™ Superfund ProgramProposed PlanSaegertown Industrial Area SiteSaegertown, Crawford County, PA October 1992

EPA ANNOUNCES PROPOSED PLAN

The U.S. Environmental Protection Agency ("EPA") is issuing this ^D^tes to rememberProposed Remedial Action Plan ("Proposed Plan") to present EPA's : •'•• •••.'Preferred Remedial Alternative for cleaning up contamination at the October 19 -Saegertown Industrial Area Site ("Site") located in Saegertown, Crawford November 26 1992County, Pennsylvania. This Proposed Plan summarizes information public* commentobtained from the recently completed Remedial Investigation and oeribd on alternatives;Feasibility Study ("RI/FS"), and the technologies being considered for iiv Proposed Ptarithe cleanup of the Saegertown Industrial Area Site. The EPA is ••'::': \ ;A:y:r' ' :..."-presenting this Proposed Plan to solicit public comment on the Novembers 19 2preferred alternative and the other alternatives for remediation of the : Pubiic meetJna atcontaminants present on the Site. EPA will select a final remedy for the :^? SaeqertowhSite only after the public comment period has ended and the comments :; jun r/sinibp Hiqhreceived during the comment period have been reviewed and School Mbok Roadconsidered. The final remedy will be outlined in the Record of Decision Saeqertown PA '••'•("ROD") for the Site. Based on new information and/or comments at 7*00 PM 'received, the remedy selected in the ROD may be different from the mfmmmmmmmmmmmmmmpreferred alternative.

The Proposed Plan is being issued as part of EPA's public participation requirements under Section117 of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, asamended ("CERCLA"). The public's comments will be incorporated in the Responsiveness Summarycontained in the ROD for the Site. This document summarizes information that can be found ingreater detail in the RI/FS report and other documents contained in the Administrative Record file for

the Site. EPA encourages the public to review these•• ••••• • •••i iMBMM documents in order to gain a more comprehensive

:•: f understanding of the Site'and the Superfund activitiesthat have been conducted there. The locations of the

SITE BACKGRpyNtjrANDiHiSTORY.,... ....... ..2 Administrative Record file for the Site and the address toSCOPE AND ROLEiOF RESPONSE ACTIQN..S send comments on this Plan are given at the back ofSUMMARY OF srrE.RiSK.,....,...,......................6 the Proposed Plan. The Proposed Plan also contains aSUMMARY Of REMEDIAL ALTERNATIVES, ij glossary of terms that may be unfamiliar to the general «

IZZZZTis public. The terms in bold print in the text are availableZZI Z t7 ; i : in tne glossary in the back of the Proposed Plan.

COMPARATIVE ANALYSI;;...«,,,,,,.«..,...,..;,1 8 ;

Lord Grpundwater................ ............ 20 •:.,•COMMUNITY ROLE...........,...............«....;........22 :

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Potvaromatic Hydrocarbons (PAHsi • PAHs component of the Remedial Investigationconsist of carbon compounds arranged in a Report. This portion of the Rl evaluates theringed structure that are moderately persistent carcinogenic and non-carcinogenic risksin the environment PAHs are present in soot presented by the contaminants at the site.and by-products of combustion. Benzo (a) Risk is calculated both for current uses andpyrene is a PAH compounds that is considered potential future uses of the property by acarcinogenic. defined population i.e. on and offsite residents,

trespassers, etc.PCBs fPotvchkxinated Biphenvte) - PCBs are agroup of toxic and persistent organic .. Saturated Zone • A subsurface area, below thechemicals used in electrical transformers, water table, in which all pores and cracks arecapacitors, and as a heat exchange fluid. filled with groundwater under pressure equal toFurther sale of PCBs for new use was banned or greater than that of the atmosphere.in 1979. PCBs are probable humancarcinogens. Scientific Notation - In dealing with particularly

large or small numbers, scientists andPlume - The three dimensional area of . engineers have developed a "short hand*

. contamination in a particular media, such as means of expressing numerical values. Forgroundwater. A plume can expand due to example, 1,000,000 can be written as 1 x 10*groundwater movement. and 1/1,000,000 can be written as 1 x 10*°.

ppb - Parts per Billion. Five parts per billion is Soiloas - The gas present in the small spacesa fractional representation of 5 parts in 1 billion between individual soil particles (sand, clay,parts. For solids, ppb is a fraction based on etc.). These gases can move through andweight, for example 5 pounds of a contaminant leave the soil or rock.in a billion pounds (500,000 tons) of soil. Forliquids ppb is based on volume, for example 5 SUPERFUND (Comprehensive Environmentaltablespoons of a contaminant in a billion Response Compensation and Liability Act - Atablespoons (3,906,250 gallons) of water. federal law passed in 1980 and modified in

1986 by the Superfund Amendments andppm - Parts per million. Five ppm is a Reauthorization Act The Act created a Trustfractional representation of 5 parts in 1 million. Fund, known as Superfund, which is available

to EPA to investigate and clean up abandonedRCRA (Resource Conservation and Recovery or uncontrolled hazardous waste sites.Act) - A statute under which EPA regulates themanagement of hazardous waste. Unsaturated zone - The area above the water

table where the soil pores are not fullyRecord of Decision (ROD) - A legal document saturated, although some water may bethat describes the remedial actions selected for presenta Superfund site, why certain remedial actionswere chosen as opposed to others, how much UV/Oxkiation - A treatment technology forthey will cost, and how the public responded. groundwater that uses a combination of UV

radiation, ozone and hydrogen peroxide toRemedial Investigation and Feasibility Study oxidize organic compounds.(RI/FS) - A report composed of two scientificstudies, the Rl and the FS. The Rl is the study Volatile Organic Compounds (VOCs) -to determine the nature and extent of Chemical compounds containing carbon thatcontaminants present at a Site and the readily volatilize or evaporate when exposed toproblems caused by their release. The FS is the air. These compounds can be used asconducted to develop and evaluate options for solvents by industry. Chlorinated ethenes arethe cleanup of a Site. a class of VOCs that contain chlorine such as

Trichloroethene (TCE), and TetrachloroetheneRisk Assessment (RA1 - The RA is an essential (PCE).

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II. SITE BACKGROUND removed and the GATX facility was closed. In1970 GATX sold the property to the Meadville

The Saegertown Industrial Area Site Area Industrial Commission. The former GATXencompasses several properties on an property in Saegertown is currently owned byapproximately 100 acre industrial park in the David J. and Judith S. Froess; the Borough ofBorough of Saegertown, Crawford County, Saegertown; Haemer Tool and Die, Inc.; Tru -Pennsylvania (see Figures 1 and 2). Weld Corporation; C.J. Ferry; and Multi-Current and former operations at the Site have Plastics, Inc.led to the release of hazardous substancesinto the environment. Groundwater, soil and . Lord Properlysoil gas samples were obtained during the Rlfrom the four industrial properties that Since 1962, Lord Corporation has producedcomprise the Site. Below is a summary of the adhesives, urethane coatings and rubberareas of concern identified and evaluated: chemicals on a portion of the Site. Lord uses

solvents including trichloroethylene ("TCE"),- Sludge and Soil Areas at the former General trichloroethane (TCEA1), xylene, and methylAmerican Transportation Corporation ("GATX") isobutyl ketone ("MIBK") in its manufacturingProperty. processes. From 1968 until approximately

1987 Lord discharged a mixture of surface- Groundwater Contamination at the Lord water runoff, roof runoff, non-contact coolingCorporation ("Lord"). water, spills and floor washings to a lagoon on

its property. In 1983 Lord submitted a National- Contaminated Sediment at the Saegertown Pollutant Discharge Elimination SystemManufacturing Corporation ("SMC"). ("NPDES") application to the Pennsylvania

Department of Environmental Resources- Contaminated Soil at Spectrum Control, Inc. ("PADER") for the discharge to the lagoon. In("SCI"). 1987 LORD stopped discharging to the lagoon

and directed the flow to the SaegertownA. Site Ownership and Use Borough Publicly Owned Treatment Works

("POTW").The following is a summary of the use of theproperties which comprise the Site and their SMC Propertyrespective former and current ownership.

In 1965, SMC started cold metal forming andFormer GATX Property metal cutting/machining operations on the Site.

SMC uses a variety of oils for cooling, cuttingFrom approximately 1951 until 1967, GATX and lubricating metal on the Site. SMC alsooperated a facility for the cleaning, painting used solvents for degreasing onsite. Cuttingand repairing of railroad tank cars on a portion oil mixed with metal chips is collected andof the Site property. Puring its active use stored in a pit onsite prior to offsite disposal.approximately 2/3 of the 37 acre GATX In February 1979 the waste oil collection pitproperty was covered with rail sidings. GATX was flooded with surface water runoff from aoperated a wastewater treatment plant onsite heavy rain. The rainwater displaced the oiland wash water and solvents used to clean the resulting in a reported release of between 670railroad cars were disposed of in a sludge bed, and 1500 gallons of waste oil. The waste oillagoon, and pond on the Site. Wastes stained a 150 foot by 20 foot area along thecontained in the cars and disposed of by SMC property line, and partially on theGATX reportedly consisted of fuel oils, sludges, adjacent SCI property. In June 1979phenols, caustic soda, unknown solvents and approximately 778 cubic yards of waste/soildegreasers, paint and tar residues, anhydrous was excavated from this area and taken offsiteammonia, benzene, chlorphene, scrap iron for disposal. SMC continues to operate itsbarrels of old paint, and wash water from tank business on this property.car cleaning. In 1967 all the rail sidings were

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Mr. Pat Gaughan and reduce or eliminate infiltration of rain waterCommunity Relation Coordinator or other precipitation into the waste. ThisU.S. Environmental Protection Agency minimizes the movement of contaminants fromRegion III the site through ground water, surface water,303 Methodist Building or leachate.11th and Chapline StreetsWheeling, West Virginia 26003 Carcinogen - A cancer-causing agent.(304) 234-0238

CFR - The Code of Federal Regulations. ForFollowing the conclusion of the thirty (30) day . example, the citation 40 CFR 260 means Titlepublic comment period on this proposed plan, 40 of the Code of Federal Regulations, Parta Responsiveness Summary will be prepared. 260.The Responsiveness Summary will summarizecitizens' comments on EPA's Preferred Groundwater - Water found beneath the earth'sRemedial Alternative and EPA's responses to surface that fills pores between soil, sand, andthese comments. EPA will then prepare a gravel particles to the point of saturation.formal decision document, the Record of Groundwater often flows more slowly thanDecision (ROD), that summarizes the decision surface water. When it occurs in sufficientprocess and the remedy selected for the Site. quantity, groundwater can be used as a waterThis ROD will include the Responsiveness supply.Summary. Copies of the ROD will be madeavailable for public review in the information Incineration - A treatment technology involvingrepository. Once the formal decision destruction of waste by controlled burning atdocument is approved, EPA will invite the high temperatures.parties responsible for contamination at theSite to participate in the implementation of Information Repository - A location whereremedial design and remedial action for the documents and data related to the SuperfundSite. project are placed by EPA to allow the public

access to the material.GLOSSARY

Inorganic Compounds - Chemicals substancesAquifer - An underground geologic formation, of mineral origin that do not contain carbon.or group of formations, containing useable Inorganics include metals such as lead.amounts of groundwater that can supply wellsand springs. National Contingency Plan (NCP) - The Federal

regulation that guides the determination andAdministrative Record - EPA's official manner in which sites will be cleaned up undercompilation of documents, data, reports, and the Superfund program.other information that is considered importantto the status of, and decisions made, relative National Priorities List (NPU - EPA's list of theto a Superfund sftft. The record is placed in nation's top priority hazardous waste sites thatthe information repository to allow public are eligible to receive federal money foraccess to the material response action under Superfund.

Benzo (a) pyrene equivalents - B(a)P Order of magnitude - a range of valueequivalents - compares the relative extending from some value to teq,times thatcarcinogenic potency of various PAH value.compounds to benzo (a) pyrene which isassigned a value of 1. Organic Compounds - Carbon compounds

such as solvents, oils, and pesticides. TCE,Capping - Construction of a protective cover PAHs and PCBs are all organic compounds.over areas containing wastes or contamination. Some organic compounds can cause cancer.Caps prevent surface exposure of the wastes

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i biological combination, refer to the discussionoh Alternative 5 above. The presumed source Detailed information on the material discussedarea, the RG-1 sump, is in close proximity to herein may be found in the Administrativethe manufacturing areas on the Lord property. Record for the Site, which contains the Rl, RA,The Alternatives involving source remediation and FS Reports and other information used by

;_ (4, 5, 6 and 7) all involve placement of wells EPA in the decision-making process. EPA' and piping in and around these production encourages the public to review theareas. Administrative Record in order to gain a more

comprehensive understanding of the Site andCosts. The Lord No Action alternative would Superfund activities that have been conductedhave no capital, O&M or net present worth there. Copies of the Administrative Record arecost. Of the Alternatives containing remedial available for review at the following Information

, action, Lord Alternative 2 - Containment, would Repositories:i have the lowest capital costs and the second

f, lowest net present worth cost. The In-situ Saegertown Industrial Area Site Repository]i Biological Alternative 5 has the lowest net Saegertown Area Library

resent worth. Lord Alternative 6, 320 Broad StreetCombination of pumping and treatment with air Saegertown, PA 16433sparging, steam stripping or biological Attn. Nancy Long

, treatment, the preferred alternative, is the third (814) 763-5203highest capital cost for an action alternativeand is the fourth highest in net present worth. and

VII. COMMUNITY ROLE IN SELECTION U.S. EPAPROCESS Region IIIf 841 Chestnut Building, 6th Floorthis Proposed Plan is being distributed to Philadelphia, PA 19107solicit public comment regarding the proposed Attn. Anna Butch (3HW01)remedial alternatives for cleaning up the Site. (215) 597-3037EPA relies on public input so that the remedyselected for each Superfund site meets the Public Comment Periodneeds and concerns of the local community.To assure that the community's concerns are The public comment period will run frombeing addressed, a public comment period October 21,1992, to November 20, 1992.lasting thirty (30) days will follow this public Written comments, questions and requests fornotice and a public meeting will be held in the information can be sent to:community. It is important to note thatalthough EPA has proposed a Preferred Mr. Steven J. Donohue (3HW24)Alternative, no remedy selection for the Site Remedial Project Managerhas been made. All comments received will be U.S. Environmental Protection Agencyconsidered and addressed by EPA. Region III

841 Chestnut Street8 : Philadelphia, PA 19107: i (215) 597-3166i \ •fc j •: - i Arrangements have been made for a public'h* meeting to be held on Novembers, 1992 at|"i|i 7:00 p.m. at the Saegertown Junior/Seniorvf •:- High School, in Saegertown, PA. Questions?•>;' regarding the public meeting should be|;:!i '••'• directed to:

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Figure 1

SITE LOCATIONand REGIONAL TOPOGRAPHIC MAP

SAEGERTOWN INDUSTRIAL AREA SITE

Source: Meadville, PA, 7.5 Minute USGS Topographic Quadrangle Map1968, Photorevised 1973.

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were to occur breakdown products could be Imptementability. Lord Alternatives 2, 3, and 7formed that are more toxic than the parent are proven technologies that have beencompounds. Alternatives 6 and 7 provide a specified in numerous CERCLA RODs.combination of a proven technology in However, there are several implementabilitypumping and treating with source control for issues associated with the use of Alternative 7the area of the plume with the highest (vapor extraction) at the Saegertown Site. Thecontaminants. mass of the contaminants at the Saegertown

Site is present in the saturated zone and vaporReduction of Toxicity, Mobility, or Volume extraction is not capable of removing ..through Treatment Lord Alternatives 3 contaminants from the saturated zone. Thethrough 7 would significantly reduce the water table in the vicinity of the RG-1 sumpchlorinated ethene mass in the saturated zone would have to be lowered in order toand groundwater at the Site. Lord Alternative implement vapor extraction. The contaminants2 would reduce the contaminant mass to a adsorbed onto the soil in the dewatered arealesser extent than Alternative 3 through 7. outside the vapor extraction area would not beAlternatives 4, 6 and 7 should be more subject to the groundwater flushing action ofeffective at removing contaminants in any the pumping and treatment portion of thisadsorbed or non-aqueous phase. Alternative alternative. Alternative 4 (air sparging) is a5, if a successful biological treatment scheme fairly recent technology but has been shown tocould be developed and implemented, would be effective at removing chlorinated VOCs at areduce the toxicity and mass of contaminants. small number of Sites. If improperly designed,Alternative 7, Combination with In-situ vapor air sparging could cause migration ofextraction, while the most proven in-situ contaminants. The biological degradationtreatment, has implementation problems approach in Alternative 5 has not yet been fullyassociated with the need to lower the water developed or implemented to effectivelytable in the contaminated area. Contaminants degrade TCE and PCE - the primary Sitewill remain on soil particles after the water contaminants in a full scale project.table is lowered. Vapor extraction is used to Incomplete degradation of chlorinated ethenestreat the most highly contaminated source area could result in production of vinyl chloride andand it is not practical to install a vapor other degradation products that are as toxic orextraction system to treat the entire area where more toxic than the parent compoundsthe water table will be lowered. Once the currently present in the aquifer. Both the airwater table is lowered in this area the soil is no sparging and steam stripping portions of Lordlonger subject to the groundwater flushing Alternative 6 would be effective in removing theaction of the pumping and treatment portion of chlorinated ethenes present in the saturatedthis Alternative. zone. Both technologies utilize the same

principles for operation - introducing a gas toShort Term Effectiveness. The risk associated volatilize dissolved contaminants from thewith the current Site use scenario was not aquifer by direct contact or by creatingcalculated during the.FS since there is no turbulence. The effectiveness of both iscurrent use of the contaminated groundwater. dependent on the installation of injection andNo drinking water wells in the area are affected extraction wells in direct contact with theby the groundwater contamination on the Lord contaminants. Both technologies utilize vaporproperty. Remedial construction workers extraction to remove the air/steam containingwould be exposed to contaminated soil during the contaminants. This portion of theany well and pipe installation activities alternative would remove any unsaturated zoneassociated with Lord Alternatives 2 through 7. contaminants. Steam stripping, if used in LordAlternatives 2 and 3 would take approximately Alternative 6, would require the construction30 years to complete remediation. Alternatives and operation of a steam source. There are4 and 5 would take approximately 5 years and many maintenance and operational problemsAlternatives 6 and 7 would take 10 and 14 associated with the production and delivery ofyears respectively to complete remediation. steam over long distances. For a discussion

on the implementability of the Alternative 6 -

SCI Property presence of TCE and TCEA.

In 1974 SCI began manufacturing ceramic EPA began a Site Inspection of thecapacitors and electroplating silver, nickel and Saegertown Industrial Area Site in 1984.tin on the Saegertown Industrial Area Site. Sampling confirmed the presence of TCE andPrior to 1974, a milk plant operated on the SCI TCEA in groundwater onsite. Soil and sludgeproperty. SCI used TCE before 1978, and samples from the GATX pond area revealedTCEA after 1978, to clean the capacitors. SCI the presence of TCE, PCE, polyaromaticutilized acetone, MIBK, toluene, acids, and hydrocarbons ("PAHs*) and 1,4-caustics from 1974 until 1989. Plating . dichlorobenzene.operation on the SCI property werediscontinued in 1989. In April 1990 SCI began On June 16, 1988, the Saegertown Industrialgasket forming operations on the property. Area Site was proposed for listing on the

National Priority List CNPL*) of Superfund Sites.B. Enforcement History Several current and former companies that

occupied the industrial park were identified asIn April 1980, during routine sampling of the potentially responsible for the contamination at

, Borough of Saegertown's municipal wells, the the Site.PADER discovered that Borough Well #2("BW2") was contaminated with TCE at a level In late 1989, four companies signed anof 310 ppb. The Borough removed BW2 from Administrative Order on Consent ("Consentservice, but continued to pump the well in an Order") with EPA (Docket No. III-90-08-DC).attempt to flush the contaminants from the Under the terms of the Consent Order Generalgroundwater. Figure 2 shows the approximate American Transportation Corporation, Lordlocation of BW2 in relation to the Site. The Corporation, Spectrum Control, Incorporated,Borough hired a consultant to investigate the and the Saegertown Manufacturingpotential sources of the contamination. Corporation agreed to conduct a RemedialDeteriorating barrels containing sludge were Investigation/ Feasibility Study for the Site.found in test pits dug in the vicinity of the pond On February 21, 1990, the Site was listed onon the former GATX property. Analysis of a the NPL.sample from one of the deteriorating barrelsshowed the sludge contained 100 ppb TCE. The RI/FS for the Saegertown Industrial AreaThe Borough's consultant concluded that the Site has recently been completed andsludge in the pond and the sludge in the approved by EPA.former treatment area on the GATX propertywere the sources of the contaminants III. SCOPE AND ROLE OF RESPONSE ACTIONimpacting BW2.

The Proposed Remedial Action described inIn 1980 PADER sampled Lord Corporation's this Proposed Plan will comprehensivelydischarge to its non-qontact cooling water address the threats posed by the release oflagoon. Analysis of the samples found they % hazardous substances at the Saegertowncontained trace to low levels of several volatile Industrial Area Site. The principal threatsorganic compounds ("VOCs") including TCE, • posed by the Saegertown Industrial Area Sitetetrachloroethylene ("PCE"), benzene and are the releases of hazardous substances fromxylene. Lord believed the source of these the former GATX pond area and former GATXcontaminants was from the city supplied water lagoon/sludge bed areas. EPA plans to issuethat was used for its cooling water needs and one ROD at the Site that will address thewas not the result of any activity by Lord. source material present on the former GATX

property and the source area and groundwaterIn 1981 samples were taken on the SCI contamination present on the Lord Corporationproperty from a well used by a former milk property.plant that operated on the property. Analysisof the groundwater samples revealed the

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Alternatives 4A and 4B and portions of 3B, Offsite Incineration would have the highestAlternatives 7A and 7B has been specified in capital and net present worth cost. GATXnumerous CERCLA RODs with similar waste. Alternative 6, the preferred alternative, has theThe sludge and soil volumes may be too small third highest capital cost and is the seventhto justify the mobilization and capital expense highest Alternative in net present worth costs.of a slurry-phased biological treatment system.A very large area would be required in order to COMPARATIVE ANALYSIS OFconstruct a landfarm treatment cell due to the ALTERNATIVES - LORD GROUNDWATERvolume of sludge and soil requiring treatment,and the relatively slow biodegradation rates . Overall Protection. Since Lord Alternative 1experienced under landfarm conditions. (No Action) would neither eliminate nor reduceBiological treatment by landfarming would not to acceptable levels the threats to humanbe likely to reach residual concentration of health or the environment presented byPAHs in the low ppb level necessary to reduce contamination at the Site, it will not berisk below acceptable levels using the future discussed in the remainder of this analysis.Site use scenario. Solvent extraction Alternative 2 would not reduce contaminantassociated with Alternative 5 and a portion of volume enough to lower future risk toAlternative 8 has been specified in several acceptable levels. Lord Alternatives 3 throughCERCLA RODs for Sites with similar 7 would reduce the amount of contaminantcontaminants. However, solvent extraction has mass in the groundwater aquifer. Alternativesyet to be demonstrated in a full scale soil 4, 6 and 7 should be more effective than thecleanup. Contaminants have varying solubility pumping and treating alternative alone sincein solvents and the most appropriate solvent or they would better remove contaminants thatsolvents would have to be determined in are adsorbed or in a non-aqueous phase.treatability studies prior to implementing Lord Alternatives 6 and 7 that combine sourcesolvent extraction. A residual of the solvent treatment with aggressive pumping andcan remain in the soil after treatment and may treating of groundwater would be the mostrequire further treatment prior to being effective at removing contaminants.redeposited onsite. Wastewater is produced inthe solvent extraction process and would have Compliance with ARARs. Levels of chlorinatedto be treated and discharged. The cost ethenes in the groundwater are in excess of-.timate for solvent extraction assumes the Safe Drinking Water Act Maximum Contaminantstewater will be disposed of at the Levels (MCLs). The goal of the groundwater

wdegertown POTW. The capital costs for this remedy for the Site is to restore the quality ofalternative would increase significantly if a groundwater to comply with ARARs. The Lorddischarge permit to the Saegertown POTW No Action and Containment Alternatives do notwere denied. There are no implementability satisfy the goal of restoration. Lordissues associated with Alternatives 1, 2 Alternatives 3 through 7 have the potential to'(Capping) or 3A (Offsite Landfilling). meet ARARs.

Costs. Capital costs Include the primary * Long Term Effectiveness and Permanence.equipment needs for an alternative. Lord Alternatives 3 through 7 would likelyOperational and Maintenance (O&M) costs . • reduce risk to acceptable levels under theinclude the costs for utilities and general future use scenario. Alternative 3, although notmaintenance of the equipment. Net present as effective as the in-situ alternatives is aworth is the total cost of the equipment and its proven technology. Alternative 4, has not beenoperation and maintenance cost for a 10 year specified in any CERCLA RODs to date but,period. The GATX No Action Alternative would has been demonstrated to be successful at ahave the lowest capital cost, lowest O&M and small number of sites involving chlorinatedlowest net present worth. Of the Alternatives VOCs and gasoline contaminants. Alternativecontaining remedial action GATX Alternative 2, 5, in-situ treatment of chlorinated ethenes, hasContainment Onsite, would have the lowest yet to be demonstrated for a full scalecapital and net present worth cost. Alternative remediation project. If incomplete degradation

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iv. SUMMARY OF SFTE RISKS September 1990 by the companies that signedthe Consent Order with EPA. The fence was

The Risk Assessment performed during the erected to prevent contact with the sludgeRI/FS identified the former GATX pond area, contaminants. The Risk Assessment madeformer GATX lagoon/sludge bed areas, and certain assumptions in calculating risk on thethe Lord groundwater aquifer contamination on former GATX property, including that athe Site as posing an unacceptable level of hypothetical trespasser would be able torisk. Risk was calculated based on inhalation access the pond area sludge despite theof ambient air and ingestion of soils and presence of the fence. It should be noted thatsludges in the GATX areas, and a combination higher levels of contaminants were found in theof inhalation, ingestion, and dermal absorption subsurface than on the surface. The amountof groundwater from the area. The Risk of contaminants on the surface was used toAssessment ("RA") studies both carcinogenic calculate the risk since this would be mostand non-carcinogenic, current and future risk, available to a trespasser. Although TICs wereat the Site based on the levels of contaminants present in the GATX sludge, they were notfound during the Remedial Investigation. Table included in the risk calculations since there is1 contains a summary of some of the Risk- not enough information available on theScenarios posed by the Site. carcinogenic/non-carcinogenic effects of these

compounds.The National Contingency Plan fNCP*)establishes acceptable levels of carcinogenic Current human exposure pathways torisk for SUPERFUND sites at between one in contaminants on the former GATX property10,000 and one in 1 million additional cancer include volatile air emissions from the pondcases if no cleanup actions are taken at a site. area; dermal contact and incidental ingestionExpressed as a scientific notation, this of contaminated sludges and soils; and dermaltranslates to an acceptable risk range of contact and incidental ingestion of surfacebetween 1 x 10"4 and 1 x 10"8 over a defined water. Exposure to Site contaminants viaperiod of exposure to contaminants at a site. these pathways would pose an unacceptable

health risk to children and adults that wereIn addition to carcinogenic risk, chemical onsite trespassers.contaminants that are ingested, inhaled ordermally absorbed may present a non- The groundwater beneath the former GATXcarcinogenic risk to different organs of the property is not currently used as a potablehuman body. This non-carcinogenic risk or water source. Under a scenario where a futuretoxic effect is expressed as a Hazard Quotient onsite resident would utilize this groundwater("HQ"). A HQ exceeding one is considered an for a potable water supply, its use would notunacceptable non-carcinogenic risk. represent an unacceptable future cancer risk

(6.4 x 10"6) but would present an unacceptableFormer GATX Pond Area and Sludge non-cancer health effect risk. The RiskBed/Lagoon Area . Assessment utilized the highest detected level

of a contaminant found in the groundwater onSampling conducted during the Rl confirmed the former GATX property. Some wells had nothe presence of sludge in the pond and in the detected contaminants and the levels detectedsludge bed/lagoon areas on the former GATX in other wells were not consistently foundproperty onsite. Figure 3 depicts the location every time they were sampled. Based on theof the sludge areas onsite. The sludge is a location and extent of onsite groundwaterblack viscous material that contains hazardous contamination, the Site is not impacting thesubstances, including VOCs, PAHs, and Saegertown municipal or private wells nor istentatively identified compounds (TICs") at such an impact anticipated in the future.levels up to 24% by weight. In addition, PCBsand elevated levels of lead were detected insome soil and sludge samples. A fence waserected around the former GATX pond area in

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19

Long Term Effectiveness and Permanence. As to bacteria used in the biological treatment.stated above, GATX Alternatives 3A, 3B, 3C Research has shown that the larger PAHand 6 would either effectively destroy the compounds are more difficult and take longercontaminants or remove them from the Site. to biologically degrade. Some of these sameThese alternatives would all reduce the level of PAH compounds are considered carcinogenicrisk associated with the current Site use and and would have the most stringent risk basedany possible future Site use. Alternatives 4, 5, cleanup levels. Metals are not subject to7 and 8 would achieve a significant reduction biological degradation processes and wouldin contaminant volume but it is unclear if the remain in the soil and sludge. VOCs presentresidual remaining after biological treatment . in the sludge and soil are likely to volatilizewould be low enough not to present a risk in during the biological treatment processes.the future Site use scenario. Alternative 2 Alternative 5 (and the relevant portion ofwould not achieve a permanent reduction in Alternative 8) would utilize solvent extraction tocontaminant mass and long term effectiveness leach contaminants from the soil and sludge,would be dependent on institutional controls, collect the contaminants and then treat them.such as deed restrictions, and maintaining the Because of the high concentration ofcap's integrity. . contaminants in the sludge at the Site, solvent

extraction would only reduce the materialReduction of Toxicity, Mobility, or Volume requiring offsite disposal by approximatelythrough Treatment GATX Alternatives 3B, 3C 60%. Some residual would remain in the soiland 6 would achieve the highest reduction in and sludge after treatment. Since solventcontaminant toxicity, mobility and volume. extraction has not yet been demonstrated on aThermal treatment of organics (VOCs and full scale, removal efficiencies and level ofPAHs) can destroy over 99.99% of these residual are hard to predict. Metals can becontaminants. Thermal treatment processes removed from the soil in a second soil washingdo not destroy metals. Incinerators equipped process after the solvent has extracted thewith particulate scrubbers are capable of VOCs and PAHs.handling waste with an amount of metalsgreater than what was found in the GATX Short Term Effectiveness. GATX Alternatives 2sludge. The captured metals and those through 8 would all reduce the risk associatedremaining in the ash following thermal with the current Site use scenario, however,treatment could be immobilized, by chemical nearby residents and onsite remedialfixation or incorporation in a matrix, j: "ior to construction workers could be exposed toonsite or offsite disposal. Alternatives 2 and airborne particulate and contaminants that3A (Capping and Offsite Landfilling might volatilize from the sludge and soil duringrespectively) do not reduce the toxicity, excavation and material handling activities.mobility or volume of the contaminants unless Alternatives 2, 3A, 3B...3C and 6 would take ansome treatment is done to the soil and sludge estimated one year to complete. Alternatives 5prior to offsite landfilling. Alternatives 7A, 7B and 8 would take an estimated two years toand 8 could also invqlve thermal treatment of complete. Alternatives 4 is estimated to takethe more heavily contaminated soil and sludge. eight years and Alternative 7 to take four yearsHowever the balance of the soil and sludge to complete.would be treated by a biological treatment orsolvent extraction. Alternatives 4A and 4B Implementability. Thermal treatment,(Biological Treatment) would achieve some associated with GATX Alternatives 3B, 3C, 6reduction in Toxicity and Volume, however little and portions of Alternatives 7A, 7B and 7C, isdata is available to predict the removal a proven technology that has been specified inefficiency attainable and the volume of residual numerous CERCLA RODs. Mobile incineratorscontamination that would remain. Some of the are available to perform the thermal treatmentsludge contains as much as 27% organic outlined in Alternative 6. There is no knowncontaminants. Dilution with clean soil would commercial incinerator in Pennsylvania wherebe required in order to reduce the the soil and sludge can be sent for offsitecontaminants to a level that would not be toxic disposal. Biological treatment associated with

AR3LH927

18

Primary Balancing Criteria COMPARATIVE ANALYSIS OFALTERNATIVES - GATX SOIL/SLUDGE

• Long-Term effectiveness andpermanence: Overall Protection. Since GATX Alternative 1

The ability of the remedy to afford long (No Action) would neither eliminate nor reduceterm, effective and permanent protection to to acceptable levels the threats to humanhuman health and the environment along with health or the environment presented bythe degree of certainty that the alternative will contamination at the Site, it will not beprove successful. discussed in the remainder of this analysis.

GATX Alternative 2 (Capping) would not• Reduction of toxicity. mobility or volume: reduce the mass of contaminants or theirThe extent to which the alternative will toxicity but would reduce the level of risk

reduce the toxicity, mobility, or volume of the associated with the current Site use bycontaminants causing the site risks. preventing contact and accidental ingestion of

the contaminated sludge and soil and limit the• Short term effectiveness: air exposure route. The future Site use wouldThe time until protection is achieved and still present an unacceptable risk for Alternative

the short term risk or impact to the community, 2. GATX Alternatives 3A, 3B, 3C and 6 wouldonsite workers and the environment that may reduce the level of risk associated with thebe posed during the construction and current and future site use scenarios.implementation of the alternative: Alternatives 3B, 3C and 6 are capable of

destroying over 99.99% of the organic• Implementability: contaminants with a corresponding reductionThe technical and administrative feasibility in toxicity. Incinerator air pollution control

of a remedy, including the availability of devices are expected to be able to achieve airmaterials and services needed to implement ARARS. Offsite landfilling, unless combinedthat remedy. with some treatment, would not reduce the

toxicity or volume of contaminants in the soil or• Cost: sludge. GATX Alternatives 4, 5, 7 and 8Includes estimated capital, operation and (biological treatment and solvent extraction)

maintenance, and net present worth costs. are capable of significantly reducing the levelof VOCs and PAHs in the soil and sludge,

Modifying Criteria however, residual contamination would remainfollowing the implementation of these

• State Acceptance: alternatives. The amount of residualWhether the State concurs with, opposes, contamination would be less for Alternatives 7

or has no comment on the Preferred Remedial and 8 since the initial .contaminantAlternative. concentration in the former lagoon and sludge

bed soil are lower than in the pond area, it is• Community Acceptance: not known if the removal efficiencies ofWhether the public agrees with the Alternatives 4, 5, 7 and 8 would reduce the

Preferred Remedial Alternative (this will be levels of residual contaminants to a level whereassessed in the Record of Decision following a they would pose an acceptable risk in currentreview of the public comments received on the ' or future Site use scenarios.Administrative Record and the Proposed Plan).

Compliance with ARARs. ARARs^would likelybe met by all the remedial alternatives with theexception of the No Action alternative. GATXAlternatives 4, 5, 7 and 8 may require atreatability variance to comply with LandDisposal Restriction as provided for under theResource Conservation and Recovery Act("RCRA").

TABLE 1SUMMARY OF

SAEGERTOWN INDUSTRIAL AREA SITERISK SCENARIOS

CANCERRISK / HQ

4.9x1 0*

1.4X10'5

19x1 0'5

3.8x1 0'3

HQ = 2.2

2.7x1 Q-5

2.8x10''

HQ = 21

2.9x1 0'5

6.4x1 Q-6

HQ =1.9

2.3x1 0*

HQ = 6.7

AREA

GATXPOND

GATXPOND

GATXPOND

GATXSLUDGEBED/LAGOON

GATXRAILSIDING

GATXPOND

GATXPOND

GATX

LORD

MEDIA

SURFACESEDIMENT

AMBIENTAIR

AMBIENTAIR

SOIL

SOIL

SOIL

AMBIENTAIR

GROUNDWATER

GROUNDWATER

HAZSUB.

PAHSPCBsAs.

VOCsPAHs

VOCSPAHs

VOCsPAHsPCBsMET.

PAHsAs.

VOCsPAHsPCBsMET.

VOCsPAHs

VOCsMET.

VOCSMET.

POPULATION

TRESPASSER

ONSITEWORKER

OFFSITERESIDENT

ONSITERESIDENT

ONSITERESIDENT

ONSITERESIDENT

ONSITERESIDENT

ONSITERESIDENT

ONSITERESIDENT

ROUTE

INGEST

INHALE

INHALE

INGEST

INGEST

INGEST

INHALE

INGESTINHALEDERMAL

INGESTINHALEDERMAL

LAND USE

CURRENT

CURRENT

CURRENT

FUTURE

FUTURE

FUTURE

FUTURE

FUTURE

FUTURE

Carcinogenic risk is expressed by using scientific notation; for example, 1 x 10* meansthat one additional person in 1 million could develop cancer over a defined period ofexposure to contaminants at a site. A risk between 1 x 10"* and 1 x 10* is consideredan acceptable risk range for SUPERFUND Sites.

Non-carcinogenic risks are presented as a Hazard Quotient ("HQ"). An HQ exceeding one isconsidered an unacceptable risk.

pCflooaH53H

§OTswo

(-«*

9IX

MSKj

north

17

Lord Alternative 7 - Combination of Pump and treatment.Treat with In-situ Vapor Extraction

EPA's preferred alternative for the SMCEstimated Capital Costs: $1,890,000 property is the No Action Alternative.Estimated Annual O&M Costs: $275,000 The No Action Alternative would be protectiveEstimated Present-Worth Costs: $3,800,000 of human health and the environment.Estimated Implementation Time: FourteenYears EPA's preferred alternative for the SCI property

is the No Action Alternative.This alternative is similar to Alternative 6 in that The No Action Alternative would be protectivegroundwater pumping and treatment would be of human health and the environment.used to treat the area of the plume with alower concentration of contaminants but in-situ Actual or threatened releases of hazardousvapor extraction would be used in the area of substances from this Site, if not addressed bythe plume with the higher concentration of the preferred alternative or one of the activecontaminants. The pumping and treatment measures considered, may present a currentshould remediate the plume and also prevent or potential threat to public health, welfare, orfurther migration of the plume. In-situ vapor the environment.extraction is only capable of removingcontaminants in the unsaturated zone. In selecting EPA's preferred alternative EPAGroundwater beneath the manufacturing evaluated each proposed remedy against thebuilding and in the vicinity of the RG-1 sump nine criteria specified in the Nationalwould have to be pumped to lower the water Contingency Plan. The alternative must firsttable to create a deeper unsaturated zone. satisfy the threshold criteria. Next the primary

balancing criteria are used to weigh theVI. EVALUATION OF ALTERNATIVES tradeoffs or advantages and disadvantages of

the alternatives. Finally after public commentEPA's preferred alternative for the former GATX has been obtained the modifying criteria areproperty is GATX Alternative 6. Excavation and considered. Below is a summary of the nineOnsite Incineration. criteria used to evaluate the remedial

alternatives.Excavation and Onsite Incineration is thepreferred alternative for the treatment of the Threshold Criteriacontaminated sludge and soil on the formerGATX property since it meets the threshold • Overall protection of human health andcriteria, and provides the best balance of the environment:effectiveness, permanence, implementability, Whether the remedy provides adequatereduction of toxicity, mobility and volume of protection and how risks posed through eachcontaminants through treatment. pathway are eliminated, reduced or controlled

through treatment, engineering controls, orEPA's preferred alternative for the Lord institutional controls.property is Lord Alternative 6. GroundwaterPumping and Treatment in Combination with • Compliance w'rth ARARs:Air Sparging. Whether or not a remedy will meet all

applicable or relevant and appropriateLord Combination Alternative 6 with Air requirements (ARARs) of Federai- nd StateSparging is the preferred alternative for the environmental statutes and/or whether theretreatment of the groundwater contamination in are grounds for invoking a waiver. Whether orthe vicinity of the Lord property since it meets not the remedy complies with advisories,the threshold criteria, and provides the best criteria and/or guidance that may be relevant.balance of effectiveness, permanence,implementability, reduction of toxicity, mobilityand volume of contaminants through

AR3CH93I

The contribution from the former GATX pond excavated for treatment the residual PAHarea sediment to maximum lifetime concentration remaining in soil after excavationcarcinogenic risks for older children will not exceed a level of 1.0 ppm whentrespassers onsite is 4.9 x 10'5 due to expressed as benzo (a) pyrene equivalentsaccidental ingestion of sediments. Dermal fB(a}P*) for the PAHs listed on Table 2. B(a)Pcontact with pond sediment would increase is a way of expressing the relative carcinogenicthe total risk estimated for the GATX pond potency of PAH compounds in terms of benzoarea. (a) pyrene which is given a carcinogenic

potency value of one (1). For the ProposedThe GATX pond area and sludge bed and Plan the GATX sludge is defined as containinglagoon areas would also present an 1% or greater total VOCs and SVOCs (10,000unacceptable carcinogenic and non- ppm or greater). If the GATX sludge found incarcinogenic risk if the Site were used in the the sludge bed/lagoon area and the pond areafuture by onsite residents. is excavated for treatment the soil underlying

the sludge areas must also meet the criteria ofThe GATX sludge contains a mixture of VOCs not exceeding a total B(a)P equivalent of 1and semi-volatile organic compounds ppm. Following any source removal from the("SVOCs"), while the GATX contaminated soils former GATX property, groundwater beneathcontains primarily SVOCs. The Rl indicates the property should be monitored to assessthat the VOCs are bound in the sludge and not the need for further action in this area ofsubject to leaching. An estimated 3 million concern.pounds of VOCs and SVOCs present in thesludge and soil on the former GATX property The GATX rail siding area would present anhave been onsite for at least 30 years. A increased cancer risk of 2.7 x 10~5 to a futurescientific model was run on the former GATX onsite resident due to the ingestion of theproperty for the purpose of predicting the PAHs present in the soil. This is withineffect the VOCs in the sludge would have on acceptable risk criteria for future residentialgroundwater. While the model predicted that use. Risk analysis based on the current Sitegroundwater beneath the former GATX use showed that this area of the former GATXproperty should be highly contaminated, this property does not pose an unacceptablewas not in fact the case. Sample results show cancer or non-cancer risk to a trespasser. Nothat the highest levels of VOCs detected in action was deemed necessary for this areagroundwater on the former GATX property based on current and future risk assessmentduring the Rl were: TCE -1 ppb, Benzene - 5 and the additional level of protection affordedppb and PCE - 3 ppb. Unfortunately there is by the continued industrial zoning and use ofno factor in the model to allow for the viscosity this property.of the sludge and its effect on the solubility ofthe VOCs in the sludge in the groundwater.

EPA has developed soil cleanup levels basedon an amount of residual contamination that ifleft in the soil would not affect groundwaterand not present an unacceptable risk of directcontact. EPA proposes to let certain SVOC,namely the carcinogenic PAH contaminants,drive the cleanup since they are present inboth the sludge and the soil. The VOCs in thesludge are commingled with the PAHs and willbe removed along with them in any cleanup ofthe PAHs. Table 2 presents a list ofcarcinogenic PAHs found in the soil andsludge on the former GATX property. If theGATX contaminated soil and sludge is

16

would reduce with time and possibly rebound Lord Alternative 5 - In-situ Biological Treatmentafter pumping would stop. The groundwatertreatment cost estimate is based on Estimated Capital Costs: $1,490,000UV/Oxidation which does not result in any VOC Estimated Annual O&M Costs: $217,000emissions. Chlorinated ethenes in the Estimated Present-Worth Costs: $2,400,000saturated zone would be significantly reduced Estimated Implementation Time: Five Yearsthrough the flushing action of the groundwaterpumping. The effectiveness of this alternative The In-situ Biological treatment alternative iswould depend on desorption of the designed to degrade saturated zone ..contaminants from the saturated zone soil, contaminants in place. Groundwater would bediffusion of the contaminants in the pumped and chlorinated ethenes would begroundwater and the presence of treated by uv/oxidation. The treatedcontaminants not dissolved in the groundwater groundwater would then have supplementalacting as a source. This alternative may be oxygen/gas, nutrients and other additivescapable of capturing the portion of the plume mixed with it in an above ground reactor priorto the west of the Lord property depending to being reinjected into' the aquifer. Thisupon the extent of the plume. alternative could also include unsaturated zone

source treatment in the vicinity of the RG-1Lord Alternative 4 - In-situ Air Sparging sump. The effectiveness of the In-situ

Biological Treatment alternative to degradeEstimated Capital Costs: $3,110,000 contaminants is limited by the ability of theEstimated Annual O&M Costs: $330,000 injected treated groundwater to intimatelyEstimated Present-Worth Costs: $4,500,000 contact the chlorinated ethenes in the aquifer.Estimated Implementation Time: Five Years

Lord Alternative 6 - Combination of PumpingThe in-situ air sparging alternative is designed and Treatment with Air Sparging. Steamto volatilize contaminants present in the Stripping or Biological Treatmentsaturated zone and collect them for dischargeto the atmosphere or above ground treatment. Estimated Capital Costs: $1,840,000Air sparging involves the injection of air under Estimated Annual O&M Costs: $250,000pressure via a network of horizontal trenches Estimated Present-Worth Costs: $3,400,000or vertical wells into the saturated zone of the Estimated Implementation Time: Ten Yearsaquifer. This alternative would includeelements of Lord Alternative 2 for containment This alternative combines the use of in-situof further offsite movement of contaminants. technology for the more highly contaminatedThis alternative could also include unsaturated area of the plume with a groundwater pumpingzone source treatment in the vicinity of the RG- and treatment of the downgradient portion of1 sump. It is estimated that air sparging would the plume. The pump and treat system wouldremove approximately 4.1 pounds per day of be more cost effective in remediating thechlorinated ethenes from the groundwater and portion of the plume with the lowersaturated zone. These contaminants collected concentrations of chlorinated ethene than thein the vapor phase by the extraction wells in-situ technology. Conversely the in-situwould be captured in an above ground carbon treatments would be more effective in treatingadsorption treatment system. the more highly contaminated portion of the

plume beneath the Lord manufacturingbuilding. The in-situ treatments p/oposed inthis alternative would be either air sparging,biological treatment or steam stripping.Alternatives 4 and 5 discuss air sparging andbiological treatment, respectively. Steamstripping is analogous in design to air spargingexcept that steam, rather than air, is injectedinto the aquifer.

I AR30*t933

10

TABLE 2

SUMMARY OF CARCINOGENIC PAHS FOUND ON THE FORMER GATX PROPERTY

CONTAMINANTCONC. inPPMbenzo (a)anthracenechrysenebenzo (b) fluor-anthene

benzo (k) fluor-anthenebenzo (a) pyrene

indeno (1,2,3-cd)pyrenedibenzo (a,h)anthracene

SLUDGE BEDSURFACE SOIL

2.4

1.9

3.8

3.8

2.0

1.4

0.5

SLUDGE BEDSUBSURFACESOIL

350

425

170

185

210

61.5

0.0

POND AREASURFACE SOIL

2,200

3,300

1,500

730

1,100

400

140

POND AREASUBSURFACESOIL

3,100 .-

13,000

4,000

4,000

1,900

770

300

Definitions:

GATX Contaminated Soil - Soil containing 1 ppm or greater benzo (a) pyrene equivalents for the PAHcompounds above.

Benzo (a) pyrene equivalents - B(a)P equivalents - compares the relative carcinogenic potency ofvarious PAH compounds to benzo (a) pyrene which is assigned a value of 1.

GATX Sludge - Material containing 1% or greater total VOCs and SVOCs (10,000 ppm or greater).

Lord Area Groundwater Aquifer

Sampling conducted tJuring the Rl confirmed the Rl, confirmed the presence of TCE,the presence of groundwater contamination TCEA, PCE, toluene and xylene in soil gas andbeneath the Lord corporation property on the groundwater samples. The results of thisSaegertown Industrial Area Site. VOCs investigation have been included as anincluding vinyl chloride, TCE, TCEA, PCE, and appendix to the Rl. The Rl estimates that 9.31,2 dichloroethene ("chlorinated ethenes") were million gallons of groundwater onsite has beenfound in the groundwater. Lord, during routine impacted by the plume. The chlorinatedinspections, identified a leaking sump area as ethenes in the groundwater are estimated toa possible source of the VOCs. Lord uses be moving at 0.54 to 2.50 feet per year. Thesumps to collect floor washings and spills from total mass of chlorinated ethenes in theproduction areas where adhesives are delineated area is estimated to be 7,500manufactured in its plant. Lord, in a pounds. Figure 4 depicts the aerial extent ofconcurrent investigation outside the scope of the groundwater plume. The extent of the

15

sludges. This initial lower concentration would Industrial Area Site to remove, remediate,result in a lower residual concentration after contain, or otherwise address the Lord areabiological treatment has been completed. groundwater contamination.

GATX Alternative 7B - Combination Alternative Lord Alternative 2 - Groundwater Containmentwith Slurry Phased Bforeactor and Source Control

Estimated Capital Costs: $11,900,000 Estimated Capital Costs: $950,000Estimated Annual O&M Costs: $823,000 Estimated Annual O&M Costs: $120,OOQEstimated Present-Worth Costs: $13,700,000 Estimated Present-Worth Costs: $2,800,000Estimated Implementation Time: Three Years Estimated Implementation Time: Thirty Years

This alternative would combine elements of This alternative would contain groundwater byGATX Alternatives 3A, 3B or 3C with GATX using either a physical or hydraulic barrier toAlternative 4B. This Alternative would provide prevent further offsite movement offor the removal and onsite incineration or contaminants. Air sparging wells, anoffsite disposal of the more highly interceptor trench designed for biological-contaminated sludges with the less treatment, or groundwater extraction wells withcontaminated sludge and soil treated by slurry above ground treatment of effluent are threephased bioreactor. examples of containment remedies considered

in this alternative. Unsaturated zone sourceGATX Alternative 8 - Combination Alternative treatment could be implemented in the vicinitywith Solvent Extraction of the RG-1 sump as part of this alternative.

For the purposes of costing this Alternative,Estimated Capital Costs: $11,340,000 groundwater pumping and treatment of effluentEstimated Annual O&M Costs: $1,503,000 was used. Groundwater would be recoveredEstimated Present-Worth Costs: $14,600,000 at 40 gallons per minute under this alternative.Estimated Implementation Time: Two Years An estimated maximum of 1.5 pounds per day

of contaminants would be removed from theThis alternative would combine elements of treated groundwater.GATX Alternatives 3A, 3B or 3C with GATXAlternative 5. This Alternative would provide Lord Alternative 3 - Groundwater Pumping andfor the removal and onsite incineration or Treatmentoffsite disposal of the more highlycontaminated sludges in the pond area with Estimated Capital Costs: $1,300,000the solvent extraction of the less contaminated Estimated Annual O&M Costs: $145,000sludge and soil from the sludge bed/lagoon Estimated Present-Worth Costs: $3,500,000areas. Estimated Implementation Time: Thirty Years

Lord Groundwater The groundwater pumping and treatmentalternative is designed to prevent further

Lord Alternative 1 - No Action migration of the contaminant plume andaggressively flush contaminants from the

Estimated Capital Costs: $0 saturated zone. Groundwater would beEstimated Annual O&M Costs: $0 extracted at a rate of approximately 100Estimated Present-Worth Costs: $0 gallons per minute and treated above groundEstimated Implementation Time: Immediate by UV/oxidation and discharged either on or

offsite. Unsaturated zone source treatmentThe NCP requires that EPA consider a "No could be implemented in the vicinity of the RG-Action" alternative for every site to establish a 1 sump as part of this alternative. Anbaseline for comparison to alternatives that do estimated maximum of 4 pounds per day ofrequire action. Under this alternative, no contaminants would be removed from theaction would be taken at the Saegertown groundwater by this Alternative. This amount

4f?30l*935

11

@oIw* »

8- 30) HH-1 3

Wpi* os* ^3 Hn> ao H ^O f1 i3 O (Dft Mo b * .c ow oH- ?

^ ,T3 H3CO H

Oa*d§wsK

14

which microorganisms degrade waste. extracted contaminants would then beBiodegradation of waste by microorganisms transported offsite for incineration or secondarycan be optimized when conditions including fuel blending.pH, oxygen, nutrient availability, and moistureare controlled. Sludge from the Site would GATX Alternative 6 - Excavation and Onsiterequire mixing with clean soil prior to Incinerationplacement in a landfarm treatment cell since itis too contaminated in its present condition. Estimated Capital Costs: $11,670,000Sludge would periodically be added to the cell Estimated Annual O&M Costs: $25,000,as biodegradation of the waste occurred until . Estimated Present-Worth Costs: $11,700,000all the contaminanted material is treated. Estimated Implementation Period: Six Months

to One YearGATX Alternative 4B - Onsite Slurry PhasedBioreactor This alternative would involve the excavation

and staging of contaminated soil/sludge forEstimated Capital Costs: $9,200,000 onsite incineration. Pretreatment of theEstimated Annual O&M Costs: $958,000. soil/sludge including mixing and screening.Estimated Present-Worth Costs: $12,200,000 would be required to provide a uniformEstimated Implementation Time: Three Years feedstock for the incinerator. The removal

efficiencies that are attainable for incinerationThis alternative would involve the excavation would reduce the risk to acceptable levels forand staging onsite of contaminated soils and both the current and future Site use scenarios.sludge for biological treatment in a slurry Incineration of the soil/sludge reduces orphased biological reactor. Slurry phased eliminates the toxicity and volume of organicbioreactors offer greater control over biological contaminants by converting them to non-toxictreatment processes than landfarming. combustion gases. Ash remaining after theIncreased contact time between the incineration could be redeposited onsite ormicroorganism and the contaminants, use of removed for offsite disposal either with orengineered microorganisms, decreased without fixation to immobilize any metals in theacclimation time and greater control over ash.process parameters can all be achieved in thebioreactor. A slurry, made by mixing 15% GATX Alternative 7A - Combination Alternativesludge or soil (by weight) with water, would be with Landfarmingprocessed through the bioreactor. A residualamount of contaminants would remain in the Estimated Capital Costs: $8,890,000soil/sludge after treatment. Estimated Annual O&M Costs: $419,000

Estimated Present-Worth Costs: $11,100,000GATX Alternative 5 - Solvent Extraction Estimated Implementation Time: Four Years

Estimated Capital Costs: $8,770,000 This alternative would combine elements ofEstimated Annual O&M Costs: $2,180,000 GATX Alternatives 3A, 3B or 3C with GATXEstimated Present-Worth Costs: $13,300,000 Alternative 4A to remediate the sludge andEstimated Implementation Time: Two Years contaminated soil respectively. Approximately

4,000 cubic yards of sludge would beThis Alternative involves the excavation and incinerated onsite or removed for offsitestaging of contaminated sludge and soil for disposal and approximately 5,000 cubic yardsonsite solvent extraction. Solvent extraction of contaminated soil/sludge would betransfers the contaminants from the solid biologically treated in a landfarm onsite.phase to the liquid phase. A solvent is used to Biologically treated soil and any ash from anywash the contaminants out of the soil/sludge. onsite incineration would be used forAs many as eight separate washings may be backfilling excavations. The lagoon/sludgeneeded to reduce the levels of contaminants in bed area sludges are an order of magnitudethe soil/sludge to acceptable levels. The lower in concentration than the pond area

AR30lf937

13

GATX Soil/Sludge excavated areas would have to be backfilledand graded. Above ground treatment of

GATX Alternative 1 - No Action sludges and soil may be required prior tooffsite landfilling. The sludges/soils would then

Estimated Capital Costs: $0 be transported offsite for disposal.Estimated Annual O&M Costs: $0Estimated Present-Worth Costs: $0 GATX Alternative 3B - Offsite IncinerationEstimated Implementation Time: Immediate

Estimated Capital Costs: $33,690,000 .The NCP requires that EPA consider a "No . Estimated Annual O&M Costs: $25,000Action" alternative for every site to establish a Estimated Present-Worth Costs: $33,800,000baseline for comparison to alternatives Estimated Implementation Time: One Yearthat do require action. Under this alternative,no action would be taken at the former GATX This alternative incorporates all the stepsproperty to monitor, remove, remediate, outlined in Alternative 3A except that instead ofcontain, or otherwise address soil/sludge offsite disposal at a landfill, the sludge/soilcontamination. would be transported to an offsite permited

commercial Incinerator.GATX Alternative 2 - Containment Onsite ;(Capping) GATX Alternative 3C - Offsite Disposal as a

Hazardous Waste FuelEstimated Capital Costs: $1,010,000Estimated Annual O&M Costs: $82,500 Estimated Capital Costs: $11,710,000Estimated Present-Worth Costs: $1,700,000 Estimated Annual O&M Costs: $25,000Estimated Implementation Time: One Year Estimated Present-Worth Costs: $11,800,000

Estimated Implementation Time: One YearThis alternative would involve capping all theareas of surface and subsurface sludge and This alternative incorporates all the stepscontaminated soil on the former GATX property outlined in Alternative 3A except for the finalto prevent dermal contact and minimize rainfall offsite disposal location. Instead of offsiteinfiltration. Some surface regrading would be disposal at a landfill or incinerator, thenecessary to redirect surface water that sludge/soil would be transported to a cementcurrently collects in the GATX pond and other kiln approved for the burning of hazardouslow areas. Deed restrictions, fencing and waste derived fuels. Alternatives 3A, 3B andcontinued monitoring would be needed to 3C would all reduce the Site risk to acceptablereduce the potential for future human levels for both the current and future scenariosexposure. as well as meet ARARs. After implementation

of these alternatives, monitoring would beGATX Alternative 3A - Offsite Landfilling performed to assess the impact and

effectiveness of the source removal onEstimated Capital Co'sts: $10,000,000 groundwater.Estimated Annual O&M Costs: $25,000Estimated Present-Worth Costs: $10,100,000 GATX Alternative 4A - Onsite LandfarmingEstimated Implementation Time: One Year

Estimated Capital Costs: $4,300,000The Rl has estimated that 9,000 cubic yards of Estimated Annual O&M Costs: $5.13,000sludge/soil are contaminated on the former Estimated Present-Worth Costs: $7,500,000GATX property. Under Alternatives 3A, 3B and Estimated Implementation Time: Eight Years3C, this material would be excavated andstaged prior to removal for offsite disposal. This alternative would involve the excavationThe former GATX pond would have to be and staging onsite of contaminated soils anddrained, prior to excavation, then regraded sludge for biological treatment in anwith clean soil to its former contours. Other engineered cell. Landfarming is a process by

12

groundwater plume to the west of the Lordproperty was not fully delineated during the Rldue to the inability to gain access to theseproperties; however, EPA believes thatsufficient information regarding groundwatermovement and contamination was collectedduring the Rl to move ahead with theProposed Plan and ROD for the Site. The TABLE 3extent of the groundwater plume can bestudied further during remedy implementation. SUMMARY OF REMEDIAL ALTERNATIVES

FOR THEConsumption of the Lord groundwater poses SAEGERTOWN INDUSTRIAL AREA SITEmaximum lifetime carcinogenic risks of 2.3 x10"2 for a future onsite resident. This GATX Alternative 1 - No Actiongroundwater is not currently used but, under a GATX Alternative 2 - Containment Onsitescenario where a future onsite resident would (Capping)utilize this groundwater for a potable water GATX Alternative 3A - Offsite Landfilling.supply, it would represent an unacceptable GATX Alternative 3B - Offsite Incinerationcarcinogenic risk. The Hazard Quotient of 6.7 GATX Alternative 3C - Offsite Disposal as a(greater than 1) indicates this scenario would Hazardous Waste Fuelalso represent an unacceptable non- GATX Alternative 4A - Onsite Landfarmingcarcinogenic health effect risk. GATX Alternative 4B - Onsite Slurry Phased

BioreactorSMC Sediment and SCI Soil GATX Alternative 5 - Solvent Extraction

Based on the levels of contaminants present in GATX Alternative 6 - Onsite IncinerationSMC sediment this area was qualitatively GATX Alternative 7A - Combination Alternativeassessed in the RA and determined not to with Landfarmingpresent an unacceptable environmental or GATX Alternative 7B - Combination Alternativehuman health risk using the current or future with Slurry Phased BioreactorSite use scenarios. The SCI soil was GATX Alternative 8 - Combination Alternativequantitatively assessed in the RA and found to with Solvent Extractionalso not represent an unacceptableenvironmental or human health risk using the Lord Alternative 1 - No Actioncurrent or future Site use scenarios. No action Lord Alternative 2 - Groundwater Containmentis proposed to be taken at these areas. The and Source ControlNo Action Alternative would be protective of Lord Alternative 3 - Groundwater Pumping andhuman health and the environment. Treatment

Lord Alternative 4 - In-situ Air SpargingLord Alternative 5 - In-situ Biological

V. SUMMARY OF REMEDIAL ALTERNATIVES Lord Alternative 6 - Combination with AirThe Feasibility Study \'FSn) contains all the Sparging, Steam Stripping orremedial alternatives considered for the Biological Treatmentcleanup of the Saegertown Site. SMC and SCI Lord Alternative 7 - Combination with In-situAlternatives are not being presented in the Vapor ExtractionProposed Plan since the No Action Alternativewould be protective of human health and theenvironment. Table 3 presents a list of theGATX and Lord Alternatives that were analyzedin detail in the FS. Below is a summary of thealternatives.

AR31H939