PRIVILEGED IRK PRODUCT PREPAREDJN ANTICIPATION OF UTIfiATION

I .*' {(\V>

EfTfcORtEMENTSO.NEIDENTIAL

REPORT TO U.S. ENVIRONMENTAL PROTECTION AGENCYOFFICE OF WASTE PROGRAMS ENFORCEMENT

I FOCUSED FEASIBILITY STUDY

THE WADE SITE.j| (CHESTER, PENNSYLVANIA)

, MARCH

Prepared by:

METCALF & EDDY, INC.50 staniford Street

Boston, Massachusetts 02111

The work upon which this publication is based wasperformed under Subcontract to GCA/Teohnology Division,under Contract to U.S. Environmental Protection Agency.

EPA Work Assignment No. 81)-117GCA Work Assignment No. 84-117-003

rEPA Contract No. 68-01-6769

OCA Subcontract No. 1-625-999-222-002

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I V"'— ,.\ (Red)TABLE OF CONTENTS

Page

CHAPTER 1 - FOCUSED FEASIBILITY STUDY OBJECTIVES 1-1

CHAPTER 2 - FOCUSED FEASIBILITY STUDY ASSUMPTIONS 2-1

CHAPTER 3 - SITE REMEDIAL ALTERNATIVES 3-1

Historical Development of the RemedialAlternatives 3-1

Remedial Alternative Development 3-6CHAPTER 4 - ENDANGERMENT ASSESSMENT . 4-1

CHAPTER 5 - REMEDIAL ALTERNATIVE INITIAL SCREENING 5-1

Ground Water Interception/Withdrawal RemedialAlternatives 5-1

Soil Excavation/Removal Remedial Alternatives 5-2Site Capping Remedial Alternatives 5-3

Focused Feasibility Study Conclusions fromInitial Screening 5-4

•' List of Remaining Remedial Alternatives 5-5CHAPTER 6 - DETAILED EVALUATION OF REMEDIAL ALTERNATIVES 6-1

Technical Evaluation of Remedial Alternatives 6-10• Public Health Risk Assessment 6-12

'• Environmental Risk Assessment 6-15j Institutional Analysis • 6-18

Impleraentabtlity/Reliability Analysis 6-20Cost Analysis 6-22

Post Closure, Long-Term Monitoring Plan 6-24Cost-Effectiveness Matrix 6-34

REFERENCES

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TABLE OF CONTENTS (Continued) ^ 'Page

APPENDICESA - Environmental Assessment Documentation A-1B - Contaminant Levels (mg/kg) in Soils on

the Wade Site B-1

C - Remedial Alternative Implementation CostEstimating Baok-Up Sheets C-l'

D - Post Closure, Long-Term Monitoring Plan CostEstimating Back-Up Sheets D-1

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i . ORIGINAL

_ CHAPTER 1

FOCUSED FEASIBILITY STUDY OBJECTIVES

The focused feasibility study (FFS) for the Hade Site is

an abbreviated form of a general feasibility study conducted forhazardous waste site remedial alternatives. The FFS is conductedin a short, limited time frame with focused study objectives.

I These study objectives were determined by the U.S. Environmental

Protection Agency and form the basis of its tasking to Metoalf &

'• Eddy, Inc. to conduct the Wade Site FFS. These study objectives| i are as follows:

. Technical evaluation of the remedial measures

identified by R. F. Weston (1983).. Development and initial screening of Wade Site Remedial

Alternatives., Detailed evaluation of remaining site Remedial

Alternatives to include:

- Cost Analysis

- Public Health Risk Assessment as part of theEndangerment Assessment

- Environmental Risk Assessment as part of the

Endangerment Assessment- Institutional Issue Analysis- Implementability/Reliability Analysis

, Selection and recommendation of the most cost-effectiveRemedial Alternative(s).

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. Development and posting of a long-term post closure,

site monitoring plan.The technical evaluation of proposed remedial measures will focuson a review of the "Draft Report, Results of Soil Analysis andCost Estimates for Selected Remedial Activities Regarding the

Wade Hazardous Waste Site in Chester, PA.," prepared for the

Pennsylvania Department of Environmental Resources by Roy F.Weston, Inc., November, 1983 (RFW, 1963). The technical

evaluation will consist of a review of the six item remedialaction plan for the Wade Site, on-site contaminated soil quantity

estimates and remedial costs. A list of Wade Site remedialalternatives including the No Action Remedial Alternative was

developed covering all combinations of the six item remedial plandiscussed in the RFW, 1983 report. The total list of remedial

alternatives was screened based on technical criteria and theendangerment assessment to eliminate alternatives from furtherdetailed evaluation. The detailed evaluation of the remaining

remedial alternatives will be based on a cost analysis,

(alternative implementation costs, and long-term

monitoring/maintenance costs), an endangerment assessment,institutional issues analysis and impleraentabillty/reliabilityissue analysis. A cost-effectiveness, decision matrix will bedeveloped presenting all remaining remedial alternatives andtheir corresponding cost and effectiveness ratings,Justification and back-up tables will be provided for all ratingsgiven in the oost-effectiveness matrix. Metcalf & Eddy will

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select and recommend the most cost-effective remedialalternatives that effectively mitigate potential adverse impacts

on public health and the environment. A long-term, post closure,site monitoring plan and costs will also be developed anddescribed for all screened remedial alternatives.

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CHAPTER 2

FOCUSED FEASIBILITY STUDY ASSUMPTIONS

In order to expeditiously undertake and complete a focusedfeasibility study of the Wade Site, many assumptions were madethat pertain to all aspects of the study. The results of Metoalf& Eddy's focused feasibility study are qualified and based on thefollowing listed assumptions. It was not an objective of thisstudy to generate any new site analytical information or to conducti

!.. site remedial investigations other than a brief site visit.f The general study assumptions and specific task

assumptions listed below will enable the reader to review all{ major study assumptions without having to refer to eachliii

individual report section. The assumptions are as follows:

| ' General Assumptions1. Future site land use will consist of light industrial/

commercial operations. Foundation for future lightbuilding construction on-site will be restricted toexisting on-slte concrete floor slabs.

2. Metcalf & Eddy has been provided with all available,

accurate site analytical data,3. On-site soil contamination is limited to those areas

already sampled and does not exist under existingbuilding concrete floor slabs due to integrity offloor slabs and past waste operation disposalpractices as discussed with Mr. Michael Steiner ofPADER.

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4. There are no upgradient, off-site ground water

monitoring wells.5. Parking will be permitted on any asphalt cap that is

installed.6. There will be no short- or long-term on-site storage

of excavated soil material.7. Ground water contaminant concentrations will not be

attenuated between on-site ground water monitoringwell sampling locations and the aquifer/Delaware River

recharge interface,Public Health Risk Assumptions

1. Under all alternatives, children will still gain entryto the site, both during remedial activities and postclosure of the site, despite attempts to close off the

site.2. Increasing the amount of soil excavated exposes more

contaminated soil to the air and, thereby, increasesthe potential for increased exposure to the public onand off-site during remedial activities.

3. During all remedial activities and any futureconstruction on the site, a site health and safetyplan will be implemented. All necessary personalprotection equipment will be provided and worn, andnecessary ambient air or personal monitoring will be

performed.

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4. All trucks carrying soil off-site will be equippedwith covers to prevent loss of contaminated soil from

truck during transport to a secure landfill.5. The probability of an accident resulting in a spill

from trucks transporting contaminated debris or soilincreases with the number of loads transported.

Environmental Risk Assessment - Assumptions1. Comparison with Existing Criteria

a. Ambient Hater Quality Criteria - As this portionof the Delaware River is under tidal influence,the criteria for protection of saltwater aquaticlife have been used in the evaluation.

b. Red Book - Quality Criteria for Hater - Standards

in the Red Book are not applicable to theprincipal water quality concerns at mils site.

2. Effects on Sensitive Environmentsa. Habitat of Endangered Species - The tidal portion

of the Delaware River is considered to be a

habitat for endangered species due to effortsunderway to restore the lower Delaware astransient habitat for the anadromous, endangered

fish species, Atlantic sturgeon.b. Wildlife Sanctuary - There are none believed to

exist within a 3 mile radius of the site.

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_ o. Vulnerable Ecosystem - There are none believed to

exist within a 3 mile radius of the site. TheDelaware River in this area is too severelyimpacted by numerous sources to be considered a

vulnerable ecosystem,v d. Based on available information, no breeding

grounds for important species on wetlands arebelieved to be located within a 3 mile radius of

the site.

3. Effect on Human Resources

a. Commercial - No commercial resources, known toexist in the area,

b, Cultural - No historical or archaeologicalresources are known to exist within a 3 mileradius of the site based on available data.

4. Timing of Effects:a. The effects of the no-action alternative are

presently occurring and will occur indefinitely.b. The major effects include input of contaminants to

the river and aesthetic and residential impacts.c. The topsoil oap alternatives have a greater chance

than asphalt caps for some continued input ofcontaminants to the river.,

5. Effects of Failure Scenario:

a. The principal failure scenario is thatcontaminants will be transported offslte via

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ground water either chronically or as a result ofunexpected failure of the alternative,

b. Asphalt cap options have a lower probability offailure than topsoil with seed caps.

Institutional Issues Analysis Assumptions1. On-Site Requirements:

a. No dredging or filling i;? associated with anyalternative.

b. No alteration of wetlands or wildlife habitat is

involved.c, No alternative includes ground water or leaehate

controls, but those alternatives which includeasphalt capping would reduce leaehate production

and migration.d. There is no point source discharge so no NPDES

permit is required.2. Off-site Requirements:

The decisions to remove surface debris and to

excavate soil each constitute a thresholdtriggering off-site requirements. Therequirements, for example, of meeting Department

of Transportation regulations, do not change withthe amount of debris or soil removed.

3. NEPA:All remedial alternatives are likely to require

similar review under NEPA.

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4. Relocation:Relocation of nearby population is not

anticipated.5. Community Relations:

This effort involves primarily communityacceptance based on their perception of the

effectiveness of an alternative at reducing public

health/environmental dangers.

6. Coordination With Other Agencies:In general, the need for coordination with other

agencies will be similar for all thealternatives. The ranking is based on the extent

of coordination and potential for administrative

delays.Iroplementability/Rellability Analysis Assumptions

1. An asphalt cap is less permeable over time than atopsoil cap and nay require more maintenance.

2. Remedial alternatives which remove moat of thecontaminant source are most effective in terras of

reliability.3. Remedial alternatives which involve the least work

effort at the site are those that are easiest to

implement and take the least amount of time to

implement.

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Cost Analysis Assumptions1. On-site debris quantity estimates are correct as

contained in the RFW Report, November 1983-2. On-site building demolition debris quantity estimates

are correct as contained in RFW Report, November

1983.3> Above ground, on-site metal and wood to be removed is

uncontaminated.I 4. Cost figures are not based on salvageable steel,

machinery or other materials in on-site buildings,' 5. Building demolition and demolition debris removal

includes all on-site above ground tanks.Ml 6. The on-site buried 5,000 gallon fuel tank is full of1 petroleum residues and water and the on-site buried

chemical storage tank is full of 5' standing liquidand sludge.

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7. The following costs were not included in R.F.f.\ Heston's November 1983 report:

' - Decontamination of on-slte tires andcollection/disposal of decontaminated waste.

I - Hauling contaminated crushed druns to Niagara

Falls for final disposal.

- Removal/disposal of on-site buried 5,000 gallonfuel oil tank and contents of on-aite buriedchemical storage tank.

- Engineering Fees

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""^ - Indirect Costs (legal fees, permitting costs,

community relations) (5))>- Sump sampling and analysis and sump waste

removal/disposal.- Rough grading and site leveling after building

k demolition/debris removal.[ 8. Soil volume would swell by 15J after loading into /0/ispMrtl

trucks for transportation to final disposal site. wJtnfI I Vfcf{,, 9. Crushed drums volume would swell by 50jt after loading y/Jj

i , into trucks for transportation to final disposal /

site.I 10. Disposal fee is $90/ton for contaminated soil and/orV.Ii crushed drums at the Niagara Falls, New York disposal

I , site., 11. Lump sun costs to include health and safety measures,'• general conditions, mobilization, demobilization, and

. ,, miscellaneous.! 12. There are three on-site sunps to be sampled after

•* i[ j building demolition.. 13. On-site crushed drums and above ground contaminated'- soil will be removed for all renedial alternatives

' (except No Action) regardless of SoilExcavation/Removal Options,

14. Truck weighing scale will be removed and pit will be

filled in.15. On-site building basements will be filled in.

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16. On-site tunnel entrances will be filled in.17. Site will be graded, filled and leveled to a depth of

approximately 12 inches which will cover anysubsurface structures which protrude the surface at

the present.Post-Closurej Long-Term Monitoring Plan Assumptions

1. Construction of two, 2" diameter multi-levelstainless steel off-site, upgradient ground watermonitoring wells.

2. Use 30 year monitoring period based on RCRA.3. Implementation of remedial alternatives will proceed

on-site over a period of 0-3 years.4, Priority pollutant analysis for ground water and soil

samples for the first 5 years and then analysis fortargeted contaminants from 6-30 years.

5. For Remedial Alternative 1:. Site Inspections/Sampling ground water and soil

twice a year for 30 years.. Ground water monitoring wells (OWMW) rehabilitated

based on the schedule as discussed in detail laterin this report.

6. For remedial alternative 2:. Site Inspections/Sampling ground water and soil

quarterly for 0-3 years, twice a year for 4-10

years and once a year for 11-30 years.

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. Ground water monitoring wells (GHMW) rehabilitated

baaed on the schedule as discussed in detail laterin this report.

7. For renedial alternatives 3, 5, 7, 9, and 11«. Site Inspections/Sampling ground water quarterly

for 0-3 years, twice a year for the 4-10 years and

once a year for the last 20 years.. Ground water monitoring wells (GWMW) rehabilitated

based on the schedule as discussed in detail later

in this report.. Asphalt maintenance every 3 years,. Asphalt overlay or replacement every 15 years.

8. For remedial alternatives 4, 6, 8, 10, and 12:

. Site Inspection/Sampling ground water quarterly1 for 0-3 years, twice a year for 4-10 and once a

' year for years 11-30.. Ground water monitoring wells (GWMW) rehabilitated

' based on the schedule as discussed in detail later.. in this report.'•' . Topsoil maintenance every two years.

. Site mowing each year,9, On-site and off-site ground water monitoring wells

will not be vandalized.10. Existing galvanized GWMWa will be replaced after

first ten years by stainless steel OHMW's.

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11. Five GWMW's will be used for sampling/analysis (3

existing, on-site downgradient GHMW's and ^ new off-site, upgradient GHMW's).

12. No cost escalation factors were used in determining

final monitoring costs.

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CHAPTER 3

SITE REMEDIAL ALTERNATIVES

Historical Development of Remedial Alternatives

Since 1980, after the completion of initial sitecharacterization studies the EPA and DER have engaged severalorganizations to develop remedial alternatives for clean-up ofthe ABM/Wade Hazardous Waste Site.

In December of 1980, the EPA requested assistance from theNational Enforcement Investigation Center (NEIC) in developing

cleanup alternatives for the Wade Hazardous Waste Site. NEICdeveloped three remedial alternatives based on their field

investigations, conducted February 7-8 and March 13-14, 1979(7)and on the Betz-Converse-Murdoeh, Inc., draft report titled"Phase I: Investigation of Contamination From a Hazardous WasteSite, Wade Property, 1 Flower Street, Chester, PA".

The proposed remedial alternatives emphasized reducing theexposure of area residents and workers to surface contaminants onthe site and/or volatile chemicals migrating off the site.

The three options considered included removingcontaminated materials to depths of 12, 36 and 72 inches belowgrade, as follows:

Option 1 - Removal of 12 in. of contaminated material,backfilling with clay and covering withasphalt.

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Option 2 - Removal of contaminated material to 36 in.below grade, and backfilling with clay and/orsoil.

Option 3 - Removal of contaminated material to 42 in.below grade, and backfilling with clay and/orsoil.

Additional remedial alternatives that were considered by iI

the NEIC and rejected, included: ;I 1. Construction of a barrier wall to impede movement of :i i

shallow ground water as well as methods for collecting |i

and treating ground water. This alternative wasrejected because measurable impact on the quality of i

•'I water supplies and the Delaware River were notanticipated, • i

2. Excavation of all contaminated material down to ,';bedrock to pursue a "zero risk" option. This was

considered unwarranted and would result in exorbitantcosts for excavation, disposal and treatment. i

3. Isolation and above grade capping of the site with no.1

contaminant removal other than above grade materials.I This alternative was not considered because it would, restrict future aite use.

Following the development of the NEIC alternatives, aremedial approach to cleaning up the Hade Site was developed by

the EPA. In developing this alternative the EPA atated that theywanted an approach that would provide ••clean-up" in a cost

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effective manner. Their goal was not to restore the site for anyspecific use, but to restore the environment. Followingdiscussions with NEIC and with the Region the following approachwas developed:

1, Above grade removal of structures and materialsincluding removal and disposal of remaining drums,buildings and surface debris.

2. Capping the site with 1 foot of clay and 4 1/2 inchesof asphalt.

3. Cleanup of ground water by means of collection at thesite for transport and discharge to the regionalwastewater treatment authority, DELCORA, for

treatraent(20).The Mitre Corp., under contract to DER to analyze

alternative remedial measures and recommend a single permanentremedy, reviewed the EPA suggested alternative and the results ofearlier studies. This resulted in the development of analternative which combined and expanded upon the actionsrecommended by NEIC and EPA. The alternative, described in theSeptember 16, 1981 Mitre Report, is summarized as follows:

1. Remove, categorize and dispose of all drums and theircontents found on the property,

2. Remove and dispose of all debris and tankers on thesurface of the property,

3. Remove and dispose of one foot of soil from theproperty,

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_ 4. Demolish and dispose of unsound structures.5. Backfill the property with clean earth and top soil

and seed.6. Install pumping wells for ground water collection, a

activated carbon system for ground water treatment andv a system for reinjeoting treated ground water.I In September and December of 1981 the DER met with the EPA' Region to discuss the Wade Site. The meetings resulted in

I j further modifications to the technical approach to the siteclean-up. A description of the clean-up activities decided upon

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' during these meetings is presented in a letter dated 4/12/82 to

Mr. Peter Bibko, of the EPA Region III, from Peter Duncan, former

secretary of the DER. Modifications to the above approach

••, included 1) leaving empty drums on-site, 2) removing onlycontaminated soil and debris, 3) leaving rubble from demolishedbuildings on-site to be used for fill material rather thanremoving it, 4) installing a cap of either impermeable cover orloam and seed over the graded fill and 5) if sufficient funds areavailable for operation over a 10 year period and if warranted bydocumented evidence that ground water contamination presents a

[ threat to public health or the environment, then installing a1 r ground water collection system for treatment on or off-site, The

DER found the technical and economic feasibility of ground watercollection and treatment questionable, due to only low levels ofground water contamination. Based on the cleanup activitiesdescribed in this letter R. F. Heston, contracted by the DER in

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1980, developed a Remedial Action Plan, which is presented intheir report of November, 1983. (18) The Remedial Action Plandeveloped by R. F. Weston included the items described in theMitre Report, as modified by the DER and EPA. In addition, theydeveloped six separate soil removal alternatives, based on theresults of soil analyses performed during a site characterization

program,Several other alternatives were evaluated by Heston and

rejected including:1. Volatilization of volatile contaminants by excavating

the soil and spreading it in thin layers and turningperiodically to expose it to the atmosphere or placingthe soil in windrows, This technique was rejected onthe basis of low efficiency due to the small size ofthe site, no off-site location available, no removalof BN/A contaminants, the requirement of airmonitoring, unpredictable weather conditions, and thepossible requirement of mechanical aeration.

2. Land farming and composting, for aerobic degradationof organic contaminants. This alternative wasrejected because of the possible requirement for

commercially-developed mutant bacteria, the lowconcentrations of organic material present in thesoil, required treatability studies and pilot testing,specialized equipment, long processing times,

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_ continuous monitoring and because the technique had

not been proven for decontamination of soil.3. Creation of a secure cell on-site, by means of an

impermeable cover, continuous monitoring of groundwater and possibly impermeable side walls or liner to

^ prevent migration of contaminants away from theproperty boundaries, This alternative was rejectedbecause the contaminated soil would remain In an urbanarea, the cell would have to be perpetually monitored,the hydrological properties of the site are notsuitable for a secure cell, the property would have tobe restricted from other use and state and federalpermits may be required,

4. Total removal and off-site disposal of soil at alicensed, secured landfill and backfilling the sitewith Imported soil. This alternative was rejectedbecause site investigation show the soil contaminationis localized in descrete areas and because of the highcost of this solution.

In 1964, the EPA engaged Metcalf & Eddy (GCA) to reviewprevious studies and remedial alternatives and to recommend analternative based on a focused feasibility study.Remedial Alternative Development

Development of a list of complete remedial alternativesfor the Wade Site has not been performed based on informationprovided to M&E by the U.S. EPA and described in the previous

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section. In order to perform a detailed evaluation, it isnecessary to develop this list of remedial-alternatives whichwould include a No Action Remedial Alternative. This list wasdeveloped by combining some or all of the six remedial measures(RFW, 1983) in various combinations. Based on the previousstudies and information available, 45 remedial alternatives weredeveloped for the Wade Site. The 45 alternatives are described

in Table 1.

TABLE 1. REMEDIAL ALTERNATIVES

Remove, decontaminate and dispose of tankers and on-site waste piles including tires and debris.; aiuc naauw r.-—

. • - Demolish buildings./ , . - Level site, fill and grade property3 - Remove, decontaminate and dispose of tankers and on-

site waste piles, including tires and debris.1 - Demolish buildings.i - Level site, fill and grade property.

- Install clay cap.4 .- 'Remove, decontaminate and dispose of tankers and on-

site waste piles, including tires and debris.- Demolish buildings.- Level site, fill and grade property.- Install asphalt cap,

5 - Remove, decontaminate and dispose of tankers and on-site waste piles, including tires and debris.

- Demolish buildings.- Level site, fill and grade property.- Install topsoil cap.

6 - Remove, decontaminate and dispose of .tankers and on-site waste piles including tires and debris.

- Demolish buildings.- Level site, fill and grade property.

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TABLE 1 (Continued). REMEDIAL ALTERNATIVES

Number Description

- Excavate and remove all soil contaminated to athreshold level of 100 ng/kg for both volatile andBN/A extractable organics to the level at whichextent of contamination was confirmed (Weston SoilRemoval Option 1A).

- Install clay cap.7 - Remove, decontaminate and dispose of tankers and on-

site waste piles inoludirs tires and debris.- Demolish buildings.- Level site, fill and gride property,- Excavate and remove all soil contaminated to a

threshold level of 100 rag/kg for both volatile andBN/A extractable organics to the level at whichextent of contamination was confirmed (Weston SoilRemoval Option 1A).

- Install asphalt cap.6 - Remove, decontaminate and dispose of tankers and on-

site waste piles including tires and debris.- Demolish buildings.- Level site, fill and grade property.- Excavate and remove all soil contaminated to a

threshold level of 100 rag/kg for both volatile andBN/A extraotable organios to the level at whichextent of contamination was confirmed (Weston SoilRemoval Option 1A).

- Install topsoil cap.9 - Remove, decontaminate and dispose of tankers and on-

site waste piles Including tires and debris.- Demolish buildings.- Level site, fill and grade property.- Excavate and remove all soil contaminated to a

threshold level of 100 ng/kg for both volatile andBN/A extraotable organics. If either threshold isexceeded by less than 20>, excavate to level ofconfirmed contamination, If threshold is exceededby 20f to 100% excavate to one foot beyond level ofconfirmed contamination. If threshold is exceededby more than 100?, excavate to level of confirmed"cleanliness" (Weston Soil Removal Option IB).

- Install clay cap.

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Number Description

10 - Remove, decontaminate and dispose of tankers and on-site wastepiles including tires and debris.

- Demolish buildings.- Level site, fill and grade property.- Excavate and remove all soil contaminated to a

threshold level of 100 mg/kg for both volatile andBN/A extraotable organios. If either threshold isexceeded by less than 20} excavate to level ofconfirmed contamination. If threshold is exceeded by20} to 100} excavate to one foot beyond level ofconfirmed contamination. If threshold is exceeded bymore than 100} excavate to level of confirmed"cleanliness" (Weston Soil Removal Option 1B).



threshold level of 100 mg/kg for both volatile andBN/A extractable organics. If either threshold isexceeded by less than 20} excavate to a level ofconfirmed contamination. If threshold is exceededby 20} to 100} excavate to one foot beyond level ofconfirmed contamination. If threshold is exceededby more than 100} excavate to level of confirmed"cleanliness" (Weston Soil Removal Option IB).

- Install topsoil cap.12 - Remove, decontaminate and dispose of tankers and on-


threshold level of 100 mg/kg for both volatile andBN/A extraotable organics to the depth at which"cleanliness" has been determined (Weston SoilRemoval Option 1C).-Install clay cap.

13 - Remove, decontaminate and dispose of tankers and on-site waste piles including tires and debris.

- Demolish buildings.- Level site, fill and grade property.

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Number Description !

- Excavate and remove all soil contaminated to a :threshold level of 100 mg/kg for both volatile and •'BN/A extractable organics to the depth at which"cleanliness" has been determined (Weston Soil ;Removal Option 1C).

k - Install asphalt cap. !i11 - Remove, decontaminate and dispose of tankers and on- '•

site waste piles including tires and debris. j- Demolish, buildings. ;- Level site, fill and grade property.- Excavate and remove all soil contaminated to a !

threshold level of 100 mg/kg for both volatile and ;BN/A extractable organics to the depth at which"cleanliness" has been determined (Weston SoilRemoval Option 1C).

- Install topsoll cap.15 - Remove, decontaminate and dispose of tankers and on-

site waste piles including tires and debris,- Demolish buildings.- Level site, fill and grade property.- Excavate and remove all soil contaminated to a •

threshold level of 100 mg/kg for the volatileorganios fraction and 500 mg/kg for the BN/Aextractable organios fraction to the level at whichextent of contamination has been confirmed (WestonSoil Removal Option 2A).

- Install clay cap.16 - Remove, decontaminate and dispose of tankers and on-


threshold level of 100 mg/kg for the volatileorganics fraction and 500 mg/kg for the BN/Aextraotable organics fraction to the level at whichextent of contamination has been confirmed (WestonSoil Removal Option 2A).


site wastepiles including tires and debris.- Demolish buildings,- Level aite, fill and grade property,

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O TABLE 1 (Continued). REMEDIAL ALTERNATIVES

Number Description

- Excavate and remove all soil contaminated 'to athreshold level of 100 mg/kg for the volatileorganios fraction and 500 mg/kg for the BN/Aextractable organics fraction to the level at whichextent of contamination has been confirmed (Weston

I Soil Removal Option 2A).- Install topsoil cap.

18 - Remove, decontaminate and dispose of tankers and on-1 site wastepiles including tires and debris.

- Demolish buildings.I - Level site, fill and grade property.i - Excavate and remove all soil contaminated to a

threshold level of 100 ng/kg for the volatile and500 mg/kg for the BN/A extractable organics. Ifeither threshold is exceeded by less than 20}excavate to level of confirmed contamination. Ifthreshold is exceeded by 20} to 100} excavate to onefoot beyond level of confirmed contamination. Ifthreshold is exceeded by more than 100} excavate tolevel of confirmed "cleanliness" (Weston SoilRemoval Option 2B).

- Install clay cap.

19 - Remove, decontaminate and dispose of tankers andon-site waste piles including tires and debris.Demolish buildings.

- Level site, fill and grade property.- Excavate and remove all soil contaminated to a

threshold level of 100 mg/kg for the volatile and500 mg/kg for the BN/A extractable organics. Ifeither threshold is exceeded by less than 20}excavate to level of confirmed contamination. Ifthreshold is exceeded by 20} to 100} excavate to onefoot beyond level of confirmed contamination. Ifthreshold is exceeded by more than 100} excavate tolevel of confirmed "cleanliness" (Heston SoilRemoval Option 26).


site wastepiles Including tires and debris.- Demolish buildings.- Level alte, fill and grade property.

0002023-11

MtIC Air A f Rt)Y

IJ

,1

Lr

i ORIGINALtfnd)


Number Description

- Excavate and remove all soil contaminated to athreshold level of 100 mg/kg for the volatile and500 mg/kg for the BN/A extractable organios. Ifeither threshold Is exceeded by less than 20}excavate to level of confirmed contamination. Ifthreshold is exceeded by 20} to 100} excavate to onefoot beyond level of confirmed contamination. Ifthreshold is exceeded by more than 100} excavate tolevel of confirmed "cleanliness" (Weston SoilRemoval Option 2B).

- Install topsoil cap.

21 - Remove, decontaminate and dispose of tankers and on-site wastepiles including tires and debris.


threshold level of 100 mg/kg for the volatileorganics fraction and 500 mg/kg for the BN/Aextraotable organics fraction to the level at which"cleanliness" has been determined (Heston SoilRemoval Option 2C).

- Install clay cap.

22 - Remove, decontaminate and dispose of tankers and on-site waste piles including tires and debris.


threshold level of 100 mg/kg for the volatileorganics fraction and 500 mg/kg for the BN/Aextraotable organics fraction to the level at which"cleanliness" has been determined (Heston SoilRemoval Option 2C).


site waste piles including tires and debris.- Demolish b'llldings.- Level site, fill and grade property.- Excavate and remove all soil contaminated to a

threshold level of 100 rag/kg for the volatileorganics fraction and 500 mg/kg for the BN/Aextractable organics fraction to the level at which"cleanliness" has been determined (Heston SoilRemoval Option 2C).

- Install topsoil cap.

3-12

Ml 1C Air A (ROT

ORIGIHAl(Rod!


Number Description

24-45 - Each of the above alternatives (except Alternative1) with ground water interception, withdrawal andtreatment.

3-13

(fed)CHAPTER 4

ENDANQERMENT ASSESSMENT

Description of the Site arri Site History

The current physical state and disposal history of the

Wade Site has been described In detail In recent reports and neelnot be repeated here. (23,21))

On and Off-Site Contamination

Over one hunlreJ different organic and Inorganic compounds

and metals have been Identified on the Wade property during the

course of investigations at the site. (6,7,17.1-17.5,23,21)

While the majority have been Identified In surface soils, many

have been detected in both air and ground water samples taken

from the site.

Recent sampling by R.P. Weston indicates that

contamination of soils on the site is widespread. (18,23,24)

Weston divided the site Into approximately 60 grids and sampled!to depths of five feet for total volatile organic compounds (VOC)and total base-neutral and acid extraotable (BNA) fractions of

priority pollutants at four points within each grid; Individualcompounds were not identified. Their results showed

contamination by VOC, BNAs, or both In the top 12-18 inches of

soil In nearly every grid. Contamination was detected Inapproximately 20 grids at the 36 inch level and In 9 grids at the60 inch level. Concentrations at the 12-18 Inch level rangedfrom <10 to 13,000 mg/kg (Ave: 360 mg/kg) for VOC and from <25

to 23,000 mg/kg (Ave. 727 mg/kg) for BNA.

MMCMi « (DOT

I . ORIGIN.iDespite the numerous Investigations that have taken place

on the site, the data do not easily permit generalization of theareal extent of contamination by any one compound. Not allcontractors analyzed for the aame compounds or used the sameanalytical methods. To Indicate levels of Individual compoundsdetected In the surface soils, results showing concentration inunits of mg/kg from previous Investigations by the EPA NationalEnforcement Investigation Center (NEIC) In 1979 and by Ecologyand Environment, Inc. in 1982 are presented In Appendix B.

Very little information is available about off-sitecontamination. Although a couple of air samples were taken

upwlrvi of the site (7,17.4) virtually all soil samples and groundwater samples were taken within the boundaries of the WadeProperty. Therefore, no comparison with off-site contamination

! is currently possible.t>i Toxloologioal Properties, The large number of compounds found at the site and the

; ^ ' time constraints on this study precluded detailed analysis an}; ( discussion of the toxlclty of each compound. The NEIC summarized' 0

the toxloologlcal properties of the compounds Identified during, | their Investigation (7). They reported that most of the

f compounds Identified In air and soil have, been associated with avariety of acute and chronic health effects In humans, laboratory

animals, or both, when Inhaled or ingested In sufficientquantities. Several compounds were reported to have an Irritanteffect on the skin, eyes, or mucous membranes.

&«-2 000306

MftC Akf n fODT

• v ' ' , ' '

I •>.x~ At least six organic compounds or classes of compounds areI suspect human carcinogens; benzene, chlorinated benzines,

chloroform, tetrachloroethylene, trlohloroethylene, and bls-(ethylhexyl phthalate). Oe;-taln metals fourri at the site -hevavalent chromium, nickel and arsenic - are known human

ii carcinogens.r Assessment of the likely public health Impact of the

compounds detected on the Wade site depends on both the

likelihood and magnitude of potential exposure to possiblereceptors as well as on the toxlclty of the compounds

themselves. The assessment of potential public health Impact

appears in a later section of this endangerment assessment.

Environmental Pate and Transport\ The principal pathways for migration off-site ofP' contaminants detected at the Wade Sites are transport by ground

! water and volatilization to air. Blodegradation andi photodecompositlon may also decrease the concentrations of many

; ' of the organic compounds detected at the site. However, these

processes are not considered to account for significant reduction

of chemical contamination cannot be quantified for this siteI. given data provided to M&E and therefore have not been considered

i further In this analysis.Ground water la the major off-site transport mechanism at

the site. An evaluation was conducted to ascertain the nature

and magnitude of off-site contaminant transport via ground

water. This was accomplished In two principal tasks: 1)

*• ,-3 M0307

MfK ALT A

ORIGINAL [(Red) I

i verification of the quantity and direction of ground water flow f^ at the site and 2) estimation of the concentrations of

contaminants resulting offslte under the No-Action alternative !1 using historical ground water monitoring data. The details of i

both the ground water flow analysis and contaminant transport j

estimation are presented In Technical Appendix A. The principal [

i- results of the assessment are summarized below. jThe water balance for the Wade Site was recalculated, and

! i a value of 10,000 gallons per day of ground water was estimated

by Metcalf & Eddy to be the maximum that could be discharged from

:; the site. This Includes underflow entering the site plus

Infiltration on the site. Most of the ground water from the site

'''' flows directly to the Delaware River. There may be someI discharge to the southwest of the site but no monitoring wells

had been Installed that could allow determination of off sitei[ transport to this area.

In order to estimate the potential Impact of contaminated

ground water discharged from the site fco the Delaware River,

! concentrations of specific chemicals measured In the on-sltei

ground water monitoring wells were used with Delaware River flow

and ground water flow data to estimate contaminant loadings tothe river. The flow In the Delaware was estimated to be about

15,000 cfs, or 9,695 mgd while the ground water discharge wascalculated to be approximately 10,000 gpd or 0.01 mgd, a small

fraction of the total flow In the Delaware (See Appendix A). The

4-4

MftC ALT n fODY

(Bed)

volume of ground water discharge calculated by M&E Is about 5times greater than estimates by previous contractors.

Ground water monitoring data from Betz, Converse, and

Murdoch, Inc. Technical Memoranda for concentrations of organiccompounds and metals In monitoring wells number 1 and 1A through9 and 9A were reviewed. Wells 6 and 6A were located about 100

feet from the river. Wells 4 , 4A, 5, 5A, 8, 8A were locatedtoward the middle of the site while Wells 9, 9A, 1-3, and 1A-3A

were located furthest from the river. The highest concentrations

ani on the site were generally found In the wells 3A, 4A, 8A,

and 9A.

To develop a worst-case estimate of the Impact of these

contaminants from the site on the river, the actualconcentrations detected In the wells were assumed to be

transported to the river without any attenuation by soil or by

degradation. Final concentrations In ug/L of metals and organiccontaminants In the river were calculated assuming: 1) mixingwith the full flow, and 2) half flow of the Delaware River.

Mixing In half the flow of the river was calculated since

contaminants may be more likely to spread In a plume down part ofthe river than to mix completely and Immediately In full flow of

the river. The calculations using half the river flow were usedas a further estimate of a worst case situation.

Table 2 presents the results of the calculations fororganic loadings to the river, and Table 2A presents the results

of the calculations for metals loadings to the river. All

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concentrations for all organic compounds were Included In theanalysis. The highest ground water concentrations of all metals

were used In the Inorganics analysis. The resultant

concentrations of organios and metals In the river are all In thesub-ralerogram/L range, and below applicable ambient water quality

criteria.As part of a more conservative estimate of the ground

water Impact on the Delaware River, one one-hundreth (1/100) of

the full flow of the Delaware River can be used to determine the

resulting concentrations of organics and metals after dilution.Even with this low dilution, the concentrations of organics and

metals are below the applicable ambient water quality criteria.

Public Health Risk AssessmentIntroduction. Pour potential routes of human exposure to

compounds found at the Wade Site were evaluated to estimate the

potential Impact of the site on public health; air, drinking

water, fish, and soil. Three methods were used to Judge or

evaluate the potential public health Impact of these exposures;1. Existing governmental and non-governmental standards

for exposure.

2. Comparison of Estimated Dally Intake (EDI) from a• given exposure to Acceptable Dally Intake (ADI) based

on animal or human exposure data. (33)3. Estimates of Increased lifetime risk of cancer In the

exposed population using EPA Carcinogen AssessmentGroup guidelines on carcinogen risk assessment. (31)

"'„*MO ('ftOiJ.4

; ORIGINALffinfl

Results for the carcinogen risk assessments are expressed

In terms of Increased lifetime risk of cancer. They represent anIndividual's Increased risk of cancer due to a lifetime's (70

years) exposure to a given chemical, over and above the risk ofcancer due to other exposures. A risk of 1x10"° corresponds to a

one In a million Increased chance of cancer for an Individualover a lifetime or 1 cancer case per million people exposed overp

a lifetime.Acceptable Dally Intake (ADI) values are derived from

either No Observed Adverse Effect Levels (NOAELs) or Lowest

Observed Adverse Effect Levels (LOAELs) found In animal

experiments or In epldemlological studies with an appropriate

factor of safety. They are derived only for noncarclnogenlo,

non-mutagenlc, acute or chronic effects.

An ADI value represents what available scientific evidence

can currently show to be the amount of a compound that may be

Ingested or Inhaled dally without adverse health effects. An ADI

value Is not necessarily an absolutely safe level; Its

significance may be limited by the ability of animal experiments

to detect effects of very low doses. However, it la a useful

bench mark for judging exposures to toxic chemicals.

Because the toxlclty data necessary to calculate ADI

values and carcinogenic risk estimates have been developed for arelatively few compounds, quantitative analysis of the Impact of

each exposure route could only be performed for a subset of thecompounds Identified on the Wade site. Despite this limitation,

1-11

MIICHIF A CDDV

ORIGINAL{Rprfl

\ these analyses served as a useful indicator of the relative: impact, and therefore, relative importance, of different routes

of exposure.ii jUr,

Air sampling data were collected during two separateInvestigations, one in March 1979 by EPA, (7) and the other In

r June 1980 by Betz, Converse and Murdoch. (17.D The results ofthese sampling programs are presented In Tables 3 and 1. Becausethese data were collected before and during Initial remedial

, activities (respectively) when much of the waste stored at the

i site was still present, these air samples may be somewhat higheri than concentrations that might be encountered today.

For comparison, each table also Includes OccupationalI Safety and Health Administration (OSHA) Permissible Exposure

Limits (PELs) and American Conference of Governmental Hyglenlsts! (ACQIH) Threshold Limit Values (TLVs) for the compoundsi detected. Although PELs and TLVs have been developed for eight-

hour time-weighted average exposures In occupational settings,

they are useful here in assessing the potential acute effects ofexposure to persons entering or playing on the site for a portionof the day.

i Both tables show that concentrations of compounds detected

at the site do not present an acute exposure hazard personseither on or off-site. On-slte concentrations of specificcompounds were 2-1 orders of magnitude (100 tolO.Ono clmes) below

their respective standards, even for samples taken In buildings

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Furthermore, according to a February 3, 1981 letter fromCarroll Wills, NEIC, to Joseph Donovan, Enforcement Division

Region III, the Delaware Is an unlikely source of drinking water;"there are apparently no downstream withdrawals of surface water

for potable supplles"(3)•i Investigation of Contaminated Pish from the Delaware

r The Delaware River Is used as a source of fish both near

to and downstream of the site. Many of the compounds detected inj ground water on the Wade Site are known or believed to

bloconoentrate in the fatty tissue of fish, raising the

possibility that persons eating fish from the Delaware may bereceiving high concentrations of toxic or carcinogenic compounds.

To evaluate this possibility, steady-state concentrations

of contaminants In fish were calculated for three different

levels of potential contamination: 1) pure ground water (worst

case), 2) ground water diluted In the full flow, and 3) ground

water diluted In half the flow of the Delaware River. Using an

estimate of 6.5 grams c.f fish Ingested per day developed for EPA

Water Quality Criteria (31) the average dose to an Individualfrom each chemical could be approximated. This dose was then

evaluated in terms of both the ADI and the potential Increased

lifetime risk of cancer for each compound. Because

bloconcentratlon factors, ADI values and, carcinogenic potency

factors were not available for all compounds, these calculations

could not be carried out for all of the contaminants detected in

4-17

J, >-.

FT"

r

! ORIGINALwhere vapors would be more likely to accumulate. Subsequent '"""'dilution of these concentrations downwind of the site Is expectedto reduce exposures to population living a few blocks away byanother factor of 10 or more.

Carcinogenic rlak estimates were developed for benzene,

which was detected on site, and trlchloroethylene which was

detected both on and off the site. These results, presented InTable 5, were obtained using several assumptions; 21 hours of

exposure, 23nr of air breathed per day, over a 70 year period(lifetime), and 100 percent absorption of the contaminant into

the body. While conservative, these assumptions are consistent

with those used by the EPA Carcinogen Assessment Group. (31)

The results indicate that, under the assumptions made, theconcentrations of benzene and trlohloroethylene found off-site

are associated with risks of cancer that are relatively high,ranging from 5.2 x 10"5 - 2.2 x lO"*1. The total carcinogenicrisk based on these compounds alone is about 3.1 x 10"11. Therisk associated with the trlchloroethylene detected upwind off-site is 1.1 x 10"5.

Drinking Water

Drinking water Is not likely to be a significant route of

exposure to contaminants from the Wade Site. According to thereferences used In this assessment, the aquifer underlying the

Wade Site la not used as a source of drinking water either byIndividuals or by municipalities. Therefore, although the ground

water beneath the site is contaminated, no one Is likely to

M t T C A L T ft CPOT

ORIGINAlTABLE 5. INCREASED LIFETIME RISK OF CANCER FROM

AIRBORNE BENZENE, TRICHLOROETHlfLENE DETECTED ON ORNEAR THE WADE SITE

Concentration LocationConcentration (MS/HI-') of Sample

Benzene

Trlchloroethylene

30(1)

7(D

21(2)

5(D

InsidebuildingInsidebuilding

Onslte

Upwindoff site

. . IncreasedUnlt^/ LifetimeRisk , , Risk of.(ug/m3)"1 Cancer^1'

7.1xlO"6 2.2X10"11

5.2x10-5

2.7xlO"6 6.5x10-5l.lxlO'5

1. Reference 7.2. Reference 17.53. Reference 3t.

The unit risk is the increase.1 lifetime risk of cancerassociated with breathing 1 ug/m' of a chemical every dayover a 70 year llfespan for a 70 kg person.

1. The Increased lifetime risk of cancer represents theIncremental increased risk of cancer (due to exposures to agiven compound over a lifetime) over an Individual's lifetimerisk of cancer from other causes.The use of 2 significant figures is not meant to Implyprecision or accuracy but Is Included so that calculationsmay more easily be followed.

drink It directly. Secondly, the calculations carried out to

determine the impact of ground water discharge from the site on

the water quality of the Delaware River, showed that theresultant concentrations were likely to be very low. (see

Table 2). Even under worst case assumptions, projected

concentrations of individual and total organic compounds in theRiver were orders of magnitude below existing EPA guidelines on

drinking water quality (Suggested No Adverse Response Levels -SNARLS).

f If) 03 311-16

fT"

(WfilMI.

ground water samples. Results of these analyses that could becarried out appear in Tables 6 through 11.

The results show that only If It were assumed that thefish are living In the undiluted ground water from the Wade site,

would estimate daily Intakes and lifetime Increased risks of

cancer reach high levels. Once the maximum levels of

contaminants found on the site have been diluted in either thehalf or full flow of the Delaware River, the public health Impact

attributable to the Ingestion of contaminated fish becomes

minimal. The estimated total carcinogenic risk obtained by

summing the risks associated with the maximum concentration ofeach carcinogen identified In the ground water and diluted in thehalf flow of the Delaware Is 1.9 x 10~8. if the dilution factor

for ground water In the river were actually one twentieth (1/100)

of the full flow (simulating entralnment of the contaminant plumealong the river bank), the estimated total risk would be

3.8 x 1Q-6. The EDI would still be orders of magnitude below the

ADI for any Individual compound.

Contact with Contaminated SoilContact with contaminated soil la a more direct and

potentially more serious route of exposure than the other routes

discussed previously. Possible public health Impacts Includeacute Irritant effects on skin or mucous membranes, and acute or

chronic toxic effects from repeated exposure. Children and otherpersons playing on the site are the most susceptible population

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at risk. The off site population Is not expected to be affectedbecause It Is much less likely to come into contact with thesoil.

No evidence to date suggests the site may be responsiblefor acute health effects. A study conducted In I960 by theCenter for Disease Control found no evidence of acute healtheffects In 86 residents whose homes were within a 1-blook radiusof the Wade Site or in 14 children who acknowledged playing on

the site (1). The investigation consisted of a non-random, door-

to-door survey of residents living directly around the site andinterviews with local physicians who had conducted medical

screenings of children living near the site for symptomspotentially related to exposures on the site. The screeningsIncluded questions about headache, eye Irritation, skin rashes,

smell or taste of noxious air or water as well as a complete

physical examination and laboratory evaluation. The study foundno effects of acute chemical exposures either in local residents

or even In children who acknowledged having played on the site.Metcalf & Eddy's assessment of the estimated dally Intake bychildren of chemicals at the site (discussed below) tends tosupport the findings of the CDC study.

A limitation of the CDC study is that it did not considercarcinogenic or other chronic effects. Metcalf & Eddy's riskassessment of potential exposures to contaminated soil, suggeststhat carcinogenic risks may be elevated for persons playing onthe site on a regular basis.

1-31Mite*tr A roov

rnlf'ilTo evaluate the potential for acute or chronic effects |

from exposures to chemicals at the site, it was necessary toestimate the potential Intake of contaminants from soils. Sinceno figures were available on average amounts of soil Ingested (or jInhaled and ingested) per day, a crude estimate was made. 1Assuming relatively dusty conditions, 10 mg/m^ ( the ACOIH [

standard for nuisance dust), a breathing rate of about 1 m^/hour, ;

100 mg/kg of a contaminant In the soil, and four hours of play on [the site per day by the average child, H mlcrograms of soil might ;be expected to be inhaled/ingested on a dally basis." j

A value of 100 mg/kg was selected to be evaluated for •toxic effects for two reasons. First, concentrations of i

contaminants were not always available in units of mg/kg, but ;rather were given in mg/llter of leaehate. Second, the 100 mg/kglevel had been selected by R.P. Weston (18) as a potential

threshold level triggering soil removal. Actual contaminantconcentrations In soils detected by EPA-NEIC and Ecology and

Environment, Inc. are presented in Appendix B, These tables show

that individual contaminant levels In surface soils oftenexceeded the 100 mg/kg level by 2-20 times,

Using the estimate of soil Ingested per day, potentialdose to an individual could be estimated. Doses for specific

compounds were then compared to their ADIs and evaluated In terms

» While only a fraction of total partloulates, the resplrablefraction, actually reaches lower parts of the lungs, largerparticles are believed to be entrapped in the upper airwayswhere they may be coughed up and Ingested.

MC*U rt ( 00V

. ORIGINAL! . (Rod)

of their carcinogenic risk. Carcinogenic risk estimates werebased on assumptions of 70 years exposure to a 70 kg person.(31) The results of these analyses appear In Tables 12 and 13.

These analyses show that, under the assumptions made, theestimated dally Intake values (EDI) for individual chemicalsexcepting mercury and silver were several orders of magnitude

below their respective ADI values. Even If true soilconcentrations had been used In the analyses, the EDI values for

Individual compounds would not, in general, have exceeded theirrespective ADI values.

Despite these findings for individual compounds, thepotential toxic effects of exposure to the total concentrations

of toxic compounds found on the site remains a concern. Possible

additive or synerglstlo effects of exposure to the multitude of

compounds identified at the site could contribute to greater

public health Impact than the exposures to Individual compoundsmight suggest.

The carcinogenic risks, particularly for some of the

volatile organic compounds, were relatively high compared to

carcinogenic risks associated with other routes of exposure.Therefore, inhalatlon/lngestlon of contaminated soil may be amore significant route of exposure for persons playing on orentering the site.

Physical Safety Considerations

The site remains a safety hazard to persons entering orplaying on the site and In abandoned buildings. Despite locked

000340

M M C « I » A t n

QRIGlNAi

TABLE 12. EDI/ADI FOR COMPOUNDS INHALED/INGESTED INCONTAMINATED SOILS ON THE WADE SITE

_______________ EDI^tmg/day) ADI(g^mg/day EDI/ADI

Chemicals

11-37

Benzene I.OxlO'3 1.008 3.97x10*3Dlchlorobenzenes 1.0x10" 0.91 4.3xlO~31,2 Dlchloropropane 1.0xlO"3 Q.98 1.1xlO"3Dimethyl Phenol 1.0xlO~3 0.8 l.OOxlO"2Ethyl Benzene 1.0xlO"3 1,5 2.5xlO"3Fluoranthene 1.0xlO~3 0.12 9.5xl0'3Methylene Chloride I.OxlO'3 37.5 l.lxlO'lPhenol 1.0xlO"3 6.8 5.9x10"^Phthalates 1.0xlO~JDimethyl 1.0xl0'3 1.8 2.2xlO"3Diethyl 1.0xlO"3 875 t.6xlO"6Dlbutyl I.OxlO'3 1.8 2.2xl0'3Butyl 1.0xlO"3 700 5.7xlO"6

Tetrachlorobenzene 1.0x10"^ 0.35 l.lxlO"2Toluene I.OxlO'3 13^) S.OxlO"51,3,1, Trlchlorobenzene I.OxlO'^ 0.161 8.6xlO"31,1,1 Trlchloroethane I.OxlO"3 37.5 l.lxlO"'*Metals

Copper I.OxlO'3 NAChromium (VI) 1.0xlO"3 o.ll 2.9xlO'2Lead 1.0x10*3 o.lO I.OxlO"2Mercury 1.0xlO"| 0.020 0.2Silver 1.0xlO-3 0.016 0.31. EDI « Estimated Dally Intake.———————————————————2. ADI « Acceptable Dally Intake.

MtlCAlF A COOT

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, QRIGIKAI.

TABLE 13. INCREASED LIFETIME RISK OF CANCER FROMINHALATION/INQESTION OF CONTAMINATED SOIL

ON THE WADE SITE

Increased ',. Dose . Lifetime

BHi mg/kg/day12' Risk of" ingested Cancer

Benzene 0.052 I.OxlO"3 2. 1x10""

Chloroform 0.18 I.OxlO"3 7.2x10""

Chlorinated Benzenes 1.68 I.OxlO"3 6.7xlO"31,1,2 Trlchloroethane 0.057 1.0xlO"3 2.3x10""

1,1 Dlchloroethylene 1.01 4,OxlO~3 1.2xlO"3

Heptachlor 3.37 1.0xlO"3 1.3xlO"2

bis (ethylhexyl) „phthalate 0.011 1.0xlO"3 5.6xlO"5

Tetrachloroethylene 0.039 OxlO"3 1.6x10""

Trlchlorethylene 0.013 1.0xlO"3 5.2xlO"5T. carcinogenic potency factor as developed by carcinogen

Assessment Group. Presented In Anderson, E., QuantitativeMethods In Use in the United States to Assess "Olncer Risk,accepted for publication in Risk Analysis^, March 1983'.

2. Assumptions!For inhalation of contaminated dust:

a. Dusty condlton. Dust levels at ACGIH recommendedTLV for nuisance dust 10 mg/m^.

b. 23-21 m* breathed/day • 1 m^/mc. 1 hours play /day.d. Of dust Inhaled, 100J trapped in lungs, throat,

nasal passages.e, 100% of contamination absorbed into body.f. 70 kg person.g. Lifetime exposure (70 years).h. 100 mg/kg contamination.

3. Calculation!10 M x 1m3/day x 100 5S- x B|_ . I.Oxlo'3 H_

m IKg 10°mg day

ji-38 000342

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WIGIKAL(Rod)

gates to the site, persons from the surrounding neighborhood areknown to gain access to the site.

Initial remedial activities on the site have not remove}

all safety hazards from the site. Two partially full undergroundtanks, an underground 1-foot x 1-foot tunnel beneath the main

building, and structurally damaged buildings present serious

physical hazards to persons gaining access to the site. Theidentity of compounds in the remaining underground tanks have notbeen established as of this writing but nevertheless the tanksthemselves are at least partly accessible from the ground. Both

the tanks and the tunnel may contain oxygen deficient or toxicatmospheres that Increase the likelihood of accidents. The major

fire at the Wade Site in 1978 damaged the structural Integrity of

several building on-slte, increasing the likelihood of unexpected

collapse. Finally, remaining piles of debris (wood and tires)are potential fire hazards.Environmental Risk Assessment

Based on information developed the Environmental Fate andTransport section, the principal potential environmentalreceptors are fish located In the near-field Delaware River. The

site has not been found to contribute any significant quantities

of contaminants to the air, thua there is believed to be no

measurable effect on any far field aquatic or terrestrial

communities. The site Itself and the site vicinity are notconsidered to be actual or potential habitat for any type of

1-39

ORIGINAL(Red)

sensitive species, as these areas have been developed, industrialsites for many years.

Under the no-action alternative, the site will continue toi

discharge ground water containing numerous organic contaminants ito the river. The concentrations resulting in the river after (

mixing have been shown to be extremely low, In most cases several |

orders of magnitude lower than the applicable ambient Water [Quality criteria (saltwater aquatic life) and U.S. EPA Health |

Advisories (SNARLS) for ingestlon of toxic and carcinogenic [

compounds In drinking water.

Although the loadings of contaminants from the Wade Site

to the Delaware are expected to be very low, the Delaware RiverIs currently the focus of efforts to restore the lower Delaware

as habitat for anadromous Atlantic Sturgeon, an endangered

species. For this reason the continued input of contaminants to 'the river via ground water may still be considered to have some

small, but unquantlflable adverse Impact on the environment.

These considerations have been factored into the Environmental

Risk Analysis as presented in Chapter 6. The other principalenvironmental effects of the site include aesthetic impacts on

residents living In the site vicinity, due primarily to thepresence of a hazardous waste site.Conclusions

The principal conclusions to be drawn from thisendangerment assessment are:

0.1 0 3 <U1-10

to ORIGIKAL|P> (Rod)

1. Based on air monitoring results, concentrations ofvolatile organic compounds on the Wade Site do notpresent acute exposure hazards to persons on or offsite. Although low by acute standards, concentrationof benzene found did present slightly elevatedlifetime risk of cancer to persons directly on site.These calculations assume that air concentrations of

chemicals detected In studies conducted In 1979 and1980 by other contractors are representative ofcurrent concentrations on the site.

2. Inhalatlon/lngestlon of contaminated soil Ispotentially the serious route of exposure for persons

entering or playing on the site. Under theassumptions used In this analysis, lifetime risks ofcancer from inhaling/Ingesting small amounts ofcontaminated soil on the site were higher than risksfrom other routes of exposure. This finding appliesonly to persons with chronic exposures to soil on thesite (I.e. children playing dally on the site overlong periods of time). No evidence of potential acute

health effects were found, a finding consistent withresults of a study by the Center for DiseaseControl. (1)

3. Persons entering the site may be exposed to toxicchemicals both In the air and In contaminated soil and

1-11 000345

are therefore the most susceptible population at riskfrom contaminants on the Wade Site.

1. Underground tanks and tunnels, structurally damagedbuildings, and piles of flammable debris presentimmediate safety hazards to persons entering orplaying on the site.

5. Drinking water and fish are not likely to be

significant routes of exposure to chemicals from the

Wade Site. Ground water beneath the site is not usei

as a source of drinking water and concentrations ofchemicals in the Delaware resulting from contaminate-)

ground water discharge to the Delaware are estimatedto be negligible.

6. Contamination on the Wade Site is not expected to have

a serious Impact on the environment either throughvolatilization of chemicals to the air or release ofcontaminants via grounJ water to the Delaware River.

Both releases have been estimated to be extremely low.

1-12

}'•L.

(Rpil)

CHAPTER 5

REMEDIAL ALTERNATIVE INITIAL SCREENING

Ground water Interception and Withdrawal Remedial AlternativesIn order to determine the need for ground water

management, including interception and withdrawal, as a remedialalternative at the Wade Site, an evaluation was conducted toascertain the nature and magnitude of offsite contaminant

transport by ground water. This involved two principal tasks;1) verification of the quantity and direction of ground waterflow at the Wade site, and 2) estimating the concentrations ofcontaminants resulting offsite.

Existing hydrological and ground water quality data fromBetz, Converse, and Murdock, Inc. reports and NUS, Corp. water

table maps were used in the analysis, The water balance for thesite was recalculated (see Appendix A) to determine a realistic,yet conservative estimate of the quantity of ground water

discharge daily from the site. The hydrologioal evaluation alsodetermined that the Delaware River is the principal outflow pointfor ground water from the Wade Site. In Chapter 1, ContaminantFate and Transport, details are given regarding the analysisperformed to determine the impact of contaminated ground water onthe Delaware River. The results of the analysis indicate that,based on all organic contaminants detected in ground water at thesite, continued input of contaminated ground water to theDelaware River under the no-action alternative would not have a-.,measurable adverse impact on water quality or biota. The '

5-1

MfTC A(.r A tOOt

iv

concentrations of individual organics after mixing of groundwater with both the estimated full flow and half flow of theDelaware River, are all well below all applicable Ambient WaterQuality Criteria (saltwater aquatic life) and U.S. EPA Health

Advisories for ingestion of toxic and carcinogenic compounds inwater (Table 2). Therefore, due to the negligible impact of

ground water on the offsite environment and public health, groundwater interception and withdrawal remedial actions wereeliminated from further consideration.Soil Excavation/Removal Remedial Alternatives

Neither current scientific understanding of the toxicity

of the compounds found at the site, nor the accuracy of thesampling method support making distinctions such as those calledfor under soil removal options 1B or 2B, excavation tointermediate depths.

There are currently no standards for exposure to total

volatile organic (VOC) or total base neutral/acid extractable(BNA) fractions. The toxicity of the contaminated soil depends

in part on the individual compounds present and in part on anyadditive or synergistic effects that the compounds may exerttogether. Since no compelling toxioological evidence supports athreshold of 100 rag/kg of total VOCs or BNAs versus 50 mg/kg or

150 mg/kg, it is unlikely that any meaningful distinction can bemade between excavating to "clean" depth or to one foot below thelast contaminated sample on the basis of public health impact.Furthermore, there were numerous discrepancies between the levels

B 0003435-2

of VOC/BNA contamination found in composite samples and thosefound in their constituent quadrants. In several grids, thecontaminant concentrations in composite samples greatly exceededthe set threshold levels, yet the analytical data from individual

quadrants indicates the opposite. In other grids, thisrelationship was reversed. These results suggest that the

sampling method may not be an accurate indicator of the extent ofcontamination of the whole grid. While this lack of correlationis a general problem with all the soil removal options, itsuggests that making distinctions between soils that are 20%, 21-

100J or greater than 100$ over the threshold is not valid over anentire quadrant, On the basis of the toxicological issues and

the sampling discrepancies, Metcalf & Eddy concluded that soilremoval options 1B and 2B were unjustified and should beexcluded.Site Capping

The site capping options range from relatively impermeable

clay capping to asphalt capping to relatively permeabletopsoil/seeding capping. Clay capping is the most effective ofthese capping options at preventing infiltration of precipitationinto the unsaturated soil zone (contaminated soil) and subsequentmovement into the ground water,

Precipitation has and does infiltrate the unsaturated zoneon-site and recharges the ground water, however the results of

the Endangerment Assessment for the No Action remedialalternative, as previously discussed, indicated minimal risks as

0003405-3

a result of on-slte ground water contamination. On this basis,\ground water interception, withdrawal and treatment remedialalternatives were eliminated from further consideration anddetailed evaluation, Therefore, it is not necessary to preventinfiltration by installing a relatively impermeable clay cap onthe site or to intercept, withdraw and treat the ground water,The clay capping option will be eliminated from furtherconsideration for those remedial alternatives it is listed within Table 1. The other more permeable capping options (asphalt,topsoil) will be considered in more detail as part of thedetailed evaluation of remedial alternatives,

Focused Feasibility Study Conclusions from Initial Screening ofRemedial Alternatives

I 1, Ground water Interception/withdrawal/treatraentI' ' remedial alternatives are eliminated from a detailed

evaluation based on results from an endangermentassessment.

2. Impermeable clay capping remedial option is eliminatedfrom consideration as a result of the endangerment

' assessment,

3. Soil Removal Options 1b and 2b are eliminated from adetailed evaluation based on results from anendangerment assessment.

1. Under the no-action alternative, the site presents aphysical safety hazard to persons entering or playingon the site,

0003305-1

5. Under the alternatives which do not involve capping,; •

persons entering or playing on the site may inhale, $I

ingest, or come Into skin contact with toxic levels of icontaminants. f

6. The site does not generate concentrations of I'contaminants in air that pose an acute or chronic >health threat to the population living off-site. j

7. Given current patterns of ground water contamination iion the site, the nature and quantity of compounds jbeing discharged to the Delaware River do not have a '

major impact on public health or the environment. :List of Remaining Remedial Alternatives I

The following list identifies the 12 remedial alternativeswhich remain after the Initial screening process described abovewhich was conducted on the original 15 remedial alternatives,The list is as follows;

1, No Action

2, Remove, decon & dispose of tires & tankers, remove

on-site waste piles; demolish buildings, level site,

fill and grade property.3. Remove, deoon & dispose of tires & tankers, remove


fill and grade property, cover with asphalt cap,1. Remove, decon & dispose of tires & tankers, remove


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I fill and grade property, cover with topsoil and/•— s

seeded cap,i 5. Remove, decon & dispose of tires & tankers, remove

on-site waste piles; demolish buildings, level site,fill and grade property, soil removal option 1A,cover with asphalt cap.

6. Remove, deoon & dispose of tires & tankers, removeI. on-site waste piles; demolish buildings, level site,

I fill and grade property, soil removal option 1A,1 ' cover with topsoil and seeded cap.;, 7. Remove, deoon & dispose of tires & tankers, remove

on-site waste piles; demolish buildings, level site,i',;j

i,|| fill and grade property, soil removal option 1C,I cover with asphalt cap.

8. Remove, decon & dispose of tires & tankers, remove

I on-site waste piles; demolish buildings, level site,

fill and grade property, soil removal option 1C,cover with topsoil and seeded cap.

9. Remove, decon & dispose of tires & tankers, removeon-site waste piles; demolish buildings, level site,fill and grade property, soil removal option 2A,

cover with asphalt cap.

10. Remove, deoon & dispose of tires & tankers, removeon-site waste piles; demolish buildings, level site,

fill and grade property, soil removal option 2A,

cover with topsoil and seeded cap.

5_6 000352

Mr K AI i n r DOT

11. Remove, deoon & dispose of tires & tankers, removeon-site waste piles; demolish buildings, level site,fill and grade property, soil removal option 2C,cover with asphalt cap,

12. Remove, decon & dispose of tires & tankers, removeon-site waste piles; demolish buildings, level site,fill and grade property, soil removal option 2C,cover with topsoil and seeded cap.

0003535-7

MMC Air A toor

fir-

CHAPTER 6

DETAILED EVALUATION OF REMEDIAL ALTERNATIVES

Technical Evaluation of Remedial Alternatives

A major objective for the technical evaluation of the

remaining remedial alternatives for this focused feasibilitystudy is to review the contaminated soil quantity estimates(Options 1A, 1C, 2A, and 2C). Another objective is to review thetechnical scope for each of the other remedial activities andtheir estimated costs as described in R.F. Weston's November 1983

report, Table 5-1. These four remedial activities were listed asfollows;

1. Remove contaminated soil.

2. Remove debris,

3, Demolish buildings.1. Grade and cap site,

Two additional tasks were added to all four remedialactivities for both technical and cost purposes. These include

tasks for a consultant engineering effort for each remedial itemas well as another task including miscellaneous efforts such aslegal work, licensing/permitting and community relations("indirect costs"). Due to the limited time frame of thisfocused feasibility study, Metoalf & Eddy conducted its technical

evaluation ba;.ed on a aeries of assumptions outlined underChapter 2. In summary, Metoalf & Eddy added certain work itemsto the technical scope for some of four remedial activities,

These modifications and review are described below.000354

6-1

MITC ALf A (DOT

I . ORIGINS.Remove Contaminated Soil - Quantity Evaluation ' ^ ' '

The quantities of contaminated soil to be removed from thesite were determined by R.F. Weston and presented in Appendix D-1of their November 1983 Draft Report. Six remedial alternative

soil excavation/removal options (1A, 1B, 1C, 2A, 2B and 2C) were

developed based on either of two threshold levels of organiccontaminants for defining whether the soil is contaminated. Onethreshold level on which three of the alternatives (1A, 1B, 1C)were based was 100 mg/kg for both the volatile and baseneutral/acid (BN/A) fractions, The second, on which theremaining three (2A, 2B, 2C) alternatives were based, was 100mg/kg for the volatile fraction and 500 mg/kg for the BN/A

fraction.A sampling program was conducted on the site by R. F.

Weston, from which the quantities of contaminated soil to be

removed could be determined, In order to identify samplinglocations, the site was divided in 61 grids (50 ft. x 50 ft.),

which were further divided into four quadrants. In most oasessamples were taken from each of the quadrants at depths of 12 to16 inches, 36 inches and 60 inches. Not all of the quadrants insome of the grids could be sampled due to the presence of

buildings, concrete pads and debris piles. A sample wasconsidered to be contaminated if one or both fractions of thethreshold limit were exceeded for a given alternative.

Weston determined the confirmed quantities of contaminatedsoil to be removed by adding up the total number of quadrants in

6-2 00035rj

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which contamination was confirmed to the depth at which it wasconfined or deeper, as specified by each alternative.

In areas where concrete was encountered during thesampling process and no samples could be taken, assumptions weremade by Weston about the percentage of contaminated soil.Depending on the alternative, either 20%, 33), 50? or 100? of the

soil in these areas was assumed to be contaminated to a depth of12 inches. In addition, based upon conversations with Mr. EdRogan of R.F, Weston, Inc., the soil under several piles of

debris was included in these estimations of potentiallycontaminated soil, although this is not evident from the WestonReport.

In addition to the above, soil samples were not taken inmany of the quadrants where buildings and other debris and tire

piles are located. These areas were not accounted for in theWeston Report.

Metoalf & Eddy reviewed the confirmed contaminated soilexcavation quantities and potentially contaminated soilquantities for Options 1A, 1C, 2A and 2C, determined by R.F.

Weston by reviewing the Soil Sampling Program data, Soilexcavating quantities were not reviewed for Options 1B and 2B

because these options were previously screened out by Metcalf &

Eddy and not considered under the detailed evaluation of remedialalternatives. Using this data the number of quadrants withconfirmed contamination and the depth of contamination weredetermined. The resultant number of quadrants determined by this

6-3 000356

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method was somewhat lower than the number determined by R.F.Weston. Based on conversations with R. F. Weston, the reason forthis is that R.F. Weston assumed that additional unsampledquadrants were contaminated to the same extent as the quadrantsadjoining them. The quadrants, or fractions of quadrants,assumed to be contaminated were counted as part of the adjoiningquadrants in which contamination was confirmed. For example, in

adding up the total number of quadrants with confirmed

contamination, quadrants such as 33B and 33D would each count asiI i 1-1/2 quadrants in order to include the unsampled adjoining

portions of quadrants 19A and C. Based on the above assumptions

Metcalf & Eddy concurs with the contaminated soil quantities asi estimated by R.F. Weston for soil removal Options 1A, 1C, 2A and

20.I

A breakdown of the soil excavation/removal estimates is

presented in Table 11. Figures 1 and 2 show the sampling

locations and contaminated quadrants on the site,Remove Debris

Removal and disposal of on-site, crushed drums andcontaminated soil pile(s) were included in the Removal of Debris

r- remedial item. These had been included under the contaminated' soil removal activity, however, it is more appropriate to

f consider them as part of removing site debris. A 50 percentswell factor was used for estimating the volume of crushed drumsafter loading into trucks for subsequent hauling to a finaldisposal site. A 15 percent swell factor was used for estimatingthe loading volume of soil from above-ground soil piles or

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excavated from the site for subsequent hauling to a final

disposal site.Demolish Building

Several items were added to the Demolish Buildings

remedial activity. These include the following:

- Rough grading and site leveling up to 12 inches over

existing grade in order to cover over any protrudingsubsurface structures which have not been removed,

- On-site sump sampling and analysis and waste removal.- Underground fuel oil tank/concents removal.- Underground waste chemical/solvent tan!: oontents

removal.- Closure of underground tunnel, filling in of building

basements and vehicle weighing station pit.These items were added to the Demolish Buildings remedial

activity because it would be appropriate to undertake these Items

during the building demolition activity. Offsite, handlingquantities of building demolition debris were calculated for thefollowing scenarios: remove all debris from site and leave somedebris on-site to fill excavated portions of the site for eachsoil excavation option under consideration (1A, 1C, 2A, 2C).These quantities are used in the subsequent cost analysis ofremedial alternatives.Site Capping

After reviewing the site capping activity, Metoalf & Eddymade a small design change for the asphalt capping activity, Thedesign of the asphalt capping would consist of the following:

6.6 000361M C K A l f A t ROT

Wfc ORIGINW (R«d)

1. Compact subgrade.

2. Use all base course, bank-run gravel, spread and gradeto nine inches thick.

3. Use 3 inch bituminous base course.t. Tack coat.5. Use 2 inch wearing course.

No major changes were necessary for the topsoil capping remedialactivity. Clay capping was eliminated from further considerationas described previously.

Introduction of Effectiveness Criteria Analysis

The following four sections present evaluations of thealternatives according to their relative public health,environmental, and institutional impact, and their relativereliability and implementabillty. Each evaluation is presentedin the form of a matrix in which alternatives are numericallyranked for several different criteria. The scores for eachalternative are then totaled in the next to last column. On thebasis of final scores, each alternative is assigned an

"effectiveness rating" in the final column of all tables. Thescales for ranking alternatives for specific criteria vary

r slightly among the four tables, However, the scale for the finaleffectiveness ratings are uniformly based on a scale of 1 to10. A score of 10 represents the most "effective" alternative.The effectiveness ratings from all four tables are presented inthe final cost-effectiveness matrix at the end of this section.

0003626-9

MMCALF A r QOV

Public Health Risk Assessment

Table 15 presents the evaluation of actual or potential Jpublic health impacts of each of the remedial alternatives. tAlternatives were ranked relative to one another on a scale of 0 [

!

to 5 (no to high impact). The ranking system is qualitative; |that is, a score of 5 for an alternative does not mean that it is |5 times worse than one with a score of 1, but rather that it isworse on a relative scale, Quantitative distinctions could not

be made between alternatives on the basis of the data availableat the time of the analysis,

For example, soil removal options requiring larger amountsof soil excavation were ranked higher than those involving lesssoil excavation. The underlying assumption was that the greaterthe surface area of soil exposed to the air, the larger the \

amount of volatile organic compounds released, and thegreater the potential for exposure to the public during the

excavation process. Quantitative assessment of potentialexposures would require, among other factors, calculation of thevolatilization rate of compounds from soil, which is Itself acomplex function of the characteristics of the soil, the chemicaland physical properties of the compounds present in soil, andambient meteorological conditions. All of the assumptions usedin ranking the alternatives on the basis of public health impacthave been stated explicitly in Chapter 3. Remedial alternativeswere not ranked on the basis of their relative contamination of

v.S'.J!«!<aS««v-<J,.<_.; -.. •W.i.-.ii'i'i

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6-11

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drinking water and fish since the Endangerment Assessment foundthat exposure via these routes were likely to be negligible.

Environmental Risk Assessment jThe Environmental Risk Assessment was conducted in ,

iaccordance with the guidelines and requirements provided in I

iL Chapter 6, Environmental Assessment, Superfund Feasibility Study i

Guidance Document (Final Draft, August 1983). The level of the ievaluation performed was not "detailed", as defined by theGuidance Document, due to the general lack of extensive data !regarding the environment in the site vicinity, and the fact that ,based on the results of the Endangerment Assessment, the sitedoes not pose a major environmental risk. The results of theEnvironmental Risk Assessment are presented in Table 16. All of

the evaluation criteria included in the Guidance Document (listed }across the top of the table) were used in the assessment. The

scale used for the relative ranking of each remedial alternativeunder each criteria, was from 0-20, with 20 representing the ,greatest impact. A zero was used to indicate that the criteriadid not apply at all. For example, zeros were given to allremedial alternatives under the Clean Air Act, Section 112,Toxics. This score was given, as none of the toxic compoundsregulated by Section 112 (S02, SOX, CO, partioulates, ozone,

hydrocarbons, and lead) have been indicated as pollutants emitted

from the site. A score of 1 was given when, based on all

available information collected in the limited time frame forthis study, the criterion does not exist in the site area (e.g.

6-12

Jr: !•-.i ;Kfi. :

drinking water and fish since the Endangerment Assessment found

that exposure via these routes were likely to be negligible.i

Environmental Risk Assessment jThe Environmental Risk Assessment was conducted in !i

accordance with the guidelines and requirements provided in jChapter 6, Environmental Assessment, Superfund Feasibility Study i

r- Guidance Document (Final Draft, August 1963). The level of theevaluation performed was not "detailed", as defined by the 'Guidance Document, due to the general lack of extensive data :regarding the environment in the site vicinity, and the fact that ibased on the results of the Endangerment Assessment, the sitedoes nob pose a major environmental risk. The results of the

''• Environmental Risk Assessment are presented In Table 16. All of1 the evaluation criteria included in the Guidance Document (listed ..

across the top of the table) were used in the assessment, The

' scale used for the relative ranking of each remedial alternativeunder each criteria, was from 0-20, with 20 representing the '

: greatest impact. A zero was used to indicate that bhe criteria j

did not apply at all. For example, zeros were given to allremedial alternatives under the Clean Air Act, Section 112,

I Toxics, This score was given, as none of the toxic compoundsregulated by Section 112 (S02, SOX, CO, particulates, ozone,

hydrocarbons, and lead) have been indioabed as pollutants emittedfrom the site. A score of 1 was given when, based on allavailable information collected in bhe limited time frame forthis sbudy, the criterion does nob exisb in bhe site area (e.g.

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000367•^ MIKM.F A ionr

wildlife sanctuary). Therefore, impacts could be associated withit. All numbers higher than 1 indicate bhe relativeenvironmental impact of each of the remedial alternabives.

The importanb assumptions made throughout bheEnvironmental Risk Assessment are listed in Chapter 2, FocusedFeasibility Study Assurapbions. Based on bhe resulbs of bheEndangermenb Assessment, it was determined that bhe Wade Site(no-acbion albernabive) would nob have a major impact on bheenvironment. However, bhere are some environmental impaobs of

the site such as aesbhebic and residenbial impacts due to the

continued presence of the site. The U.S. EPA Ambient Waber

Qualiby Criteria for bhe Protection of Saltwater Aquabio Life

were used as the principal indicabor of environmental impact onthe Delaware River. The concentration of organic contaminantspredicted to exist in the river afber dilubion (see Chapber 4Endangermenb Assessment) were also compared against the U.S. EPADrinking Water Standards, specifically the Health Advisories(SNARLS) for toxic compounds. Concenbrabions of all compounds

under both flow scenarios (Table 2) were below all applicable

drinking waber sbandards. As bhis porbion of bhe Delaware Riveris nob used as a pobable waber supply (based on available

informabion) bhese daba were nob included in Table 2, and allremedial albernabives were assigned a 1 under bhe safe DrinkingWaber Act.

6-11 000363

MIKAkF n FOOT

•-ifi'MKC

Institutional IssuesTable 17 presents the evaluation of alternabives on bhe

basis of Institutional issues. Alternatives were rankedaccording to two principal measures of instibubional

effecbiveness; permit requirements and community relations. As

in the Public Health Assessment, alternabives were ranked on ascale of 1 bo 5 wibh 5 representing the greabesb or worsbirapaob. The objeobive of ranking albernabives on bhese measures

was bo idenbify pobential insbibubional barriers bo bhe seleobionof any given albernabive.

Remedial albernabives may be subjeob bo a varieby oflocal, sbabe, and federal laws. These laws may have requiremenbs

that restrict or effectively preclude given remedial

alternatives. Based on available time, Metcalf & Eddy did nob

determine bhab any permitting requiremenbs would preclude bhe

implementation of any given remedial albernative.The justification table is a way of integrating the

various institutional measures in order that their impact may beconsidered in the cost-effectiveness analysis. Criteria used to

judge differenb remedial alternabives are defined briefly below.

Issue Desoripblon

On-Sibe Requiremenbs Consider permit and regulaboryrequiremenbs applicable bo on-siberemedial activities;

Off-Site Requirements Consider permit and regulaboryrequiremenbs applicable bo off-siberemedial activities;

6.15 000369

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0003706-16

Issue_________________Desorlptlon_________

Worker Safeby and Review requirements and policies, suchHealth as OSHA standards, for protecting bhe

safeby and healbh of workers ab remedialacbion site;

Relocation Consider requiremenbs and procedures forplanning and coordinating relocabions inremedial aobions wibh Federal EmergencyManagement Agency;

The Nabional Environ- Review procedures bo be followed andmanbal Policy Acb requirements bo be met bo ensure(NEPA) Superfund remedial aobions achieve

functional equivalency with NEPArequirements!

Community Relations Review policy recommendations andrequirements for operating a ooraraunlbyrelabions program at Superfund remedialacbions; and

Coordinabion wibh Consider recommended procedures forOther Agencies consulting with and involving bhe

Deparbment of Healbh and Human services,bhe Army Corps of Engineers, the U.S.Geological Survey, and other governmentalaubhoribies in remedial aobions.

As for other analyses, bhe relative rankings given boalbernabives are qualibative, Time and information constraints

i for this focused feasibiliby sbudy did nob permib in-depth

evaluabion of each Insbibutional issue for each albernabive. Thebasic assumptions underlying bhe rankings are lisbed in Chapter 3.Implemenbabillby/Rellability Analysis

Table 18 presenbs bhe results of the qualitative analysisof reliability and imleraentability issues for each of bhe bwelveremedial albernabives. Reliability is broken down inbo three

categories: relative effectiveness of each remedial alternative

0003716-17

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0003726-18

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(bhe degree bo which bhe albernabive meebs ibs design objeobive),durability (projeobed lengbh of bime bhab bhe designed level ofeffecbiveness can be mainbained), and bhe use of proventechnologies.

Iroplemenbablliby is also broken down inbo three categorieswhich consisb of bhe following! ease of insballabion, bime toimplement the remedial albernabive (includes any necessaryspecial studies, design, construction or other technical facbors

i which may cause a projecb bo lag) and exbenb and complexity ofmonitoring requirements,

j' A higher numerical value in Table 18 indicates bhab bhe„ individual remedial alternabive is more highly reliable and/ori' irapleraentable. The effectiveness ratings column ranks bhe

I remedial albernatives based on the sum of the reliability and

iropleraenbabiliby assessmenbs. The effectiveness rabings are usedin bhe cost-effectiveness matrix to aid in bhe selecbion of bhe

most cost-effective remedial albernabives.

The overall resulb of bhis assessmenb Indioabes bhabremedial albernabive number 10 (Soil Excavation Option 2A wibhbopsoil cap) is bhe most reliable/iraplemenbable albernabive. Asan example, on a relabive basis, Table 18 indicates bhabalbernative No. 10 has bhe following!

6-19 000373

MMC ftl.r ft tOOT

.'.W.i.'siVW.'fi,;1..

1. Fewer monitoring requirements as a resulb of bhe

bopsoil cap, ;2. Requires less bime to implement of all bhe soil ,

exoavablon options (lowest quantity of contaminated :soil requiring excavation);

I3. Easiest to install of bhe soil opbions due bo bhe j

smaller soil excavabion quantities;4. Uses relatively proven technology, i.e. contaminant .

source removal with proper disposal;5. More durability wibh a bopsoil cap bhan asphalt due bo

a longer period of bime bhab the level of effective-

ness can be maintained.6. More effecbive bhan bhe no action remedial alternative

and non source removal alternatives, however, not as

effective as those remedial alternatives which remove(excavate) more of the oonbamlnanb source material(soil). ;

Cost Analysis i

Table 19 presents the site implementation costs for allbhe 12 remedial albernabives based on Metoalf & Eddy's oosbestimates for Site Debris Removal, Building Demolition, SibeCapping and Contaminated Soil removal. These four remedial itemswere reviewed by Metcalf & Eddy with the subsequent addition of

certain tasks as previously discussed. Appendix B oonbalns bhe

6-20

MITCAkr A CDOY

J, .,,.. ,',

TABLE 19. REMEDIAL ALTERNATIVE COST ANALYSIS

RemedialAlterna-tiveNo.

1.

2.

3.4.

5.6.

7.8.

9.10.

11.12.

SiteDebrisRemoval($)

0

529,029

529,029529,029

529,029

529,029

529,029529,029

529,029

529,029

529,029529,029

DemolishBldgs($)

0268,745

268,745

268,745252,750

252,750243,156

243,156

260,871

260,871

256,439

256,439

SibeCapping

00

331,93075,620331,93075,620

331,930

75,620

331,930

75,620

331,930

75,620

SoilExoava-bion($)

0

0

0

0

1,191,250

1,191,250

1,979,755

1,979,755

714,530

714,5301,012,512

1,012,512

TobalImplemen-tationCosb(*)

0797,774

1,129,704873,394

2,304,959

2,048,6493,083,8702,827,560

1,836,360

1,580,0502,129,9101,873,600

M(K Atf ft (PO V

oosb estimating sheets with quantity breakdowns and unit costs

etc. which were used bo calculate bhe costs shown in Table 19.Additional assumptions used for this cost analysis are obbainedunder Chapter ?., The botal remedial alternative irapleraentabionoosbs are included in bhe cosb-effeotiveness matrix bo aid in bheselection of the most cost-effective remedial albernatives.Post Closure, Long Term Monitoring Plan

Once remedial activibies have been completed on the WadeSite, it is required thab bhe site be further monitored for a

period of 30 years to debermine bhe effeobiveness of bhe remedialaobivlbies. The Posb Closure, Long Term Moniboring Plan

describes bhe approach bo formulating a monitoring program suibedbo bhe remedial aotivibies previously coraplebed, The plan

includes a descripbion of all bhe various basks which will beaccomplished during bhe moniborlng program. The oosbs assooiabedwith bhe implemented monitoring plan will ultimately depend uponwhich remedial albernablve is finally seleobed for bhe sibe.

The following is a descripbion of four post closure, long

term monitoring plans based upon bhe remedial albernabive wibhwhich ib is associated;

A. Remedial alternative No. 1 (No Action)The plan includes bhe following basks:1. Sibe Inspection:

The sibe inspection will include a visual

inspection of surface conditions and the

monitoring wells. The inspection will determine

0003766-22

M(KM.f A

rwhether any new contamination has appeared on thesurface or whebher bhere have been any obher majorchanges in bhe overall sibe conditions. Duringbhe inspection, waber level measurements will betaken on all accessible monitoring wells on-site.

2. Installation of upgradienb raoniboring wells:Two upgradienb monitoring well clusbers will beinsballed in off-slbe looablons (Figure 3) inorder bo monitor bhe waber qualiby of bhe groundwaber before ib flows under this sibe. Eachmonitoring well cluster will consist of oneshallow and one deep well both constructed in bhe

unconsolidabed overburden raaberials.

3. Waber and soil sampling:A bobal of five monlboring well clusters will besampled along wibh one drainage pipe outfall.Both bhe shallow and deep wells will be sampled abeach raoniboring well olusber locabion. The fivemonitoring well olusbers will include bwo looabed

upgradient and off-sibe and bhree locabeddowngradienb along the soubhwesb perimeter of the

sibe (Wells 3, 3A, 4, 4A, 6 and 6A). The purpose

of bhls sampling is bo debermlne ground waberqualiby before ground water enters bhe sibe andground waber qualiby as ib leaves bhe sibe,

0003776-23

!"'••>ii;'-'

r

Three soil samples will be collected across bhe

sibe from a depbh of 12 bo 18 inches (Figure 3).The purpose of bhe soil sampling is to determineif there are any changes in bhe contaminationfound on the surface of bhe sibe.

4. Laborabory Analysis:

Bobh waber and soil samples will be analyzed for

priority pollutants, cyanide and TOC based uponcontaminants identified in previous sibe sampling.Afber five years of sample collection bhe sampling

probocol will be re-evaluabed bo determine ifcerbain pollutants can be bargebed such bhab there canbe a reduobion in bhe cosb of laborabory analysiswibhoub any reducbion in monitoring effecbiveness.

5. Replacement of Monitoring Wells:

The present bhree downgradienb well olusbers were

originally constructed wibh galvanized pipe and ib isanbioipabed bhab bhe wells will need to be replaced in

10 years. The bwo upgradient wells will be

constructed with stainless sbeel pipe and Ib isanticipated that the wells will need bo be replaced in

15 years. Moniboring well deberiorabion may resulbfrom corrosion of the pipe or screen, accumulation of

silb in bhe well, or plugging of bhe screens,

6"25 000379

t

6. Well Maintenance and Rehabilitation:

A program of well maintenance and rehabilibation willbe implemented every five years bo insure bhab bhemonitoring wells will provide representative samples

and that the surface integrity of bhe well has nobbeen compromised or tampered wibh.

The following is a list of the various assumptionsused to calculate bhe tobal cost of the Post Closure,

Long Terra Moniboring Plan for bhe Remedial AlbernabiveNo. 1. The actual calculations are shown in Appendix C.

Cost Assumptions;a. The site inspection and sampling will be completed ab

the same time,b. The costs for the inspection/sampling include

personnel and laborabory oosbs. Ib was assumed thatthe site would be sampled twice a year. Laboraboryanalysis cost was based on 13 waber and bfcpee soilsamples, It was assumed that laboratory costs couldbe reduced by approximately 50J after five years by

bargebing individual contaminants and reducing bhebobal number of contaminants analyzed.

o. Ib was assumed bhab bhe bwo upgradienb well olusberswould be replaced afber 15 years and bhab bhe bhree

downgradienb well clusters would be replaced afber 10years.

6-26 000330

MITCALF ft tDDY

d. The cost of installing bhe two upgradienb wellclusters was based on the use of two-inch diameterstainless sbeel casing and screen and bhe assumptionthat bhe shallow and deep wells will be screened from10 to 15 feeb and from 25 bo 30 feeb respeoblvely.

e. The replacement cost for bhe bwo upgradienb wellclusters was based upon bhe original installationcosts.

f. The replacement oosb for bhe bhree downgradient wellclusters was based upon bhe original oonsbrucbion

i design of bhe wells and bhe use of bwo-inoh diameter, -| stainless sbeel casing and screen materials.'"' g. The well maintenance and rehabilitation oosb was based1 upon an assumed cosb of $1,000 per well clusber. Ib

was also assumed bhab bhe maintenance and1 rehabilitation would be completed on all five well

clusters during five year interval.

' B. Remedial Albernabive Ho. 2 (Limited Clean-up. No Cap)

The plan includes bhe following basks:1. Sibe Inspection:

The sibe inspection is bhe same as bhat described inbhe Remedial Alternabive No. 1.

2. Installation of upgradienb monitoring wells:The installation of bhe bwo upgradienb moniboring well

clusters is bhe same as bhab described in bhe RemedialAlbernabive No. 1.

6-27 000381

MITCALf n tDOt

"(IV.i

3. Water and Soil sampling:

The waber and soil sampling is bhe same as bhabdescribed in bhe Remedial Albernabive No. 1 excepbbhab bhere will be a greaber number of sample runs asdescribed in bhe cost assumptions.

4. Laborabory Analyses:

The Laborabory Analyses are bhe same as bhose

described in bhe Remedial Albernative No, 1.5. Replacement of Monitoring Wells:

The replacement of bhe raoniboring wells used duringbhe sampling program will be bhe same as bhabdescribed in bhe Remedial Albernabive No. 1.

"' 6. Well Mainbenanoe and Rehabilibabion:' The well maintenance and rehabilitation is the same as

bhat described in bhe Remedial Albernabive No. 1.; The Cost Assumptions are the same as bhose described in, bhe Remedial Albernabive No. 1 exoepb for bhe frequency of' sampling. The frequency of sampling is described In bhe

j following schedule;I.I

a. 4 sampling runs per year for bhe firsb 3 years of bheJ raoniboring program.. b. 2 sampling runs per year for bhe 4th through bhe 10bh

year of the monitoring program.o. 1 sampling run per year for bhe 11bh bhrough bhe 30th

year of bhe monitoring program.

to 0003326-28

MI i c A I r n COOY

;iwiGH •'•

The actual oosbs calculated for the Post-Closure

Monitoring Plan for the Remedial Albernabive No. 2 are shown in

Appendix C.C. Remedial Albernabive Nos. 3. 5, 7,9.and 11 (Full Clean-up,

Asphalb Cap).1. Sibe Inspection:

The site inspecbion is bhe same as bhat described inbhe Remedial Albernabive No. 1 exoepb thab ib willInclude bhe inspection of bhe asphalb cap. Sincethere will be some parking on the sibe, bhe asphalt

cap will need to be inspeobed for cracks and breaks inthe asphalb surface and bhe surface will need bo berepaired periodically to insure bhe inbegrlby of bhe

seal.2. Installation of upgradienb monitoring wells:

The installation of the bwo upgradienb raoniboring wellolusbers is bhe same as that described in the Remedial

Alternative No. 1.

3. Water Sampling:The water sampling program is bhe same as bhab

1 described in bhe Remedial Albernative No. 1. However,due bo bhe iraplaoemenb of an asphalb cap over thesite, ib will no longer be possible or necessary bo

bake soil samples,

6_29 000383

Mt!c«ir n too*

4. Laborabory Analyses:The laborabory analyses will be bhe same as bhosedescribed in bhe Remedial Albernabive No. 1 exceptthat there will be no soil sample analyses required.

5. Replacement of Moniboring Wells: [

The replaoeraenb of bhe monitoring wells used duringthe sampling program is bhe same as bhab described in jbhe Remedial Albernabive No. 1. j

6. Well Nainbenanoe and Rehabilitation: >The well maintenance and rehabilitation program is the I

I same as that described in bhe Remedial Albernabive No.

1-Iii! 7. Asphalb Maintenance:I A program of asphalt maintenance will be implemented

every bhree years bo insure bhab bhe inbegrity of bhe

, cap is nob compromised and that minimal water isallowed to infilbrabe through bhe surface of bhe

i site. Maintenance of bhe asphalb surface may be ii required more ofben bhan every bhree years and will1' depend upon bhe condibions discovered during bheI scheduled sibe inspections.

8. Re-cover of Asphalt Surface:

The entire site will be re-covered wibh asphalb afbera period of 15 years.

0003346-30

MIICAlf A COOT

ff' **] ''<--'.':?:'''$•!'•'/?;$,• •••:•:[ ' |.ipvMis«j»«*aiMi>....i~---''''-v»i1>i.«i>»'«;. -

The oosb assumptions will be bhe same as bhosedescribed in bhe Remedial Albernabive No. 1 (a bhrough

g) except for bhe following:b. No soil sample will be required since bhe asphalbcap precludes bhe necesslby of baking any samples.The frequency of sampling bhe monitoring wells forwaber qualiby will be bhe same as bhab described in bheCosb Assumptions for bhe Remedial Albernabive No. 2.h. The oosb for asphalt maintenance Is based upon an

assumed cost of $3,000 bo be spenb every bhree yearsin repairing any cracks or breaks in bhe asphalb

surface.i. The oosb for re-covering bhe asphalb surface is

'' based upon a one-time cost of $70,000 bo be spenbafber a period of 15 years bo re-cover bhe enbire

I sibe.The aobual oosbs oaloulabed for bhe Posb-Closure

i Moniboring Plan for bhe Remedial Alternatives Noa. 3, 5, 7, 9,

and 11 are shown in Appendix C.D. Remedial Albernabive Nos. 4. 6_, 8, 10 and 12 (Full Clean-up,

I Topsoil Cap)The plan includes bhe following basks:

1. Sibe Inspection:The site inspection is bhe same as bhab described in

bhe Remedial Albernabive No, 1 excepb bhat Ib willinclude bhe inspection of bhe bopsoil cap, This

000385

Inspeobion will include checking for any erosion of

bhe cap, any bhinning of bhe bopsoil maberial, anybase areas which may need bo be re-seeded or anypossible new contaminant break-out on the surface,

2. Installation of Upgradient Monitoring Wells:The Installation of bhe bwo upgradienb raoniboring well

clusters is bhe same as bhab described in bhe RemedialAlbernabive No. 1.

3. Waber Sampling:

The waber sampling program is bhe same as bhabdescribed in bhe Remedial Albernabive No. 1. However,

because bhe sibe will be covered by a bopsoil cap ibwill nob be necessary bo collect soil samples.

4. Laboratory Analyses:

The laboratory analyses will be bhe same as thosedescribed in the Remedial Alternative No. 1 exceptbhab bhere will be no soil sample analyses required.

5. Replaoemenb of Moniboring Wells:The replacement of bhe monitoring wells used during

bhe sampling program is bhe same as bhab described inbhe Remedial Albernabive No. 1.

6. Well Mainbenanoe and Rehabilitation:The well maintenance and rehabilitation program is bhesame as bhab described in bhe Remedial Alternative No. 1.

W6-32 000336

MIKAU A [QOY

i_.'

7. Topsoil Maintenance:

A program of bopsoil maintenance will be implementedevery bwo years bo insure bhab bhe bopsoil capooraplebely covers bhe sibe. Periodically ib may benecessary bo fill in erosion channels, bo add bopsoilbo areas where bhe bopsoil appears bo be bhinning andbo re-seed areas where bhe vegebabion has becomesparse.

8. Mowing of Grass:

Once bhe bopsoil cap has been constructed and ib has

been seeded and sodded ib will be necessary bo mow bhenew grass during bhe growing season. The bask wouldbe performed on a yearly basis probably during bhe

1 summer months and will become an integral part of thesibe mainbenanoe.

The Cosb Assumptions will be bhe same as bhose described

in bhe Remedial Albernative No 1 (a. through g.) excepb for bhe

i following:| b. Because bhe sibe has been capped wibh bopsoil ib will

not be necessary bo collect soil samples as bheI original sibe Is no longer exposed on bhe surface,

The waber sampling frequency will be the same as bhab

described in bhe Cosb Assumptions of the Remedial

Alternabive No. 2.

6-33 000387

MTTC Hit A (DDY

I

h. Ib is assumed bhab bopsoil mainbenanoe will berequired every bwo years ab a cosb of $2,000 for each

mainbenanoe.i. Ib is assumed bhat the grass growing on the bopsoil

cap will need bo be mowed every year as needed duringbhe summer months, The assumed cost for mowing of thegrass per year is $2,000.

The actual cost calculations for bhe Posb-ClosureMoniboring Plan for Remedial Albernatives Nos. 4, 6, 8, 10 and 12

are shown in Appendix C.COST-EFFECTIVENESS MATRIX AND SELECTION OF MOST COST-EFFECTIVE

REMEDIAL ALTERNATIVES

This section discusses bhe final mabrix, which integrates

cost and "effeobiveness" measures, and bhe use of bhe mabrix toselect a remedial albernabive thab is consisbenb wibh theobjectives of the National Contingency Plan.

The cost-effeobiveness matrix presented in Table 20

integrates estimates of cost with assessments of public health,

environmental, institutional, and irapleraentability/rellability

oriberia for each remedial albernatlve. For each albernabive afl'-.al "effectiveness" rating and effeobiveness/oosb rating havebeen developed and are presented in bhe lasb bwo columns of bhe

mabrix, Final effeobiveneas rabings are calculabed byraulblplying bhe weighbs accorded a given effeobiveness measure

by bhe individual effectiveness rabings given for each measure(i.e. Public Healbh, Environmental, etc.). Final cosb rabings

6-34 000338

MltCAU A IOQY

I '

,{*JV

XH

g

B "|N 'HZ

I*M

asIt K

s >«:*?S

S'iw**>k "•

illBa*iss:.

000331)6-35

»M <

w

ig" sp 1S °

'V

**,

*>*,

Vs:

ill

ilKto'*'"!

£S

3s h'

SSS

Isl

siloft*

8a=ft '*S«^JH

. 0003SO6-36

\i<\

are calculated by multiplying bhe sum of the implementation andmonitoring oosbs by bhe weighting faobor, one in this case. Theeffectiveness/cost rablng for each remedial albernabive is bhedivision of bhe two separabe rabings discussed above.

The weighting factors, which appear in bhe bop row of bhemabrix, refleob bhe relabive prioriby given bo each effeobivenessmeasure and cosbs by bhe U.S. Environmental Probeobion Agency'sOffice of Wasbe Programs Enforoemenb. The relabive prioribiesare as follows: public healbh, bhe environment,

r implementabiliby/rellabiliby issues, insblbublonal issues, andcost.

! The Nabional Conblngency Plan (NCP) dlcbabes bhe remedialLi

albernabive should be selected on bhe basis of bobh oosbi

effeobiveness and effecbiveness at reducing impacts on publichealth and bhe environment. In part, bhe NCP states bhab

seleobion of a remedial albernabive should be based on:"bhe lowesb cosb albernabive bhab is technologically

ifeasible and reliable and which effectively mitigates and

J minimizes damage bo and provides adequabe protection of.... Public Healbh, Welfare, and bhe Environment." (FR 47I (137): 31217, Friday, July 16, 1982.)r On bhis basis, bhe no-action albernabive may effectively

be eliminated. Albhough ib has a high ''effecbiveness cost"rablng (a function of bhe small cosb of doing nobhlng), Ib israbed lowest in terms of effecbiveness and bherefore should nobbe considered further. The non-soil removal albernabives,

W6-37 0003 31

r

, i'^oiiV1 U,.'.

alternabives 2-4, may also be eliminated from consideration usingbhe same reasoning.

The soil removal albernabives, alternatives 5-12, have thehighesb "effectiveness" rabings, the moab "effeoblve" of thesebeing albernabives 10 and 12. These also have bhe highesbeffeotivness/cost ratings of the soil-removal options.

Finally, of these bwo albernabives, albernabive 10 has ahigher "effeoblveness/oosb" rabing bhan albernabive 12.

On bhe basis of Metcalf & Eddy's analyses, we recommendbhab alternative 10 be selecbed. This albernabive requires bhefollowing: bhe removal, decontamination, and disposal oftankers, tires and debris; soil removal (opbion 2A) demolition ofbuildings; leveling, filling, and grading bhe sibe; and coveringwith a seeded bopsoil cap.

There are bwo basic justifications for bhis albernabive;one is that ib appears to be more oosb-effecbive bhan albernabive12 and bhe obher is bhab albernabive 12 is nob likely bo changesignificantly the impacts on public health or bhe environment.

Additionally, albernabive 12 is nob likely bo improvesignificantly any irapaob on bhe Delaware River. The pollutantloading to the Delaware River from bhe enbire site does notappear bo have a major irapaob. The removal of soil below bhe 5foob level from bhe bhree bo five grids thab would be affeobedunder albernabive 12 would therefore nob be expeobed bo have anyraeasureably different irapaob from bhab of albernabive 10.

W6-38

'• w'rnw-:.''-3::: -Jt?

The exposure rabe of most concern for bhe Hade sibe from

bhe sbandpoinb of public healbh is inhalabion/ingesbion ofcontaminated surface soils. Further removal of soil beneath bhe5 foob level (Albernabive 12) would have no impact on this route

of exposure.Further removal of contaminated soil down bo 5' allows for

bhe fubure developraenb of bhe sibe as a commercial properby sinceany excavabion for sewerage lines, etc. would be expected bo liein this depth range. The top soil cap also allows for

inexpensive excavabion,In conclusion, choice of albernabive 12 over albernabive

10 is nob clearly Jusbified on bhe basis of impact on publichealbh. As albernabive 10 appears bo be slightly more coat-

effective based on bhls analysis, ib should be selecbed for

implementation ab bhe Hade Sibe.

6_39

ipuM. [. I.VftiiUtttaiti

IIREFERENCES

000394

I IJ: ' 'I

\

REFERENCES

The following lisb of reports and file documents were

reviewed for this evaluation:1. U.S. EPA, 1982, "Exposure Analysis of ABM-Wade

Disposal Sibe - Chester, PA," by John Sohaun,Exposure Assessment Group, Office of Research and

Development, August 6.2. Unknown author and dabe, Handwrlbben "Proposed

Remedial Aobions."3. U.S. EPA, 1981, Memo: "Clean-up Albernabives for

ABM-Wade Sibe," from Carroll G. Wills bo JosephDonovan, Esq., Enforcemenb Division, Region III,

February 3.4. Undabed memo, Hydrogeologiat, Roy Murphy, Sampling

Resulbs.5. Public Healbh Service, 1980, Memo; "Mulbiple Toxic

Chemicals in an Illegal Dump, Chester, PA", fromChronic Disease Division, Bureau of Epidemiology boDirecbor, Cenber for Disease Conbrol, EPI-80-12-2,

November 12.6. Betz.Converse,Murdoch.Inc., 1981, Addendum;

"Technical Memorandum 4," for U.S. EPA and PA DERReport Phase II: Investigation of Contamination froma Hazardous Waste Disposal Sibe, Wade Properby, BCM

Projeob No. 00-5164-04, Auguab.

i 000393

MI1CAU B lOOT

" 7. U.S. EPA, 1979, "Field Invesbigabion for ImrainenbHazard Asaessmenb, ABM-Wade Disposal Sibe, Chesber,PA," by Thomas 0. Dahl, Office of Enforoemenb, 330/2-79-020, June.

8. NUS Corporabion, 1983, Lebber: Survey for Mean SeaLevel, from Don Senovioh bo Kabhy Hodgkiss of U.S.EPA, C-585-7-3-18, July 15.

9. U.S. EPA, 1982, Memo: "Metals Results of WadeSamples," from E. Raraona Trovabo bo Daniel K.Donnelly, Cenbral Regional Laborabory, November 29.

10. U.S. Disbriob Courb, 1983, Summary of Proposed TrailTestimonies, U.S.A. vs, Hade, from Sidney Margolis boJoseph Donovan of U.S. EPA, Office of Regional

| , Counsel, November 2.11. PA DER, 1982, Quesblons and Answers Regarding Cleanup

Aoblvlbles on bhe Wade Hazardous Wasbe Sibe, Cheater,

i PA, October 15.12. U.S. EPA, 1981, Memo: "Review of Report," from

[,.l Thomas 0, Dahl to Joseph J.C. Donovan,• Attorney/Advisor, Region III, May 28.'• 13. Ecology and Envlronraenb, Inc., 1982, Lebber Report;T "Field Invesbigablons of Unoonbrolled Hazardous Wasbe

Sibes," by Gregg H. Crystall bo Linda Y,. Bbornazian,

EPA Region III, TDD No. F3-8209-04, EPA No. PA-160,

Oobober 26.

to • 00039G11

MfTCALF A COOT

14. Hesbon, 1982, "Hazardous Waabe Sibe Cleanup, WadeProperby in Chesber, PA," by Roberb H. Pease, Jr. forCommonwealth of Pennsylvania DER, Augusb.

15. Betz.Converse.Murdoch.Inc., 1980, Letber: "DrafbAnalybioal Daba Tables, Hazardous Wasbe Invesbigabionab Wade Sibe," from Terrenoe J. McManus bo Michael

Zickler of EPA Surveillance and Analysis Division,Region III, BCM Projeob No. 00-5165-01, Augusb 15.

16. Betz.Converse.Murdoch.Inc., 1980, Corrections bo

Summary Reporb "Phase I: Invesbigation ofContamination from a Hazardous Waste Disposal Sibe,Wade Properby," for U.S. EPA and PA DER, BCM No. 00-

5165-01, Oobober 28.P f 17.1 Bebz.Converse.Murdoch.Inc., 1980, Phase I, "Technical

Memorandum 2, Geology/Groundwaber", by Richard L.KraybiU for U.S. EPA and PA DER, Augusb.

17.2 Bebz.Converse.Murdoch.Inc., 1980, Phase I, "TechnicalMemorandum 3, Surface Waber", by William S. Neubeok

for U.S. EPA and PA DER, Augusb.17.3 Bebz.Converse.Murdoch.Inc., 1980, Phase I "Technical

Memorandum 4, Aquatic Assessment", for U.S. EPA and

. PA DER, Augusb.17.4 Bebz.Converse.Murdoch.Inc., 1980, Phase I 'Technical

Memorandum 5, Air Qualiby," for U.S. EPA and PA DER,

Augusb.

000397in

L

MCTCAUr » tODY

17.5 Bebz.Converse.Murdoch.Inc., 1980, Phase I "TechnicalMemorandum 6, Surface Soil and Debris," by TerranoeJ. MoManus for U.S. EPA and PA DER, August.

18. Roy F. Heston, Inc., 1983, Reporb: "Resulbs of Soil

Analysis and Cost Estimates for Selected Remedial

Activities Regarding bhe Wade Hazardous Wasbe Sibe inChesber, PA," for PA DEB, November.

19. U.S. EPA, April 8, 1981 Memo: "Suggested Remedy forbhe ABM Wade Case" from Lamar Miller, Technical

Division, Hazardous Hasbe Enforcement to Jim Bunting,Legal Division, Hazardous Wasbe Enforcement.

20. Mibre Corp., July 30, 1981 Lebber: Cosb esblmabe forEPA Suggested Remedial Albernabive, from Roberb H,Pease, Jr. of Mibre bo Keibh Welks, Toxic Hasbe

Invesbigabion and Prosecution Unit, Comm. of Penn.

Depb. of Jusbioe.21. Mibre Corp., Sepb. 16, 1981, Reporb: "Esblmabe Cost

of Remedial Aobion Plan for The Wade Hazardous WasbeSibe, Chesber, PA".

22. Unbibled; Section 4 - Developraenb of RemedialApproach.

23. Roy F. Wesbon, Inc., 1983, Final Draft "SibeCharacterization Activities on bhe Wade Properby,

Chesber, PA," for PA DER, November.

M0398iv

24. Roy F. Hesbon, Inc., 1983, Drafbt "SibeCharacterization Activities on bhe Wade Properby,

Chesber, PA," for PA DER, October.25. U.S. EPA, 1984, Memo; "Posiblon Paper Regarding bhe

Relabionship of an Endangerment Assessment boRemedial Investigations...," from Abe Mibbelman bo

Gene Luoero, Office of Wasbe Programs Enforcement,

February 2.26. Unknown aubhor and dabe, brief one-page background of

Wade Sibe.27. U.S. EPA, Dabe unknown, Memo: "Wade Sibe, Chesber,

PA, Enforoeraenb Record of Decision," from BruceSmith, Superfund Enforcement Branch bo Thomas

Eichler, Regional Administrator.

28. Wehran Engineering, Site Map, ABM-Hade Sibe, Sheet 1

of 3, Map 1, Project No. 02330155.

29. Unbibled, Geologic Section A-A.30, Unbibled, Geologic Section B-B.31. R.E. Wrighb, Undabed, Well logs, for NUS.32.1 Bebz.Converse.Murdoch.Inc., 1981, Phase II "Technical

Memorandum 1, Subsurface Soils," by James V. Husted

for U.S. EPA and PA DER, May.i **

32.2 Betz. Converse.Murdoch.Inc., 1981, Phase II"Technical Memorandum 2, Surface Soil and Debris, byJames V. Husted for U.S. EPA and PA DER, May.

000391)v

MIKAt,' A KOOY

i rr I' £J

[T~

'n.,32.3 Bebz.Converse.Murdoch, Inc., 1981, Phase II

"Technical Memorandum 3, Delaware River Sediment

Assessment," May.33. U.S. EPA, 1982, Memo: "Healbh Effects Assessment

Summary," from Michael L. Deurson bo JaniceJablonski, Hazardous and Industrial Hastes Division,Augusb 18.

34. U.S. EPA, 1983,"Quantitative Approaches in Use in bhe

Unibed Sbabes bo Assess Cancer Risk," by Elizabeth L.Anderson, copy accepted for publication in "Risk

Analysis", March 23.1, 35. Movement of Selected Mebals, Asbesbos, and Cyanide in

II1 Soil; Applications bo Haste Disposal Problems. EPA

1 600/2-77-020, April 1977.36. Chemical and Physical Effecbs of Municipal Landfills

! on Underlying Soils and Groundwaber EPA 600/2-78-096 May 1978.

vi 000400

I ft/, *•/' J" i

APPENDIX A

i f ;•'; i ••••••—!„,.•.,

I

APPENDIX A

ENVIRONMENTAL ASSESSMENT DOCUMENTATION

As parb of M&E's initial screening of remedialalbernabives for bhe Hade Sibe, an evaluation was conducted boascertain bhe nabure and magnitude of offsibe contaminanttransport via ground waber, This was accomplished in bwosbeps: 1) verificabion of bhe quanbiby and direction of groundwaber flow ab bhe aibe, and 2) estimation of bhe concentrationsof contaminants resulting offsibe based on historical monitoringdaba.

Soil and ground waber daba, including all raw daba andinberprebablons provided In the various Bebz, Converse, andMurdoch Inc. Reporbs (1981 and 1982; see References) werereviewed In deball. Our conclusions regarding geohydrologyissues were generally similar bo bhose frcra bhe previoussbudies. In bhe case of bhe ground waber oubflow deberralnablon,

however, a new value was calculated bhab resulbs in a moreconservabive, "worst case" estimate of bhe impact on bhe river.Our evaluation of bhe hydrogeology of bhe sibe is summarized

below.The saburabed unconsolldabed deposits ab bhe sibe are

relabively bhin and are underlain by bhe poorly permeableHissahiokon formation. They are also horizontally sbrabified,wibh lenses and serai-continuous layers of fine-grained materialsoccurring within bhe aquifer bhroughout bhe site, The wells thatwere Insballed for the previous sbudlea Included bobh deep and

00040MI1CAI.F ft COOT

shallow screened inbervals. Separabe pobenbloraebrlo surfacecontour maps were prepared for bhe deep and shallow portion ofbhe aquifer, and bhis analysis is based on bhose maps and on bhedata used bo prepare bhem.

Generally ground water flows inbo bhe Wade sibe from bhenorth and northeast. Under natural conditions, the ground waberwould be expected bo flow essentially horizontally across bhesibe and discharge bo bhe Delaware River. The existence ofdrainage facilibies on- and off sibe, however, may influence bheground waber flow sysbem.

Ground waber in the deeper parb of bhe aquifer flowsessentially to the southwest and south beneabh bhe sibe. A neb

downward hydraulic gradient exists between bhe upper and lowerportions of the aquifer in bhe norbhern parb of bhe sibe;however, bhe amounb of downward leakage is probably smallcompared bo the horizontal flow because of bhe horizonbalstratii'ication in bhe aquifer. A neb upward gradient exists inthe southern part of bhe sibe. However, verbical movement is

again estimated bo be low compared bo horizonbal flow,particularly since this parb of bhe sibe is near bhe dischargepoinb (Delaware River) which is deep enough bo largely or

completely penetrate bhe aquifer, Ground waber in bhe deeperparb of bhe aquifer is apparently nob affected by bhe shallowdrainage lines bhab cross bhe property west of bhe Wade sibe.

Ground waber In bhe shallow parb of bhe aquifer flows Inbobhe sibe from bhe north and norbheast. The flow direction

A-3 000403

(fir-::

through and away from bhe sibe la to bhe southwest and soubh.The shallow ground waber system receives bhe contaminants frombhe sibe as rainfall infiltration percolates down bo bhe waberbable, The resulbing plume bhen moves largely horizontally todischarge into bhe Delaware River in elbher case.

No upgradienb, offsibe wells were installed in bheprevious sbudies. Wells 7 and 7 A and 1 and 1A were used borepreaenb background conditions, since they are believed to beleast affected by waber qualiby degradablon ab bhe Wade Sibeibself.

The daba from bhe previous sbudies indicabe bhab bheground waber beneath bhe sibe will ultimately reach bhe DelawareRiver wlbhoub Impaobing any waber supply wells. To debermtne bheeffeob of bhe Hade sibe on bhe river, an estimate had bo be madeof the oubflow from bhe sibe, previous reporbs had indicated anoutflow of aboub 2,000 gallons per day. A larger oubflow wascalculated for this sbudy baaed on bhe following assumptions. Ibwas assumed bhab all oubflow from bhe sibe is potentiallycontaminated, so bhab bhe area through which oubflow occurs is20,000 square feeb (as in previous estimates). The gradient wasincreased from ,01 bo ,02 since bhab was bhe measured gradlenb inbhe shallow part of bhe aquifer on bhe NUS maps. Thepermeability was estimated bo be as high as 1x10"^ bo "1.5x10"'.The resulbing ground waber oubflow was determined bo be about10,000 gallons per day, which represenbs a worsb case groundwaber discharge bo bhe Delaware River.

000404A-4

r

In order bo determine bhe irapaob of this discharge on theDelaware River, concentrations of specific chemicals measured inthe ground waber raoniboring wells were used along wibh groundwaber and Delaware River flow daba bo esblmabe loadings bo bheRiver.

An approximate flow bo bhe Delaware River ab Chesber wasestimated by summing bhe annual average flows in cubic feeb persecond (ofa) from USGS flow gaging stations ab Trenbon, wibhflows from several downstream creeks and rivers. The flows used

are listed in Table A-1.

TABLE A-1. DELAWARE RIVER FLOW AT CHESTER, PENNSYLVANIA

Flow (cfs, annual averager1'

11,57028210.71.408.8

2,87169.928.6

USGS Sbablon

TrenbonNesharainy CreekTacony CreekPigeon RunDarby CreekSohuylkill RiverDarby CreekCobbs Creek

14,842.1 = 15,000 ofs

T 1974 daba; annual averages generally based on severalprevious years' daba.

The flow of 15,000 ofs derived la considered oonservabive,as Ib does nob account for input from streams on bhe New Jerseyside of bhe river, and ground waber infllbratlon along. bherlverbank.

Ground waber monitoring data from Betz, Converse, Murdoch,Inc. Technical Memoranda for oonoenbrabions of organic compounds

A'5 00040rJ

r:Wi[

A-6 000406

MITCAir a C00»

in Hells 1, and 1A bhrough 9 and 9A Inclusive were reviewed. To [i'

make a worsb case estimation of bhe inpub of these contaminants \I

from bhe albe bo bhe river, bhe aobual concentrations detected in \I

the wells were assumed bo be bransporbed bo bhe river wibhoub any jabtenuablon by soil, ground waber or degradablon processes, The jfollowing equablon was used bo determine whab bhe resulbanb

rconcentrations in bhe Delaware River would be given 10,000 gpd ofoubflow from bhe site containing bhe specific contaminants. j

Final concentrations in bhe Delaware River afber mixing ii

wibh 10,000 gpd of ground waber infiltration from Wade Sibe: i

CGW ' QGH * CDR ' QDR 'Q W M = Q Q H + Q p R i

where QQW s 10,000 gpd s 0.01 mgd :QDR a 9,965 mgd (full flow)

il QDR = 4,847.5 ragd (half flow), used bo make estimate more/ ' conservative ,

CDR s ambient concenbrabions of organic contaminants in• bhe Delaware River. No daba available.

• ; Table 2 shows bhe results of these calculations. All' ' concentrations measured (i.e. all bhoae other bhan "less-bhan")

for all wells on the sibe were used. As can be seen from bheI

table, bhe resulbanb conoenbrations in bhe river, using even bhe |very high concentrations found in some wells, are all in the verylow ug/L range, Moat of these levels could nob actually be

measured by conventional analytical methods. All concentrations,under both Delaware River flow scenarios, are well below allapplicable Ambient Hater Qualiby Criteria and all U.S. EPA HealbhAdvisories (SNARLS) for bobh boxlo and carcinogenic effecbs.

Lr

APPENDIX B

000407

• '' •

Table 1SAMPLING STATION DESCRIPTIONS' ftBH-WADE DISPOSAL SITE

Chester, PennsylvaniaMarch 13-14, 1979

Station No. Description8

04 Surface soil sample Immediately belowdfalrrvsrvTon tanker. Location 27m(SB ft) from reference pole 89884 and21m (69 ft) from reference pole 89883. j

i05 Surfacejflil, sample near tanker and !

over-turned drums. Location 9.6m !(32 ft) from reference pole EPA-2 and '17m (56 ft) from reference corner A. !

07 Sludge-like material next to collapseddrum. Location 19m (62 ft) from refer-ence corner B and 22m (72 ft) from refer- jence corner C.

:OB Sludge-like material near collapsed II

drums. Location 5.8m (19 ft) from :''reference corner D and 12m (41 ft) from jreference corner E. _ !

10 Soil sample approximately 23cm (9 1n) ',raown from surface. Location llm (37 ft) i

' from reference corner D and 12m (41 ft) 1from reference corner E. i

11 Soil sample approximately 13cm (5 1n) down1 from surface. Location 12m (38 ft) from

reference corner E and llm (36 ft) fromreference corner F. '

19 Liquid from «ump.b Location 10m (34 ft) 'from reference corner C and 10m (34 ft)from reference corner D. * !

i20 Floor scrapings near stored drums 1n building. '

Sources U.S. EPA "Field Investigation for Imminent Hazard Assessment, jABM-Wade Disposal Site, Chester, PA", by Thomas 0. Dahl, Office [of Enforcement, 330/2-79-020, June. !

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Simple Description and Detection Unit

DetectionLimit

Hater Samples (ppb)Hide, Station A, Blank ,0Hade, Station B, D.S. River .0Hade, Station C, Culvert .0Hade, Station D, Manhole** < .0Hade, Station E, U.S. River ,0

IDetection

I. Sample I Soil Samples (ppm)I 821001-06 Hade, Station SI, River bank, South Site 3.3

-07 Hade, Station 52, River bank, North Site 0.3Hade, Station S3, River bank, Near Tank 0.3Hade, Station S4, Still 1n Area A Near Tank 3.3Hade, Station SS, Soil Area B 3.3

Source: Ecology and Environment, Inc. "Field Investigations of UncontolledHazardous'Waste Sites, Task Report Co the Environmental ProtectionAgency, Contract No, 68-01-6056, Letter Report of Wade Site", toLinda Boornazlan-EPft Region III, October 26, 1982.

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APPENDIX D

000457

APPENDIX D

A. Remedial Alternative No. 1 (No Aotlon)

Assume:1. Inspection/sampling (13 water and 3

>s

Sampling frequency!2 per year for 30 years

Sampling/analytical coats:0-5 years: $19,700 per sample run6-30 yearsi $11,300 per sample run

2. Install 2 upgradlent monitoring well clusters: $12,000

Replacement after 15 yearsi $12,0003. Replacement of 3 dovmgradlent monitoring well

clusters after 10 years (one time only): $16,5004. Hell maintenance and rehabilitation: every 5 years, $5,000

§ $1,000 per well cluster (not required 30th year)

Present worth calculation: Note 1

' (Assume 1Q% Interest)j 1. P/A - 5 years - $39,100/year $119.372

P/A - 25 years - $22,600/year = $205,110

I P/F - 5 yeara - $205,110 127,3722. $12,000 12,000

P/F - 15 years - $12,000 , 2,873

p/A.s Present worth of annual payments.P/F • Present worth of future payment.

D-1 000458

MITCAl.' • IDDT

Lr

3. P/F - 10 years - $16,500 6'361

It. P/A - 50* - 5 - »5,000P/F - 5, 10, 15, 20, 25 years - $5,000

PW = $305,112

0-2 000/159

B. Remedial Alternative No. 2 (Limited Clean-up, no cap)Assume:1. Inspection/sampling (13 water and 3 soil)

Sampling frequency:" 1 p e r year: 0 - 3 years

2 per year: 1-10 years1 per year: 11-30 years

Sampling/analytical costs:0-5 years; $19,700 per sample run'6-30 years: $11,300 per sample run

2. Installation of 2 upgradient monitoring wellclusters: $12,000Replacement after 15 years: $12,000

3. Replacement of 3 downgradient monitoring wellclusters: $16,500

1. Well maintenance and rehabilitation; every 5 years $5,0005 years § $1,000 per well cluster (not required 30th year)

Present worth calculation:(Assume 10jt interest)

1. P/A - 3 years - $78,800 $195,976P/A - 2 years - $39,100 = 68,398P/F - 3 years - $68,398 51,387P/A -'5 years - $22,600 = 85,677

P/F - 5 years - $85,667 53,197P/A - 20 years - $11,300 = 96,208P/F - 10 years - $96,208 37,088

D-3 000^0

2. $12,000 *12'000

P/F . 15 years - $12,000 2«8733. P/F - 10 years - $16,500 6,361

l». P/A - 50H - 5 - $5,000" P/F - 5, 10, 15, 20, 25 years - $5,000 ——liM

PW = $366,316

"W

D.I, OOO-dRl

C. Remedial Alternative Noa. 3.5.7.9 and 11 (Full Clean-up,

Aaphalt cap)Assume:1., Inspection/sampling (13 water only) ,

Sampling frequency1 per year: 0-3 years2 per year: 1-10 years1 per year: 11-30 years

Sampling/analytical costs:0-5 years: $15,100 per sample run6-30 years: $9,000 per sample run

2. Install 2 upgradient monitoring wellclusters: $12,000

Replace after 15 years; $12,000

3. Replace 3 downgradlent monitoring wellclusters after 10 years (one time only): $16,500(after 10 years - one time only)

1, Hell maintenance and rehabilitation:every 5 years 6 $1,000 per well cluster (not required

I 30th year) $5,000r- 5. Asphalt maintenance: $3,000

(every three years)6. Re-cover asphalt: * $70,000

(after 15 years)

D-5

Mltcmr • fPPr '' 'V-'* I ' "'"'.'•'"'',,•,'. ...

Present worth oaloulatlon:(Assume 10* interest),. P/A . 3 years - *60,100 *150'215

P/A - 2 years - $30,200 = 51,127• P/F - 3 years - $51,127 ' 39'388P/A - 5 years - $18,000 = 68,238

*fi* 93R l|2»369p/F . 5 years - $63,238P/A - 20 years - $9,000 = 76,626P/F - 10 years - $76,626 29'539

$12,0002- *12,000

P/F . 15 years - $12,000 C|*• oA 1

3. p/F - 10 years - $16,500 '7 131„. p/F - 5, 10,15, 20, 25 years

5 P/F -3, 6,9, 12, 15, 18,21,21, 17 years $3,0009,276

16.010.6. P/F - 15 years - $67,000 •————

PW = $315,195

000363D-6

I1CHI.I • IOOY

D. Remedial Alternative Noa. 1.6,8.10 and 12 (Full Clean-up,

Topsoil oap)Assume;

1. Inspection/sampling (13 water only)Sampling frequency:

1 per year: 0-3 years2 per year: 1-10 years1 per year: 11-30 years

Sampling/analytical costs:0-5 years: $15,100 per sample run6-30 years: $9,000 per sample run

2. Install 2 upgradient monitoring well: ' clusters; $12,000

I Replace after 15 years: $12,000

3. Replace 3 downgradient monitoring wellclusters after 10 years (one tima only) $16,500

1. Hell maintenance and rehabilitation:every 5 years g $1,000 per well cluster (not required

30th year) $5,000[ 5. Topaoil maintenance! $2,000

(every two years)I 6. Mowing grass (every year) $2,000

; Present w'orth calculation:(Assume 10Jt interest)

j 1. P/A - 3 years - $60,100 PW = 150,215

\^J P/A - 2 years - $30,200 = 51,127

000464D-7

39,388P/F - 3 years " $51,127

P/A - 5 ye*" - *18'°00 B 68'238 12,369p/F - 5 years - $62,238P/A - 20 years - $9,000 = 76,626

' 29. 539"P/F - 10 years - $76,626 «'"»

$12,0002. $12,000 28?3

P/F - 15 years - $12,000 '6,361

3 p/F - 10 years - $16,500,'. P/A - 5, 10, 15, 20, 25 years $5,000 T,W5. P/A -20»- 15, 2. 1,6....-28, 30 years 9,350

6. p/A - 30 years - $2,000 ^

PfillfllEGEDlliKPJlODUCTPIlEPJIIIEDIN ANTICIPATION Of

D-8

ITC»l.r • 1001

focused feasibility study [ the wade site chester

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