WORK PLAN FOR REMEDIAL INVESTIGATION/FEASIBILITY STUDY COTTMAN AVENUE SITE PHILADELPHIA, PENNSYLVANIA TO COTTMAN AVENUE PRP GROUP MARCH 1991 BCM PROJECT NO. 00-6023-01 PREPARED BY \A^, Lx- GLENN C. RANDALL SENIOR GEOLOGIST oUPA,T - DANIEL E. ERDMAN, P.G., CPGS SENIOR PROJECT MANAGER FREDERICK M. POLI, P.E. SENIOR VICE PRESIDENT BCM 5602y • Engineers, Planners, Scientists and Laboratory Services One Plymouth Meeting • Plymouth Meeting, PA 19462 •• Phone: [215) 825-3800
Transcript
WORK PLAN
FOR
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
COTTMAN AVENUE SITEPHILADELPHIA, PENNSYLVANIA
TO
COTTMAN AVENUE PRP GROUP
MARCH 1991
BCM PROJECT NO. 00-6023-01
PREPARED BY
\A , Lx-GLENN C. RANDALLSENIOR GEOLOGIST
oUPA,T -DANIEL E. ERDMAN, P.G., CPGS
SENIOR PROJECT MANAGER
FREDERICK M. POLI, P.E.SENIOR VICE PRESIDENT
BCM5602y • Engineers, Planners, Scientists and Laboratory Services
One Plymouth Meeting • Plymouth Meeting, PA 19462 •• Phone: [215) 825-3800
CONTENTS
1.0 INTRODUCTION . 1
1.1 General 11.2 Objectives of RI/FS 1
1.2.1 General Objectives 11.2.2 Specific RI'/FS Objectives 1
2.0 SITE BACKGROUND INFORMATION 2
2.1 Site Description 22.2 Site History ' 3
2.2.1 Ownership of the Site 32.2.2 Activities at the Site 42.2.3 Studies of the Site 42.2.4 Remedial Actions at the Site 6
2.3 Climate • 72.4 Topography 82.5 Geology 82.6 Hydrogeology 92'. 7 Soils 102.8 Chemical and Biological Parameters 11
3.0 SCOPING OF THE REMEDIAL INVESTIGATION AND FEASIBILITY STUDY 12
3.1 Summary of Existing Data 123.2 Applicable or Relevant and Appropriate 13
Attachment 2 EWK Consultants, Inc. Letter dated May 23, 1988
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TABLES
Table 1 Preliminary Listing of Possible Federal Applicable 14or Relevant and Appropriate Requirements,Cottman Avenue Site
Table 2 Commonwealth of Pennsylvania Possible Applicable 17or Relevant and Appropriate State Requirements,Cottman Avenue Site
Table 3 Summary of Chemical Sample Analyses 26Table 4 Chemical/Physical Parameters 30
FIGURES
Figure 1 Proposed Sample Location Map Pocket
Figure 2 Project Organization Chart 46
Figure 3 Projected RI/FS Schedule 47
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BCM; :1.0 INTRODUCTION
1.1 GENERAL
BCM has been retained by the Cottman Avenue Interim PRP Group to developa Work Plan for a Remedial Investigation/Feasibility Study (RI/FS) forthe Metal Bank of America, Inc. site located on Cottman Avenue, Phila-delphia, Pennsylvania (Cottman Avenue Site or the Site).
This document represents a Final Work Plan, albeit abbreviated, preparedafter consideration of review comments to earlier submlttals. A finalField Sampling Plan and Quality Assurance Project Plan will be developedusing the elements of the scope of work presented here as a basis. Thesedocuments will be prepared 1n accordance with the latest EPA guidancedocuments related to Superfund Site Investigations.
1.2 OBJECTIVES OF RI/FS
1.2.1 General Objectives
The RI phase of the RI/FS will gather and assess Information to determinethe nature and extent of risks posed by the site to public health and theenvironment.
If the site represents a greater than acceptable risk or potential riskto public health or the environment, or generally exceeds applicable orrelevant and appropriate requirements (ARARs) for any contaminated media,the detailed FS portion of the study will proceed to determine whatfeasible and cost-effective options are available to address such risk.
1.2.2 Specific RI/FS Objectives
The specific RI/FS objectives and rationale are summarized below:1. Characterize the nature and extent of contamination remain-
Ing 1n the Impacted area of the Site.
2. Identify potential source areas that may be contributing toany groundwater contamination present within the Impactedarea of the Site.
3. Estimate the Impact on the quality of the Delaware Riverand estimate any health and environmental risks associatedwith use of these surface waters and/or sediments':
4. Characterize the nature and extent of soil contamination todetermine the potential Impact of fugitive dust and othersource emissions on neighboring land uses.
To explain the focus of the scope of this Work Plan, the following sec-tion provides a detailed description of the Site. This description Isbased on Information provided by ERA, the United States Geological Survey(USGS), the U.S. Army Corps of Engineers (the Corps), the United StatesCoast Guard (USCG), the Pennsylvania Department of EnvironmentalResources (PADER) the Delaware River Basin Commission (DRBC), The MetalBank of America, Inc. (Metal Bank of America or Metal Bank), andothers. It Is organized as follows:
- Site description- Site history- Climate- Topography- Geology and Soils- Hydrogeology- Chemical and Biological Parameters
2.1 SITE DESCRIPTION
The Site property is located at the corner of Cottman Avenue and MllnorStreet in an industrial area of northeastern Philadelphia, Pennsylvania(Figure 1, pocket at back of Work Plan). The Site Is bordered by CottmanAvenue on the west, Mil nor Street on the north, Hancock Paper Company (apaper recycling company) and Morris Iron & Steel Company (a metal salvageyard) on the east, and the Delaware River on the south. To the west ofCottman Avenue is St. Vincent's School. There Is a stormwater outfallowned by the City of Philadelphia at the southern end of Cottman Avenue.This outfall empties into a mudflat area which is also west of the Site.There is a marina to the west of the mudflat.
The Site property consists of two areas: (a) the scrap metal recoveryarea, located on the southern portion of the property, and (b) the build-ing area, located on the northern portion of the property. Site accessis controlled by the locked buildings and a 6-foot high fence on allsides of the southern portion of the Site except that bordering the River.
The scrap metal recovery area on the southern portion of the property Isapproximately six acres in size. The Site consists of artificial fillover a layer of clay that was once the bed of the Delaware River. Eightypercent of this area (essentially all of it except the concrete pad andthe far southwestern area next to. the River and mudflats) has beenregraded and seeded, and there are no visual signs ofv past use. Theremaining area in the southwest corner formerly contained a groundwater
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BCMrecovery and treatment system. Recovery operations were terminated asper judicial order of June 12, 1989. Since that time the recovery wellswere permanently closed, and the oil recovery system dismantled andremoved. The area was covered with clean fill.
The building area, near Cottman Avenue, consists of three vacant brickand steel buildings.
2.2 SITE HISTORY
Based on a preliminary title search, correspondence between John Mattlonl,Counsel to Metal Bank of America, and Jack Kelly, Project Officer of ERARegion III, and Information from EPA's files, the following 1s a historyof the Cottman Avenue Site.
2.2.1 Ownership of the Site
Prior to 1955, the Site was owned by Dlsston Manufacturing Company("Dlsston"), a manufacturer of power equipment. Dlsston acquired variousportions of the Site In several separate transactions between 1882 and1928. The War Assets Administration owned at least part of the Siteduring some of the time between Dlsston's acquisition of the Site and Itssale to H.K. Porter In 1955.
H.K. Porter Company purchased Dlsston Manufacturing and later sold theCottman Avenue site to L. Goldsteln's Sons, Inc. ("Goldsteln's") (MetalBank's predecessor which was owned by Irvlng and John Schorsch) 1nOctober of 1962. Apparently at some time In the mld-1960's, Goldsteln'schanged Its name to The Metal Bank of America, Inc. On December 4, 1968,the assets of The Metal Bank of America, Inc. (except for real propertyat Cottman Avenue and State Road) was purchased by The Union Corpora-tion. The owner of the purchased assets of Metal Bank was M.B.A., Inc.,a subsidiary of Union Corporation formed December 9, 1969. The name ofM.B.A., Inc. was changed later that month to The Metal Bank of America,Inc., the name 1t continued under until June 1985. In 1985, becauseMetal Bank was no longer an operating company (Its assets having beensold, except for the real estate at Cottman Avenue and at State Road) thename was changed again to UCO-MBA, Inc. The real property was purchasedby John and Irvln Schorsch, principals of The Metal Bank of America,Inc., and The Metal Bank of America, Inc. leased the property from theSchorsch1 s from 1968 to 1980. In 1980, The Metal Bank of America, Inc.entered Into an Installment sales contract with the Philadelphia Author-ity for Industrial Development ("PAID"), which had purchased the propertyfrom the Schorsch's.
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2.2.2 Activities at the Site
From the time of Gol.dsteln's purchase of the property 1n 1962 1t was usedfor storage of various scrap metals. Beginning In late 1968 or early1969 until early 1973, transformer salvage operations were conducted atthe site. According to Information 1n EPA's files, some of the transfor-mers purchased by Metal Bank contained oil. This oil was drained on aconcrete pad which was connected to an underground storage tank. Spillsof the oil and possibly a rupture of the underground tank caused soil andgroundwater contamination at the site. Between 1968 and 1972 copper wiremay have also been burned at this site to remove Insulation. Accordingto Metal Bank representatives, oil was not burned onslte. From 1973 to1985 Metal Bank of America continued to store various scrap metal at theSite but no transformer salvage operations have been conducted at theSite since some point 1n 1973. Metal Bank of America has conducted reme-dial actions at the Site, starting In 1972-73 under the auspices of theUSCG. The groundwater recovery and treatment system operated from 1981to 1989.
A portion of the buildings on the premises were leased to various ten-ants: Lincoln Van and Storage for 8 to 10 years, ending In 1985; anautomobile body repair shop for four or five years until approximately1983; and Pennsylvania Alternator and Generator Exchange for approxi-mately 1 year, until sometime In 1983. During the 1970s Relsher Fordstored new cars on the premises. A 11st of the past tenants compiled byMetal Bank representatives 1s provided In Attachment 1. In any event,according to representatives of Metal Bank, no PCB or transformer relatedactivities were known to occur In the buildings after 1962 and before thesecondary treatment unit was Installed 1n 1981.
2.2.3 Studies of the Site
In 1972, the USCG took action with respect to reports of oil seeping fromthe Metal Bank of America site. After a series of Inspections, the USCGconcluded that Metal Bank was the source of the seep. In 1972, the USCGperformed visual Inspections and took oil samples from the Cottman AvenueSite and from the nearby Delaware River. As a result of these studies,from 1972 to mld-1973, Metal Bank performed various remedial actions atthe Site following the recommendations of the USCG. These actionsIncluded surface cleanup of spilled oil, cleanup of the shoreline,Installation of an aluminum caisson filled with sand to capture any oilspills from the property, and Improved housekeeping. According to MetalBank, the underground storage tank was drained 1n 1972 or 1973. In 1981,the tank was drained of residual water, cleaned, and filled with con-crete. After that time, no new oil was placed there. Metal Bank ofAmerica ceased acceptance of transformers, and transformer operations atthe Site ceased 1n 1973. According to Metal Bank, 1n 1973 the USCG tooksamples of soil from the Site. Analysis of these samples Indicated thepresence of oil; however, analysis using then-available state-of-the-arttechnology did not detect PCBs In the samples.
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The Coast Guard kept the facility under Investigation and took numeroussamples from the Site 1n 1977 and 1978. According to Metal Bank person-nel, government personnel from the Coast Guard and EPA Inspected theentire Cottman Avenue Site property, the Interiors of all buildings onthe premises, and all open areas, Including those bordering Mil nor Street.
Site visit reports during this period state that the perimeter of theproperty contained a zone of oil seepage estimated o be 70 feet long.011 samples collected for analysis contained over 800 ppm of PCBs.Several consultants conducted studies between 1978 and 1980 to evaluatethe hydrogeologlcal properties of the subsurface oil spill and availablealternatives to control PCB contamination: Roy F. Neston, Inc., Hydro-aeoloalc Evaluations of a Subsurface Spill at the Metal Bank of America.Inc. Disposal Site (October 12, 1978). Energy and Environmental Analy-sis, Inc., Evaluation of Metal Bank of America's Cottman Avenue Site(May, 1979). Roy F. Weston, Inc., Evaluation of Alternatives for Controlof PCB Contamination of Metal Bank of America Site. Inc. (March 1980).In 1977, the EPA relnvestlgated the Site for possible PCB contamination.The July 1973 USCG samples, which had been retained, were retested usingnew procedures developed 1n the Interim. These new analyses disclosedthe presence of PCBs In the oil and other samples.
In 1977, representatives of the USCG as well as EPA, PADER, the Corps,the City of Philadelphia, the F1sh and Wildlife Service, the NationalOceanic and Atmospheric Administration (NOAA), the DRBC, and othersInspected the Site pursuant to the Coast Guard's authority under Section311 of the Clean Water Act. As a result of this extended Site Inspec-tion, an Initial work scope was prepared with preliminary conclusions andrecommendations.
During the period following October 1977, the USCG and EPA undertook twoseparate Investigations and had two extended studies prepared 1n aneffort to document the nature and extent of PCB-contamlnation of the Siteand to Identify and evaluate the available alternative remedial actions.The feasibility and cost-effectiveness of these different technologieswere also assessed at that time.At the same time, Metal Bank employed technical consultants who alsoperformed their review, inspections and analyses of the Site. Based onthe location, conditions, and use of the Site, Metal Bank's consultantsconcluded that the most appropriate action was to leave the PCBs Inplace, removing only the freely recoverable oil because this would resultin the least risk to human health and environment.In 1980, the Environmental Protection Agency filed suit against MetalBank of America, Union Corporation (Its parent), and Irvin and JohnSchorsch, owners of the site, under the Toxic SubstanEes Control Act(TSCA). During the litigation, Metal Bank, through its consultant EWK
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BCMConsultants, Inc., designed and Installed a groundwater recovery andtreatment system which 1s described 1n detail below. This suit wassettled 1n 1983 under a Stipulation whlcn required Metal Bank, to Installand operate the present oil recovery and treatment system until allrecoverable oil 1s removed from the 51 to. The Stipulation was approvedby EPA, the Department of Justice and the City of Philadelphia. TheStipulation was approved by a federal court judge after public notice waspublished In the Federal Register. According to Metal Bank, PADER dis-missed an enforcement action against Metal Bank as moot In light of theStipulation terms.
Ecology and Environment, Inc. prepared a hazard ranking system (MRS)model for Metal Bank of America Cottman Avenue site on July 21, 1982.The MRS score for the Site was 33.23. Most of this score related to theproximity of the Torresdale water supply Intake approximately 1.2 milesupstream of the Metal Bank site. The HRS score was apparently base'd onassumptions about the theoretical possibility of PCBs from the Sitereaching the Intake. The Site was placed on the National Priorities List(NPL) In 1983.
In December 1987, members of the Cottman Avenue PRP Group, among others,received letters from EPA notifying them of their status as potentiallyresponsible parties (PRPs) under the Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA). These allegationswere based on Invoices which Indicate that Metal Bank of America, eitherdirectly or through brokers, may have purchased transformers and otherelectrical equipment for recycling from these PRPs.Metal Bank, through Its counsel and EWK Consultants Inc., elected toperform additional studies 1n 1987-88, as described 1n the attachedletter from Dr. Klepplnger, EWK's principal! to Turner Smith dated
-May 23, 1988 (Attachment 2). These data were not available for review.
EPA conducted soil sampling at St. Vincent's School/Orphanage on April 1,1989, and sampling of site monitoring wells In March and August of 1989.
i EPA determined that the soil samples did not reveal a health risk; problem. The monitoring well samples showed that a floating layer of oil
was stm present 1n some portions of the site.2.2.4 Remedial Actions at the Site
As previously described, Metal Bank took action 1n 1972 and 1973 to cleanup the surface soils, drain the underground storage tank, and Install a
* caisson. In 1981, the tank was drained of residual water, cleaned, andfilled with concrete. The Stipulation between Metal Bank and the United
| States required Metal Bank to, among other things, recover all recover-l, able oil from the Site. Metal Bank had three operational recovery wells
at the Site. Groundwater from two of the wells was pumped to a baffled•; oil and water separation unit consisting of a three-tank oil separation
unit near the wells. Oil collected from the well was placed In a mobile
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transfer tank and eventually placed 1n an accumulation tank. The tankwas reported by Metal Bank to be outside the 100 year flood plain. Oil1n the accumulation tank continued to separate and water was removed forappropriate processing. Groundwater from the baffled tanks was pumped toonslte buildings for secondary treatment described below. This pumpingand separation system did not operate between December and Februarybecause of freezing weather.
The secondary treatment system 1n the building had two parallel tankswith floating absorbent sheets to collect the oily mix from the water.From these separation units, the water passed through 55-gallon drumscontaining activated carbon. The treated groundwater was then dischargedInto the City of Philadelphia sanitary sewer system, pursuant to thedischarge authorization which Is attached to the court approved settle-ment. Oily solid material from the well area tanks or the building tankswas collected In drums for disposal.
Recovery operations were terminated as per judicial order of June 12,1989. Since that time the recovery wells were permanently closed, andthe oil recovery system dismantled and removed. The area was coveredwith clean fill.
According to Metal Bank representatives, 1n addition to the foregoing,remediation has Included cleanup of the property and termination of alltenant leases. All buildings and exterior grounds have been cleared oftrash and debris. All fences have been repaired and are maintained byMetal Bank. All scrap materials were removed from the property. Theopen grounds of the property to the south and east have been leveled.Clean fill has been seeded. The ground Is now covered with grass, exceptIn the pumping area.
Water recharge has periodically been Implemented, I.e., river water hasbeen flooded over the Impacted area of the site to Increase the oilrecovery.
Clean concrete rubble Is stockpiled at the site pending completion of allrecoverable oil recovery. At that time the shore line 1s proposed to bestabilized using the clean concrete rubble.
2.3 CLIMATE
Philadelphia lies w.1th1n the temperate zone. Winter temperatures rarelygo below 0°F and summer temperatures rarely rise above 100°F. The annualaverage dally high temperature Is 63.4T. The annual average dally lowtemperature Is 45.1°F. The monthly average dally high ^.temperature forJuly (hottest month) is 86.1eF. The monthly average daily low tempera-ture for January (coldest month) is 23.8°F. Snow cover generally occursfor a total of less than 30 days 1n a typical year and relative humidityaverages 57 percent annually. Precipitation averages 41.42 inchesannually, and is uniformly distributed throughout the year.
IBCMThe prevailing wind directions in the Philadelphia area are from the westand southwest to the east and northeast approximately 31 percent of thetime throughout the year. Wind velocity 1s predominantly between 7 and10 knots. Calm prevails 0.7 percent of the time.
2.4 TOPOGRAPHY
The Cottman Avenue Site is virtually flat with a gentle slope towards thesouth and southeast. Surface water from the Site drains directly intothe Delaware River. Surface elevation at the Site is approximately 10feet above mean sea level.
2.5 GEOLOGY
The Cottman Avenue Site is located within the Atlantic Coastal PlainPhysiographic Province. The Site 1s less than one mile southeast of theboundary (fall line) between the Piedmont Physiographic Province and theAtlantic Coastal Plain Physiographic Province. This area of the AtlanticCoastal Plain consists of Quaternary and Cretaceous sediments which lieunconformably upon a basement of early Paleozoic rocks.
The basement rocks are a complex assemblage of crystalline metamorphosedsedimentary and igneous rocks. These rocks outcrop at the fall line andare exposed in the Piedmont adjoining the northwest margin of the CoastalPlain. The crystalline basement rock dips from 40 to 80 feet per mile tothe southeast; thus the overlying sediments form a wedge shaped mass thatthickens toward the Atlantic Ocean. The bedrock 1n the vicinity of thesite is overlain by the Rarltan formation which consists of alternatingbeds of nonmarine clay, sand, and gravel. In the vicinity of the Site,and 1n ascending order, the bedrock is overlain by the Farrington Sandmember, the Lower Clay member, the Sayreville Sand member, and the MiddleClay member.
The Farrington Sand member consists of yellowish gray to pale yellowishbrown coarse sand and fine gravel which grades upward into medium- tofine-grained sand, the Lower Clay member is composed of stiff clay ofvariable color containing beds of soft stratified clay and thin lenses offine grained sand. The Sayrevllle Sand member consists of a sequence ofyellowish brown tcT orange very fine to coarse grained sand beds. TheMiddle Clay member consists of stiff clay of variable color containingfew thin streaks of fine grained sand.
The thickness of these beds is variable and In some places the beds arenonexistent. In the Philadelphia area, the Sayrevllle S and Is commonlynot present and the Middle Clay lies directly on top of the Lower Clayfrom which it cannot be distinguished.
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Based upon existing published data and data from previous site investiga-tions, bedrock beneath the Cottman Avenue Site is expected to be encoun-tered at approximately 50 feet below ground surface. Immediately overly-ing the bedrock is approximately 15 feet of Farrington Sand, whfch isoverlain by approximately 20 feet of recent alluvium or Lower Clay, whichis overlain by approximately 15 feet of fill. The fill materials repor-tedly contain pieces of brick, lumber, cloth, metal, and concrete alongwith natural earth materials (sand, silt, gravel, etc.). The materialbeneath the fill is reportedly a stiff gray clay of low permeabilitywhich appears to be continuous with the Delaware River bottom; it 1s notknown at this time 1f this material represents the Lower Clay member orrecent alluvial materials.
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2.6 HYDROGEOLOGY
Based upon existing well records, the bedrock in the Coastal Plain in thePhiladelphia area can serve as a source of small groundwater supplies.Groundwater movement 1n the bedrock is dependent upon secondary openingssuch as fractures and joints which are enlarged as a result of weatheringand deformation. Residual clay on top of the weathered bedrock serves asa confining layer between the bedrock aquifer and the overlying Farring-ton Sand. Groundwater generally flows towards the southeast within thebedrock with a relatively steep gradient 1n the vicinity of the fall line.
The Farrington Sand is used as an aquifer in the Coastal Plain area ofPennsylvania. The Farrington is predominantly under confined conditionsdue to underlying impermeable material and overlying clay. The overlyingclay layers are absent In some areas. Wells screened within the aquiferproduce yields ranging from 30 gallons per minute (gpm) to 1,350 gpm andaverage about 400' gpm. The average transmlssivity of this aquifer is1,000 gallons per day per square foot.
The Lower and Middle Clay units have extremely low permeability valuesand serve as effective barriers to the movement of groundwater.
1 Although it is equally as permeable as the Farrington Sand, the Sayre-v i l l e Sand is not an Important aquifer 1n this region due to its lack ofthickness and aerial extent. No hydraulic data Is available with regardto recent alluvial clay deposits. The Farrington and Sayreville aquifersare artesian in many locations within Pennsylvania. There is no existinginformation regarding potentiometric conditions within the FarringtonSand beneath the Site.
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Hydrogeologic conditions beneath the Site were Investigated by Roy F.Weston (Weston) and reported in a document dated October 12, 1978
I entitled Hydrogeologic Evaluation of a Subsurface Oil Spill at the Metal1. Bank of America. Inc. Disposal Site. The Weston document reported that
groundwater is encountered approximately 10 feet below ground surfacewithin the fill materials on site. Weston also reported the followinghydrogeologic data about the fil.l materials:
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- Groundwater flows toward the Delaware River
- Groundwater gradient 1s 0.0041 ft/ft- Hydraulic conductivity Is 8.62 feet per day
- Groundwater flow velocity Is 0.035 feet per day
The Weston report went on to assess the volume of water and oil discharg-ing from the Site to the Delaware River as well as the PCB contaminantloading to the Delaware River via groundwater and oil transport. The1978 Weston document reported the following:
- 1,300 gallons of groundwater were discharging from the Siteto the Delaware River each day (approximately 480,000 gallonsper year).
- Approximately 0.05 gallons of oil were discharging from theSite to the Delaware River each day (approximately 20 gallonsper year).
- 3.2 x 10~4 pounds per year of PCBs were discharging fromthe Site to the Delaware River via groundwater transport.
- 0.2 pounds per year of PCBs were discharging from the Site tothe Delaware River via oil transport.
The Weston study was completed prior to the Installation of the ground-water recovery system and does not reflect the amount of oil removed bythis system.
2.7 SOILS
The United States Department of Agriculture, Soil Conservation Service(SCS) has classified the soils at the.Site and 1n other highly built-upareas of Philadelphia County as Urban Lands. Urban structures cover somuch of this land type that Identification of the soils 1s not practi-cal. In most cases, urban lands have been smoothed, and the originalsoil material has been disturbed, filled over, or otherwise reworkedprior' to construction.
It 1s known through analysis of historical aerial photographs that thestudy area of the Cottman Avenue Site was part of the Delaware Riverprior to 1950. This area was gradually filled 1n. Filling operationsappear to have been completed sometime between 1950 to. 1967. Morerecently the entire surface of the southern portion of tHe site has beenregraded with fill placed over most of the land surface.
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2.8 CHEMICAL AND BIOLOGICAL PARAMETERS
There Is an extensive amount of data available on the chemistry of water,sediments, and biota in the Delaware River Estuary. Reports from bothprivately funded (industry, academia, non-profit, etc.) and publiclyfunded (federal, state, etc.) water, chemical, and biological monitoringprojects on the Delaware Estuary will be reviewed as part of this study.The public and private agencies will be contacted for information viaverbal communications.
Given the extensive history, accumulation of data, and small geographicsize of the Site, the available data will be carefully evaluated in con-junction with the sampling and analysis set out in the remainder of thisWork Plan. This Work Plan is designed to provide new data where neededand to fill in the gaps in the previous studies. Section 4.2.1.5identifies, some of the specific sources of data which will be reviewed aspart of the existing environmental baseline information.
L.
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3.0 SCREENING OF THE REMEDIAL INVESTIGATION AND FEASIBILITY STUDY
3.1 SUMMARY OF EXISTING DATA
The scoping of the Metal Bank RI/FS was accomplished by Initially review-Ing existing analytical data for the study arta. Data were then summar-ized and evaluated to determine existing and potential contaminant migra-tion and exposure routes. Site history was assessed to Identify targetcompounds which may exceed EPA criteria. Comparison of site contaminantswith ARARs will ultimately lead to the evaluation of the risks and, Ifnecessary, Identification of remedial technologies and alternatives forfurther remediating the Site.
EWK Consultants Incorporated of Washington, D.C., on behalf of Metal Bankhas prepared studies to determine whether the Cottman Avenue site repre-sents a significant risk to public health or the environment followingcompletion of the court ordered remediation. These studies are describedIn the attached letter from Edward W. Klepplnger, Ph.D., of EWK Consul-tants to Turner T. Smith Jr., of Hunton & Williams (common counsel to theGroup) dated May 23, 1988. These studies Include a public healthassessment encompassing: discharge of contaminated groundwater and ItsImpact on drinking water and aquatic life; past offslte deposits of PCBsand possible combustion by-products; and effects of residualcontamination In the mud flats. According to Dr. Klepplnger, the designof the study assumed that the court ordered remediation would becompleted and at that time the status of the Site would be as follows:
1. All recoverable oils would have been recovered.
2. Contaminated groundwater leaving the Site would be at aconcentration of 200 ppb or less with an average flow of1,300 gpd (Weston, 1978).
3. No visible spill area would remain onslte, the Site wouldbe stabilized with clean vegetative soils, and the bankwould be stabilized.
According to Dr. Klepplnger, his preliminary evaluation of these testsIndicate the following:
(a) groundwater 1n the separation tanks contained no detectablelevel of PCBs (I.e., less than 70 ppt);
(b) no fish tissue samples exceed the acceptable limit estab-lished by the FDA; and *"'
(c) levels of PCBs, PCDDs and PCDFs In soil were at backgroundlevels for an urban area.
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BCM]Dr. Kleppinger concludes that completion of the court ordered remediation"will result 1n a site that does not represent a significant threat topublic health or the environment."
These studies win .be assessed concurrently with all other pertinent siterelated data, following EPA's receipt of these studies and transmlttal toBCM.
The scope of the new Information that the RI/FS must develop was Identi-fied through existing data review, assessment of potential contaminantmigration and exposure routes, consideration of possible ARARs, and thescoping of preliminary technologies and remedial alternatives. Based onour current understanding of the available data, various activities havebeen Identified to collect the appropriate Information (I.e., subsurfaceexploration, sediment, and groundwater sampling).
The remainder of this section will document the findings of the scopingprocess and Identify the specific RI/FS objectives for meeting theproject goal.
3.2 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
Criteria must be used to provide performance levels for remedial alterna-tives. These criteria apply to the reduction of public health andenvironmental risks and the attainment of applicable or relevant andappropriate public health and environmental requirements (ARARs).
Remedial objectives have associated proposed ARARs which are chemicalspecific. The proposed ARARs for specific chemicals will be based uponhealth or risk based concentration limits or ranges 1n various environ-mental media.
A preliminary listing of possible Federal and State ARARs is containedwithin Tables 1 and 2, respectively.
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TABLE 1
PRELIMINARY LISTING OF POSSIBLE FEDERAL APPLICABLEOR RELEVANT AND APPROPRIATE REQUIREMENTS
COTTMAN AVENUE SITE
Requirement Rationale
1. Hazardous Waste Requirements (RCRA Standards applicable to treating, storing,Subtitle C, 40 CFR, Part 264) and disposing of hazardous waste.
2. Safe Drinking Water Act
a. Maximum Contaminant Levels (MCLs) Remedial actions may provide cleanup to the. MCLs.
b. Maximum Contaminant Level Goals SARA Section l2l(d)(2)<A)(11)(MCLGs)
c. Underground Injection Control May be applicable to onslte groundwaterRegulations (40 CFR, Parts 144, redrculatlon systems.145, 146, and 147)
3. Toxic Substances Control Act (15 May be applicable to cleanup.U.S.C. 2601). TSCA health data,chemical advisories, PCB spillcleanup policy.
4. Health Advisories,.EPA Office of RI activities may Identify presence of chemi-Drinking Water cal for which health advisories are listed.
5. Clean Water Act (PL92-500)
a. State water quality standards Remedial actions may Include discharge to(PA Code Title 25, Chapter 95) surface waters.
b. Federal water quality criteria Remedial actions may provide groundwater(FWQC) remediation and discharge to surface waters.
c. NPDES permit Remedial alternatives may Include dischargeto surface waters.
BCMTABLE 1 (Continued)
Requirement Rationale
6. Section 404(b)(l) Guidelines for Remedial alternatives at site may potentiallySpecifications of Disposal Sites Include dredging and filling 1n wetlands.for Dredged or Fill Material (40CFR, Part 230)
7. Rivers and Harbors Act of 1899 Remedial alternatives at site may affect the33 CFR Parts 320-327 Delaware River.
8. Dredged Material Disposal Sites Remedial alternatives at site may IncludeDenial or Restriction Procedures dredging and filling 1n wetlands.(404(0; 40 CFR, Part 231)
9. Regulation of Activities Affecting Corps of Engineers regulations apply to bothWater of the U.S. (33 CFR, Parts wetlands and navigable waters (Section 10,320-329) Waters).
10. Clean Air Act (42 USC 7401)
a. National Ambient Air Quality Remedial alternatives may Include Incinera^.Standards (NAAQS) for six tion.criteria pollutants (40 CFRPart 50)
b. Public health basis to 11st Remedial alternatives may Include indnera-pollutants as hazardous under tion.Section 112 of the Clean Air Act.
11. OSHA Requirements (29 CFR, Parts Required for workers engaged in onslte1910, 1926, and 1904) remedial activities.
12. Executive Orders 11988 (Floodplain Both floodplaln and wetland resources may beManagement) and 11990 (Protection affected by the site remedial alternatives.of Wetlands)
13. DOT Rules for Hazardous Materials Remedial alternatives may include offsiteTransport (49 CFR, Parts 107, treatment and disposal.171.1-171.500)
14. Endangered Species Act of 1978 Considered 1n the public health and environ-(16 USC 1531) mental assessment. »•••
15. Fish and Wildlife Coordination Act Remedial alternatives may affect wetlands and(16 USC 661) protected habitats.
AR302I02
TABLE 1 (Continued)
I.
Requirement Rationale
16. F1sh & Wildlife Improvement Act of Remedial alternatives may affect wetlands and1978 (16 USC 742) protected habitats.
17. Fish. & HildHfe Conservation Act of Remedial alternatives may affect wetlands and1980 (16 USC 2901) protected habitats.
18. Pesticide Registration, Tolerances, Pesticides are presently not considered siteand Action Levels contaminants.
19. Health Effects Assessments May be considered 1n the public health riskassessment included 1n RI report.
20. EPA's Groundwater Protection Strategy Remedial alternatives must consider EPAclassification of groundwater conditions atsite.
21. General Pretreatment Regulations for Considered for remedial alternatives inyol-Ex1sting and New Sources of Pollution vlng pretreatment of groundwater prior to(40 CFR Part 403). treatment at a POTW.
22. Stipulation between USA and City of Cleanup levels established for previous andPhiladelphia V. Metal Bank of America existing remedial actions.
A-R302I03
BCMTABLE 2
COMMONWEALTH OF PENNSYLVANIAPOSSIBLE APPLICABLE
OR RELEVANT AND APPROPRIATE STATE REQUIREMENTSCOTTMAN AVENUE SITE
Requirement Rationale
1. Pennsylvania Solid Waste Management Standards for treating, storing, and d1s-Act of hazardous wastes.
2. Pennsylvania Clean Streams Law Remedial actions may Include discharge tosurface waters.
3. Pennsylvania Solid Waste Disposal Standards for treating, storing, and d1s-Regulatiqns, PA Code Title 25, posing of hazardous wastes.Chapter 75
4. Pennsylvania Pollutant Discharge Remedial actions may Include discharge toElimination System (NPDES) Rules, surface waters.PA Code Title 25, Chapter 92
5. Pennsylvania Water Quality Standards, Remedial actions may Include discharge toPA Code Title 25, Chapter 93 surface waters.
6. Pennsylvania Wastewater Treatment Remedial actions may Include discharge toRequirements, PA Code Title 25, surface waters.Chapter 95
7. Pennsylvania Industrial Waste Remedial actions may Include discharge toRegulations, PA Code Title 25, surface waters.Chapter 97
8. Pennsylvania Special Water Pollution Applicable for permitted solid waste disposalRegulations, PA Code Title 25, facilities.Chapter 101
9. Pennsylvania A1r Pollution Control Incineration 1s considered a potentialRegulations, PA Code Title 25, remedial action.Chapters 121 through 143
10. Pennsylvania Stormwater Management Remedial actions mayKrequ1re stormwater man-Act of October 4, 1978, Act No. 167 agement systems.
AR302IOI*
TABLE 2 (Continued)
Requirement Rationale
11. Pennsylvania Erosion Control Regula- Soil disturbances during proposed remedialtlons, PA Code Title 25, Chapter 102 actions may require erosion and sedimentation
control measures.
12. Pennsylvania Hazardous Substances Applicable to wastes shipped offsite forTransportation Regulations PA Code analysis, treatment, or disposal.Title 13 (Flammable Liquids andFlammable Solids) and Title 15(Oxidizing Materials, Poisons, andCorrosive Liquids)
13. Pennsylvania N1ld and Scenic Rivers Considered 1n the public health and envlron-Act, Act of December 5, 1972, Act mental assessment. Remedial actions mayNo. 283 Include discharge to the Delaware River.
14. Rare and Endangered Species Regula- Considered In the public health and envlron-tlons PA Code Title 58 mental assessment.
15. Pennsylvania Dam Safety and Remedial actions may Impact waterwaysEncroachment Act, PA Code Title 25, regulated by this act.Chapter 105
16 Pennsylvania Water Nell Drillers Only properly licensed drillers will beLicense Act, PA Code Title 25, contracted for work covered by this act.Chapter 107
Source: Pennsylvania Environmental Research Foundation, Inc. 1980
SR302IQ5
BCM4.0 TASK PLAN FOR REMEDIAL INVESTIGATION
4.1 TASK 1 - PROJECT PLANNING
Included 1n this task are preparation and submlttal of the draft workplan, draft sampling and analysis plan, final work plan, and f'nalsampling and analysis plan. Activities comprising this task are:
- Data collection and review- Site reconnaissance- ARAR determination (preliminary)- Remedial alternatives Identification (preliminary)- RI/FS bralnstormlng and scoping- Phase 1 and 2 (If necessary) Work Plan preparation- Field Sampling and Analysis Plan preparation- Quality Assurance/Quality Control Plan preparation- Health and Safety Plan preparation
4.2 TASK 2 - FIELD INVESTIGATIONS
The following field Investigations are proposed for the RemedialInvestigation.
4.2.1 Initial Activities
4.2.1.1 Bid Specifications and Subcontractor Procurement
Bid specifications will be prepared and subcontractors will be procuredto accomplish all tasks of the Remedial Investigation as required. Sub-contractors will be procured for topographic mapping, soil borings andwell Installation; majority of other tasks will be conducted by BCM.
4.2.1.2 Topographic Map
A topographic map of the site and surrounding property will be devel-oped. The map will cover a 2,000 feet by 1,700 feet area according tothe following specifications:
- 1 Inch = 50 feet
- 1-foot contour Interval
- Horizontal control relative to Pennsylvania state planecoordinate system *"'
- Vertical control relative to mean sea level (USGS) datum
19
AR302I06
BCMThe map will be compiled by a licensed photogrammetrlst based upon arecent aerial photograph of the site. This map wil l then be usedthroughout the RI/FS process to develop figures for the RI/FS report.
4.2.1.3 Climatic Data Compilation
Climatic data for the study area will be collected to facilitatepotential environmental assessment and public health assessment transportmodeling. Data to be collected will Include:
- Wind direction data <w1nd rose)- Annual precipitation data- Flood records
4.2.1.4 Existing Well Survey
A survey will be conducted of state well records to determine 1f ground-water from the upper aquifer 1n the vicinity of the site Is potentiallybeing used for Industrial or home purposes. Data from this survey andother .sources will be used 1n the environmental assessment and publichealth assessment and to design the sampling program. Boring logs forexisting wells 1n the vicinity of the site will be obtained, ifavailable, from records of the Pennsylvania Department of EnvironmentalResources and other sources and analyzed to assess the geology of theregion. Well log analysis will be used to assess the thickness of theclay layer which reportedly underlies the site. A stratlgraphlcassessment of the region will be made with the Intent of developingtechnical data relative to vertical migration of PCBs or other Identifiedsite contaminants.
4.2.1.5 Review of Existing Environmental Baseline Information
This task will Include a compilation and review of environmental datafrom the STORET database and other sources, as available. Thl.s STORETdata review will establish a baseline characterization of the
I distribution of PCB in the environmental and biological media in the• general area. The review will focus on PCB analysis 1n and along the
lower Delaware and Schuylkill Rivers. Listed below are some of theagencies which utilize the STORET database as a data repository:
1. New Jersey Department of Environmental Protectiont = - -
2. Delaware River Basin Commission
3. USEPA Headquarters
1. 4. USEPA Region III *"'
5. USEPA Region II
20
H DQO9 I HI
6. Delaware Department of Natural Resource and EnvironmentalControl
7. City of Philadelphia, Pennsylvania
8. Pennsylvania Department of Environmental Resources
The available STORE! data will be categorized by media (surface water,sediment, biological sample) and location of the sampling sites.Follow-up contact will be made with select agencies or organizationsresponsible for the sampling/analyses to verify sampling and/oranalytical procedures and determine the usability of the data for theRI/FS and Public Health Assessment.
BCM will review other sources of Information specific to PCBs and theiri distribution 1n the area, Including, but not limited to, the following:
Corps of Engineers (COE), U.S.G.S., Academy of Natural Sciences ofPhiladelphia, data collected through the Delaware Estuary Program, PADER,NJDEP, EPA, NOAA, and F1sh and Nlldllfe. Analytical data from previousEWK studies (as available through EPA) will also be reviewed as part ofthis Initial task.
A preliminary search of scientific and technical journals found tenrelevant articles on modeling, monitoring or research specifically on theDelaware River Estuary. This material will be retrieved and reviewed.^Material on background or typical urban concentrations of PCBs and'related ch'emlcals will be obtained from the scientific literature as wellas Information for the area from Philadelphia's Air Management Servicesand the Torresdale Water Treatment Facility. The following paragraphsbriefly describe some specific sources of Information which will beexamined as part of'the existing environmental baseline Information.
In 1978, a comprehensive chemical-quality reconnaissance of the DelawareEstuary was performed by Sheldon and Kites (1978). Center channel grabsamples were taken from locations which stretched from Marcus Hook,
; Pennsylvania (river mile 78) to Trenton, New Jersey (river mile 132).The samples were analyzed for approximately 100 organic compounds.
In 1980-81, the United States Geological Survey (USGS) conducted anestuary-wide survey which screened both the water column and sediment formost of the 126 priority pollutants.
As a component of a study by the Delaware River Basin Commission (DRBC)called DEL USA, the DRBC and two of Its member states (Pennsylvania andNew Jersey) conducted a water quality/sediment screening survey of the
f Delaware Estuary In the spring of 1986 (DRBC, 1987a). The region of theL estuary Investigated 1n this survey stretched from T1n1cOm Island (river
mile 85) to the Burlington-Bristol Bridge (river mile 117.8). The surveyInvolved the screening of sediment and water column samples taken at 27locations (nine stations with three locations across the river at eachstation). Each sample (sediment and water column) was screened for mostof the 126 priority pollutan.ts.
21
A.R302I08
BCMThree other portions of the DRBC's DEL USA project focused on characteri-zation of aquatic life and the Impact of priority pollutants 1n the Dela-ware River. Results of these portions of the study were reported sepa-rately. The first report presents data from the Pennsylvania F1shCommission (PFC). on an Inventory of the fish populations collected duringthe summers of 1984-1986. A total of 53,499 fish and 53 species from theDelaware Estuary were collected (DRBC, 19875). The second report is on astudy of fish health (pathology) and fish tissue toxics conducted In theOctober 1986 to December 1987 period. Target fish (catfish family andwhite perch) were collected at ten locations 1n the Delaware Estuary.Individual fish and composites of fls.h were examined for general health,pathogens, tumors and lesions, parasites, specific enzymatic compounds,and organic and Inorganic toxics (DRBC, 1988). The third report 1s onthe use of bloassay to determine the toxldty of river water to aquaticorganisms (DRBC, 1986). In August 1986, grab samples were collected fromthe Delaware River at four different stations. Cerlodaphnla dubla andfathead minnow seven-day mini-chronic toxldty tests and Mlcrotox toxl-dty tests were performed on the water samples.T. Lloyd Associates (TLA), consultants to 'the US F1sh and Wildlife Ser-vice, conducted detailed biological studies of the project site andsurrounding environs on October 3-4, 11 and 18, 1979. TLA sampled thesite for fish, benthlc Invertebrates, water quality and depth. F1sh werecollected 1n eight trawls made adjacent to P1er 217 North and repeated onOctober 18, 1979. Also, a gill net was set parallel to the shorelineImmediately downriver from P1er 217 North for a period of approximately27 hours. Three bottom samples were obtained using a 0.25 meter ponardredge. The parameters measured Included temperature, pH, dissolvedoxygen, and waterflow observations.
The ecology In the Delaware River Estuary and adjacent wetlands werecharacterized with respect to the Site by the National GceanograpMc andAtmospheric Administration (NOAA) 1n 1984. This will be considered Inreview of the existing environmental baseline Information, as well.
BCM will also examine other Information relative to potential terrestrialand aquatic environmental receptors. Sources of Information may Include,but not be limited to, the following: contacts with F1sh and Wildlife,NOAA, Pennsylvania F1sh Commission and Game Commission for Information onEndangered and Threatened Spedes, environmental studies of the COE.This baseline Information will be useful 1n characterizing the localenvironment, Identifying potential target receptors and migrationpathways, and estimating risk 1n the Public Health Assessment.
A wetlands Inspection of the site will be performed prior to Implementingthe field sampling program. This site inspection will be for.the generalpurpose of Identifying any areas which may be classified* as wetlands 1naccordance with mult1-jur1sd1ct1onal regulations. An approximatedelineation of wetland areas on the site (1f present) will be sufficientprior to the field sampling program, as their locatlon(s) will be
22
ftR302!09
BCMconsidered 1n placement of the office trailer and construction of thedecontamination pad. A surveyed delineation of any Identified wetlandswill subsequently be performed, as their presence would be considered 1nboth the FS and Risk Assessment.
4.2.1.6 Mobilization
This subtask will consist of field personnel orientation and equipmentmobilization and will be performed at the Initiation of the field activi-ties as necessary. Mobilization tasks may Include but will not belimited to:
- Field team orientation meeting- Field office trailer mobilization- Health and safety decontamination equipment setup- Electrical, telephone, and potable water hookup- Drill rig mobilization- Underground utility Identification.
Site security measures will be addressed during mobilization. Althoughthe property Is currently fenced, additional measures will be taken toprotect the equipment used during the RI Investigation.
The field office will be secured and locked when not In use. Samplingsupplies, hand tools, and other small equipment will be stored 1n lockedfacilities, such as the office trailer or a separate shed. The drIU rigand other vehicles will either be secured at the site or removed from thepremises when not In use.
Vandalism to monitoring wells and piezometers 1s often a problem at urbanInvestigation sites. Steel protective casing with tamper-resistant lockswill be Installed at all monitoring well and piezometer locations uponcompletion.
During certain phases of the Investigation, a security service providinga uniformed guard will be contracted. During both the tidal study andthe aquifer (pump) tests, sensitive and expensive monitoring equipmentwill be 1n use and exposed across the site. For these operations, aguard will be employed to assure that there Is no tampering with thisequipment.
4.2.2 Soils Investigation
A soils Investigation will be conducted during the RI to collect datathat can be used 1n the Public Health Assessment and 1n assessing thehydrogeologlc setting. These surface soil samples will be collected toaugment previous samples and to assess exposure route's that may beassociated with soils within the study area.
23
4R302I10
BCMThere is a total of 73 pre-determined sample Intervals In the soilinvestigation program. Sixty-nine (69) of these samples will be obtainedfrom three pre-set Intervals In each of 23 drill-rig borings completedabove the water table, and'four of these samples will be obtained fromtwo pre-set intervals in each of two hand-auger borings. Other soilsamples may be selected for laboratory analyses, based on the criteriadiscussed in the following paragraphs of this section.
Twenty-three soil borings will be advanced through the fill materials tothe groundwater surface at the locations depicted on Figure 1. Oneboring will be placed adjacent to the former location of the concretedrain pad. Each of the 23 borings will be continuously sampled viasplit-barrel sampler technique. Samples from the unsaturated zone ofeach boring will be retained for analysis:
- The 0.0- to 0.5-foot depth interval immediately below anyfill added during 1989, if identifiable
- The 2.0- to 4.0-foot interval beneath the 1989 fill and olderfill contact if recognizable, or the 2.0- to 4.0-footinterval below grade if the contact is unrecognizable
- The 2-foot interval immediately above the groundwater tableIn addition to the predetermined depth Interval sampling stated above,each split-barrel sample will be scanned with an ultraviolet (UV) lightfor the fluorescence characteristic of oil. Any detected fluorescencewill be qualitatively assessed as to magnitude, with a temporary samplecollected. At completion of the soil boring, that interval with the
', highest fluorescence (If any) other than the predetermined sampleintervals will have the corresponding sample retained for analysis.
It is anticipated that an average of one additional sample per boringwill be designated for analysis based on the UV screening. If more thanone zone of significant contamination is suggested by the UV screening,
I then a field decision may be made to designate more than one additionali sample for laboratory analysis. Likewise, 1f there is no UV fluorescence
in a given boring, additional sample analysis may be eliminated.
j Six of the borings will be extended through the saturated portion of thefill to a depth of 10 feet Into the underlying clay or river alluvium. AShe 1 by tube sample will be collected from the top of any undisturbed
1 (i.e., natural) clay layer encountered in these six deeper borings.
The purposes of these six deeper borings are:
L 1. To ascertain the thickness of the saturated fill materialacross the site.
1^
24
flR302lI I
L
2. To provide geological characterization of the natural soilsunderlying the fill.
3. To provide samples of the natural soils for chemicalanalysis. .
The first deeper boring will be drilled near the former concrete drainpad where ti.e chance of encountering a floating oil layer Is consideredmore likely. The remaining five locations will be selected In the field,with locations biased toward those locations where floating product Isencountered. The UV screening technique will be used 1n the deeperborings as 1n the shallower ones. Soil samples from the natural clay/underlying alluvium will be selected for laboratory analysis 1f the UVscreening or visual observations Indicate the presence of oil.
The two soil boring locations 1,n the grass area north of Building 7 willbe sampled with a hand auger. Each location will be sampled from the0.0- to 0.5-foot and 1.5- to 2.0-foot Intervals.
All soil samples collected will be analyzed for TCL Pesticides/PCBs,total petroleum hydrocarbons <TPH) and total organic carbon (TOC)(Table 3).
Additionally, samples from each horizon (total of T2 samples) will beanalyzed for the U.S. ERA Target Compound List (TCL) volatile organiccompounds plus 10 tentatively Identified non-TCL compounds, polychlorl-nated dibenzofurans (PCDFs), and polychlorinated dlbenzodioxins (PCDDs).These 12 samples, plus 6 additional soil samples, will also be analyzedfor TCL semi volatile organic compounds plus 20 tentatively Identifiednon-TCL compounds, and TAL metals. The samples to be analyzed for theadditional parameters will be selected 1n the field. Furthermore, thesesamples will be selected from borings which are located within the limitsof the oil contamination (as defined on Figure 3.3 of the 1978 Westonreport and Figure 1 of this report). Several of the shallow soil boringsare in the area where incinerators were previously located. Aerialphotographs will be used to locate three of the soil borings at locationsof the incinerators.
Six Shelby tube soil samples will be collected from the confining layerfor laboratory permeability tests.
Because of the spatial density of soil borings, proposed wells or piezo-meters and soil boring locations are often very closely located (see Sec-tion 4.2.3.1). Because of this, and in the interest of cost and timesaving, five wells and two piezometers will be Installed in existing soilborings. Upon completion of soil sampling, the five soil borings adja-cent to monitoring wells 1, 3, 4, 11, and 12 (see Figure 1) will befurther advanced to the clay layer and the previously listed five wellswill be installed. Likewise, two of the three proposed piezometers (seeSection 4.2.3.1) will be installed within adjacent soil boring holes.
25
BCM———————— SUMH
*Number ofSamples for Number ofSpecific Field
Media Analysis Duplicates
Soil* 73* 10. (69 samples from 73* 10' pre-set depths in 73* 10
23 drill-rig bor- 12 1ings, plus 4 18 2samples from pre- 18 2
• set depths in 2 12 1hand-auger borings) 12 1
Sediment 39 3i (39 samples) 7 1
2 12 12 1
• ; 27 2
Groundwater 15 1(15 samples) 15 1
7 17 17 17 1
^^ (In select samples
Oil — Groundwater 4 1(4 samples) 4 1
4 14 1
Oil - Surface Water** 3 NRSeep 2 1Seep 2 NRSurface Water 4 1Surface Water 4 1
: Wipe Samples 18 2
i Benthic Organism 6 -; Tissue 6 -
' TABLE 3
HRY OF CHEMICAL SAMPLE ANALYSESCOTTMAN AVENUE SITE
! Microbiological 5 NR NR NR Epifluorescence Microbiological, (Bacterial Samples) Analysis (3 lab replicates per
- - • sample)
(1) Note - All surface water, qroundwater and sediment samples will also have Table 4 analyses (See Table 4).(2) TAL Inorganics Analysis will exclude cyanide as a parameter* Approximately 23 additional soil samples (one per boring) may be collected as a result of UV light screening
in the 23 borings completed above the water table. The UV screening will also be used to determine if anysamples obtained during the water table in 6 deeper borings will be submitted for laboratory analyses.
** Collection and analyses depends on presence of surface sheen and seep water.OPD - One per dayI NR - Not required."Source: BCM Eastern Inc. (BCM Project No. 00-6023-01)
5602y AR302I13
The remaining soil borings which are not completed as monitoring wells orpiezometers will be grouted to ground surface at completion of soilsampling.
4.2.3 Hydroqeologlc Investigation
The proposed hydrogeologlc Investigation 1s designed to: 1) define thesite geology and hydrogeology, 2) delineate the nature and extent of anygroundwater contaminants; 3) delineate the nature and extent of anyfloating product on the water table; and 4) provide data Input to theendangerment assessment and feasibility study.
Data generated via the water elevation survey and tidal monitoring pro-grams will be used to establish the groundwater flow direction andgradient.
Geologic and hydrogeologlc data developed during well Installation andwell monitoring will be used 1n conjunction with gradient and flow direc-tion data and pumping test data (permeability) to characterize thegroundwater system beneath the site.
Pump test data may also be used as necessary for development of the FS.Sections 4.2.3.1 thru 4.2.3.5 provide more detail regarding hydrogeologlcdata to be generated.
4.2.3.1 Monitoring Well Installation
Fifteen monitoring wells and three piezometers will be Installed 1n thefill material overlying the clay layer (Figure 1). Monitoring wells andpiezometers will be used to collect groundwater table elevation dataduring the pumping tests and water level elevation survey. In addition,monitoring wells-will serve as groundwater sample collection points andas aquifer test pumping wells. Well 1 will be used to determine 1f thereIs floating oil on the groundwater surface 1n this area. Any floatingoil found In well 1 will be sampled and analyzed for TCL Pesticides/PCBs. Well 12 will be used to evaluate the chemistry of groundwaterunder the northern portion of the site. Wells 9 and 10 will be used aspumping wells to determine aquifer characteristics for the fill materials(see Section 4.2.3.3). These wells are located within the area offloating product as defined by Weston (1978).
Monitoring wells and piezometers will be constructed from 4-1nch and2-1nch Inside diameter (I.D.) schedule. 40 PVC riser and screen (0.020-Inch slot), respectively. Thirteen of the monitoring wells will bescreened from the top of the clay layer to 5 feet above the water table.The two other monitoring wells will be screened below the water table tothe top of the clay to facilitate groundwater sampling Without possiblecontamination by any floating phase product. Locations of these twowells (not shown on Figure 1) will be determined following completion ofthe Initial 13 monitoring wells. Piezometers will be screened across the
27
water table to the top of the clay similar to the Initial 13 monitoringwells. Screen Intervals for both monitoring wells and piezometers willbe back filled with clean silica sand (e.g., Jes.sle Morle No. 2 sand) toapproximately 2 feet above the top of the screen. A bentonlte pelletseal will be gravity emplaced from ground surface atop the sand pack to athickness of 2 feet. A 10 percent bentonlte and cement grout will bepressure grouted via a tremle Into the borehole annul us from the top ofthe bentonlte seal to ground surface. A locking protective outer steelcasing will be Installed over the PVC well, with an outward slopingcement cap completing the well and piezometer Installation.
Following well and piezometer Installation, the wells will be developedby the drilling contractor via a centrifugal pump. Development waterwill be stored 1n tanks which will be transported to an appropriate wastedisposal facility as determined by waste classification analysis.
Following Installation, the monitoring wells and piezometers will besurveyed for horizontal and vertical control by a Pennsylvania licensedsurveyor. Existing wells and piezometers will also be surveyed forhorizontal and vertical control.4.2.3.2' Tidal Monitoring
A tidal monitoring program will be performed prior to aquifer testing toassess the tidal effects on the groundwater flow regime. River elevationdata from the closest USGS gauging station (approximately 3,000 feetdownstream of the site) will be obtained and correlated to short Intervaldigital level recorder data collected from eight site wells. Data willbe collected over a 3-day period. Tidal measurements will also beobtained at a temporary gauging station established Immediately adjacentto the site.
4.2.3.3 Water Level Elevation Survey
Four complete rounds of water level measurements will be performed todevelop data necessary to establish an accurate assessment of the ground-water flow direction. Each round will consist of measuring the depth tothe water table and the thickness of any floating oil for each well andpiezometer. If possible, water level measurements from existing wellsand piezometers at the site will also be used.
4.2.3.4 Monitoring Well Sampling
A groundwater sample will be obtained from each of the 15 new monitoringwells a minimum of 2 weeks after well development. Well sampling pro-cedures and sequence will be as follows: K,
1. Measure depth to water table.2. Measure thickness of oil (1f present) floating on water.
28
A R 3 0 2 I 1 5
BCM3. Sample oil (If present) floating on water.4. Purge well of 3 to 5 well volumes of water.5. Sample groundwater.
Analysis for the chemical/physical parameters listed In Table 4 forgroundwater will be Included for all samples.
Depth-to-water and oil thickness will be measured with an Interface probewhich will be confirmed with the wetted tape method. The separate phasefloating oil will be sampled using a Teflon bailer. Well purging andgroundwater sampling will be accomplished using a peristaltic pump anddedicated well hose. 011 thickness (1f present) and depth-to-groundwaterwill be measured on the day the well sampling occurs. In addition, around of depth-to-groundwater measurements will be made 1n all wellsduring one of the days that sampling Is underway.
In the wells screened above the water table, samples of floating oilcollected from the four wells with the thickest separate phase floatingoil layer (If present) will be analyzed for TCL Pest1c1des/PCBs and fullTCL scan plus 30. Currently, It Is assumed that Well No. 1 will be oneof the four wells.All of the groundwater samples will be analyzed for TCL Pest1c1des/PCBsand TPH. Additionally, seven groundwater samples will be analyzed forTCL Organlcs plus 30 and TAL Inorganics. The locations of these sevensamples will be selected In the field. If PCDDs and PCDFs are found Inthe soil, the floating oil layer (If present) will also be analyzed forthese chemicals during a second phase of the Investigation. For theseven TAL metal analyses, samples will be collected for both filtered andunflltered sample analyses at the same Intervals. If soil analyticalresults from the RI program are available prior to groundwater sampling,these results will be considered In selecting the well locations formetals analyses. The usefulness of unflltered sample analyses for metalsmay be discussed with the EPA 1n view of the metal concentrations 1nsoils and groundwater usage In the area (which will be determined bycompletion of the area well Inventory). The applicability of theunflltered analyses In the public health assessment will be evaluatedwith consideration to these factors.
Groundwater samples taken 1n the presence of a floating oil phase aresusceptible to trace contamination of the water sample by the oil phase.Currently, the difficulties associated with two-phase sampling have notbeen completely resolved. The potential approaches to avoid or clarifythe possibility of trace levels of oil 1n groundwater samples are asfollows:
1. Two wells screened below the level of the waterKtable willbe sampled to attempt to exclude any floating product fromthe well.
29
AR302I 16
TABLE 4
CHEMICAL/PHYSICAL PARAMETERS
A. Surface Water and Groundwater
1. Field Parameters
TemperatureDissolved Oxygen (DO)
1 EhPHSpecific Conductance
2. Laboratory Parameters
i Total Suspended Solids (TSS)AlkalinityHardness
f total Dissolved Solids (TDS)Total Organic Carbon (TOC)
f Grain size analysis (ASTM Method with hydrometer analysis)
% solids (RAS)
Note: Laboratory permeability analysis may be assigned.
5602y17
2. All groundwater samples will be taken with a special samplingprocedure for organlcs recommended by EPA (Superfund methods).This method Involves suction lift of the water via a 6mm teflontube Into the sample container at the ground surface.
3. Analysis of individual PCB isomers will be done on any ground-water sample with detectable levels of PCBs. Information on thesolubility of the individual PCBs isomers will be ussd todetermine 1f there Is a preponderance of isomers present abovesolubility limits. Such a finding would indicate the presenceof trace levels of oil.
4.2.3.5 Pumping Tests
Pumping tests will be performed on the two proposed pumping wells todetermine the aquifer characteristics of the fill materials with respectto recovering contaminated groundwater.
Important aspects of the test Include determination of the degree of fillmaterial heterogeneity, the extent and geometry of the radius ofinfluence of each test well, and identification of hydrologlc boundaries.
Proposed soil borings through the saturated fill will provide preliminaryInformation on the variability of the material before conducting theaquifer tests. Three-day monitoring of water level changes 1n site wellsbefore the aquifer tests will aid in characterization of tidal influences.
Two constant flow rate aquifer tests up to 48 hours long will be carriedout. This test duration should be adequate for establishing a steady-state flow condition. The test duration should also be long enough forestablishing tidal fluctuation impacts on groundwater flow and foridentifying hydrologlc boundaries. A low pumping flow rate will beestablished to avoid dewatering the test wells at low tide. Recoverymonitoring of the aquifer will continue until the pumping test wells haverecovered to 90 percent of the original static water level, provided thistakes place over a reasonable time period (1 day maximum).
If results of the aquifer tests Indicate extreme heterogeneity of thefill material select wells will be 1n situ permeability tested (slugtested). Test wells will be chosen based on the aquifer test results, toprovide a cross-section of fill permeabilities. P'roposed construction ofthe majority of the monitoring wells across the water table dictates thatcollection of rising head rate data will be emphasized.
Pumped water will be handled 1n the same manner as well developementwater (see Section 4.2.3.1). Digital level recorders will be utilized tocollect drawdown and recovery data from the pumping w"ell and nearbymonitoring wells or piezometers for each pumping test.
31
10
Tidal monitoring data (see Section 4.2.3.2) wm be collected concurrentwith the pumping tests (If necessary). These data win be used tocorrect for any tidal influence on the flow regime.
4.2.4 Sediment. Seep. Surface Hater, and Biological Sampling
The objective 1s to perform chemical analysis for TCL Pest1c1des/PCBs andselected other parameters on sediment, surface oil, seep, and watersamples from the tidal mud flat area Immediately adjacent to the CottmanAvenue site. The sample collection procedures will be biased toselectively sample any visible oil sheen and determine the distributionof any PCBs detected 1n sediment, suspended sediments, water or oilsheen. Microbiological samples for bacterial cell counts will also becollected adjacent to PCB sample locations.
; 4.2.4.1 Sediment and Benthlc Organism Sampling
Sediment sample locations are:
- Five locations bordering the riprap (total of 11 samples)
- Twelve locations In the mud flats (total of 18 samples)
- Three locations along each of three transects (total of 9samples) extending Into the Delaware River. These transectsare shown on Figure 1 from the southwest, southcentral, andsoutheast locations of the site.
- One location Immediately downstream of the site
Specific locations for sediment samples along the rip-rap will bedetermined 1n the field following a walking survey of the r1prrap area,during which areas of the bank will be probed with a shovel and visibleobservations of any substantial oily sheens will be noted. Therefore,the five rip-rap sediment locations shown oh Figure 1 may be subject to
: change. BCM will discuss the results of the walking survey and therationale for selection of the actual sampling locations prior toImplementing the rip-rap sampling.
For the rip-rap sediment locations, surface samples (0.0 to 0.5-footdepths) will be collected at all five locations. At the three locationsclosest to the known spill area, additional samples at 0.5 to 1.0-footdepths, and at 1.0 .to 1.5-foot depths will also be collected. Thus, the
1 total number of sediment samples at the five rip-rap locations 1seleven. All 11 samples will be analyzed for TCL PCBs/pest1c1des . and
I TPH. For two selected surface (0.0 to 0.5-foot) locations, analyses forL TCL semi-volatile organlcs + 20, PCOFs, and PCDDs will be" Included. All
11 rip-rap area sediment samples will be analyzed for the chemical/physical field and laboratory parameters listed on Table 4.
32
flR302l 19
Three sediment samples will be obtained from each of three transects fromthe rip-rap toward and Into the Delaware River. The locations are shownon Figure 1 and may be changed 1f, during the walking survey of therip-rap, a seep 1s noted; In such case, a transect will be Initiated'atthe seep location. For the transects, the sample locations will bespaced approximately 15 feet apart; this distance may be shortened If awater depth greater than 15 feet 1s encountered. Samples will becollected from the upper one foot of sediment at each transect location.The nine samples will be analyzed for TCL PCBs/pest1c1des, TPH, and forthe chemical/physical field and laboratory parameters listed In Table 4.One sample from the transect by the southeast corner of the property willalso be analyzed for TCL semi volatile organlcs + 20, and TAL Inorganics.
One sediment sample will be obtained downstream of the site, at alocation off the end of the Quaker City Marina. This sample will becollected from the upper 0.5 feet of sediment at a location within fivefeet of the shoreline. This sample will be analyzed for TCL PCBs/pesticides, TCL semi volatile organlcs + 20, TAL Inorganics, and TPH.This sample will also be analyzed for the chemical/physical field andlaboratory parameters listed on Table 4.
Initially, a total of 12 samples will be obtained 1n the mud flat areaadjacent to the site. These locations are shown on Figure 1 as threetransects, each consisting of four sampling locations. The samplespacing 1s arranged such that the closer spaclngs are closer to thesite. The 12 samples will be collected from the upper 0.5 feet ofsediment. These samples will be analyzed for TCL PCBs/pestlcldes. Threeof the 12 <1.e., the one along each transect closest to the site) willalso be analyzed for TCL semi volatile organlcs + 20. All 12 samples willalso be analyzed for the chemical/physical field and laboratoryparameters listed on Table 4.
In addition to the 12 sediment samples along the three transectsdiscussed above, approximately six additional sediment samples will beobtained during the benthlc organism sampling at these samplinglocations. The benthlc organism sampling locations will consider theresults of the Initial sediment analyses. Consequently, the locations ofthese approximately six additional sediment locations will be determinedat a later date. Currently, 1t 1s anticipated that these samples will becollected from the upper 0.5 feet of sediment and that analyses will beperformed for TCL PCBs/pestlddes, TPH, and the chemical/physical fieldand laboratory parameters listed on Table 4.
The results of the river, rip-rap area, and mud flat sediment analyseswill be considered along with other Information developed through theRI. The usefulness of sediment analyses from the river will beconsidered along with the existing environmental Information andhydraulic and sediment transport factors, before It Is determined thatthe analyses of the river sediment samples are usable for sitecharacterization and public health assessment purposes.
33
AR302120
BCMAs mentioned above,' benthlc organism sampling will be performed atapproximately six locations. The number of locations may change based onthe sediment sampling results. The purpose of these analyses is toassess potential bioaccumulation in biota. A benthic macroinvertebrateorganism survey will be conducted in the immediate vicinity of, and atthe time of, the initial sediment sampling.
The purpose of the L?nth1c macroinvertebrate organism survey is toIdentify species which may be present in adequate densities, and whichare appropriate, for tissue sample analyses. Currently, the clam speciesCorbicula is considered a candidate organism. A list of the speciesfound during the benthic macroinvertebrate organism survey will bepresented to the EPA. Actual species selection for chemical analyseswill be made after review of the survey data In conjunction with theEPA. Likewise, if the collection of adequate tissue material isquestionable, decisions on location, availability, and suitability oftissue samples will be discussed with the EPA.
The collection of the benthic organism samples will proceed in thefollow.ing general manner. Collection of the target species will beconducted until sufficient tissue Is obtained. If too few organisms arefound at the sample site, then animals from the surrounding area willalso be collected. If surrounding areas are sampled for biota, the areaof sediment collection will be likewise expanded. The biota will bedescribed at the time of sampling.
The benthic organisms will be analyzed for TCL PCBs/pesticides. Inaddition, total lipid content of the samples will be determined bylaboratory procedures.4.2.4.2 Seep Samples
The objective 1s to collect a sample of water leaving the site, quantifyany oil and/or PCBs present, and distinguish between PCBs in oil or waterand PCBs adhering to suspended soil material. The tidal characteristicsof the river, topography of the site, limited evidence of oil sheen andabsence of definitive sampling methodology for oil sheen preclude anexact description of seep sample collection. Rather, site-specificdecisions will need to be made at the time of collection. The followingis a preliminary description of the approaches that will be used tocollect the seep samples.At low tide, two seep samples, if possible, will be collected with which-ever of the following techniques is most feasible: 1) filling a samplingbottle directly from a stainless steel tube inserted into the seep area,or 2) collection of water in a four liter borosilicate beaker positionedimmediately below a seep area. One sample from the selected seep will beanalyzed as a total sample for TCL Pesticides/PCBs and TPH. The sameanalysis will be conducted on the supernatant water from the secondsample after allowing suspended solids to settle out for 24 to 48 hours.
34
AH 302 I
BCM4.2.4.3 Surface Water Samples
The objective of the water samples will be to differentiate between PCBsdissolved in the water, and PCBs attached to suspended solids. It 1sexpected that the sample locations will be 1n the tidal flats during theebb tide while there 1s still sufficient water to submerse a samplebottle.Two water samples will be collected at each of two locations for a totalof four samples. The bottles will be opened under the water surface toexclude any oil 1n the surface layer. At each of the locations, onesubsurface sample will be analyzed for TCL PC6s/Pest1c1des and TPH whileonly the supernatant water will be analyzed for these same parameters 1nthe other sample. The analyses on the supernatant water 1n the samplebottle will be done after standing for 24 to 48 hours to allow settlingof suspended sol Ids.4.2.4.4 Surface 011 SamplesFor surface oil, three samples will be collected by dipping a clean glassplate vertically Into water 1f sheen 1s present. Oily material whichclings to the plate 1s then scraped Into a sampling jar (Harvey andBurzell, 1972). The analyses for PCB oil requiring 5 to 15 mis will beused.
4.2.4.5 Microbiological Samples
Five quantitative surface sediment samples will be collected adjacent toPCB sampling locations. The bacteria will be dislodged from the sediment(Kaplan and Bott, 1989) and counted with a fluorescent stain (Porter andF1eg, 1980), three replicates per sample. The results will be expressedIn bacteria cells per unit area.
4.2.5 Buildings
Wipe samples for TCL PCBs/Pestlddes analyses will be taken 1n twobuildings on the site at locations to be selected by EPA, BCM, and Dr.Klepplnger for Metal Bank. Ten samples will be taken from Building 7(map In Attachment 1) and eight samples from Building 2.
4.3 TASK 3 - SAMPLE ANALYSIS AND DATA VALIDATION
4.3.1 Sample Analysis
Table 3 Identifies the number of analyses to be completed as part of theRemedial Investigation. Table 3 also provides an estimate of the numberof QA/QC samples to be analyzed. EPA's Annapolis lab will approve theQA/QC program. All analyses will be performed by a CLP certified labora-tory or a laboratory performing CLP protocol and providing CLP deliver-ables packages. The laboratory will be approved by the EPA.
35
4.3.2 Quality Control and Data Validation
Validation Is a systematic process of reviewing a body of data to provideassurance that the data are a'dequate for their Intended use.
The review and validation of the laboratory data win be conducted bychemists using the following ERA documents:
- USEPA, 1988. Laboratory Data Validation. Functional Guide-lines for Evaluating Organic Analysis. Hazardous SiteEvaluation Division. USEPA - Washington, D.C. February 1988.
- USEPA, 1988. Laboratory Data Validation. Functional Guide-lines for Evaluating Inorganic Analyses. Hazardous siteEvaluation Division. USEPA - Washington, D.C. June 1988.
Additional documents on special procedures will be used wheneverappropriate.
Several factors that will be considered are sample holding times, Instru-ment calibration, blank results, surrogate recoveries, matrix spike/matrix spike duplicates, cha1n-of-custody, and any other control proce-dures that are applicable.
4.4 TASK 4 - DATA EVALUATION
The purpose of this task Is to organize the validated data collected fromthe field and laboratories Into a working format for analysis, and thenperform the necessary evaluations to meet the project objectives.Task 4, therefore, has two distinct components; data reduction and dataevaluation. Following are brief descriptions of these components.
- Figures displaying boring and monitoring well locations andelevations
- Various hydrogeologic cross-sections
- Flow nets and groundwater contours
- Well log descriptions- Aquifer test data
4.4.1 Data Reduction>•'Data obtained from the various field Investigations will be condensed and
organized to facilitate evaluation and presentation. Reduction of hydro-geologic data will result In the production of various tables, figures,and drawings describing and summarizing the pertinent site features.
36
AR302I23
BCMData reduction wm be facilitated by computerization. The computerizedsampling and analytical data base will be amenable to format manipulationand creation of different sorting profiles. Sorting profiles will.assist1n evaluating the occurrence and distribution of contaminants within thedifferent media. Appropriate tables, maps, and figures will be producedto summarize the occurrence and distribution of contaminants at the siteand adjacent environs.4.4.2 Data Evaluation
Once the data 1s reduced to a usable format, 1t will be reviewed and; evaluated 1n order to determine 1f the RI/FS project objectives have beenI met. If additional data 1s required to perform the Phase 3 FS (detailed
alternative evaluation) Including treatabillty tests as necessary andf additional field data as necessary to refine general site characterlza-| tion, a Phase 2 RI may be conducted.
! 4.5 TASK 5 - PUBLIC HEALTH ASSESSMENT
The Public Health Assessment (Task 5) and Environmental Assessment (Task6) collectively constitute the Risk Assessment (RA> portion of theRI/FS. The RA will follow accepted EPA protocols Including, but notnecessarily limited to, those presented 1n the documents "Risk AssessmentGuidance for Superfund: Volumes I and II," April 1989 (EPA/540/1-89/002). The Public Health Assessment portion of this RA will befinalized by EPA or the EPA contractor, with close coordination and Inputfrom BCM.
The role of BCM In the Public Health Assessment Is to collect site-specific data needed for the assessment and to assimilate the data 1n aform suitable for preparation of the RA report. Because the RA 1s sointegrated with the overall RI/FS process, and because performance of theFS depends heavily on the assessment results, the involvement of BCM withEPA during the various steps of the assessment Is essential.
During the course of the RI, BCM will collect site-specific Informationrequired to conduct the RA, and to supplement the chemical and physicaldata listed In previous sections of this work plan. A determination ofadditional site-specific information, 1f any, needed to complete the RAmay be made by EPA in coordination with BCM.
Site-specific information for the RA will Include, but not necessarily belimited to, that listed for the following tasks (EPA, 1989):
1. Characterization of physical setting; ^
2. Characterization of potentially exposed human health andenvironmental populations
37
Based on the RI data, BCM will assimilate the data In a report for EPA'suse 1n the Risk Assessment.
The report will provide the pertinent Input parameters for the PublicHealth Assessment. BCM will meet with EPA to discuss the use of theacquired Information during these steps. In accordance with the currentEPA directive concerning Risk Assessments (ONSER Directive No. 9835.15),EPA has no specific obligation to utilize the Risk Assessment input datacompiled by BCM. BCM will review the results of the Public HealthAssessment completed by EPA. It is desirable that interpretativedifferences be resolved between BCM and EPA before subsequent steps ofthe RA are performed because remedial alternative performance goals andanalysis of risks for the remedial alternatives are based on the RA, andparticularly that data developed for the Public Health Assessment.It is assumed that EPA will present the Public Health Assessment in adocument. Their results will be considered by BCM In performance of theFS.
The following RI and RA coordination steps involving the EPA RiskAssessor are anticipated:
1. The EPA risk assessor attends all site-scoping meetings andvisits the site. The PRP contractor and the EPA riskassessor discuss potential exposure routes, for thepurposes of RI data' collection.
2. The PRP contractor prepares the Work Plan, and the riskassessor reviews it.
3. The EPA risk assessor attends an RI-prev1ew presentation bythe PRP contractor, if asked. The contractor may use thismeeting to present the PRP's ideas on exposure routes andscenarios, based on data collected for the RI. The EPArisk assessor defers decisions on these matters until afterreviewing the draft RI.
4. The EPA risk assessor reviews and comments on the draftRI. If asked, the EPA risk assessor meets with the PRPcontractor to explain the comments and discuss possibleInput variables for the public health assessment.Considering the PRP's data, EPA guidance, best science, andprofessional judgement, the EPA risk assessor selects themost appropriate input variables. These selections are theresponsibility of EPA alone; this is the heart of the newpolicy.
38
5. The ERA risk assessor calculates the risks and writes thepublic health assessment. The assessment, labeled "draft,"1s Immediately sent to a TES contractor for QA review. Atthis stage, the assessment 1s considered work 1n progressand remains confidential, for the same reasons unrevlewedchemical data are confidential.
6. The ERA risk assessor reviews comments from the QA reviewerand resolves all Issues by revising the public healthassessment or conferring wl.th the reviewer. The draftpublic health assessment 1s sent to the PRP for review.
7. The PRP reviews the draft public health assessment andsubmits comments. The QA review contractor, afterconferring with the ERA risk assessor, responds to eachcomment. The ERA risk assessor revises the public healthassessment to address all PRP Issues which the ERA riskassessor and the QA reviewer agree are valid. The FinalDraft public health assessment 1s Incorporated Into theadministrative record.
4.6 TASK 6 - ENVIRONMENTAL ASSESSMENT
This assessment will consider the presence of potential terrestrial andaquatic environmental receptors Including, but not limited to threatenedor endangered animal and plant species. The assessment will alsoconsider the ecology of the wetlands adjacent to the site (e.g., wetlandsdelineation and functional value determination) and the potential forImpact from the release of contaminants at the site. The evaluation ofthe animal and plant life will be based on an analysis of the site and
-existing Information for the Delaware River collected 1n Task 4.2.1.5.The potential for primary Impact will be modeled using release ofcontaminants from the site and will be evaluated using the tissue datathat may be collected as discussed 1n Section 4.2.4 of this work plan.The environmental assessment will address bloconcentratlon of thechemicals and possible toxic effects on biota.
The environmental assessment will follow accepted ERA protocols,Including, but not necessarily limited to Risk Assessment Guidance forSuoerfund Volume II: Environmental Evaluation Manual (EPA/540/1-89/001),and Ecological Assessment of Hazardous Haste Sites (EPA/600/3-89/013).
1 The risk analysis and the environmental assessment will be discussed 1n acontext which considers contamination present In the soils and -Delaware
i River which 1s unrelated to the site. This Information will be gatheredi. from existing studies on contamination In area soils afid the Delaware
River. In the Delaware River, existing data on concentrations of chemi-cals 1n the water, sediments, and biota will be examined to determine therelative contribution of contaminants from the site.
39
AT> lr>2 13 C,
I.
The RI data assimilated Into a BCM report for EPA's use 1n the RiskAssessment will. Include data specifically useful for the EnvironmentalAssessment. In accordance with the current ERA directive concerning RiskAssessments (OSWER Directive No. 9835.15), EPA has no specific obligationto utilize the Risk Assessment Input data compiled by BCM.
The 7 coordination steps Identified 1n Section 4.5 for the Public HealthAssessment apply as well to the Environmental Assessment.
4.7 TASK 7 - TREATABILITY STUDY PILOT TESTING
The need for treatablHty studies and/or pilot testing will be evaluatedfollowing completion of data validation/evaluation and the Initialscreening of remedial technologies. Prior to the Initiation of anystudies, a meeting will be held with EPA to review the objectives, scopeof work <1f any), and proposed schedule.
4.8 TASK 8 - REMEDIAL INVESTIGATION REPORT
This task encompasses the preparation of the draft and final versions ofthe Remedial Investigation Report. The RI report w1.ll Include theresults of the previously discussed tasks Including the following:
- Site surface and subsurface conditions
- Extent and nature of soil, groundwater, sediment, and build-ing (Nos. 2 and 7) contamination (1f any)
- Hydrogeologlcal condition and aquifer parameters
- Analytical data and QA/QC backup
- Results of public and environmental assessments
* - When finally published, the RI and FS will be one document.
40
4R302I27
BCM .5.0 TASK PLAN FOR FEASIBILITY STUDY
The Feasibility Study (FS) win be conducted in three phases. TheInitial phase of the FS will be Implemented during the time that ERA 1sreviewing the Phase I RI draft report. Concurrent RI/FS activities willexpedite completion of the FS.
The FS will be prepared 1n accordance with the Interim Final Guidance forConducting Remedial Investigations and Feasibility Studies Under CERCLA,(October 1988, Guidance on Preparing Superfund Decision Documents (July1989). CERCLA Compliance with Other Laws Manual 1 Parts I and II (August1988 and August 1989).
5.1 TASK 9 - IDENTIFICATION AND DEVELOPMENT OF REMEDIAL ALTERNATIVES(PHASE I)
5.1.1 Development of Remedial Response Objectives and Response Actions
Should remedial alternatives be necessary, applicable or relevant andappropriate requirements (ARARs) will be Identified to aid 1n the devel-opment of appropriate remedial alternatives. ARARs Include not onlyfederal laws, but also state laws and local (City of Philadelphia) lawsIf they are more stringent and promulgated.
The results of the RI Endangerment Assessment and the comparison of sitecontaminants with ARARs will be used to develop any necessary remedialresponse objectives for the Cottman Avenue site. Cleanup levels will bedefined so that any risk to public health and the environment are m1t1-
: gated to an acceptable level.
The remedial response objectives will be the basis by which a 11st ofapplicable technologies will be Identified. To the maximum extent prac-
'. t1 cable, remedial actions that utilize permanent solutions and alterna-tive treatment technologies or resource recovery technologies willspecifically be considered. To the extent possible, treatment optionswill emphasize alternatives that eliminate the need for long-term manage-ment at the site and that would reduce toxldty, mobility, and volume.
5.1.2 Identification of General Response Actions
> Based on the data collected during the RI and the remedial responseobjectives established, general response actions, 1f necessary, will be
I further defined. Should site remediation be required, appropriate[. response actions may Include contamination contalnmertt, contaminant
removal, onslte treatment, 1n-s1tu treatment, and/or no-action. Theno-action response will be considered as a baseline against which anyother responses are measured.
41
R ft 3 fi 9 i o n
The scope of work presented In the RI Hork Plan 1s intended to provide abasis for determining potential impact to the various media, Includingair. If it is determined that the building wipe samples and surface soilsamples from the borings are not adequate to provide the data required toassess potential impact to the air media, then air monitoring/samplingand, as appropriate, dispersion modeling will be conducted.
5.1.3 Identification of Appropriate Technologies and Assembly ofRemedial Alternatives
Based on the identified list of appropriate response actions, a list ofremedial technologies will be compiled. Site conditions in conjunctionwith available remedial technologies will then be considered towardassembly of the site-specific remedial action alternatives.
5.2 TASK 10 - SCREENING OF THE REMEDIAL TECHNOLOGIES AND ALTERNATIVES(PHASE II)
Phase II of the FS 1s an initial screening of the identified technologiesand alternatives. The objective of this effort is to eliminate from fur-ther consideration those technologies/alternatives that are not effective(from an engineering or institutional standpoint), or are too costly.The range of technologies/alternatives will be refined by eliminating:
- Technologies/alternatives that are not effective because theyhave adverse environmental impacts, do not provide adequateprotection of public health, or do not attain ARARs.
- Technologies/alternatives that are more costly than otheralternatives/technologies and do not provide greater environ-mental or public health benefits, reliability, or a more per--manent solution.
Reasons for elimination of any technologies/alternatives at this stagewill be documented in the FS report.
5.3 TASK 11 - DETAILED ANALYSIS AND EVALUATION OF ALTERNATIVES(PHASE III)
The alternatives that pass the Phase II initial screening will be furtherevaluated and compared as required in CERCLA as amended by SARA. Boththe short- and long-term effects for each alternative will be evaluated.Long-term effectiveness factors will include those cited in SARA Section121(b)(l). The effectiveness of the alternatives will be assessed,taking into account whether or not the given alternative*"adequately pro-tects human health and the environment, whether it attains federal andstate ARARs, whether it significantly and permanently reduces the toxi-city, mobility, or volume of any contaminants, and whether it is techni-cally reliable.
42
4R302I29
BCM
L
Alternatives will "be evaluated against implemental factors, Including thetechnical feasibility and availability of the technologies each alterna-tive would employ; the technical and Institutional ability to monitor,maintain, and replace technologies over time; and the administrativefeasibility of Implementing the alternative.
Finally, the costs of construction and the long-term costs of operatingand maintaining the alternatives will be analyzed using pre.ent-worthanalysis.
5.4 TASK 12 - FEASIBILITY STUDY REPORT
The Feasibility Study Report will be prepared 1n order to document andsummarize the procedures described 1n the previous paragraphs of thissection. Generally, the report will Include six Individual sections. Asummary of site characteristics along with the Endangerment Assessmentand the Identification and selection of ARARs wVll be presented 1n Sec-tion One. Section Two will present a detailed description of the screen-Ing of remedial actions and technologies. A discussion of proposedremedial action alternatives will be presented In Section Three and adetailed evaluation and cost analysis of the alternatives will beIncluded in Section Four. Section Five will summarize the Identifiedremedial action alternatives. A letter will accompany the FS Report, Inwhich the remedial action recommended by the PRPs will be Identified anddiscussed. This letter will be developed from Information presented 1nSection Six of the FS.
During the development of the Draft FS Report, a meeting will be conduc-ted at the EPA Region III office to further discuss the alternatives con-sidered during the FS.
43
'AR302l3fi
L
BGM6.0 PROJECT MANAGEMENT APPROACH
6.1 ORGANIZATION AND APPROACH
The proposed project organization for the RI/FS 1s shown on Figure 2.Frederick M. Poll, P.E., Senior Vice President and manager of BCM'sIndustrial Environmental Services Department, win be the Pr1nc1pal-1n-Charge of this project. Project management and coordination win be pro-vided by Daniel E. Erdman, P.G. CPGS. Glenn C. Randall will be thedesignated Task Manager for the Remedial Investigation. The designatedTask Managers for the Feasibility Study and Environmental Assessmentportions of the project are R. Thomas Numbers, P.E. and Daniel Smith,Ph.D., respectively.
The Project Manager will coordinate the services of outside contractorsas needed. Together with the Pr1nc1pal-1n-Charge, the Project Managerwill ensure staff availability and coordinate Interdisciplinary andInterdepartmental efforts required for efficient completion of thisproject. Laboratory services will be coordinated through Rocco Alessan-dro, Ph.D., Manager of BCM's Laboratory, as both the BCM laboratory andoutside laboratories will be utilized on this project.Christian M. Schnelder 1s the Health and Safety officer designated to theproject, whose responsibilities will Include development of the site-specific health and safety plan. Steffan Helblg, Assistant Vice Presi-dent, will provide technical consultation 1n geology and hydrogeologyduring the project. Carol R. Collier, a Vice President at BCM, and LindaHenry, Ph.D., a contracted consultant, will provide technical consulta-tion 1n the area of the Environmental Assessment and related Issues.Experienced personnel 1n required disciplines will be assigned to projecttasks as needed from BCM's staff.
6.2 QUALITY ASSURANCE
At BCM, the overall quality assurance for a specific project Is theresponsibility of the designated Pr1nc1pal-1n-Charge. Several specialityroles of quality assurance are also provided with the RI/FS, as shown onFigure 2. HI 111am Fleming, P.E. 1s the Quality Assurance/Quality Controlofficer whose general responsibility will be assuring that the projectproceeds In accordance with USEPA accepted protocols. Quality Assuranceof analytical data, Including validation of laboratory results, will bemanaged through Atwood F. Davls.
44
AR302I3I
6.3 PROJECT SCHEDULE
Figures 3 depicts the schedule of tasks and activities for the CottmanAvenue site. The schedule for the field Investigation assumes that nosite restrictions win be encountered and Is dependent upon EPA approvalof the Work Plan which will be developed using this document as a basisfor the scope of work as stipulated In the signed consent order.Since the actual start date 1s not yet established, the RI schedule mayrequire revision based on the Impact of winter weather on fieldactivities.
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1 Review 4 Comment ot « Report (EPA)
| TASK »-IDENTIFICATION 4 DEVELOPMENTI Of REMEDIAL ALTERNATIVES% Develop Response OOjectrves 4 Aenons2 loenMy General Response AaionsJ loenttyTecnnotogies/AssemeieAlemairve*^ - FS Presentation to EPA
1 TASK 10 • SCREENING REMEDIAL** TECHNOLOaES ANO ALTERNATIVES
VSK 11 - DETAILED ANALYSIS ANO„ EVALUATION OF ALTERNATIVES
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BCMREFERENCES
Chemical Characteristics of Delaware River Channel Sediments Philadel-phia, Pennsylvania to Trenton, New Jersey: US Army Corps of EngineersPhiladelphia District. DACW-61-79-D-0020.
Delaware River Basin Commission (DRBC) 1986 - Chronic Toxlcity BloassayReport DEL USA Project Element 13
Delaware River Basin Commission (DRBC) 1987a. Toxics Review of the Dela-ware Estuary DEL USA Project Element 16.
Delaware River Basin Commission (DRBC) 1987b. Fish-Population Study.DEL USA Project Element 9
Delaware River Basin Commission (DRBC) 1988. Fish Health and Contamina-tion Study. DEL USA Project Element 10.
EPA,. 1988b. Guidance on Remedial Actions for Contaminated Groundwater atSuperfund Sites. U.S. Environmental Protection Agency. EPA/540/G-88/003.
EPA, 1988a. Guidance for Conducting Remedial Investigations and Feasi-bility Studies Under CERCLA. Interim Final. U.S. Environmental Protec-tion Agency. Office of Emergency and Remedial Response. EPA/540/G-89/004.
Hochreitar, Joseph J. Jr., 1981. A USGS Survey: Chemical Quality Recon-naissance' of the Hater and Surficial Material in the Delaware RiverEstuary and Adjacent to New Jersey Tributaries USGA/WRI/NTIS 82-36, pp.41
Sheldon, L.S. and Kites, R.A., 1978. Organic Compounds in the DelawareRiver: Environmental Science and Technology, V.12, no. 10, pp. 1188-1194.
Survey of the Huntington and Philadelphia River Water Supplies for Purge-able Organic Contaminants: (EPA-903/9-81-003), November 1980.
U.S. National Oceanographic and Atmospheric Administration (NOAA). 1984NOAA Hazardous Waste Site Report Metal Bank of America (111-26), Phila-delphia, Pennsylvania. April 13, 1984
Harvey, G.W. And Burzell, L.A. 1972. A Simple Microlayer Method forSmall Samples. Limnology and Oceanography 17: 156-7.
Kaplan, L.A. and Bott, T. 1989. Diel Fluctuations in Bacterial Activityon Streambed Substrata During Vernal Algal Blooms: Effects of Tempera-ture, Water Chemistry and Habitat. Limnology and Oceanography 34:718-733.
Porter, L.G. and Fieg, Y.S. 1980. The Use of DAPI for Identifying andCounting Aquatic Mi-croflora. Limnology and Oceanography 25: .143-148.
48
|SCM
ATTACHMENT 1
LIST OF TENANTS
BCM
i.
HISTORY OF USE OF BUILDINGS AT COTTMAN AVENUE SITEFROM APPROXIMATELY 1962
Property was vacant In 1962 when acquired by L. Goldsteln's Sons, Inc.(Metal Bank of America's predecessor).
Uses of Buildings (refer to attached map).
1. In 1969, wooden building of approximately 36,000 squarefeet and some vacant ground being used by Matt Slap Chevro-let for automobile storage maintenance and repair, exten-ding to some undetermined date. Building thereafterremained empty until torn down 1n approximately 1984.Concrete slab foundation remains.
2. a. Quaker Chemical Co. — used for warehousing/storage ofrock salt.
b. Unknown company — used for warehousing and packagingoperation.
c. Empty until utilized for oil process building/officeconnected with remediation (1981).
3. a. Rug shampoo company.
b. Unknown company — used car refurbishing for resale(approximately 4-5 years ending 1n 1983).
c. Empty.4. Empty brick building not used by Metal Bank.
5. a. In 1969 being used by Relscher Ford — approximately2,000 square feet of building and 2 acres of vacantground used for storage and dealer preparation of newcars.
b. Elllott Lewis Air Conditioning r- storage of trucksand parts.
c. General Alternator (Pennsylvania Alternator & Genera-tor Exchange) — alternator and starter repair(approximately 1982-83). h..
d. Empty.
R
I6. a. Lincoln Van and Storage Co. — storagt of household
goods for military service personnel <8 to 10 yearsending 1985).
b. Empty.7. a. Unknown company — slitting operation, cold rolled
steel operation limited to receipt of product, grad-ing, shipping to customers.
b. May have been used during winter 1978-1979 by MetalBank for preparation and packaging of cobalt residuefor domestic and foreign shipment.
c. Empty until utilized for water process building con-nected with remediation (1981).
8. a. Matt Slapp Chevrolet — storage of new cars (late1960s and 1970s).
b. Relscher Ford -- storage of new cars (late 1960s and1970s).
L
R 3 n 9 I o o
BCM
ATTACHMENT 2
EWK CONSULTANTS, INC.LETTER DATED MAY 23, 1988
BWK CONSULTANTS INC.( « • ,1 -m i ^ EV, »r••• « ••• •» »•• •! 11 i iiiiiniii in • •• iXkO',
2) Hey 1989
Tamer Tf asith*flunto* * Williawe707 feast flain Street
Yoa asked that I provide a preliminary report on theatudiee we have been conducting at Cottnan Street over ttie*la»t BOO the.
..... information is provided to you confidentially and .is not to be releaeed to the 8P\ or any other party withoutprior written consent.
The studies were designed to answer the question ofwhether the Cottaan eite would represent a significantthreat _to public health or the environment once the. court .ordered and approved remediation was completed.
The design of tke study aesuaed that the oourt orderedreeediation would be ooapleted and at that tine the statusof the eite would be ae follows?
Xll •recoverable" oils would have been recovered,Ceotaninated groundwate* leaving the site would be
at a oeejoenerajtiott o€ 200 ppb or less with an average flowof 1 900 gpd (Weston 1 78) •3> Kto vieible spill area on site. Vlso, we plan oncovering the site with clsan vegetative soils and stabilisethe bank although this is not required by the oourt order
AR302UQ
Ubold tfrtyt th0Q o* a significant throat to publio 't*t tnvivonatnt? *• licttd all of tft« tptclfic .
;trat (asd havt analyzed taeh) at folio*** .* * t * *»
of contaninattd gzoundwatar and it*X.I or inking »a«tr and \«2 aquatic lift*V. Vfftett of patt oCC-»*itt atolian dtpotit* of PCS* ;
and pottifelt ootlM*tion byproduct* y aoAC, Sffveta of r»«i<!aal ootxtami nation in th* »vx» fiat*
th«
\.l oriakiog•itoation undv; •*v«rtl •o«Mprio* aod
ao porobl«ui. w« *l»o took «*flpi«« of wat«r fro*RaocM>ry W*ll 1 as* th« out«14« tank» (that i» BO tr«atB«ntoth«r thaa oil mJciaaiftg). Vh« wall ««jnpl« contained a availajount of oil do* to th« a«c««»ity of MuBplin? thru an oillayer; how«v*r tb* ro«ult* art ia tn« 1*** than 10 ppbrai»9*» 7H* groon watar in th* fXimaing t**t *hotf*4noa-*dtt*otabl* l«v*l« (lea* than 70 ppt),
* «
X.3 an4 Ci Aquatie Lif*i . 'Zf tHaro it or had baaa a tignif leant problta oaaaad
da« to PCBt ditoharging froa the titt; rtoogaiciag that thtditeha g* would havt bttn sueh wort* ia tn* 1970t; it thouldthow up at tht top of tht aquatic lift food chain in thtfi*h.
Wt ttt op two crittri*. Oo tht f 1th axcaad tht TD\ PC»livit* of 2 pp»? Xr* thtrt difftrtnot in PCB oonetntrationtbttwt a typtt of fith; bottom fttdtrt; tte. and bttwttaoolltctioa location*? W* eolltcttd fith in tht fall at thttiat of highttt fat and PCB Itvtlt.
Voot of tho fiaU (toot 70) txottd 2 ppa IB* Itvtlt.T))«*« iaelud* ttlt and oatfitH oaught at tht KB* titt« Mypv«ltBiMacy «Mly*i« oC tHt data by location and fith typ«do«*a*t indioat* any probltat du* to tht KM tit*«
cttultt wt«t *o low that w* dteidtd that 7CDD andPCor analyt** woald bt a watt* of tiat*
Itvtl ditoHargt* bar* not oxoattd a preblta.Zt o*% bt eoeelod«d tHae pr««««t and futura d* »iai»u»ltv«lt cannot and will not*
R 3 n
Aeolian DepositstThe aoet sensitive downwind receptor 1m the St.
we do aot believe that ?C5a were burned at theCottoaa ftree-t ait*,; PVC plastics probably were* la orderto ecr on the coaeonfetive side we aaalysed tbe samplseobtained firosi 8t» 7inc*afc'« for 7CB«; PCDOi
distribution* *r« tfbtt woald b» «xp«ct«d for tacooe*ntr«tton« clou* to MB*.
in th« 1970s »Hov ?C9 Uv l* la th» 100 *fof ?pB in »«tJia«Qt« n««r th* b«ox. Un«2«r t«ra« of th« courtord«r; th«9« will r««*ia. Do th«y r«pr«««nt a significantthr«*tt
Slgaifionnt l«v«ls of ?C3* from Mmx «r« aot gtttlagiato aquAtic lif« - ••• \.l abov«* w« •xaaia*! wntthtr thiseoataaia«t«4 »«di««nt w«* washing away. Historic*! asrial ,photography and personal obssrvation shows that ths and flatis accreting. w? s currsnt practical policy ftasms to ba tolaava *C* contaaiaatsd sodimsnts in plae* wn«r« thsy &rs notbaing wasTiad away« or &ra in th* paroant rang* ofcontaainationr ••• for oxaople Wauk*oan» Illinois; and tfsirSadford* Massachusetts. Howsvsr; Z bsliavs that tha bankshould b« fuffthsr stabilized and havs stagad coacrsts rip •rap at tha sit* to that sventual snd.
Tha above r«pca*aat» a preliminary assaaaaaat of thedata % e Xcve obtaiaa«i over tha last months* V ile wecontinue to «valaata> the asss of data; ws oonoloda thatcompleting tha court ordered reaediation will raault ia asite that doee aot represent a significant threat to publichealth or the environment.
