50,000
2, p. BI-2
Chlorobenzene
1
7
5,000
35,000
2, p. BI-3
Chloroform
4
40
500
20,000
2, p. BI-3
Chromium
1, 2, 3, 4
100
500
50,000
2, p. BI-3
Chrysene
1, 4
2xl0"6
5,000
0.01
2, p. BI-3
Cobalt
2, 4
0.0
5,000
0.0
2, p. BI-3
Copper
1, 2, 3
10
50,000
5xl05
2, p. BI-3
Cyanide
4
1,000
0.5
500
2, p. BI-3
1,2-Dichloroethene
1,2
0.004
50
0.2
2, p. BI-5
2,4-Dimethylphenol
1
0.4
500
200
2, p. BI-4
Di-n-butyl phthalate
4
2xl0"2
5,000
100
2, p. BI-5
Ethylbenzene
1, 2, 3, 4
0.07
50
0.35
2, p. BI-4
Fluoranthene
1, 4
--
--
--
2, p. BI-6
2-Hexanone
4
--
--
--
2, p. BI-8
Iron
1
0.1
5,000
500
2, p. BI-8
235
-------
GW to SW Component/Environmental Threat
TABLE 36 (Continued)
ECOSYSTEM TOXICITY/PERSISTENCE
FACTOR VALUES
SHERWIN-WILLIAMS/HILLIARDS CREEK
Hazardous Substance
Source
Number
Ecosystem
Toxicity/
Mobility/
Persistence
Factor Value
(Table 35)
Bioaccumulation
Factor Value*
Ecosystem
Toxicity/
Persistence/
Bioaccumulation
Factor Value
Reference
Lead
1, 2, 3, 4
1,000
50,000
5xl07
2, p. BI-8
Magnesium
1, 2, 4
-
-
-
2, p. BI-8
Manganese
1
0.0
50,000
0.0
2, p. BI-8
Mercury
1, 2, 3, 4
100
50,000
5xl06
2, p. BI-8
2 -Methylnaphthalene
1, 2
0.1
50,000
4,000
2, p. BI-8
Naphthalene
1, 2
400
50,000
2xl07
2, p. BI-9
Nickel
1, 2, 3
0.4
500
200.0
2, p. BI-9
Pentachlorophenol
1, 3
100
50,000
5x 106
2, p. BI-9
Phenanthrene
1, 4
0.1
50,000
5,000
2, p. BI-9
Pyrene
1, 4
0.2
50,000
25,000
2, p. BI-9
Selenium
1
1,000
500
5xl05
2, p. BI-10
Silver
1
10,000
50
5xl05
2, p. BI-10
T etrachloroethene
1, 2
0.0
50
0.0
2, p. BI-11
Toluene
1, 4
7.0
5,000
35,000
2, p. BI-11
1,1,1 -Trichloroethane
4
0.4
5
2
2, p. BI-11
1,1,2 -Trichloroethane
1, 4
40
50
2,000
2, p. BI-11
T richloroethene
1, 2, 4
40
50
2,000
2, p. BI,
B2-1
1,2,4-
Trichloromethylbenzene
1
--
--
—
2, p. BI-11
1,3,5-
Trichloromethylbenzene
1
--
--
—
2, p. BI-11
Vanadium
1
0.0
500
0.0
2, p. BI-11
Xylenes
1, 2, 3, 4
40
50
2,000
2, p. BI-12
Zinc
1,2,3,4
4.0
50,000
2x 105
2, p. BI-12
Notes:
* Fresh-water bioaccumulation factor values are assigned.
- Not listed in the SCDM.
Ecosystem Toxicity/Mobility/Persistence/Bioaccumulation Potential Factor Value: 5><107
236
-------
GW to SW Component/Environmental - Hazardous Waste Quantity
4.2.4.2.2 Hazardous Waste Quantity
The source HWQ values for each of the four sources is greater than zero. As documented in Section
4.1.4.3, wetlands are subject to Level I and II concentrations; therefore, a default value of 100 is assigned
for the HWQ value (Ref. 1, Section 2.4.2.2, Table 2-6).
237
Hazardous Waste Quantity Factor Value: 100
-------
GW to SW/Environmental - Waste Characteristics Factor Category Value
4.2.4.2.3 Waste Characteristics Factor Category Value
The waste characteristics factor category value is determined by taking the product of the highest
ecosystem toxicity/mobility/persistence factor value for lead and the HWQ value and multiplying the
product by the highest ecosystem bioaccumulation factor value for lead (Ref. 1, Section 4.1.4.2.3).
1,000 x 100 = 100,000
Ecosystem toxicity/persistence factor value
x Hazardous waste quantity factor value: 100,000
100,000 x 50,000 = 5 x 10"
(Ecosystem toxicity/persistence X hazardous waste quantity)
x ecosystem bioaccumulation potential factor value: 5 x 109
Waste Characteristics Factor Category Value: 180
(Ref. 1, Table 2-7)
238
-------
GW to SW Component/Environmental - Targets
4.2.4.3 ENVIRONMENTAL THREAT - TARGETS
Level I Concentrations
The Level I concentrations for ground water to surface water migration component are the same
concentrations documented in Section 4.1.4.3 for the surface water overland flow component. Lead was
documented in both an observed release to groundwater and to surface water as documented in Section 4.0
of this documentation record (Ref. 1, Section 4.2.1.3 and Section 4.2.1.4). Because the surface water
sampling locations documenting Level I concentrations and the PPE to surface water from overland flow and
groundwater are the same, the Level Itargets are the same. See Section4.1.4.3 for the Level I concentrations.
239
-------
GW to SW Environmental - Level I Concentrations
4.2.4.3.1 Sensitive Environments
4.2.4.3.1.1 Level I Concentrations
Sensitive Environments
Sensitive environments other than wetlands have not been identified within the 15-mile downstream target
distance.
Wetlands
The wetland areas were identified from Reference 93, Wetland Inventory Map. The wetland is a palustrine
forested broad-leaved deciduous and needle-leaved evergreen, and palustrine scrub/shrub and emergent
wetland (Ref. 93). The sampling locations identified in the Level I Concentrations section above are within
this wetland (Ref. 97). The wetlands subject to Level I concentrations are those wetlands located between
PPE-1 and the most distance downstream Level I sampling location (HC-SW-39) (Ref. 1, Section 4.1.1.2).
The total length of wetlands from PPE-1 to the most downstream sampling location (HC-SW-39) containing
Level I concentrations is estimated to be 5,708 feet (Refs. 93; 97). Since wetlands are located on both sides
of Hilliards Creek, the total length of wetlands subject to Level I concentrations is two times 5,708 feet or
11,416 feet or 2.16 miles (Ref. 1, Section 4.1.4.3.1.1). The wetland frontage is summarized in Table 25.
The wetland frontage is summarized in Table 37.
TABLE 37
LEVEL I WETLAND FRONTAGE
Wetland
Wetland Frontage
Reference
Palustrine emergent, palustrine
forested, palustrine scrub/shrub
2.16 mile
93; 97
Total Level I Wetland Frontage: 2.16 mi.
The wetland ratings value for 2.16 miles is obtained from Reference 1, Table 4-24 and is 78.
Level I Wetland Value: 50
(Ref. 1, Table 4-24)
For wetlands subject to Level I concentrations, the wetland value (75) is multiplied by 10 (Ref. 1, Section
4.1.4.3.1.1).
Level I Concentrations Factor Value: 750 (Ref. 1, Section 4.1.4.3.1.1)
240
-------
GW to SW Environmental - Level II Concentrations
4.2.4.3.1 Sensitive Environments
4.2.4.3.1.1 Level II Concentrations
Sensitive Environments
Sensitive environments other than wetlands have been not been identified within the 15-mile downstream
target distance.
Wetlands
The wetland length subj ect to Level II concentrations is located between surface water sampling location HC-
SW-39 (most distance Level I concentration) and sediment sampling location HC-SD-43, the most distant
Level II sediment sampling location. That length is estimated to be 778 feet or 0.15 mile as measured on Ref.
97 (Refs. 93; 97) and includes the length of wetlands on both the north and south banks of Hilliards Creek
(Ref. 1, Section 4.1.4.3.1.1). The Level II wetland frontage is summarized in Table 38.
TABLE 38
LEVEL II WETLAND FRONTAGE
Wetland
Wetland Frontage
Reference
Palustrine emergent, palustrine
forested, palustrine scrub/shrub
0.15 mile
93; 97
Total Level I Wetland Frontage: 0.15 mile
The wetland ratings value for 0.15 mile of wetland frontage is obtained from Reference 1, Table 4-24 and is
25.
Level II Wetland Value: 25
(Ref. 1, Table 4-24)
Level II Concentrations Factor Value: 25 (Ref. 1, Section 4.1..4.3.1.2)
241
-------
GW to SW Environmental - Potential Contamination
4.2.4.3.1.3 Potential Contamination
Sensitive Environments
Sensitive environments potentially exposed to contaminants from the Sherwin-Williams/Hilliards Creek are
not evaluated because the presence of sensitive environments other then wetlands subj ect to Level I and II
concentrations have not been identified.
Potential Contamination Factor Value (SP): Not evaluated
242
------- |