i · * i nus project number s797 ... installation of a methane gas recovery ... in glendon and...
TRANSCRIPT
|A Halliburton Company
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I
IFOCUSED FEASIBILITY STUDY REPORT
OPERABLE UNIT 1- . PRIVATE WELL USERS
~~ INDUSTRIAL LANE SITE| • NORTHAMPTON COUNTY, PENNSYLVANIA
- _ EPA WORK ASSIGNMENTI • NUMBER 78-3R62.3
_ CONTRACT NUMBER 68-01-6699
* I NUS PROJECT NUMBER S797
[
— SEPTEMBER 1986
flR30!3y
NUSCORPORATION
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FOCUSED FEASIBILITY STUDY REPORTOPERABLE UNIT 1
PRIVATE WELL USERS
INDUSTRIAL LANE SITENORTHAMPTON COUNTY, PENNSYLVANIA
EPA WORK ASSIGNMENTNUMBER 78-3R62.3
CONTRACT NUMBER 68-01-6699
NiUS PROJECT NUMBER S797
SEPTEMBER 1986
SUBMITTED FOR NUS BY: APPROVED FOR SUBMISSION:
WILLIS C. ISNER, P.E. DAVID E. MaclNTYRE, P.E/PROJECT MANAGER REGIONAL MANAGER ^
REGION III
1 A Halliburton Company
CONTENTS
SECTION PAGE
EXECUTIVE SUMMARY ES-1
1.0 INTRODUCTION AND SCOPE OF WORK 1-11.1 SITE BACKGROUND INFORMATION 1-41.1.1 SITE LOCATION AND DESCRIPTION 1-41.1.2 GENERAL SITE-RELATED HISTORY 1-51.1.3 FUTURE LAND USE 1-61.2 REMEDIAL INVESTIGATION SUMMARY 1-61.2.1 PRIVATE WELL SURVEY 1-71.2.2 NATURE AND EXTENT OF CONTAMINATION 1-91.3 APPLICABLE, RELEVANT, AND APPROPRIATE REQUIREMENTS 1-111.4 REMEDIAL OBJECTIVES AND GENERAL RESPONSE ACTIONS 1-17
2.0 SCREENING OF REMEDIAL TECHNOLOGIES 2-12.1 REMEDIAL TECHNOLOGY SCREENING PROCESS 2-22.2 NO ACTION 2-22.3 NO-ACTION WITH MONITORING 2-32.4 ALTERNATIVE DRINKING WATER SUPPLY 2-32.5 PRIVATE WELL TREATMENT 2-32.6 REMEDIAL ALTERNATIVE DEVELOPMENT 2-6
3.0 REMEDIAL ALTERNATIVES DESCRIPTION 3-13.1 ALTERNATIVE!-NO ACTION 3-13.2 • ALTERNATIVE 2-NO ACTION WITH MONITORING 3-13.3 ALTERNATIVE 3-TAP-IN TO PUBLIC WATER SYSTEM 3-13.4 ALTERNATIVE 4-INDIVIDUAL WELL TREATMENT SYSTEMS 3-3
AND MONITORING
4.0 DETAILED EVALUATION OF REMEDIAL ACTION ALTERNATIVES 4-14.1 ALTERNATIVES EVALUATION METHOD 4-14.1.1 TECHNICAL ASPECTS 4-14.1.2 PUBLIC HEALTH CONCERNS 4-24.1.3 INSTITUTIONAL ISSUES 4-34.1.4 COST CRITERIA 4-34.2 REMEDIAL ACTION ALTERNATIVE NO. 1 - NO ACTION 4-44.2.1 PUBLIC HEALTH CONCERNS 4-44.3 REMEDIAL ACTION ALTERNATIVE NO. 2- NO ACTION WITH 4-6
LONG-TERM MONITORING4.3.1 TECHNICAL EVALUATION 4-64.3.2 PUBLIC HEALTH CONCERNS 4-64.3.3 INSTITUTIONAL ISSUES 4-7
AR30I3i*3
CONTENTS (CONTINUED)
SECTION PAGE
4.4 REMEDIAL ACTION ALTERNATIVE NO. 3 -TAP-IN TO 4-7PUBLIC WATER SYSTEM
4.4.1 TECHNICAL EVALUATION 4-74.4.2 PUBLIC HEALTH CONCERNS 4-84.4.3 INSTITUTIONAL ISSUES 4-84.5 REMEDIAL ACTION ALTERNATIVE NO. 4-INDIVIDUAL 4-10
WELL TREATMENT SYSTEMS4.5.1 TECHNICAL EVALUATION 4-104.5.2 PUBLIC HEALTH CONCERNS 4-114.5.3 INSTITUTIONAL ISSUES 4-114.6 COST EVALUATION SUMMARY 4-124.6.1 REMEDIAL ACTION ALTERNATIVE NO. 1-NO ACTION 4-124.6.2 REMEDIAL ACTION ALTERNATIVE NO. 2-NO ACTION 4-12
WITH MONITORING4.6.3 REMEDIAL ACTION ALTERNATIVE NO. 3-TAP-IN TO 4-12
PUBLIC WATER SYSTEM4.6.4 REMEDIAL ACTION ALTERNATIVE NO. 4-INDIVIDUAL 4-14
WELL TREATMENT SYSTEMS WITH MONITORING
REFERENCES R-1
APPENDICES
A COST ESTIMATE CALCULATIONSB RISK ASSESSMENT CALCULATIONS AND GRANULAR
ACTIVATED CARBON TREATMENT CALCULATIONS
in
TABLES
NUMBER PAGE
ES-1 REMEDIAL ACTION ALTERNATIVES CAPITAL AND ES-5PRESENT-WORTH COSTS
1-1 PRIVATE WELL SURVEY SUMMARY 1-81-2 REGULATORY STANDARDS AND GUIDELINES FOR VOLATILE 1-15
GROUNDWATER CONTAMINANTS2-1 INITIAL LIST OF REMEDIAL ALTERNATIVES AND EPA 2-7
ALTERNATIVE CATEGORIES4-1 REMEDIAL ACTION ALTERNATIVES COST SUMMARY 4-13
FIGURES
NUMBER PAGE
1-1 LOCATION MAP 1-21-2 SITE STUDY AREA 1-33-1 GROUNDWATER MONITORING LOCATIONS FOR REMEDIAL ACTION 3-2
ALTERNATIVES NO. 2 & NO. 43-2 LOCATION OF GLENDON AND LUCY'S CROSSING RESIDENTS NOT 3-4
CONNECTED TO THE EXISTING PUBLIC WATER SYSTEM
DRAWINGS
NUMBER PAGE
S797-11-01 GROUNDWATER SAMPLING LOCATIONS & MAXIMUM BACKVOLATILE ORGANICS DETECTED POCKET
IV
1
II1III
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ttI AR30I31*6
EXECUTIVE SUMMARY
The Focused Feasibility Study (FFS) Report for the Industrial Lane Site has been prepared at therequest of the United States Environmental Protection Agency (EPA), Region III, under WorkAssignment Number 78-3R62.3, Contract Number 68-01-6699. This study was prepared in accordancewith the requirements of the National Oil and Hazardous Substances Contingency Plan (NCP)published pursuant to Section 105 of the Comprehensive Environmental Response, Compensation,and Liability Act of 1980 (CERCLA).
The scope of work for the FFS - Operable Unit 1 has been developed in consultation with the EPARegion III office and will focus on remedial alternatives for private well users in the study area. Aforthcoming FFS-Operable Unit 2 will focus on remedial actions that address source control measuresand groundwater remediation in the study area. The methodology for preparation of the FS followsthe steps as outlined in the Feasibility Study Guidance Document (EPA, June 1985).
Site Background
The Industrial Lane Study area encompasses approximately 2 square miles in Williams Township,Northampton County, Pennsylvania. The study area borders on the city limits of Easton and theLehigh River. The communities of Glendon and Lucy's Crossing are located in the west andsouthwest portion of the study area. Key features within the study area are an active PennsylvaniaDepartment of Environmental Resources (PADER) permitted landfill known as the Chrin Landfill,several active and abandoned industrial properties, commercial establishments, and farming andresidential areas.
A potential public health problem was recognized in 1983 as a result of groundwater contamination,and the site was placed on the National Priorities List (NPL). The listing was based on a HazardRanking System (HRS) report prepared primarily for the Chrin Landfill. Extensive groundwater andleachate sampling was conducted by PADER and the EPA prior to the NUS FIT III RemedialInvestigation (Rl). This sampling indicated low levels of several organic and inorganic prioritypollutants. The source of these contaminants has not been conclusively traced to the landfill or anyother distinct source. In addition to the Chrin Landfill, there are several other potentialgroundwater contamination sources within the study area. These include an abandoned sand andgravel pit, active and/or abandoned industrial use properties, and private on-lot sewage disposalsystems (septic systems). Also, several iron ore mines and an iron works operated in the study area.The iron mine drainage and/or iron works paniculate emissions may have contributed to the
ES-1
elevated metal content of the soils and groundwater. Limited data is available on characterizationof these sources and their potential effect on the private wells in the study area.
Future Land Use
Presently, the Chrin Landfill is approximately 30 acres in size and operating under a PADER permit asa sanitary landfill. If pending PADER permit applications are approved, the proposed futureexpansion of the Chrin Landfill will include developing approximately 13 acres east and adjacent tothe landfill for the acceptance of municipal solid waste and demolition waste. Also proposed is theinstallation of a methane gas recovery system, a resource recovery facility, and/or a mass burningincinerator with energy recovery capabilities.
Also, significant changes to the area are expected to occur along the proposed I-78 right-of-waycorridor, which extends east to west approximately 850 feet north of industrial Drive near the ChrinLandfill. Land use of this area will be influenced by proposed zoning changes, which include thedevelopment of a commercial district along the I-78 corridor.
Remedial Investigation Results
The objectives of the Rl were to characterize the type and extent of contamination at the site and toevaluate the potential public health and environmental concerns associated with thatcontamination. The following narrative summarizes the findings of the Rl as they pertain to thisFocused Feasibility Study.
A survey of residential water supplies was performed by NUS FIT during the Rl. There areapproximately 152 residences in the study area, and SOdwellings have been identified in thecommunities of Lucy's Crossing and Glendon. At least seventeen of the Glendon and Lucy's Crossingresidents have private wells. Two of these homes also have public water service. Ail of the well usersin Glendon and Lucy's Crossing have curbside public water available but have not been connected tothe system at this time.
Hazardous Substance List (HSL) chemicals were detected in groundwater samples collected fromresidential wells in the Industrial Lane Study Area. Compounds detected in samples from residentialwelts include tetrachloroethene, trichloroethene, 1,1,1-trichloroethane, and chloroform at relativelylow concentrations [i.e., approximate instrument detection limits of 5 yg/l or parts per billion (ppb)].
ES-2
No adverse noncarcinogenic effects are anticipated through household exposure to the presentlevels of well contaminants; however, carcinogenic risks may be incurred through drinking andinhalation of volatile chemicals released during showering. The present carcinogenic risk for eachexposed individual has been estimated to be approximately 1 x 10-6 (or a 1 in 1,000,000 chance thatan exposed person will contract cancer over a 70-year lifetime of exposure) for residents of GlendonBoro, and 2x 10-5 (or a 1 in 50,000 chance) for exposed persons living in Lucy's Crossing. These riskestimates were established based on the average concentrations detected in contaminatedresidential wells from separate sampling rounds. The origin of these groundwater contaminants hasnot been conclusively demonstrated.
A partial leachate collection system is in place at the Chrin Landfill. Analytical results for leachatesamples and groundwater monitoring well samples indicate that HSL chemicals are being leachedfrom the landfill waste deposits. The fact that estimated leachate generation rates significantlyexceed leachate collection rates indicates that landfill leachate is migrating to the groundwater andwill most likely continue in the future.
The future impact on the residential wells as a result of this ieachate generation is unknown. Anindication of the future potential effect on groundwater quality is the carcinogenic risk estimated byassuming a residential well is placed in the immediate vicinity of the landfill (near monitoringwell N-8). Using the worst-case groundwater concentrations for well N-8, the cancer risk is 7 x 10-3for ingestion and inhalation exposure through drinking and showering. This corresponds to a 1 in140 chance that an exposed individual will contract cancer over a 70-year lifetime (see Appendix Bfor calculations and assumptions).
The future potential risks posed by the maximum concentrations in monitoring well N-8 are muchgreater than those to which the receptors are presently exposed, but it is not known whetherresidential concentrations will reach these levels or possibly exceed these levels. Factors such asdispersion, degradation, and adsorption should preclude concentrations in the residential wellsreaching levels similar to those in N-8 unless contaminant release from the landfill or other potentialsources increases dramatically in the future and the natural processes stated above fail. Theanalytical results for samples collected from NUS monitoring well N-8 were used as the basis forassessing future human health risks.
13(4,9
Feasibility Study Objectives and Criteria
The purpose of this Focused FS is to provide an array of technically sound and cost-effective remedialaction alternatives that eliminate or reduce the risk to the receptors (private well users). As a result,protection to the public health and welfare is provided.
Previous remedial action objectives focused on either preventing an increase in the present risk levelor reducing the present or potential risks to acceptable levels. An acceptable level of risk wasdefined as being within EPA's Region III guidance levels of 10-4 to 10-7 with 10-6 as a target level.Therefore, the remedial objective identified for the private well ingestion pathway is to prevent afuture increase in well water contamination above a 1 x 10-6 target risk level.
Screening and Development of Remedial Technologies and Alternatives
Since this FFS is focused on actions at the receptor and will not address groundwater or sourcecontrol measures, appropriate response actions identified to meet the objective include thefollowing:
• No action with monitoring• Alternative water supplies• Individual well treatment systems with monitoring
Remedial Action Alternative Descriptions
The following narrative provides a brief description of each remedial action alternative (RAA)developed for the Industrial Lane Site. Table ES-1 summarizes the capital and the present-worthcosts for each RAA.
Remedial Action Alternative No. 1 - No Action
A no-action alternative was developed, as required by EPA FS guidance in accordance with the NCP.No action will not require the implementation of any remedial cleanup, investigation, or monitoringactions. The risk posed by a no-action alternative is a potential future ingestion of the groundwaterat a risk level greater than 10-6, which is greater than EPA's target level.
,fiR30i350
TABLE ES-1
REMEDIAL ACTION ALTERNATIVESCAPITAL AND PRESENT-WORTH COSTS
INDUSTRIAL LANE SITE
Remedial Action Alternative
1. No Action2. No Action with Monitoring
3. Tap-In to Public Water System4. Individual Well Treatment Systems with Monitoring
Capital Cost
NA
$63,700
$30,800*
$134,600
Present-WorthCost
NA
$480,000
$30,800*
$1,001,000
NA- Not Applicable*Cost is approximate based on estimate of number of homes using private wells without publicwater supply.
ES-5 AR30135I
Remedial Action Alternative No. 2 - No Action with Monitoring
Under this alternative, no remedieil technologies would be implemented and no action would betaken at this time to improve conditions at the site. Associated with this alternative is theestablishment of a 30-year program to monitor the groundwater quality and to assess the risks to thewell water users at the site. The monitoring program would include the following activities:
• Construction of four monitoring wells (two per cluster)• Annual monitoring of 16 residential wells (sampled on a rotating quarterly basis)• Quarterly monitoring of six monitoring wells
All samples would be analyzed for HSL volatile organics and the following parameters: pH, BOD,COD, Anions, Cations, ammonia, and total dissolved solids.
The results of the monitoring program would be evaluated by a designated agency to track furthermigration of contamination, to identify the level of risk to the public health, and to identify a pointat which remedial action will be required.
Remedial Action Alternative No. 3 - Tap-In to Public Water System
This alternative would involve the installation of water service lines from the Easton Suburban WaterAuthority's existing street water supply mains to approximately 15 residences in Glendon and Lucy'sCrossing that are presently using private wells. The implementation of this alternative wouldeliminate the health risks associated with exposure to contaminated groundwater by eliminating thepotential for ingestion, inhalation, and direct contact; thus the public health would be adequatelyprotected. No monitoring would be required with this alternative, since this FFS is focused on therisk to the receptors (groundwater users). A companion document, FFS - Operable Unit 2 will addressgroundwater monitoring.
Remedial Action Alternative No. 4- Individual Well Treatment Systems with Monitoring
This alternative would involve the installation of a granular activated carbon (GAC) treatment unit ineach residence in Glendon and Lucy's Crossing that is using private wells for drinking and/orshowering (approximately 16 residences). In order to provide proper operation and maintenance ofthe units, a contractor service would be required to monitor the effluent on a quarterly basis and toreplace the carbon filter on an annual basis, if required. Since such a system is designed to treat
ES-6 fiR30!352
specific chemicals at specific concentrations, groundwater monitoring will also be required on aquarterly basis. Should vinyl chloride (present in one of the monitoring wells) or other untreatablechemicals also contaminate the residential wells, GAC treatment would be ineffective, and otherremedial measures would be required to protect the public health.
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1.0 INTRODUCTION AND SCOPE OF WORK
This Industrial Lane Site Focused Feasibility Study (FFS) was prepared in response to theU.S. Environmental Protection Agency (EPA) Work Assignment No. 78-3R62.3 under ContractNo. 68-01-6699. The scope of work for the FFS - Operable Unit 1 has been developed in consultationwith the EPA Region III office and has been revised from the original scope of work in the workassignment.
The focus of this evaluation (Operable Unit 1) will be on remedial alternatives for private well usersin the study area. The study area is defined to include the communities of Glendon, Lucy's Crossing,and the areas between these communities and the existing Chrin Landfill and upgradient of thelandfill. The site location and study area are shown on Figures 1-1 and 1-2. All of the private wellshad Hazardous Substance List (HSL) compounds below detectable levels or at levels low enough torepresent ingestion risks of 1 x 10-6 in Glendon and 2 x 10-5 in Lucy's Crossing. Significant levels ofHSL compounds were not detected in the Morgan Hill area wells. The potential contaminantexposures and associated risks are described in detail in Section 1.2 and in the EndangermentAssessment (NUS FIT, June 1986).
The methodology used to prepare this FFS generally followed the steps prescribed by the NationalContingency Plan and outlined in the EPA FS Guidance Document (USEPA, June 1985). These stepsare as follows:
• Identify General Response Actions
Identify site problems and pathways of contamination (remedial investigation).
Identify general response actions that address site problems and satisfy remediationgoals and objectives.
• Identify and Screen Technologies and Develop Remedial Alternatives
Identify possible technologies in each general response action, and then screen thetechnologies to eliminate inapplicable and infeasible technologies based on siteconditions.
1-1 fiR3Qi355
SOURCE' USQS EASTON.NJ-PA QUAD. (7.5 MINUTE SERIES) 1973
FIGURE I-
LOCATION MAP IMUStINDUSTRIAL LANE STUDY AREA. NORTHAMPTON CO..PA |__]_j CXDFf3OFIArOM
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LOCO
CDCO
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Assemble technologies into alternatives, based on the remaining feasibletechnologies.
• Develop and Evaluate Alternatives
Identified remedial alternatives are developed in detail and evaluated in terms oftechnical feasibility, environmental and public health impacts, and costs.
1.1 Site Background Information
1.1.1 Site Location and Description
The Industrial Lane study area encompasses approximately 2 square miles in Williams Township,Northampton County, Pennsylvania. The study area borders on the city limits of Easton and theLehigh River. The study area is situated approximately 15 miles east of Allentown and 50 miles northof Philadelphia, Pennsylvania (see Figure 1-1). The following information was obtained from theFinal Draft Rl Report dated June 1986.
The Lehigh River and the Lehigh River Canal form the approximate northwestern border of the studyarea. The communities of Glendon and Lucy's Crossing are located in the west and southwestportion of the study area. Morgan Hill is situated within the east and south portions of the area. Thetotal population of the study area is estimated at 517. Key features within the study area are anactive Pennsylvania Department of Environmental Resources (PADER) permitted landfill known asthe Chrin Landfill, several active and abandoned industrial properties; commercial establishments;and farming and residential areas. Refer to Figure 1-2 for a more detailed illustration of theIndustrial Lane study area.
A potential public health problem due to groundwater contamination was recognized by state andFederal agencies during the early 1980s. The site was placed on the National Priorities List (NPL) in1983, based on a Hazard Ranking System (HRS) report prepared for the Chrin Landfill.
Local residents alleged that large quantities of industrial waste and potentially hazardous materialswere disposed at the landfill. These allegations have not been confirmed. Extensive environmentalsampling (conducted by PADER and EPA prior to the Rl investigation) of groundwater monitoringwells, surface water, and residential wells within the vicinity of the Chrin Landfill has indicated low
1-4 fiR3QI358
levels of several organic and inorgeinic priority pollutants. The source of these contaminants has notbeen conclusively determined.
In addition to the Chrin Landfill, several other potential groundwater contamination sources existwithin the study area. These include an abandoned sand and gravel pit, active and/or abandonedindustrial-use properties, and private, on-lot sewage disposal systems (septic systems). Historicalinformation indicates that several iron ore mines operated in the study area and that an iron worksoperated near Glendon from approximately 1844 to 1896. It is suspected that iron mine drainageand/or iron works particulate emissions have contributed to the elevated metal content of the soilsand groundwater. Remedial actions for these sources will not be addressed in this FFS.
1.1.2 General Site-Related History
The site is listed on the NPL under the name Industrial Lane. Industrial Drive is the name of record forthe road that extends through the central portion of the study area. However, to avoid confusion,the name Industrial Lane will be used throughout this report. The 1874Atlas of NorthamptonCounty depicts the area currently occupied by the Chrin Landfill as undeveloped, with the exceptionof several iron ore mines. These mines are depicted, on available historical maps, as being locatedapproximately 450 feet south of the road now known as Industrial Drive, within the vicinity of whatis now the southern area of the Chrin Landfill and the abandoned industrial use property (nowknown as the Pennsalt area). Aerial photographs from 1947 of the Industrial Drive and Holly Streetintersection area, including the northern portion of Morgan Hill, indicate that the Chrin Landfill areawas used for agricultural purposes. Several small open areas, located in the central area of what isnow the oldest portion of the landfill, may represent the likely locations of the above-described ironore extraction pits. Aerial photographs from November 1958 show the landfill area as remainingundeveloped and mostly wooded. The previously described iron ore extraction areas appear as ifthey had been naturally revegetateid or were graded over. In 1958, the current operator purchasedthe property, and in 1961, the site was developed and used as a sanitary landfill. Aerial photographsfrom June 1964 confirm that landfilling activities had begun at the Chrin Landfill. Photographs from1971 show the continued expansion of the landfill to encompass an area of approximately 13 acres.April 1980 aerial photographs show the increased expansion of the landfill to approximately30 acres. Presently the landfill is active and operating under a PADER permit as a sanitary landfill.The size remains at approximately 30 acres, with an additional 10 to 20 acres of support areas, fromwhich cover soils have been excavated for the landfill.
1-5
1.1.3 Future Land Use
If pending DER permit applications are approved, the proposed future expansion of the ChrinLandfill includes developing approximately 13acres east and adjacent to the landfill for theacceptance of municipal solid waste and demolition waste. Also proposed, is the installation of amethane gas recovery system for the generation of electrical power and a resource recovery facility,including materials such as paper and glass and/or a mass burning incinerator with energy recoverycapabilities.
Significant changes to the area are expected to occur along the proposed I-78 right-of-way corridor,which extends east to west approximately 850 feet north of Industrial Drive near the Chrin Landfill(refer to Figure 1-2). Currently, these areas are zoned mostly residential with some light industry.Proposed future land use of this area will undoubtedly be influenced by proposed zoning changes,which include the development of a commercial district along the I-78 corridor.
1.2 Remedial Investigation Summary
A remedial investigation (Rl) of the Industrial Lane Site was performed by the NUS Region III FieldInvestigation Team (FIT) from December 1984 to June 1986.
The results of the investigation are contained in the Final Draft Rl Report dated June 1986. The Rlobjectives were to characterize the type and extent of contamination at the site and to evaluate thepotential public health and environmental concerns associated with that contamination. The scopeof work performed by FIT included
• Site features investigation• Evaluation of previous investigations• Assessment of potential sources of contamination• Evaluation of Chrin Landfill operations• Surface water, sediment, and soil sampling and analyses• Hydrogeologic investigation and groundwater sampling and analyses• Air sampling and analyses• Biota environmental impact assessment• Public health risk assessment
1-6 AR30I360
Because this FFS - Operable Unit 1 is focused on the private well users and their present and potentialrisks, the pertinent Rl findings related to the private well users will be summarized.
1.2.1 Private Well Survey
A survey of residential water supplies was performed by NUS FIT during the Rl. A total of152 residences in Lucy's Crossing, Glendon, along Industrial Drive and in the Morgan Hill area wereidentified for the survey based on 1984 aerial photographs of the site. The survey was conductedusing questionnaires (October, 1984), personal field interviews (March, 1986), and user records fromthe Easton Suburban Water Authority (March, 1986). A summary of the survey results is containedon Table 1-1.
A total of 50 residences have been identified in Lucy's Crossing and Glendon. Information, which hasbeen obtained on all of those residences, indicates that approximately 17 private wells are in use andapproximately 35 residences are connected to the public water system. Two homes have bothprivate wells and public water. The homes in Lucy's Crossing and Glendon that use private wells havecurbside public water lines; however, they have not been connected at this time.
The Industrial Drive area uses public water exclusively; no private wells are being used in this area.
The Morgan Hill area survey identified a total of 84 residences; however, information was obtainedon only 48 of the 84. Forty-six of those residences use private wells, and it is suspected that theremaining Morgan Hill homes use private wells, since public water supply service is not available inthe area. Information was not obtained for 36 Morgan Hill residences in the survey area. However,this is not expected to be a critical data limitation for the FFS because Morgan Hill is generallyupgradient of all of the potential sources of contamination and none of the private wells sampledindicated significant contamination.
It is recommended that the private wells in use in the site area be verified as to number, location, andusage prior to designing the remedial action, if implemented. This verification will confirm thecompleteness of the present survey and will provide an update if present conditions change by thetime of remedial action.
The private wells identified in the survey were drilled wells with depths ranging from 25 to 460 feet.Average depth is approximately 140 feet. The Lucy's Crossing wells range in depth from 37 to
1-7 A R30J36I
TABLE 1-1
PRIVATE WELL SURVEY SUMMARY (MARCH, 1984 TO MARCH, 1986)INDUSTRIAL LANE SITE
Community
Lucy's Crossing
GlendonIndustrial DriveMorgan Hill
TOTAL
No. ofHomes
Identified^)
15
35
18
84
152
No. ofQuestionnairesDistributed^)
15
35
3
84
137
No. of Homeswith PrivateWells InUse(3)
9(5)
8(5)
0
46
63
No. of HomesUsing PublicWaterSupplyW
7
28
18
0
54
No. of HomesWithout
Information
0
0
0
36(6)
36
Notes:0) Homes identified based on 1984 aerial mapping of the study area and field verification
by NUS Region III FIT.(2) Water-supply questionnaires distributed by NUS Region III FIT, response rate 53%
(73/137).(3) Private well locations determined from questionnaire results, personal interviews, and
Easton Suburban Water Authority records. Note: Glendon and Lucy's Crossing homesusing private wells have curbside water lines not presently connected.
W Public water supply use determined from questionnaire results, personal interviews,and Easton Suburban Water Authority records.
(5) One residence in Lucy's Crossing and one residence in Glendon have both a private welland a public water connection.
(6) One residence has a cistern and one has bottled water for drinking water.
1-8 /1R30I362
120 feet, and the Glendon wells with construction information range in depth from 78 to 156 feet.Most of the deeper wells in the study area are on Morgan Hill.
The available information indicates that all of the private wells are either partially cased (solid pipeto bedrock) or are completely cased with perforated or slotted pipe. It is assumed that the wellsintake water across the entire length of their aquifer penetration.
A total of 37 private wells were sampled during the Rl. These include all 9 of the Lucy's Crossingwells, 4 of the Glendon wells, 21 wells in the Morgan Hill/Valley area, and 3 unused wells alongIndustrial Drive (R. Cressman, Tornbler, and Pfister). Results of the analyses are described inSection 1.2.2.
1.2.2 Nature and Extent of Contamination
Hazardous Substances List (HSL) chemicals have been detected in groundwater samples collectedfrom residential wells in the Industrial Lane Study Area (Figure 1-2). Residential wells andmonitoring well locations are indicated on drawing No. S797-11-01 included in the back pocket ofthis report, which includes tabulations of the chemicals detected in the groundwater samples.Compounds detected in samples from residential wells include tetrachloroethene, trichloroethene,1,1,1-trichloroethane, and chloroform. These chemicals were detected at relatively lowconcentrations in the residential well samples (i.e., approximate instrument detection limits of 5 yg/l[parts per billion or ppb]).
As demonstrated in the Endangerment Assessment for the Industrial Lane Site (NUS/FIT, 1986a), noadverse noncarcinogenic effects are anticipated through household exposure to the residential wellcontaminants. It has been shown that carcinogenic risks may be incurred through drinking andthrough inhalation of volatile chemicals released from groundwater during showering, however.
The carcinogenic risk for each exposed individual has been estimated to be approximately 1 x 10-6 (ora 1 in 1,000,000 chance that an exposed person will contract cancer over a 70-year lifetime ofexposure) for residents of Glendon Boro, and 2x10-5 (or a 1 in 50,000 chance) for exposed personsliving in Lucy's Crossing (NUS/FIT, 1986a). These risk estimates were established based on the averageconcentrations detected in contaminated residential wells from separate sampling rounds.
1-9 3R30I363
The origin of these groundwater contaminants has not been conclusively identified. However,similar chemicals were detected in groundwater at and around the Ashland Chemical plant and theChrin Landfill. Other potential point sources, including septic systems, also exist in the study area.
No conclusive link between the Chrin Landfill and/or Ashland Chemical and the residential wells canbe identified based on available data. An indication of the uncertainty in the present site assessmentis provided by the analytical results for groundwater samples collected during the investigation. (SeeDrawing No. S797-11-01 in the back pocket.) No consistent contaminant "plume" could be detected.Indeed, some wells were found to contain chemical contaminants, whereas others located only ashort distance away contained no detectable levels of chemicals. These apparently anomalousfeatures are probably a manifestation of the lateral and vertical proximity of the various wells tobedrock fractures. Groundwater samples directly downgradient of two possible sources (i.e.,Ashland Chemical and the Chrin Brothers Landfill) indicate that chemicals have reached thegroundwater as a result of industrial/disposal operations.
It is believed that contaminants below the Ashland Chemical plant ultimately discharge to theLehigh River. No evidence (hydrologic or chemical-analytical) indicates that this area is the source ofthe residential well contamination. In addition, no impact on the river from this or any other sourcewithin the study area has been detected.
The Chrin Landfill lies upgradient of Glendon Boro and may also be hydrologically connected toLucy's Crossing. All chemicals detected in the residential wells have been found at higherconcentrations in monitoring wells within and downgradient of the landfill (see DrawingNo. S797-11-01). Wells located upgradient of the landfill have historically contained only"background" levels of any chemicals (i.e., isolated occurrences of volatile organic compounds orVOCs; generally less than 5 yg/L [ppb]). The upgradient wells lie in proximity to the landfill, and theoccasional occurrence of VOCs in these wells may be a result of influx caused by well purging prior tosampling.
A partial leachate collection system is in place at the landfill. Analytical results for leachate samples(coupled with results for the groundwater samples) indicate that HSL chemicals are being leachedfrom the landfill waste deposits.
It has not been possible to characterize the transport and fate of the HSL chemicals in leachate fromthe landfill because of the complicated hydrogeology. Therefore, future impact on the residentialwells as a result of this leachate generation is unknown. The carcinogenic risk estimate was
generated by assuming that a residential well is placed in the immediate vicinity of the landfill's mostcontaminated monitoring well N-8 located adjacent to the landfill. The exposure assessmentapproach employed in the Endangerment Assessment (NUS/FIT, 1986a) was coupled with theseworst-case groundwater concentrations to arrive at an incremental cancer risk of 7 x 10-3 (ingestionaland inhalational exposure through drinking and showering, respectively). This corresponds to a 1 in140 chance that an exposed individual will contract cancer over a 70-year lifetime. Calculations andassumptions are included in Appendix B.
It should be noted that, although the future potential risks posed by the maximum concentrations inNUS monitoring well 8 are much greater than those to which receptors are presently exposed, it isnot known whether residential concentrations will reach these levels, or possibly exceed these levels.A number of factors such as dispersion, degradation, and adsorption should preclude concentrationsin the residential wells reaching levels similar to those in well 8 unless contaminant releases from thelandfill or other sources are dramatically increased in the future and cannot be continuated bynatural processes.
The remainder of this document will focus on mitigating the human health impacts attributable toexisting residential well contamination under both present and future potential conditions. Theanalytical results for samples collected from well N-8 will be used as the basis for assessing futurehuman health risks.
1.3 Applicable, Relevant, and Appropriate Requirements
One of the primary concerns in the development of remedial action alternatives for sites covered bythe Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) or"Superfund" is the degree of human health or environmental protection afforded by a givenremedy. To this end, the United States Environmental Protection Agency (USEPA) has indicated thatApplicable, Relevant, and Appropriate Requirements (ARARs) be identified that pertain to each sitein particular. "As a general rule, the Agency's (USEPA) policy is to attain or exceed applicable orrelevant and appropriate Federal environmental and public health requirements in CERCLA responseactions" (Federal Register, Vol. 50, No. 224, November 20,1985).
In view of the nature of contamination at the Industrial Lane Site, the following environmentalFederal regulations are considered applicable:
• The Safe Drinking Water Act (PL93-523)• The Groundwater Protection portion of the Resource Conservation and Recovery Act
(RCRA), (Subpart F - 40 CFR 264.90-264.109)
The Safe Drinking Water Act is considered most applicable to the operable unit presently underconsideration (i.e., the actual receptor wells themselves). The Safe Drinking Water Act (SDWA) wasenacted in 1974 to ensure safe drinking water supplies, protect valuable aquifers, and to protectdrinking water supplies from underground injection of wastes.
The SDWA requires the United States Environmental Protection Agency (EPA) to establish primarydrinking water regulations that specify a Maximum Contaminant Level (MCL) for organic andinorganic chemicals in water used for potable supplies. In December 1975, EPA published theNational Interim Primary Drinking Water Regulations, which included MCLs for a number ofchemicals, primarily inorganic substances, radionuclides, and pesticides. The MCLs represent theallowable lifetime exposure to a chemical contaminant for a 70-kg adult who consumes 2 liters ofwater per day. Lifetime exposure limits were set at the lowest practicable level to minimize theamount of contamination ingested in water, especially when exposure from other sources is large.In addition to human health considerations, the technical and economic feasibility of achieving thedesired concentration is also considered in establishing an MCL. Chloroform is the only groundwatercontaminant at the Industrial Lane Site for which an MCL has been established.
EPA has also developed Recommended Maximum Contaminant Levels (RMCLs) for a number of thechemicals detected in groundwater samples from the Industrial Lane study area. The RMCLs arebased solely on human-health considerations, and as such, do not consider the technical or economicfeasibility of achieving the goals. RMCLs of zero have been specified for carcinogenic substances,based on the assumption of a nonthreshold dose-response. RMCLs are nonenforceable guidelines.
In addition, MCLs have been proposed for a number of the other chemicals detected in study areagroundwater, including benzene, 1,1,1-trichloroethane, 1,2-dichloroethane, trichloroethene,1,1-dichloroethene, and vinyl chloride. These Proposed MCLs (PMCLs) are also nonenforceable. It isanticipated that after an appropriate review/comment period, these PMCLs will be promulgated asMCLs. Hence, the PMCLs are considered relevant guidelines for identification of potential remedialaction alternatives. Values of MCLs and PMCLs are presented later in this section, where additionalhuman health and environmental guidelines are identified.
fiR30i366
The Groundwater Protection portion of RCRA is applicable to regulating leachate generation at theChrin Landfill and other potential sources and will be considered in the companion document.
In addition, the Agency (USEPA) has. indicated that other appropriate criteria, advisories, guidelines,and state standards be considered in devising remedial alternatives. In addition to the MCLs,nonenforceable human health guidelines have also been developed for the groundwatercontaminants detected in both the residential and the monitoring wells. These guidelines includeSuggested No Adverse Response Levels (SNARLs), Acceptable Daily Intakes (ADIs), and AmbientWater Quality Criteria (AWQC). These guidelines have been established to account for acute andchronic noncarcinogenic effects of organic and inorganic chemicals. The Cancer Assessment Group(CAG) of USEPA has established carcinogenic potency factors (dose-response relationships) for use inidentifying the cancer risks associated with exposure to suspected or proven human carcinogens.Each of these are discussed briefly below.
Suggested No Adverse Response Levels (SNARLs) - SNARLs are guidelines developed by the USEPAOffice of Drinking Water for nonregulated contaminants in drinking water. These guidelines aredesigned to consider both acute and chronic toxic effects in children (assumed body weight of 10kg)who consume 1 liter of water per day. SNARLs are generally available for acute (1-day), subchronic(10-day), and chronic (long-term) exposure scenarios. These guidelines are designed to consider onlythreshold effects and, as such, do not consider carcinogenicity.
Acceptable Daily Intake (API) - The ADI applies to prolonged human exposure to hazardouschemicals (i.e., chronic exposure) and is based solely on the noncarcinogenic effects of chemicalsubstances. The ADI is usually expressed as an acceptable dose (mg) per unit body weight (kg) perunit time (day). It is generally derived by dividing a "no observed (adverse) effect level" (NOAEL orNOEL) or a "lowest observed adverse effect level" (LOAEL) by an appropriate "uncertainty factor."NOALs, etc., are determined from laboratory of epidemiological toxicity studies. The uncertaintyfactor (10,100, or 1,000) is based on the availability of toxicity data: 10 is used if appropriate chronichuman data are available; 100 is used if sufficient chronic animal data are available; and 1,000 isused if only subchronic animal data can be obtained. Thus, the ADI incorporates the surety of the
evidence for chronic, noncarcinogenic health effects. Even if applicable human data exist, the ADI(as diminished by the uncertainty factor) still maintains a margin of safety so that chronic healtheffects are not underestimated. Thus, the ADIs are acceptable, conservative guidelines forevaluating noncarcinogenic risks.
AR30I367
Ambient Water Quality Criteria (AWQC) - AWQC are not enforceable regulatory standards but are ofutility in assessing acute and chronic toxic effects on both aquatic organisms and humans. AWQCconsider acute and chronic effects in both freshwater and saltwater aquatic life, and adversecarcinogenic and noncarcinogenic health effects in humans from ingestion of both water(2 liters/day) and aquatic organisms (6.5 grams/day) and from ingestion of water alone (2 liters/day).The AWQC for protection of human health for carcinogenic substances are based on USEPA'sincremental cancer risk range of 10-7 to 10-5. These correspond to a 1 in 10,000,000 and a 1 in100,000 chance that an exposed individual will contract cancer over a lifetime (70 years) of exposure.Although these guidelines are strictly applicable for surface water contamination problems, theymay also be applied to groundwater problems if the drinking water exposure route is considered.
Carcinogenic Potency Factor (CPF) - The CPF is applicable for estimating the lifetime probability(assumed 70-year lifetime) of human receptors contracting cancer caused by exposure to known orsuspected human carcinogens. This factor is reported in kg-day/mg and is the slope of the cancer riskdose-response curve. This slope is determined by CAG through an assumed low-dosage linearrelationship and extrapolation from high to low dose-responses determined from animal studies.The value used in reporting the slope is the upper 95 percent confidence limit. This factor may beused to determine the likelihood that an individual will contract cancer upon exposure (probability).
Table 1-2 summarizes the available guidelines for the protection of human health. The most recentvalues of the MCLs/RMCLs/PMCLs, SNARLs, ADIs, and AWQC are presented in the table. Values havebeen presented for all chemicals detected in leachate originating from the Chrin Landfill. Thislexicon includes all chemicals detected in residential well samples.
In addition to the above, the Agency has also indicated that state regulations also be considered indevelopment of remedial action alternatives, should these goals be consistent with the goals ofFederal standards and guidelines. Several sections of Pennsylvania Code (PC) 25 are consideredapplicable to the Industrial Lane Site. These include Groundwater Monitoring tPC25:75.264(n)],Closure and Post-Closure [PC25:75.264(o)], and Landfills [PC25:75.264(v)]. All of these stateregulations are appropriate for items addressed in more detail in the forthcoming companiondocument (FFS-Operable Unit 2).
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TABLE 1-2
REGULATORY STANDARDS AND GUIDELINES FOR VOLATILE GROUNDWATER CONTAMINANTSINDUSTRIAL LANE SITE
CAS#
71-43-2
107-06-2
127-18-4
79-01-6
75-01-4
67-66-3
75-09-2
75-35-4
Chemical
benzene
1,2-dichloroethane
tetrachloroethene
trichloroethene
vinyl chloride
chloroform
methylene chloride
1,1-dichloroethene
MaximumContaminant
Level(ug/l)(1)(2)
0 (RMCL)5 (PMCL)
0 (RMCL)5 (PMCL)
-
0 (RMCL)5 (PMCL)
0 (RMCL)1 (PMCL)
-
-
7 (RMCL)7 (PMCL)
CarcinogenicPotencyFactor
(kg day/mg)(3)
2.69 xlO'2
9.21 x10'2
5.22x10-2
1. 35x10-2
2.33
7.0x10-2
7.5x10-3
5.74X10'1
AcceptableDailyIntake
(mg/day)(4)
200
-
-
-
-
-
13
-
Suggested NoAdverse
Response Level(ug/l)(5)
10-day: 230Chronic: 70
Chronic: 740<8'
1 -day: 2,30010-day: 175
1 -day: 2,00010-day: 200Chronic: 75
-
-
1-day: 13,00010-day: 1,300Chronic: 150
1-day: 1,000<8>10-day: 1,000<8>Chronic: 1,000<8>
Ambient Water QualityCriteria (ug/l)(6)
For Protection of HumanHealth
Ingestionof Fish andWater
.66(10-6)<7>
.94(10-6)<7>
.8(10-6)<7>
2.7(10-6)P)
2.0(1 0-6)<7>
.19(10-6)
.19(10-6)0)
.033(1 0'6)<7>
Ingestion ofFish Only
40.0(1 0-6)P)
243(10-6)(7)
8.85(1 0-6)P)
80.7(1 0-6)(')
525(1 0-6)<7>
15.7(10-6)
1 5.7(1 0'6)(9)
1.85(10'6)<7>
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TABLE 1-2REGULATORY STANDARDS AND GUIDELINES FOR VOLATILE GROUNDWATER CONTAMINANTSINDUSTRIAL LANE SITEPAGE TWO
CAS#
108-88-3
-
10-41-4
108-90-7
156-60-5
71-55-6
78-87-5
Chemical
toluene
total xylenes
ethylbenzene
chlorobenzene
1,2-dichloroethene
1,1,1-trichloroethane
1,2-dichloropropane
MaximumContaminant
Level(ug/l)(1)(2)
2000(PRMCL)
440 (PRMCL)
680 (PRMCL)
-
700")(PRMCL)
200 (PRMCL)
6 (PRMCL)
AcceptableDaily Intake(mg/day)(2X4)
30
160
9.5
1.0
350(10)(AADI)
38
-
Suggested NoAdverse Response
Level (ug/l)(5)
1-day: 21,50010-day: 2,200Chronic: 340
1-day: 12,00010-day: 1,200Chronic: 620
1-day: 21,000<8)10-day: 2,100<8>
-
1-day: 2,70010-day: 1,000<8>Chronic: 1.000<»
1-day: 140,000<8)10-day: 35,000<8>Chronic: 35,000<8)
10-day: 90<8>
Ambient Water Quality Criteria(ug/l)(6)
For Protection of Human Health
Ingestion ofFish andWater
1.43X10-4
1.43x103
488
-
-
Ingestion ofFish Only
4.24 x105
3.28x103
-
-
-
Notes: ._ -(1) USEPA, March 4,1982(2) USEPA, November 13,1985(3) USEPA, February 1985 and USEPA, November 13,1985(4) USEPA, May 1984(5) USEPA, May 22,1985(6) USEPA, November 28,1980(7) Value does not reflect updated carcinogenic potency factor(8) USEPA, September 30,1985(9) Values apply to halomethanes in general(10) Values apply to both cis and trans isomersRMCL Recommended Maximum Contaminant Level.PMCL Proposed Maximum Contaminant LevelPRMCL Proposed Recommended Maximum Contaminant LevelAADI Adjusted Acceptable Daily Intake (Provisional)(10-6) Value presented corresponds to an incremental cancer risk of 1 x 10-6
1'16 AR30I370
1.4 Remedial Objectives and General Response Actions
Remedial objectives were developed for the contaminant exposure pathways associated withdomestic consumption of well water. The groundwater ingestion risks for present use are 1 x 10"6forresidents of Glendon and 2x10-5 for Lucy's Crossing residents. EPA policy is to consider a risk rangeof 10-4 to 10'7 in determining an acceptable risk level for carcinogens with 10-6 level a target.
Future potential risks to Glendon and Lucy's Crossing from ingestion of groundwater werecalculated using the well N-8 analyses and are estimated to be 7 x 10-3. The future potential riskswere assessed based on the available groundwater data in the Rl. This data indicates the following:
• Lucy's Crossing and Glendon private wells are hydraulically downgradient from potentialcontaminant sources, including the abandoned sand and gravel pit, the former iron oremines, and the Chrin Landfill. The Easton Car and Construction site and and the Pennsalt-Easton Print area are both possibly upgradient (see Final Rl Report, Sections 4.0 and 7.4.2).
• The Chrin Landfill leachate collection system is inefficient, i.e., leachate generation ratesestimated significantly exceed leachate collection rates, a fact which indicates that landfillleachate currently is migrating to the groundwater and will most likely continue in thefuture (see Final Rl Report, Section 5.0).
• HSL compounds were detected in the Chrin Landfill leachate that were also detected inmonitoring well N-8 (see Final Rl Report, Section 5.3.4).
The Rl results do not permit a quantitative evaluation of groundwater flow and contaminantmigration and also do not provide a thorough contaminant source characterization. Nevertheless,the available data is sufficient to provide a qualitative assessment of contaminant migration andsource location indicating that the residents of Lucy's Crossing and Glendon are at a potential futurerisk from ingestion of groundwater.
Therefore, the remedial objectives identified for the private well ingestion pathway is to prevent afuture increase in well water contamination above a 1 x 10'6 target risk level. Based on present risk, ano-action response is inappropriate in Lucy's Crossing area and only marginally acceptable in theGlendon area. Future potential risks clearly require a remedial response action in both areas becausethe target level in both areas may be significantly exceeded. Since this FFS is focused on actions at
flR30J37l
the receptor and will not address groundwater or source control measures, appropriate responseactions identified to meet the objective include
• No action with monitoring• Alternative water supplies• Well water treatment
Technologies associated with these responses are described and screened in Section 2.0.
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1
IIII
I
IEEEEL
[ AR30I373
2.0 SCREENING OF REMEDIAL TECHNOLOGIES
Feasible remedial technologies have been identified for the general response actions listed inSection 1.4. These technologies were selected based on their achieving the remedial objectives andcleanup criteria defined for the groundwater ingestion risks. The initial list of technologies was thenscreened to modify or eliminate those that were not considered appropriate for site conditions orthat are technically limited.
The technologies that passed the initial screening were assembled into remedial alternatives thataddress the remedial objective for the Industrial Lane Site FFS - Operable Unit No. 1. As required inthe EPA FS Guidance under CERCLA (EPA, June 1985), at least one alternative should be consideredfor each of the five remedial alternative categories:
I. Alternatives for treatment or disposal at an offsite facility approved by EPA (including RCRA,TSCA, CWA, CAA, MPRSA, and SDWA approved facilities), as appropriate.
II. Alternatives that attain applicable and relevant Federal public health or environmentalstandards.
III. As appropriate, alternatives that exceed applicable and relevant public health orenvironmental standards.
IV. Alternatives that do not attain applicable or relevant public health or environmentalstandards but that will reduce the likelihood of present or future threat from the hazardoussubstances. This category must include an alternative that closely approaches the level ofprotection provided by the applicable or relevant standards and meets CERCLA's objective ofadequately protecting public health, welfare, and the environment.
V. A no-action alternative. The initial list of remedial alternatives was then screened for publichealth, environmental, and cost factors. The alternatives that passed the screening were thenfurther developed and given a detailed evaluation, as described in Sections 3.0 and 4.0.
Because of the focused nature of this FFS, some of the remedial categories cannot be addressed.These include Category I - Offsite treatment or disposal alternatives and Category III - alternatives
2-1 flR3QI37l4
that exceed standards. Identification of remedial alternatives and classification of these alternativesinto specific categories is described in Section 2.6.
2.1 Remedial Technology Screening Process
An initial screening of feasible technologies is required to eliminate obviously infeasible,inappropriate, or environmentally unacceptable alternatives.
The remedial technologies associated with the site response actions were screened using thefollowing criteria:
• Implementability - constructability and length of time to achieve cleanup.
• Applicability to site conditions - appropriate for site topography, geology, hydrology,biota, and waste characteristics.
• Technical development status - technology should be existing and proven effective for thesite application and commercially available. Innovative and emerging technologies arenot appropriate without field demonstration.
Individual remedial technologies and the results of the screening evaluation are described insubsequent sections.
2.2 No Action
The Industrial Lane site will be evaluated for the no-action alternative, in accordance with the EPAguidance Document for Feasibility Studies. Assessment of the no-action alternative provides abaseline against which the benefits and costs incurred by implementing other remedial actions canbe compared.
The no-action alternative eliminates any remedial actions at the site, and therefore would have notechnological or institutional constraints. The potential effects to the public health and theenvironment would not be mitigated. The further spread of contamination would not becontrolled.
2"2 flR30i375
The no-action alternative is retained for further consideration primarily to comply with EPAguidance for evaluating remedial actions.
2.3 No-Action with Monitoring
The no-action with monitoring alternative is potentially applicable to this site. Existing monitoringwells may be utilized for the monitoring. Sampling and analysis of the groundwater, using amonitoring well network and residential wells, can provide a long-term data base to assess thepotential migration of groundwater contamination. The evaluation of data obtained from amonitoring and analysis program will help to track the spread of contamination, if any, and toidentify a point at which other actions may be necessary at the site.
The no-action with monitoring alternative is retained for further consideration primarily to complywith EPA guidance in completing remedial alternative evaluations.
2.4 Alternative Drinking Water Supply
Alternative water supply technologies include bottled water, above-ground tanks, deeper orupgradient wells, connection to a municipal water system, relocation of water intake structures, andindividual treatment devices. Individual treatment devices are discussed in Section 2.5. ,
Bottled water and above-ground tank systems are only temporary solutions and will not be retainedfor consideration. The construction of upgradient wells, deeper wells, or relocation of water intakestructures is not applicable for the Industrial Lane Site.
Since the Easton Suburban Water Authority has existing curb service available to all the homeslocated in Glendon and Lucy's Crossing (the communities of concern), connection into the publicwater system is the most applicable of the available technologies and will be retained for furtherconsideration.
2.5 Private Well Treatment
Private well treatment is required to remove organic contaminants from groundwater, based on thefuture potential ingestion risks as described in Section 1.2.2. These risks are based on the potentialmigration of groundwater from near monitoring well N-8 to private wells in Glendon and Lucy'sCrossing. Well N-8 contaminant levels were used as the design groundwater for treatment process
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evaluations. Treatment system effluent limitations were based on applicable, relevant, andappropriate requirements, as described in Section 1.3. A summary of the treatment designgroundwater and effluent limitations is presented below:
PRIVATE WELL WATER TREATMENT REQUIREMENTS
Chemical
tetrachloroethenetrichloroethene1,2-dichloroethene
1,1-dichloroethenevinyl chloride
1,1,1-trichloroethane1,1-dichloroethanebenzenetolueneethylbenzene
chlorobenzenexylenes
Design Influent Concentration (pg/l)(1>
31
1779
7
26
66
51
17
48
1
6
460
Effluent Limitation^) (yg/l)
-
5
-
7(3)
1(4)
200
-
5
-
,
-
-
Notes:CO Based on maximum observed concentrations in monitoring well N-8(2) Proposed Maximum Contaminant Level(3) Also RMCLW PMCL cannot be achieved with available GAC technology
The only treatment technology that is applicable for home installation is granular activated carbon(GAC). GAC technology was investigated as a treatment technology to remove organiccontaminants from individual residential groundwater supplies. This option consists of installing acarbon treatment unit in each home currently without a connection to the public water supply.Whereas, GAC can generally remove a broad range of organics from drinking water, its effectivenessdepends on the specific chemicals present, their concentration, and the required degree of removal.With the existing information on groundwater characterization, it is not possible to project futurecontaminant levels in the residential wells. Therefore, this option was developed on the assumptionthat the organics present will be removed by GAC treatment. The "worst-case" contaminant levels
2-4
fl R 3 0 I 3 7 7
found at the site to date from well N-8 provide an indication of possible contaminants and levels.Vinyl chloride, present at this well, would not be effectively treated by GAC. Removal of vinylchloride by air stripping is effective; however, this treatment technique is not feasible for homeunits. Thus if vinyl chloride contamination occurs in residential wells, GAC would not be applicable.
Several aspects of air stripping process make it unsuitable for home treatment installation. Theprocess provides the best results when operated on a steady state basis which does not match thedemand pattern of home water usage. In addition, air strippers would have to be protected fromfreezing and represent an emissions source containing the contaminants transferred from the water.While it may be possible to house an induced draft unit to protect it from freezing the ventedemissions may be unacceptable and require granular activated carbon treatment. Thus thepracticallity and cost of air stripping for home treatment made further consideration of itsapplication difficult to justify.
As with any treatment system, GAC design and economics should be developed on the basis ofadequate characterization of the influent and pilot testing. The system described below is subject tomodification, based on development of more data.
A 7-cubic-foot carbon capacity pressure unit is proposed to provide for the necessary contact timeand the anticipated carbon use rate (See Appendix B for calculations). The unit would be fed by thewell pump and would feature an automatic-timer-operated backwash cycle to remove solids thataccumulate. A tank for backwash water storage is required to control discharge to residential septicdisposal systems. Backwashing frequency depends on the quality of well water which cannot beprojected for each of the individual supplies because of differences in well depth and construction.Since the carbon bed will capture suspended particulate that may be present in groundwatersupplies, backwashing is required to avoid excessive pressure loss that will interfere with operation.
Yearly replacement of the carbon is anticipated, with the vendor hauling the spent carbon to acarbon regeneration facility. In order to provide proper operation and maintenance of the units,contractor service is required. In addition, quarterly testing of the effluent is necessary.
The treatment of groundwater from private wells using individual GAC units will be retained forfurther consideration, since it is the only individual water treatment technology applicable for homeinstallation.
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2.6 Remedial Alternative Development
The remedial technologies that passed the screening were used to develop remedial alternatives.Each alternative, except for the no-action alternatives, was developed to meet the remedialobjectives established for the groundwater ingestion risks (see Section 1.4).
Because of the focused nature of the feasibility study, the remedial technologies in themselves aresufficient to meet the focused site objectives and can serve as individual alternatives. Each of thealternatives, with the possible exception of no action, provides, at a minimum, the CERCLA goal ofprotection of public health.
A total of four remedial alternatives have been identified:
• No. 1-No Action• No. 2 - No Action with Monitoring• No. 3 - Tap-In to Public Water System• No. 4 - Individual Well Treatment Systems with Monitoring
Each of these alternatives was assessed for placement in one of the five EPA remedial categories, asdescribed in Section 2.0. A summary of the remedial alternatives and their appropriate category iscontained on Table 2-1.
EPA Category 1, "Offsite Disposal," is not applicable for any alternatives identified in the FFS -Operable Unit No. 1. This category is not addressed because of the focusing on remedial actions onlyat the groundwater receptors. Source-control actions have not been considered at this time.
Category II, "Attains Standards," is. met by Alternative No. 3 - Tap-In to Public Water. This alternativeis expected to provide potable water to the identified residents at risk. The water is expected tomeet all of the applicable, relevant, and appropriate requirements for domestic use, as described inSection 1.3.
This category is also conditionally met by Alternative No. 4 - Individual Well Treatment, based onpresent private well contamination levels. The activated carbon units identified for well treatmentwill remove all presently identified HSL compounds to below PMCLs identified for safe ingestion (seeAppendix B).
2-6 AR30I379
TABLE 2-1
INITIAL LIST OF REMEDIAL ALTERNATIVES AND EPA ALTERNATIVE CATEGORIESFOCUSED FEASIBILITY STUDY
INDUSTRIAL LANE SITE
Remedial Alternative
1. No Action
2. No Action with Monitoring
3. Tap-In to Public Water System
4. Individual Well TreatmentSystems and Monitoring
EPA Categories of Remedial Alternatives
I. OffsiteDisposal
N/A
N/AN/A
N/A
II. AttainsStandards
N/AN/A*
* (Present)
III. ExceedsStandards
N/AN/A
N/A
N/A
IV. CERCLAGoal
N/A
*(Future)N/A
*(Future)
V. No Action
*
*
N/A
N/A
Notes:N/A- Not applicable* Appropriate category
2-7 AR30I380
Alternative No. 4 does not meet this category for future potential conditions because of the inabilityof the carbon treatment to reduce vinyl chloride levels from the design concentrations of 26 yg/l tobelow the PMCL of 1 yg/l.
Category III, "Exceeds Standards," is not applicable for any of the remedial alternatives. Thiscategory might be applied for individual well treatment units (Alternative No. 4) that would becapable of removing the design groundwater contaminants to levels at or below detection limits.However, treatment processes to achieve these discharge levels are considered economicallyimpractical and physically inappropriate for residential home use.
Category IV, "CERCLA Goals," is applicable for Alternative No. 4- Individual Well Treatment. Thiscategory is considered appropriate because of the potential future presence of vinyl chloride, andother organics, in the private wells, The activated carbon units identified for home well treatmentwill remove all of the organic compounds in the design groundwater (monitoring well N-8) exceptvinyl chloride. Other, yet to be identified compounds might also be present in well water in thefuture, depending on the source of contamination and the characteristics of groundwatermigration. The carbon units might not sufficiently remove some compounds from a futurecontaminated aquifer. Further, the design compounds at future higher levels might also reduce thetreatment efficiency.
These limitations on carbon treatment necessitate an ongoing groundwater monitoring program toprovide an early warning for the presence of untreatable HSL compounds. The detection of thesecompounds during monitoring will trigger further remedial action to protect the public health.
Alternative No. 2 - No Action with Monitoring, is also expected to fit into Category IV because of theproposed groundwater monitoring plan.
Category V - "No Action," is met by Alternative No. 1, which is the designated no-action alternative,as required by EPA.
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rrriiiiiriifi
3.0 REMEDIAL ALTERNATIVES DESCRIPTION
This section describes in detail the remedial alternatives developed in Section 2.0.
3.1 Alternative 1 • No Action
In accordance with EPA guidance, a no-action alternative is to be evaluated. Under the no-actionalternative, no technologies would be implemented and no action would be taken to remediate theprivate wells. Present site conditions and potential health and environmental risks will continue, andpossibly deteriorate in the future.
3.2 Alternative 2 -No Action with Monitoring
Under this alternative, no remedial technologies would be implemented and no action would betaken at this time to remediate the private wells. Associated with this alternative is theestablishment of a long-term monitoring program to monitor the groundwater and private wellsand to assess the risks to public health conditions present at the site. The monitoring program wouldinclude the followingactivities:
• Annual monitoring of 16 residential wells on a quarterly rotating basis.• Construction of four monitoring wells (two per cluster, see Figure 3-1).• Quarterly monitoring of six monitoring wells for HSL volatile organics and the following
parameters: pH, BOD, COD, anions, cations, ammonia, and total dissolved solids.
The results of the monitoring program will be evaluated by a designated agency to track furthermigration of contamination, to identify level of risk to the public health, and to identify a point atwhich remedial action will be required. This program should be followed for at least 30 years to bein accordance with the EPA guidance document.
3.3 Alternative 3 • Tap-In to Public Water System
The construction of new service lines to the existing public water system is a feasible alternative thatis based on common engineering and construction practices. The Easton Suburban Water Authorityhas stated that curb service is currently available to all the homes located in Lucy's Crossing and
3-1 AR30I383
A'R'30 13814
Glendon. These are the communities of concern, based on the current risk and potential for futurerisk from groundwater contamination. The only additions required to the existing system would bethe installation of service lines from the street mains to the residential buildings. The capital cost pertap-in (see Appendix A) includes furnishing and installing a curb box, valve, 50 lineal feet of1-1/2 inch diameter copper pipe, and providing trenching and backfilling activities. Based on watercompany records and surveys conducted in Glendon and Lucy's Crossing, there are at least15 residences not connected to the public water system. Some additional residences are serviced byboth private wells and the public water system. It is recommended that the subject private wells inuse be verified for number, location, and usage prior to designing the remedial action. Also, in theevent some residents use both wells and public water, the well system must be kept separate of thepublic water system to prevent possible cross-contamination. For the locaiton of the dwellings noton the public water system, see Figure 3-2.
3.4 Alternative 4 • Individual Well Treatment Systems and Monitoring
Under this alternative, an individual treatment unit would be installed in each home using privatewells in the communities of Glendon and Lucy's Crossing (Figure 3-2). This alternative involves theinstallation of a granular activated carbon (GAC) treatment unit consisting of a galvanized steel tankfilled with GAC and a fiberglass tank for the temporary storage of backwash. As with any treatmentsystem, the GAC design should be developed on the adequate characterization of the influent andpilot testing. The following described system is subject to modification upon the development ofmore data.
A 7-cubic-foot carbon capacity pressure unit is proposed to provide for the necessary contact timeand the anticipated carbon use rate. The unit would be fed by the existing well pump and wouldfeature an automatic-timer-operated backwash cycle to remove solids that accumulate. A tank forbackwash water storage is required to control discharge to residential septic disposal systems.
In order to provide proper operation and maintenance of the units, a contractor service is required.Yearly replacement of the carbon is anticipated, with the vendor hauling the spent carbon to acarbon regeneration facility. In addition, quarterly testing of the effluent is necessary to verify thatthe system is operating properly.
Also, since contaminant concentrations may increase and new contaminants occur that cannot beeffectively treated by the GAC treatment, it is necessary to monitor the groundwater for significantchanges in quality.
3-3 AR301385
LEGEND_ RESIDENTS WITH WELLS NOT CONNECTE" TO THE EXISTING WATER SUPPLY
///C— RESIDENT WITH CISTERN ONLY
'' ' > Itp_ RESIDENTS WITH BOfH WELLS
PUBLIC WATER /"
GLENDONBOROUGH
\FIGURE 3-2
LOCATION OF GLENDON AND LUCY'S CROSSING RESIDENTSNOT CONNECTED TO THE EXISTING PUBLIC WATER SYSTEM __ __INDUSTRIAL LANE STUDY AREA,NORTHAMPTON CO.. PA —L—i COFFORATION
A-R30 I 38^SALE: ' = 400' 3-4 -OA HaWto on Company
Under this alternative, the following monitoring activities would occur:
• Quarterly monitoring of each GAC effluent (16 total) and analysis for HSL volatile organics.
• Annual monitoring of 16 residential wells prior to treatment units (sampling to beconducted on a quarterly rotating basis). Samples would be analyzed for HSL volatileorganics and the following parameters: pH, BOD, COD, anions, cations, ammonia, andtotal dissolved solids.
• Construction of four monitoring wells (two per cluster, see Figure 3-1).
• Quarterly monitoring of six monitoring wells for the HSL volatile organics and the sameparameters as indicated for the above residential wells.
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4.0 DETAILED EVALUATION OF REMEDIAL ACTION ALTERNATIVES
4.1 Alternatives Evaluation Method
The four remedial action alternatives identified in Section 3 have been evaluated in detail using thefollowing criteria:
• Technical Aspects• Public Health and Environmental Concerns• Institutional Issues• Cost
These criteria are described individually in the following subsections.
4.1.1 Technical Aspects
Performance, reliability, implementability, and safety of each alternative are considered under thetechnical evaluation section.
Performance is based on
• Effectiveness - The ability of the remedial action alternative to perform intended function,as determined through design specifications or by performance evaluation, will beincluded in the effectiveness evaluation.
• Useful Life - The projected service of life of a remedial action alternative's componenttechnologies, the resource availability in the future life, the deterioration of a technology,and resultant changes in effectiveness will be included in the useful life evaluation.
4-1 6R301389
Reliability is based on
• Operation and Maintenance (O&M) Requirements - Technology components of remedialaction alternatives will be assessed for frequent or complex O&M requirements and theassociated costs.
• Demonstrated Performance - Technology components of a remedial action alternative willbe assessed by qualitative and/or quantitative terms for probability of failure. A benchtest study will be recommended for innovative technologies without a proven data base.
Implementability, the relative ease of installation and time required to achieve a given level ofresponse, is based on
• Constructability - The ability to actually build, construct, or implement the remedial actionalternative will be assessed along with site conditions and external factors that influencethe assessment.
• Time - The time required to implement or construct the remedial action alternative andthe time required to aichieve beneficial results will be assessed in quantitative andqualitative terms, respectively.
The safety evaluation includes the assessment of long-term and short-term threats to the safety ofnearby communities, local environs, and site workers.
4.1.2 Public Health Concerns
Each alternative was evaluated for its degree of public health protection. The public healthevaluation focuses on the capabilities of each remedial alternative to eliminate the unacceptablehealth risks associated with the site contaminant exposure pathways. These pathways andcorresponding health risks have been described in Section 1.0. The adverse effects of construction-related activities on the public are considered as well as the likely public reaction to the alternative.
4"2 AR30I390
4.1.3 Institutional Issues
Institutional issues refer to regulations that establish practice or performance standards applicableto the remediation of the site. These regulations might be Federal, state, or local.
These regulations have been described in Section 1.3 and are not repeated here.
4.1.4 Cost Criteria
The remedial action alternatives have been analyzed to estimate their respective costs forimplementation.
The development of cost analysis involves the following:
• Capital Cost Estimation• Operation and Maintenance (O&M) Cost Estimation• Present-Worth Analyses
Cost Estimates
Capital Costs are those expenditures that are initially incurred to develop and incorporate aremedial action. Capital costs consist of direct and indirect costs.
Direct Costs are those necessary for installation of the remedial action, i .e., construction, labor,equipment, materials, and service costs.
Indirect Costs include expenditures for licenses, permit fees, and contingency allowances.
O&M Costs are those required to operate and maintain the remedial action throughout its lifetime.
The method for estimating, considered unit costs and construction quantity estimates. Unit costswere assigned to the work quantities considering the materials required, the types of equipment tobe employed, and the construction difficulty expected. Labor and equipment costs are adjusted toreflect construction difficulty and diminished productivity associated with higher levels of health andsafety protection required for hazardous work items.
4-3 A R 3 0 I 3 9 I
Cost Analyses
Present-Worth Analyses discount expenditures that occur over different time periods to the presentyear. A 30-year project life, 10 percont discount rate, and zero inflation are used in the analyses.
Section 4.6 summarizes the capital costs, O&M costs, and present-worth costs for all applicableremedial action alternatives for the Industrial Lane Site.
4.2 Remedial Action Alternative IMo. 1 • No Action
This alternative will not require any implementation of remedial activities after the Rl/FS. Since nosite activities are proposed under this alternative, technical and cost evaluations will not beperformed.
4.2.1 Public Health Concerns
Under the no-action alternative, human health impacts under present site conditions are adequatelyrepresented by the carcinogenic risk estimates presented in the Endangerment Assessment for theIndustrial Lane Site (NUS/FIT, 1986a).
Contrast of the appropriate human health guidelines presented in Table 1-2 with the maximumconcentrations detected in residential well samples (drawing No. S797-11-01, in the back pocket)indicates that present domestic well concentrations do not exceed the Proposed MaximumContaminant Levels (PMCLs), Suggested No Adverse Response Levels (SNARLs), or Acceptable DailyIntakes (ADIs). Hence, under present conditions, no adverse noncarcinogenic impacts are associatedwith the no-action alternative. However, the criteria established for carcinogenic effects [i.e., theRecommended Maximum Contaminant Levels (RMCLs) and Ambient Water Quality Criteria (AWQC)]are presently exceeded in the domestic wells.
Incremental cancer risks to residents; using groundwater for drinking and showering are estimated as1 x 10-6(1 in 1,000,000) and 2 x 10-5 (1 in 50,000) for persons living in Glendon Boro and Lucy'sCrossing, respectively, under present site conditions. Although in the range of acceptable risks, theLucy's Crossing area exceeds the 10-6 target range, but the Glendon Borough area meets the targetlevel. Hence, under present site conditions, the no-action alternative satisfies all specified humanhealth objectives and guidelines. Under long-term, worst-probable-case conditions, it is projectedthat residential well concentrations may reach the concentrations currently found in well N-8,
4-4 AR30I392
located just downgradient of the Chrin Landfill. Under these conditions, PMCLs would be exceededfor trichloroethene, vinyl chloride, and benzene. ADIs would be exceeded for toluene, xylenes, and1,1,1-trichloroethane. Thus it is apparent that noncarcinogenic health effects would be incurredunder the projected worst-case conditions. In addition, estimated carcinogenic risks may attain7x10-3 (1 in 140), should domestic well concentrations reach the levels detected in NUS monitoringwell 8.
In conclusion, under present site conditions, carcinogenic human health impacts are possible. Overthe long term, both noncarcinogenic and carcinogenic human health impacts may occur under theno-action alternative.
The available data base does not permit a quantitative assessment of groundwater flow andcontaminant migration because of the complex geology in the area. Further, the many contaminant
sources have not been fully characterized. Thus, predictions of future risks to groundwater userscannot be quantified. Nevertheless, the available data is sufficient to indicate that residents ofLucy's Crossing and Glendon are at a potential increased risk from ingestion of groundwater (see
Sections 1.2 and 1.4).
The existing 30-acre Chrin Landfill is proposed for closure in the near future, at which time a new13-acre expansion area is expected to be in operation. The expansion area, if permitted by PADER,will be fully lined with a leachate collection system.
The existing 30-acre landfill will be closed using a 2-foot-thick soil cap. Available information fromthe closure plan (AGES, 1983 and AGES, 1986) recently approved by PADER, indicates that local soilwill serve as the final cap. Preliminary calculations performed by NUS using the EPA HELP Modelestimate that 21.9 inches per year of rainfall percolation will penetrate the cap. Since the existinglandfill is not lined and the leachate collection is not efficient, leachate will continue to migrate tothe groundwater.
The volume, chemical characteristics, and effect of this leachate on local groundwater quality hasnot bee predicted. However, monitoring wells at the periphery of the landfill are being sampledroutinely. The assessment of future potential risks to private well users, based on monitoring wellN-8 chemical analyses, is expected to be a conservative approach that is reasonable, based on siteconditions. Further site investigations will provide data to estimate future risks with a much higherdegree of confidence.
4-5 AR30I393
It is not anticipated that contaminated groundwater discharge will result in any measurable impacton surface water bodies in the area. This conclusion is based in part on available analytical results forsurface water samples (i.e., no orgcinic contamination has been identified in the Lehigh River, eventhough the contaminant "plume" below Ashland Chemical discharges to this stream) and onengineering judgment as guided by previous experience.
4.3 Remedial Action Alternative IMo. 2 • No Action with Long-Term Monitoring
This alternative is the same as remedial action alternative No. 1; however, existing and new samplinglocations will be used to monitor the levels of contamination in the groundwater. Monitoringincludes sampling, laboratory testing, and evaluation of the data by a designated agency to monitorthe risk to health and the environment.
4.3.1 Technical Evaluation
Other than the construction of four new monitoring wells (clustered if conditions warrant), thisalternative does not include construction activities to remediate contamination. It will provide forthe evaluation of the future contaminant migration from the sources to the groundwater. Themonitoring program"is used to determine whether contamination decreases to acceptable levelsthrough natural flushing processes, or to determine whether contaminant levels are increasing andfurther actions are necessary to remediate the situation. A monitoring period of 30 years isproposed, since a relatively long time would be required to determine if groundwater quality hasreached steady-state conditions. A no-action with monitoring alternative is technically feasible toimplement The existing monitoring wells may function for a 30-year period if properly operatedand maintained.
4.3.2 Public Health Concerns
Projected human health impacts under both present and long-term conditions under the no-actionwith monitoring alternative are essentially the same as those discussed under no action alone.
The primary difference in this alternative is that early warning of degrading groundwater conditionswould be afforded.
AR30I39/4
4.3.3 Institutional Issues
This alternative requires the construction of four new wells (two clusters of two wells each) andimplementation of a monitoring program. The institutional restraints to implementation of thisalternative are minimal. This alternative does not address a resolution of the problem, nor does itaddress remediation of the groundwater.
Under this alternative, Right of Entry Agreements would be required between EPA and the privateproperty owners for any of the following puposes:
• To construct groundwater monitoring wells• To sample groundwater monitoring wells• To sample residential wells
4.4 Remedial Action Alternative No. 3 • Tap-In To Public Water System
This alternative involves the installation of water service lines from the Easton Suburban WaterAuthority's existing street water supply mains to residential buildings located in the communities ofGlendon and Lucy's Crossing (Figure 3-2). The intent of this alternative is to eliminate the presentand future health risks associated with potable and nonpotable use of contaminated groundwater.
4.4.1 Technical Evaluation
The technologies used to provide water to a dwelling are well-established, common, engineeringand construction practices. Public water systems are very reliable and require only minimalmaintenance.
This alternative could be implemented relatively quickly to mitigate health risks under both presentand future conditions. The estimated construction time for installation of additional water servicelines in the communities of Glendon and Lucy's Crossing is approximately 1 month.
4-7 A R 3 U i 3 3 5
4.4.2 Public Health Concerns
Implementation of this alternative would eliminate the health risks associated with exposure tocontaminated groundwater. By eliminating the potential for ingestion, inhalation, and directcontact, the public health would be adequately protected.
Those residents within Glendon and Lucy's Crossing who elect to continue to use their private wellsfor nonpotable and non-showerincj purposes are not expected to incur any risk. Nonpotable wateruses, such as car washing and watering of vegetable gardens, may have associated exposurepathways, but these are deemed insignificant.
The potential for dermal uptake during direct contact has been shown to be minimal (NUS, 1986b).Volatile chemicals may be also released to the ambient air, although rapid dispersion will reduce theconcentrations almost immediately. Uptake of volatile organics by vegetables, and subsequentexposure through ingestion, is not considered a possible exposure pathway. Furthermore, any non-potable water use is expected to be intermittent, and of only short duration.
This alternative has no readily apparent occupational or public health risks associated withimplementation. The low probability of construction-type accidents associated with "heavyequipment operation and materials handling are not a major consideration. Occupational exposureduring construction is not anticipated but could be readily controlled using conventional health andsafety techniques. Environmental receptors should not be affected by short-term excavation andinstallation activities.
Long term monitoring of the groundwater is desirable and will be addressed in the forthcoming FFS,Operable Unit 2.
4.4.3 Institutional Issues
The alternative water supply can be provided by the local water company once the installation of theindividual service lines is complete1. This connection to the public water system should satisfy theNational Interim Primary Drinking Water Standards.
If this alternative is implemented, it is desirable to seal the existing domestic wells in thecommunities of concern. This could be implemented on an individual voluntary basis. The capitalcost for sealing (including all construction and engineering mark-ups) is estimated at $500 per well.
4-8AR301396
This is based on backfilling a 4inch diameter, 100 foot deep well with a cement grout. This cost isnot included in the cost of alternative No. 3 as shown in Table 4-1, since it is subject to the discretionof each affected resident.
An institutional issue of concern is the groundwater control required for future residentialdevelopment in the site area. A potential requirement is restriction both of groundwater use tofuture developments and of future well construction at existing residences. Institutional useconsiderations at various governing levels are discussed in the following section.
Commonwealth of Pennsylvania
Groundwater allocation and management in Pennsylvania is governed by common law. Under the"reasonable use" common law doctrine, the right to use groundwater is founded on landownership. The right to use groundwater beneath overlying lands is limited to the extent necessaryfor a useful, beneficial, and lawful purpose.
The "state" can effectively control and prevent the use of polluted groundwater by public watersystems. The state also has authority to control access to polluted groundwater on an existing orabandoned hazardous waste site. However, there is no statutory or common law that explicitlyauthorizes state or local entities to prevent development or require closure of private wells.
The state does not have existing laws that would authorize an agency to take property by eminentdomain, or to purchase property for the purpose of preventing human exposure to contaminatedgroundwater.
Deed restrictions may be a feasible means to prevent human exposure to contaminatedgroundwater. It is probable that a deed restriction which is designed to transfer a property interestto the state or local government entity could be theoretically enforceable by the state or localgovernment against the original party to the agreement or its successor in interest. UnderPennsylvania Solid Waste Management Act 97, Section 4.05, the grantor in ever deed for theconveyance of property, on which hazardous waste is being disposed, or has every been disposed bythe grantor, or to the grantor's actual knowledge, shall include in the property description of thedeed an acknowledgement of such hazardous waste disposal.
4-9 AR301397
Delaware River Basin Commission (DRBC)
The DRBC regulates both water quality and water quantity issues for projects that have a substantialeffect on the resource of the basin. However, there is no existing authority to prohibit or regulatethe individual withdrawal of polluted water for domestic purposes.
Local Regulatory Authority
In Pennsylvania, the Borough Code specifically authorizes municipal regulation of water wells andgroundwater use, and all local governments have the power to adopt ordinances and regulationsdeemed necessary for the peace, health, safety and welfare of the municipality.
Zoning Regulations
The Pennsylvania Municipal Planning Act specifies a number of purposes for which zoningregulations may be employed, suggesting that a zoning ordinance which restricts access to apolluted aquifer is probably authorized by law. However, no municipal entity within Pennsylvaniahas adopted such a zoning ordinance to date.
4.5 Remedial Action Alternative No. 4 • Individual Well Treatment Systems
This alternative involves the installation of a granular activated carbon (GAC) treatment unit in eachhome using private wells in the communities of Glendon and Lucy's Crossing (Figure 3-2). The intentof this alternative is to eliminate the present and future health risks associated with the potable andnonpotable use of contaminated ciroundwater.
4.5.1 Technical Evaluation
Generally GAC can remove a broad range of organics from drinking water. However, itseffectiveness depends on the specific chemicals present, their concentration, and the requireddegree of removal. With the existing groundwater characterization information for the IndustrialLane Site, it is not possible to project future contaminant levels in the residential wells. The worst-case contaminant levels found at the site to date from well N-8 provide an indication of possiblecontaminants and concentrations. GAC treatment is not a feasible technology for treating vinylchloride (present at well N-8). Thus, if vinyl chloride contamination occurs in the residential wells,
4-10AR30I398
GAC treatment would not be applicable. Removal of vinyl chloride by air stripping is usuallyeffective; however, this technology is not feasible for home units.
Pilot testing would be required for the design of the treatment system.
In order to provide proper operation and maintenance of the units, a contractor service would berequired. Yearly replacement of the carbon is anticipated, with the vendor hauling the spent carbonto a carbon regeneration facility. In addition, quarterly testing of the effluent would be necessary.
This alternative could be implemented relatively quickly. The estimated construction time for pilottesting and installation of GAC units in the 16 homes located in Glendon and Lucy's Crossing isapproximately 2 months.
4.5.2 Public Health Concerns
This alternative has no apparent occupational or public health risks associated with implementation.
Implementation of this alternative would reduce the health risks associated with exposure tocontaminated groundwater but would not eliminate all risks, since future contaminants mayincrease in concentration or new contaminants may occur that can not be effectively treated by GACunits (such as vinyl chloride). Vinyl chloride is the most potent of the carcinogens detected in themonitoring well samples (based on the carcinogenic potency factor). Although GAC units generallyhave a removal efficiency of between 60-90 percent for most organic chemicals, it is apparent thatthese treatment systems will be ineffective in mitigating long-term human exposure throughgroundwater use, should nonremovable contaminants arrive at the receptors wells. Thus,monitoring of both groundwater and effluent is required to indicate the presence or absence ofcontaminants, (i.e., vinyl chloride) toward residential wells.
4.5.3 Institutional Issues
The installation of individual treatment units in the homes using private wells in the communities ofGlendon and Lucy's Crossing should satisfy the applicable drinking water standards. Institutionalissues related to future controls on groundwater use have been described in Section 4.4.3 and arealso applicable to the installation of individual treatment systems.
4-11
Under this alternative, Right of Entry Agreements would be required between EPA and the privateproperty owners for any of the following purposes:
• To construct and/or sample groundwater monitoring wells• To sample residential wells• To install home GAC treatment systems• To sample GAC effluent and provide maintenance of units
4.6 Cost Evaluation Summary
This section outlines the applicable capital costs, O&M costs, and present-worth costs for allapplicable remedial action alternatives. A summary of these costs is shown in Table 4-1. Appendix Apresents additional detailed information regarding the development of these costs. Detailed capitaland O&M costing sheets, when applicable, are incorporated for each alternative.
4.6.1 Remedial Action Alternative No. 1 - No Action
Since no site activities are proposed under this alternative, no cost evaluations are necessary.
4.6.2 Remedial Action Alternative No. 2 • No Action with Monitoring
The capital, O&M, and present worth costs for this alternative are provided in Table 4-1. A capitalcost of $63,700 is estimated for the construction of four monitoring wells. An O&M cost of$44,160 per year is estimated for sampling and analysis of the collected water samples. A present-worth cost is estimated at $480,000 for the construction of the new monitoring wells and for the 30-year monitoring program.
4.6.3 Remedial Action Alternative No. 3 • Tap-In to Public Water System
Only capital costs are involved with this alternative. It will take approximately 1 month to connectthe homes currently using well water to the public water system. No long-term costs are involvedwith this alternative (sampling, etc.), so there is no operation and maintenance cost. The present-worth cost for the construct!on of service lines to the existing water system is $30,800.
4-12 AR30UOO
TABLE 4-1
REMEDIAL ACTION ALTERNATIVES COST SUMMARYINDUSTRIAL LANE SITE
(COSTS ARE IN 1986 DOLLARS)
Remedial Action Alternative
1. No Action
2. No Action with Monitoring3. Tap-In to Public Water System
4. Individual Well Treatment Systemswith Monitoring
Capital Cost
NA
$63,700
$30,800*
$134,600
O&M Cost(per year)
NA
$44,160
NA
$91,920
Present-Worth
NA
$480,000
$30,800*
$1,001,000
NA- Denotes Not Applicable*Cost is approximate based on estimate of number of homes using private wells withoutpublic water supply.
4-13
4.6.4 Remedial Action Alternative No. 4 - Individual Well Treatment Systems with Monitoring
Table 4-1 outlines the capital, O&M, and present-worth costs for this alternative. The capital cost is$134,600, which includes construction of four monitoring wells and installation of 16 hometreatment systems. The O&M cost is $91,920 per year, of which $44,160 is designated for monitoringgroundwater and $47,760 for monitoring and maintaining the treatment systems. The present-worth cost for 30 years is $1,001,000.
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REFERENCES
AGES, January 1,1983. Drawing No. 43881-D-026, "Chrin Brothers Sanitary Landfill - Final Grading."
AGES, January 1986. "Chrin Brothers Sanitary Landfill - Cover Material Soil Study," ReportNo. 43881-15.
Environmental Law Institute, February 21, 1986. Draft "Preliminary Report: InstitutionalGroundwater Use Controls in Three Selected States." Prepared under EPA Work AssignmentNo. 75M.
NUS/FIT, 1986a. "Final Draft, Endangerment Assessment, Industrial Lane, Northampton County,Pennsylvania." Prepared under EPA Work Assignment No. 78.3R62.3. NUS Corporation.
NUS/FIT, 1986b. "Final Draft, Remedial Investigation, Industrial Lane, Northampton County,Pennsylvania." Prepared Under EPA Work Assignment No. 78.3R62.3. NUS Corporation.
USEPA (United States Environmental Protection Agency), November 28, 1980. 'Water QualityCriteria Documents; Availability." 45 Federal Register. 231, p. 79318etseq.
USEPA, March 4, 1982. "National Revised Primary Drinking Water Regulations, Volatile SyntheticOrganic Chemicals in Drinking Water." 47 Federal Register, 43, p. 9350 et seq.
USEPA, May 1984. Summary of Current Oral Acceptable Daily Intakes (ADIs) for Systemic Toxicants.Environmental Criteria and Assessment Office, Cincinnati, Ohio.
USEPA, January 9, 1985. "Proposed Guidelines for the Health Risk Assessment of ChemicalMixtures." 50 Federal Register, 6, p. 1170 et seg.
USEPA, February 1985. Mutagenicity and Carcinoqenicity Assessment of 1,3-Butadiene.Washington, D.C.
USEPA, May 22, 1985. Superfund Health Assessment Manual. Washington, D.C. (Prepared by ICF,Inc., for USEPA)
R-1 /SR3GU01*
USEPA, June 1985. Guidance on Feasibility Studies under CERCLA. Washington, D.C.
USEPA, September 30, 1985. "Health Advisories." Office of Drinking Water (presently unpublished).
USEPA, November 13, 1985. "National Primary Drinking Water Regulations; Volatile SyntheticOrganic Chemicals; Proposed Rule." 50 Federal Register, 219, p. 46880 et seq.
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APPENDIX A
COST ESTIMATE CALCULATIONS
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AR301409
Sitet INDUSTRIAL LANEMonitoring and Domestic WellsPost Remedial MonitoringAlternatives No.2 & No.4(OSMMDWE)
Annual Costs
ITEM * ANNUAL ** COST * NOTES
******************************************************************,**1. Sampling # 9760.00 * 2 existing monitoring wells and
* * 4 new monitoring wells*(sampled# * quarterly) 16 domestic wells* * (sampled annually)# #40 manhaurs per sampling period* * plus travel» living and sarnie* He shipping costs.
*********MM*********M********M2. Analysis * 31200.00 * 12 samples per sampling period
* * (incl. blank and duplicate)* * Volatile* and select* * parameters.
*********************************************************************3. Reporting * 3200.00 * Quarterly report, 20 manhours
* * per report plus other* * direct costs.* *
******************************************************************.}**# # Post remedial monitoring will* * be performed quarterly for the* # monitoring wells and annually
TOTAL ANNUAL * * for the domestic wells forCOST * 44160.00 * 30 years.
**********************************************************************
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Sitet INDUSTRIAL LANEHome GAC Treatment UnitsPost Remedial MonitoringAlternative No. 4(O&MHOTR)
Annual Costs
ITEM * ANNUAL ** COST * NOTES
1. Sampling # 9760.00 * 16 GAC treatment effluent.* * 40 manhours per sampling period* # plus travel»living and sample* # shipping costs.
*********************************************************************2, Analysis * 25200.00 * 18 samples per quarter
* * (incl.l blank and 1 duplicate)* * Volatile*.* *
*********************************************************************3. Maintenance * 9600.00 * Replacement of carbon and
* * disposal for 16 filters* * per year.* *
**********************************************************************4. Reporting * 3200.00 * Quarterly report, 20 manhours
* * per report plus other* * direct costs.* *
*********************************************************************# * Post remedial monitoring will* * be performed quarterly for
TOTAL ANNUAL * * 30 years.COST * 47760.00 *
**********************************************************************
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APPENDIX B
• RISK ASSESSMENT CALCULATIONS• GRANULAR ACTIVATED CARBON (GAC) TREATMENT CALCULATIONS
AR30U17
NUS CORPORATION AND SUBSIDIARIES SJANDARD CALCULAT<^rOrTCC /
CLIENT USEPA Iff Bv R JH PAGE j Of
SUBJECT..CARClKO<aEH(C RISK -
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NUS CORPORATION AND SUBSIDIARIES_____ STANDARD CALCULATION
CUENt USEPA TIL F.LENO, 9f
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PAGE 2, OF g
DATE?-»0'8fc
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NUS CORPORATION AND SUBSIDIARIES STANDARD CALCULATION^
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DATE7-10-86
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DATE7-7-86
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