7RECORD OF DECISION

WESTINGHOUSE ELECTRIC (SHARON) SITEOPERABLE UNIT TWO

DECLARATION

SITE NAME AND LOCATION

Westinghouse Electric (Sharon) SiteCity of Sharon, Mercer County, Pennsylvania

STATEMENT OF BASIS AND PURPOSE

This Record of Decision (ROD) presents the selected remedial action for Operable UnitTwo (OU2) which addresses contaminated ground water, Shenango River sediments,drainageways and riparian soils at the Westinghouse Electric (Sharon) Site, Sharon, MercerCounty, Pennsylvania (Site). The remedial action was developed in accordance with thestatutory requirements of the Comprehensive Environmental Response, Compensation andLiability Act of 1980, as amended (CERCLA), 42 U.S.C. §§ 9601 - 9675, and is consistent, tothe extent practicable, with the National Oil and Hazardous Substances Pollution ContingencyPlan (NCP), 40 C.F.R. Part 300. This remedy selection decision is based upon an AdministrativeRecord compiled for this Site. An index to the Administrative Record is attached.

The Commonwealth of Pennsylvania concurs with this remedial action. A copy of theCommonwealth's concurrence letter is attached.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances in the Site ground water, Riversediments, drainageways and riparian soils, if not addressed by implementing the responseactions selected in this ROD, may present an imminent and substantial endangerment to thepublic health and welfare, or to the environment.

DESCRIPTION OF THE SELECTED REMEDY»

The selected remedial actions for the various Site media are briefly outlined as follows:

1. For The Site Ground Water:

• No Further Action With Monitoring.

• Land use restrictions (institutional controls) as previously required under the Operable Unit One

2

Record of Decision and the Operable Unit One Unilateral Administrative Order.

• The waiver of drinking water standards, as provided at CERCLA Section 121(d)(4)(C), asbeing technically impracticable to attain.

• The installation of additional monitoring wells and the development of a ground watermonitoring regimen. The number and placement of the additional wells and the monitoringrequired will be established during the Remedial Design.

2. For Shenango River Sediments:

• Removal, by a method or methods to be established during the Remedial Design, of anestimated 4,100 cubic yards of up to 48 inches (in depth) of sediments containing PCBconcentrations greater than one (1) part per million (ppm) in the Shenango River between ClarkStreet and the dam at the Consumers Pennsylvania Water Company.

• Offsite disposal of the sediments removed, including any treated sediments.

• The protection of, and the monitoring of, the water intake of the Consumers PennsylvaniaWater Company during the remedial action to assure that the public water supply is notcontaminated as a result of the remedial action.

• The establishment of a fish tissue monitoring plan as part of the Remedial Design.

• The amounts and types of backfill materials will be established during the Remedial Design andmodified, if required, during the Remedial Action.

3- For Riparian Soils:

• Removal, by a method or methods to be established during the Remedial Design, of anestimated 300 cubic yards of soils containing PCB concentrations greater than ten (10) ppm inthe floodway along the eastern edge of the Shenango River downstream from Clark Street (RiverArea 15).

• The protection of, and the monitoring of, the water intake of the Consumers PennsylvaniaWater Company during the remedial action to assure that the public water supply is notcontaminated as a result of the remedial action.

• Offsite disposal of the riparian soils removed, including any treated soils.

• The amounts and types of riparian area backfill materials will be established during theRemedial Design and modified, if required, during the Remedial Action.

4. For Site Storm Sewer Drainagewavs:

• The removal of an estimated 20 cubic yards of PCB-contaminated debris and sediments fromapproximately 600 feet of the Wishart Court sewer line north of Silver Street by a method ormethods to be established as part of the Remedial Design.

• Offsite disposal of the sediments and debris removed, including any treated materials.

STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment, complies withFederal and State requirements that are legally applicable or relevant and appropriate to theremedial action, and is cost effective. The remedy does not satisfy the statutory preference fortreatment as a principal element of the remedy because treatment would result in extraordinarilyhigh costs with no significant increase in protectiveness and because no source materialsconstituting principal threats will be addressed for actual cleanup within the scope of this action.

Because the selected remedy will result in hazardous substances pollutants orcontaminants above levels that allow for unlimited use and unrestricted exposure remaining atthe Site, a review under Section 121(c) of CERCLA, 42 U.S.C. § 9621(c), will be conductedwithin five years after the date of initiation of the Operable Unit One remedy to ensure that theremedies selected under both Operable Unit One and Operable Unit Two are providingprotection of public health and welfare and the environment.

DATA CERTIFICATION CHECKLIST

The following information is included in the ROD and/or the Administrative Record:

• Contaminants of concern and their respective concentrations.• Baseline risk(s) presented by the hazardous substances of potential concern.• Cleanup levels established for the hazardous substances and the basis for the levels.• Current and reasonably anticipated future land use assumptions.• Land use that will be available at the Site as a result of the Selected Remedy.• Estimated capital, operation and maintenance (O&M), and net present worth costs;discount rate; and the number of years over which the cost estimates are projected.

• Decisive factors that led to the Selected Remedy. *

Abraham Ferdas, Director DateHazardous Site Cleanup DivisionEPA, Region HI

Remedial Alternative Record of Decision SummaryOperable Unit Two

Westinghouse Electric (Sharon) SiteSharon, Mercer County, Pennsylvania

I. SITE DESCRIPTION AND BACKGROUND

The former Westinghouse Electric Company Sharon Transformer Plant is located alongthe west side of Sharpsville Avenue in the City of Sharon, Pennsylvania (Figure 1). The formerplant property occupies nearly 58 acres and is located within the Shenango River Valley. TheShenango River flows in a north-to-south direction and varies from 800 feet to 2000 feet to thewest of the former plant property. The former plant property is approximately one mile in lengthalong a north-south axis and ranges between 200 and 800 feet wide. The ground surface of theformer plant property is generally flat with a gentle slope from north to south, and ranges from860 feet to 900 feet above mean sea level. Currently, a large percentage of the former plantsurface is under roof or is covered with pavement and/or concrete building foundations. For thepurposes of the environmental investigations, the former plant property was divided into threeareas: the South Sector, the Middle Sector, and the North Sector. Various former and existingstructures are shown on Figure 2 (the South Sector), Figure 3 (the Middle Sector), and Figure 4(the North Sector). A railroad property formerly owned by Conrail, and currently owned byNorfolk Southern Railway Company, contains contaminated soils, and extends along the westernborder of the property occupied by the former plant. That railroad property is considered to bepart of the Site. The contamination resulting from Site-related manufacturing activities includesvarious areas of contaminated soils on the former plant property and on the adjacent railroadproperty, the ground water, the storm sewer drainageways leading from the former Westinghouseplant property to the Shenango River, and sediments and riparian soils of the Shenango River.

The area east of the Site is primarily urban residential, while the area to the west, betweenthe Site and the Shenango River, varies from commercial, institutional, recreational and light toheavy industrial. Today the whole Site area is part of an industrial expansion program under thedirection of the Shenango Valley Industrial Development Corporation and Penn NorthwestDevelopment Corporation. This area, including the former plant, has been the site of commercial,rail, and industrial activities since the mid-1800s.

Westinghouse purchased the former plant property from the Savage Arms Corporation in1922. For more than 60 years Westinghouse primarily produced distribution transformers, powertransformers, and related electrical apparatus at the Sharon Transformer Plant until its shutdownin 1984. Some of the transformers produced at the plant were liquid-cooled and approximately98 percent of those were filled with highly refined mineral oil. Approximately 2 percent of thetransformers were filled with either a silicone fluid or a commercially-produced dielectric fluidcalled Inerteen. The Inerteen was nonflammable and consisted of either undilutedpolychlorinated biphenyls (PCBs) or a mixture of PCBs and trichlorobenzene. Westinghouse

first used Inerteen at the former plant in 1936 and discontinued its use at the plant in 1976.Westinghouse typically received and stored the Inerteen in tanks at a tank farm area which wasformerly located on the west side of the Middle Sector. Westinghouse also stored Inerteen in anunderground tank onsite. Mixtures of PCS compounds which contained differing amounts ofchlorine by weight were used in Inerteen. The trade name "Aroclor" was used in conjunctionwith a four-digit number to identify the various types of PCB mixtures and their percentages ofchlorine (e.g., Aroclor 1260 contained 60% chlorine; Aroclor 1242 contained 42% chlorine).

In addition to Inerteen and transformer oil, EPA is aware that Westinghouse used severalother chemicals at the Site. These chemicals include six volatile organic compounds (VOCs):ethyl acetate; methyl ethyl ketone; toluene; xylene; trichloroethylene; and 1,1,1-trichloroethane.Westinghouse used the latter two materials in metal cleaning and degreasing operations at severallocations onsite. Metal cleaning was also accomplished by acid or phosphatizing-bath processes.Leftover material from these processes was piped to a neutralization facility where it was treated.Other materials which were used at the Site included paints, varnishes, and small amounts offlammable liquids and cyanide. Over the decades of operations at the plant, leakages and spillsof the various materials resulted in contamination of the Site soils, the drainageways to theShenango River, the sediments in the Shenango River, the riparian soils in the floodway of theShenango River, and the ground water at, and downgradient of, the former plant. (It should benoted that EPA is aware of at least two other industrial sources of ground water contaminationimmediately downgradient of the plant. These are the former Roemer Industries facility whichcontributed to solvent contamination in the ground water, and the Sawhill Tubular Productsplant, currently owned by AK Steel Corporation and operated by Wheatland Tube Company.The AK Steel facility is under an order from PADEP to address ground water contamination thatresulted from its operations.)

Since its discontinuance of Inerteen usage in 1976, Westinghouse decontaminated,removed and/or scrapped the entire Inerteen storage and distribution system. Also, from 1976through 1986, Westinghouse has voluntarily undertaken several cleanup actions at the Siteincluding:

• The excavation and offsite disposal of more than 7,800 tons of soil contaminated withPCBs, including soil from the removal of five underground storage tanks and from thecleanup of a spill of approximately 6,750 gallons of a PCB-contaminated mixture oftransformer oil and a petroleum distillate in the moat area;

b *

• The removal and landfill disposal of 60 cubic yards of PCB-contaminated fly ashfrom two settling tanks and a hot well;

• The recovery and incineration of 104 gallons of a PCB liquid that were discovered in aconcrete sump; and

• The removal, shredding and incineration of more than 4,500 PCB-containing

capacitors.

In addition, Westinghouse completed a number of voluntary cleanups that involvedvarious surface areas including basements, floors, cisterns, hot wells, cold wells, varnish tanks,underground storage tanks, above-ground storage tanks and pits. One of the current propertyowners, Winner Development LLC, is presently conducting a voluntary cleanup of the largeMiddle Sector Buildings complex as a removal action under the oversight of PADEP to addressPCB and lead contamination in those buildings. These cleanups were undertaken to reduce or, insome specific instances, to eliminate concentrations of residual PCBs and other potentialcontaminants. However, on a Site-wide basis, sufficient concentrations of contaminants remainwhich continue to pose a significant threat to the public health and welfare and the environment.

II. REGULATORY HISTORY

In November 1980, the Westinghouse facility qualified for Interim Status under SubtitleC of the federal Resource Conservation and Recovery Act (RCRA), 42 U.S.C. §§ 6901 et seq.,when Westinghouse filed a notification of Hazardous Waste Activity and Part A RCRA permitapplication to treat, store or dispose of hazardous waste. Westinghouse withdrew the Part Apermit application in July 1983 and converted to RCRA generator-only status.

In July 1983, EPA conducted an inspection of the facility pursuant to the ToxicSubstances Control Act, 15 U.S.C. §§ 2601 et seq. In April 1985, the Pennsylvania Departmentof Environmental Resources (PADER), which subsequently changed to PADEP, issuedWestinghouse an order to undertake a subsurface investigation to determine the horizontal andvertical extent of impacted ground water and soil (the final report was submitted byWestinghouse in September 1986), and for Westinghouse to submit a plan and a schedule for thecleanup and containment of impacted soils and ground water (these were submitted byWestinghouse in October 1986).

EPA proposed the Site for inclusion on the Superfund National Priorities List (NPL) inJune 1988 and added the Site to the NPL in August 1990.

hi September 1988, Westinghouse entered into a Consent Order and Agreement withPADER to conduct a Remedial Investigation and Feasibility Study (RJ/FS) to determine thenature and extent of contamination at the Site, to characterize the risks to human health and theenvironment, and to evaluate alternatives to clean up the contamination at the Site. In February1994, EPA issued to Westinghouse a Unilateral Administrative Order (UAO) pursuant to Section106(a) of CERCLA for the development and implementation of a Response Action Plan for theremoval of light non-aqueous phase liquids (LNAPL) from ground water underneath thetankfarm in the Middle Sector in order to reduce the threat of offsite migration of the LNAPL.EPA approved a Pilot Study report and addendum letter in August 1995 and approved asubsequent work plan for an LNAPL Removal Response Action. The LNAPL response action atthe Site is ongoing. On March 20, 1996, Westinghouse submitted the final Remedial

Investigation Report which was approved by PADEP on May 24,1996. On June 6, 1997,Westinghouse submitted a final Screening-Level Ecological Risk Assessment (approved byPADEP on August 7,1997), and on April 7,1998, Westinghouse submitted the final BaselineHuman Health Risk Assessment (approved by PADEP on April 22,1998). CBS Corporationsubmitted a Final Feasibility Study Report for the soils (Operable Unit One) on November 17,1998 (approved by PADEP on December 17,1998). EPA issued a Proposed Remedial ActionPlan, regarding the cleanup of soils, for public review on June 11,1999. EPA issued a Recordof Decision (ROD) for Operable Unit One on February 18, 2000.

Additionally Westinghouse (now Viacom Inc.) agreed to pursue the cleanup of themassive Middle Sector Buildings complex under the September 1988 PADER Consent Orderand Agreement and has completed the first phase of the cleanup of those buildings. As notedabove, the Buildings are contaminated with lead from lead-based paints and with PCBs. WinnerDevelopment LLC, the present owner of the Middle Sector Buildings, is currently conducting thecleanup of the Buildings, primarily under the regulatory authorities of PADEP.

On September 29, 2000, EPA issued a Unilateral Administrative Order to Viacom Inc.,Winner Development Company, and AK Steel Corporation (owner of the North Sector) pursuantto Section 106(a) of CERCLA requiring that these companies conduct the remedial design andremedial action necessary to implement the Operable Unit One ROD. On or before November 1,2000, the three companies notified EPA of their intent to comply with that UAO. Viacom Inc.submitted the required remedial design as two documents: "Final (100 Percent) Design Report;Operable Unit One (Soils)-Phase I" dated July 19, 2001, and "Final (100 Percent) DesignReport; Operable Unit One (Soils)-Phase IT' dated July 27, 2001. These remedial designdocuments were approved by EPA on August 2, 2001. EPA approved Viacom's Operable UnitOne remedial action work plans in September 2001. The Operable Unit One (soils cleanup)remedial action is currently taking place at the Site.

On October 23, 1998, pursuant to the 1998 Consent Order and Agreement with PADER ,CBS Corporation (formerly Westinghouse, now Viacom) submitted a "Feasibility StudySupplemental Sampling and Analysis Plan..." for supplemental sampling and analysis ofsediments, ground water, riparian soils and non-aqueous phase liquids (NAPLs) to PADEP andEPA. On May 21, 1999, CBS submitted a document titled "Data Summary Report [;] FeasibilityStudy [;] Supplemental Sediment Sampling..." which summarized the sampling of ShenangoRiver sediments and riparian soils. On October 29, 1999, CBS submitted a document titled"Data Summary Report [;] Supplemental Sampling and Analysis of Groundwater..." whichsummarized the sampling of ground water that had been done to that date. On November 11,1999, CBS submitted a document titled "NAPL Bench-Scale Test Reports..." summarizing theresults of bench-scale testing that was done to help in determining the effectiveness of severalpotential cleanup technologies for NAPLs. On May 19, 2000, CBS submitted a document titled"Data Summary Report Area 14 Supplemental Sediment Sampling..." which summarized theresults of the sampling and analysis of sediments in an area of the Shenango River immediatelyupstream from the Shenango Valley Division of Consumers Pennsylvania Water Company dam.

On June 26, 2000, Viacom Inc., the successor in interest to CBS, submitted a document titled"Feasibility Study Report-Operable Unit 2 [;] Sediment, Groundwater, and NAPLs..." whichprovided a summary of the cleanup alternatives analyzed for those environmental media.However, that feasibility study report did not address the drainageways from the Site to theShenango River and it also did not address bedrock ground water. The Site drainageways andbedrock groundwater were subsequently addressed in a document titled, "Addendum-FeasibilityStudy Report [;] Operable Unit 2-Storm Sewer Sediments and Bedrock Groundwater..." datedMay 18, 2001. PADEP issued a letter dated May 30, 2001 approving the Operable Unit 2Feasibility Study and Addendum. A report titled, "Technical Impracticability Of GroundwaterRestoration Evaluation" dated March 22, 2002, was prepared for Viacom Inc. That documentwas approved by EPA on July 22, 2002.

III. SCOPE AND ROLE OF THE OPERABLE UNIT

Operable Unit Two addresses ground water, drainageways and Shenango River sedimentsand riparian soils (the soils immediately adjacent the Shenango River) at the Site. The groundwater at the Site exists in two aquifers: the alluvial, or shallow aquifer, and the bedrock, ordeeper aquifer. The contamination in the alluvial ground water exists as light non-aqueous phaseliquids (LNAPL) floating on the surface of the ground water, as dense non-aqueous phase liquids(DNAPL) which have sunk to the bottom of the ground water, and as contaminants dissolved inthe ground water. The contamination in the bedrock ground water is extremely localized andconsists of contaminants dissolved in the ground water. The drainageways are the storm sewersthat drained runoff water from the former plant to the Shenango River. The river sediments andriparian soils that are addressed by this operable unit are within the section of the ShenangoRiver between Clark Street as a northern boundary, and the dam at the Shenango Valley Divisionof Consumers Pennsylvania Water Company as a southern boundary. EPA expects that OperableUnit Two will be the last of the remedial action operable units for the Site.

IV. SITE CHARACTERISTICS RELATING TO THE OPERABLE UNIT

Ground Water:

Based upon the information gathered during the Remedial Investigation and other studiesat the Site, Westinghouse determined that there are two aquifers, one above the other. Theuppermost aquifer is unconfmed and associated with alluvial deposits. Ground water is alsopresent under*confmed or semi-confined conditions within the Orangeville Shale of the lower, orbedrock, aquifer. The alluvial (upper) aquifer is separated from the bedrock aquifer by low-permeability glacial till deposits. Ground water in the alluvial and bedrock aquifers generallyflows west-southwest towards the Shenango River. The River is approximately 800 feet west ofthe North Sector, and, because of a bend in the River, is approximately 2000 feet west of theMiddle Sector and the South Sector (see Figure 1). EPA believes the linear velocity of thealluvial aquifer to be 38 feet per year based upon a combination of Site-specific data andreferenced information. It should be noted that this estimated velocity relates to the actual water

component of the aquifer but does not take into account attenuation effects such as adsorption,advection, dilution, dispersion, biodegradation, diffusion, and/or volatilization which act tointerfere with the advancement of dissolved contaminants in the aquifer. For example, the use ofPCBs and chlorinated benzenes—contaminants which are found in the alluvial aquifer-wasdiscontinued at the Site in 1976 (26 years ago), and since that time EPA believes that the alluvialground water should have advanced a minimum of 950 feet. However, these contaminants arenot present in ground water monitoring wells OS-7 A, OS-7B, OS-6A, OS-6B, OS-4A, OS-4B,and MW-17AR which are located only 400 to 500 feet downgradient of the former plant.

Light non-aqueous phase liquids (LNAPLs), consisting largely of spilled mineral oil thathas penetrated the soil to the water table, are found in the alluvial aquifer in several areas (Figure5). The largest LNAPL area encompasses several of the monitoring wells where a formertankfarm stood on the west side of the Middle Sector. LNAPLs are also found in the immediatevicinity of well M-2 inside the Middle Sector Buildings, in the immediate vicinity of well S-4inside the South Sector building, and in the immediate vicinity of well MW-7 which is west ofthe AK Steel-owned tubular products plant (currently operated by Wheatland Tube Company).(It should be noted that the LNAPL area at MW-7 is not Site-related.) Dense non-aqueous phaseliquids (DNAPLs) are found in the alluvial aquifer in a north-to-south elongated area on the westside of the Middle Sector Buildings from approximately monitoring well GM-1A at the northernend of the DNAPL area to approximately monitoring well M-l at the southern end (Figure 6).The NAPLs (which include both LNAPLs and DNAPLs) occur essentially beneath the NorfolkSouthern Railroad tracks, the former tankfarm area and other anthropogenic features which serveas a barrier and help prevent direct human contact with the contaminated ground water. The highviscosities of both the LNAPLs and the DNAPLs act to retard their migration. At least in partbecause of the presence of the NAPLs, Site-related contaminants are found in highconcentrations in portions of the alluvial aquifer.

As noted in the October 29, 1999 "Data Summary Report" for ground water, volatileorganic compounds (VOCs) found in the alluvial aquifer include tetrachloroethene (up to 25micrograms per liter (jag/1)); trichloroethene (up to 5,400 ug/1); 1,2-dichloroethene (up to 3,300Hg/1); and vinyl chloride (up to 61 ng/1). Semi-volatile organic compounds (SVOCs) found inthe alluvial aquifer include 1,2,4-trichlorobenzene (up to 1,200 milligrams per liter (mg/1));(dichlorobenzenes (total up to 400 mg/1); chlorobenzene (up to 2,200 ug/1) and benzene (up to940 ug/1). PCBs are found in the alluvial aquifer in concentrations up to 13,400 mg/1. Dissolvedcontaminants in the alluvial ground water do not appear to have migrated far from theWestinghouse facility. For example, 1,2-dichloroethene which was detected at well S-10 in themoat area at a concentration of 3,300 ng/1 during the RI in 1992-1994, was found atconcentrations of only 8 ug/1 at well OS-7A-a distance of only about 500 feet—during a samplingevent in 1999. (It should be noted that well OS-7 A was constructed after the RI was completed.)The inorganic ground water constituents, manganese (up to 8,860 ug/1) and arsenic (up to 76jig/1) were also found in the alluvial aquifer, but there is no evidence that these are Site-related,and they most likely are naturally occurring.

Contamination of the bedrock aquifer is confined to the immediate vicinity of monitoringwell M-11B at the Site and is due to the transport of contaminants from the alluvial aquifer to thebedrock aquifer by way of the well casing. Westinghouse constructed monitoring well M-l IB,located just west of the former Middle Sector tankfarm, through the contaminated NAPL areaand into the bedrock. In 1992, sampling conducted by Westinghouse for the RI showed well M-1 IB had no concentrations of PCBs. In 1999, Viacom detected total PCBs in excess of 500 ug/1in that well. However, purging of the well and re-sampling in 1999 indicated that theconcentration of PCBs was less than 10 ug/1. Viacom's subsequent samplings of M-l IB yieldedsimilar results. After Viacom detected contamination in 1999, it constructed two additionalbedrock wells immediately downgradient of M-l IB. These new wells showed no Site-relatedcontamination. These circumstances show that the contamination in the bedrock ground water atM-l IB was due to transport of the contaminants down the well casing of M-l IB from thecontaminated alluvial (upper) aquifer. Viacom sealed Well M-l IB to prevent any furthercontamination of the bedrock aquifer in that area. Bedrock well S-1B which is located at thesouthern end of the South Sector has shown very low concentrations of PCBs (approximately 2Hg/1) sporadically. EPA believes that the sporadic detections of PCBs in S-1B are not indicativeof actual PCB contamination in the bedrock ground water, but instead might be the result ofcross-contamination during sampling. The most recent analysis of the ground water from thatwell (October 1999) produced no detections of PCBs. EPA believes that there has been no Site-related contamination of the bedrock aquifer except in relation to the occurrence of the cross-contamination at well M-l IB, as noted above, and that this cross-contamination has beenaddressed by way of downgradient monitoring.

Shenango River Sediments:

The sediments of the Shenango River are contaminated with Site-related PCBsdownstream from the Clark Street storm sewer outfall. However, only the areas between theClark Street Outfall and the dam at the Shenango Valley Division of Consumers PennsylvaniaWater Company contain PCB concentrations significantly above 1 part per million (ppm). (EPAconsiders PCB concentrations above 1 ppm to pose a significant threat to aquatic ecosystems inmost instances.) These areas are designated in the RI and subsequent documents as Area 14(near the dam) and Area 15 (near the Clark Street Outfall). Viacom found the highestconcentration of PCBs in Area 14 to be 52 ppm (Figure 7) and the highest concentration of PCBsin Area 15 to be 24.1 ppm (Figure 8). Viacom's analysis of sediments in other downstream areasproduced only one sediment sample with a PCB concentration significantly above 1 ppm. Thissample, obtained in Area 12 downstream of the Ohio Street bridge, was found to contain 2.0 ppmPCBs. Viacom also found concentrations of metals, significantly zinc and lead, in the sediments.There is no evidence, however, that Westinghouse used those metals in its operations at theformer plant.

Shenango River Riparian Soils:

Riparian soils in the floodway of the Shenango River were found to be significantly

contaminated with Site-related PCBs only in Area 15 where concentrations up to 39.9 ppm werefound. In Area 15, PCBs were detected in the soils of a small area on the east bank of the Riverapproximately 100 feet downstream from the Clark Street Outfall (Figure 8).

Storm Sewer Drainagcwav Sediments:

Four storm sewer drainageways carried runoff water underground from the formerWestinghouse facility to the Shenango River: the Clark Street Sewer; the North Hot Well Sewer;the Franklin Street Sewer and the Wishart Court Sewer. Viacom inspected the drainageways forsediment accumulations and the sediments that were found were analyzed for metals and PCBs.Approximately 600 feet of the Wishart Court Sewer was the only section of drainageway foundto be contaminated with Site-related PCBs greater than 1 ppm. This storm sewer runs souththrough the moat area, parallels Dayton Way and Railroad Avenue and discharges into a culvertat Pine Run which discharges into the Shenango River. Viacom found concentrations of PCBsup to 2.2 ppm in the section of that sewer extending for approximately 600 feet north of SilverStreet. Viacom estimates the total volume of sediment and debris in that sewer section to be 20cubic yards. In addition, Viacom found concentrations of metals, notably zinc at concentrationsup to 3,840 ppm, at various places in the drainageways. However, EPA has concluded that thereis no evidence to indicate that the metals concentrations in the drainageways are related to themanufacturing activities that took place at the former Westinghouse facility.

V. CURRENT AND POTENTIAL FUTURE LAND USES

Current use of the former Westinghouse Transformer Plant property includes WinnerSteel, Inc.'s steel galvanizing operation in the South Sector, an industrial steel warehousingoperation on the AK Steel Corporation (formerly Armco, Inc.) property operated by WheatlandTube Company, and the use of a portion of the Middle Sector Buildings as a steel warehouse byWinner Steel, Inc. The portions of the Middle Sector Buildings not currently being used areundergoing interior remediation for PCB contamination as a removal action under Stateauthority. EPA anticipates that that property will likely be subject to redevelopment forindustrial use. An active railroad line owned by Norfolk Southern Railway Company bordersthe western side of the former Westinghouse Transformer Plant property. The area between theformer plant and the Shenango River is largely commercial and industrial and is expected toremain as such into the foreseeable future. The Shenango River itself is used as a source ofpotable water for the City of Sharon and for recreational fishing and boating.

> »VI. SUMMARY OF RISKS

As part of the Remedial Investigation process, Westinghouse performed and PADEP andEPA approved a complete Human Health Risk Assessment which was documented in theBaseline Human Health Risk Assessment Of The Former Westinghouse Transformer Plant,Sharon, Pennsylvania (the HHRA) dated April 7,1998. The HHRA evaluated hypotheticalupper-bound carcinogenic (cancer causing) and non-carcinogenic risks to various potential

human receptors of contaminants of potential concern in impacted media at the Site. Because theHHRA relied upon conservative assumptions, and because conservative input parameter valueswere used throughout the HHRA, EPA believes that the HHRA conservatively estimates theexposures. As such, the numeric values summarized in the HHRA should be consideredconservative estimates of risks to human health. Also, as part of the Remedial Investigation, aScreening-Level Ecological Risk Assessment dated May 1997 was developed by Westinghouse(now Viacom). The Screening-Level Ecological Risk Assessment evaluated the likelihood thatadverse ecological effects are occurring or might occur as a result of exposures to Site-relatedcontaminants.

A. Shenango River Sediments, Drainageway Sediments and Riparian Soils

Sampling and analyses conducted by Viacom have revealed PCBs in concentrations up to52 parts per million (ppm) in sediments of the Shenango River between Clark Street and the damat the Shenango Valley Division of Consumers Pennsylvania Water Company water treatmentplant. (This portion of the River is designated as Areas 14 and 15 in the RJ/FS documents.Other areas of the River which were sampled had total PCS concentrations generally less than 1ppm. As noted above, EPA considers concentrations of PCBs greater than 1 ppm in sediments tobe of ecological concern.) EPA regards PCB concentrations in some of the sediments in thisportion of the River as posing an extreme risk to ecological receptors. Additionally, metalscontamination is evident in sediments in this portion of the River. Zinc exists in the sediments inconcentrations up to 28,200 ppm. Zinc at that concentration is regarded by EPA as posing anextreme risk to ecological receptors. Also, lead (Pb) has been found in the sediments atconcentrations up to 669 ppm—a concentration that EPA regards as posing a moderate to highrisk to ecological receptors. However, there is no evidence to specifically relate the incidence ofmetals in the sediments to the former Westinghouse transformer plant.

Carcinogenic and non-carcinogenic risks to children wading in the Shenango River and,thus, exposed to River sediments were conservatively estimated taking into account possiblesediment ingestion and dermal (skin) contact with sediments. The estimated carcinogenic riskwas calculated to be 9 x 10"6. A risk of 9 x 10"6 means that, if no cleanup action is taken, 9additional people per one million exposed have a chance of contracting cancer as a result ofexposure to the contaminated medium. (This estimate uses the hypothetical exposure scenariosin the HHRA.) The total non-cancer Hazard Index for the child wader was calculated to be 1 x10"2 or 0.01. Any hypothetical risk scenario demonstrating a Hazard Index of greater than 1might be of potential concern since potential non-cancer effects cannot be ruled out. +For thechild wader, both the carcinogenic risk and the non-carcinogenic Hazard Index are within EPA'sacceptable risk range. The NCP target risks to human health are 1 x 10"6 to 1 x 10'4 forcarcinogens, and a Hazard Index of 1 for non-carcinogens.

Risks posed by human consumption offish impacted by PCBs in sediments could not bequantitatively evaluated as part of the HHRA. However, the Pennsylvania Fish and BoatCommission has issued a fish consumption advisory for the Shenango River advising that carp,

10

which are bottom-feeding fish, and muskellunge, which are large predatory fish at the top of theaquatic food chain, should not be eaten because of the PCB contamination found in those fish. Itshould be noted that Pennsylvania has adopted a statewide advisory calling for a one meal perweek restriction relating to the consumption of all fish caught in Pennsylvania waters.

As part of a sampling event to supplement the information contained in the 1996 RIReport, riparian soils in Areas 12, 13, 14, 15 and 16 of the Shenango River floodway weresampled in fall of 1998. Analysis of those samples revealed notable contamination (greater than10 ppm) only in the riparian soils of Area 15 where PCB concentrations were found as high as39.9 ppm. The contaminated riparian soils of Area 15 might pose a risk to certain ecologicalreceptors that inhabit or traverse the river corridor.

In November/December 2000, the four storm sewer drainageways leading to theShenango River from the former Westinghouse plant property were investigated for possiblePCB contamination of sediments in those drainageways as part of activities related to thecompletion of the Operable Unit Two Feasibility Study. The results of that investigation aresummarized in the document titled "Addendum-Feasibility Study Report; Operable UnitTwo-Storm Sewer Sediments And Bedrock Groundwater..." dated May 18,2001.

That investigation found that Site-related PCB concentrations exceeding 1 ppm exist insediments of only one of the drainageway storm sewers-the Wishart Court Sewer. PCBconcentrations of up to 2.2 ppm were found in approximately 600 feet of that sewer north ofSilver Street. The estimated total volume of this contaminated sediment and debris is 20 cubicyards. Human exposures to this contaminated sediment would be limited to utility workers, forexample, during sewer repair or replacement. However, the likelihood that this sediment mightbe washed into the Shenango River exists and the PCB concentrations would be of potentialconcern with regard to ecological receptors. The storm sewer investigation also found that theconcentrations of metals (e.g., lead, zinc, nickel and chromium) exceed levels of potentialconcern in some portions of certain storm sewers with regard to ecological receptors. However,there is no evidence that these metals are related to the industrial activities that took place at theformer Westinghouse plant. Instead, the metals concentrations are likely due to the many andvaried anthropogenic activities that have occurred over time in the Site area.

B. Alluvial Ground Water

Alluvial ground water at the Site is contaminated with Site-related contaminants in-threephysical forms: 1) light non-aqueous phase liquids; 2) dense non-aqueous phase liquids; and, 3)dissolved contaminants.

Light non-aqueous phase liquids (LNAPLs) are liquid substances that are less dense thanwater and, therefore, have a tendency to float on top of the ground water. LNAPLs are found inthe alluvial ground water immediately west of the Middle Sector Buildings in the area of theformer tank farm; in the Middle Sector in the area of monitoring well M-2, and in the South

11Sector in the vicinity of monitoring well S-4. LNAPL is also found in the alluvial ground waternear the Shenango River west of the AK Steel-owned tubular products plant (which is currentlyleased and operated by Wheatland Tube Company) in the vicinity of AK Steel's monitoring wellMW-7. However, there is no evidence to indicate that this LNAPL area is related to the formerWestinghouse transformer manufacturing plant.

Dense non-aqueous phase liquids (DNAPLs) are liquid substances that are more densethan water and that have a tendency to sink to the bottom of ground water aquifers. DNAPLs arefound in the alluvial aquifer in a north-to-south elongated area on the west side of the formertransformer plant. This area of contamination extends approximately from monitoring well GM-1A as a northern limit on the west side of the Middle Sector to approximately monitoring wellM-l near the onsite moat area as a southern limit.

Dissolved contaminants in the alluvial aquifer include PCBs; 1,2,4-trichlorobenzene;tetrachloroethene; trichloroethene (TCE); 1,2-dichloroethene; dichlorobenzene; chlorobenzene;benzene; vinyl chloride; dioxin and arsenic. Some of these contaminants are also found asLNAPL or DNAPL in the alluvial ground water.

For the purposes of the baseline HHRA, Westinghouse analyzed the alluvial ground waterfor risks by geographic areas onsite: the South Sector or Southern Alluvial Ground Water, andthe Middle Sector or Central Alluvial Ground Water (Table 1). (Westinghouse did not observeground water contamination exceeding the National Contingency Plan (NCP) target range in thenorthern portion of the Site.) Westinghouse evaluated the alluvial ground water in both areasconsidering hypothetical exposures of adult residents, child residents, and onsite workers. Therisk evaluations conservatively assumed that these persons might be exposed to the ground waterthrough ingestion, dermal (skin) contact, and inhalation. The calculated carcinogenic risks aredriven primarily by arsenic, vinyl chloride, dioxin and PCBs in the Southern Alluvial GroundWater; and by PCBs, TCE, arsenic, and dioxin in the Central Alluvial Ground Water. The totalcarcinogenic risk calculated in the baseline HHRA for the Southern Alluvial Ground Water is 2.2x 10'2 (2.2 additional cancers for each 100 persons exposed), and the total non-carcinogenicHazard Index is calculated to be 1710. For the Central Alluvial Ground Water, the totalcarcinogenic risk approaches 1. (This means that the probability of a person developing cancer isnearly 100 percent assuming the conservative exposure scenarios used in the HHRA.) The totalnon-carcinogenic Hazard Index for the Central Alluvial Ground Water is calculated to be5,000,000. The RI found no users of ground water in the areas of Site-related contamination.

• »The RI did not find that the Site-related contamination in the alluvial ground water is

impacting terrestrial organisms. Also, according to the RI, Site-related alluvial ground watercontamination is not reaching the Shenango River which is up to 2000 feet from the formerWestinghouse facility (Figure 1), and the ground water contamination has not been shown to beadversely impacting the River's aquatic ecosystem.

C. Bedrock Ground Water

12

PCBs, dioxin and arsenic were the substances driving the risk relating to bedrock groundwater in the HHRA (Table 1). As with alluvial ground water, the risks for bedrock ground waterwere calculated conservatively assuming the possible ingestion of, and dermal contact with, thebedrock ground water by adult and child residents and by workers. The contaminated bedrockground water was found only in very confined instances, basically at, and in the immediatevicinities of, wells M-l IB and S-1B. The bedrock ground water contamination at well M-l IBwas located directly beneath the NAPL area west of the Middle Sector and that well hassubsequently been successfully abandoned (sealed). The contamination at well S-1B has beensporadic and at very low concentrations. The total carcinogenic risk for bedrock ground waterwas calculated to be 6.1 x 10"3 (6.1 additional cancers for each 1000 persons exposed). The non-cancer Hazard Index was calculated to be 347.

VII. REMEDIAL ACTION OBJECTIVES

The Remedial Action Objectives of Operable Unit Two are described below:

For ground water:

The Remedial Action Objective for ground water is to prevent human exposures viaingestion, inhalation and dermal contact to Site-related contaminants in the ground water. NoRemedial Action Objectives are deemed necessary to prevent exposures of ecological receptorsto contaminated ground water because such exposures are neither present nor probable.

For riparian soils:

The Remedial Action Objective for riparian soils is to eliminate potential exposures ofecological receptors to soils in the floodway of Area 15 of the Shenango River where those soilshave total PCB concentrations greater than 10 ppm, and to minimize the probability that soilshaving PCB concentrations between 1 and 10 ppm would erode into the River. EPA selected the10 ppm cleanup level for the soil in order to protect ecological receptors that might come incontact with the soil, and to be consistent with EPA's cleanup levels in similar situations at othersites.

For Site drainagewavs:

The Remedial Action Objective for the Site drainageways is to eliminate the possibility ofsediments containing concentrations of PCBs of 1 ppm or greater from washing into theShenango River. EPA selected the 1 ppm cleanup level to be consistent with the 1 ppm cleanuplevel proposed for Shenango River Sediments.

For Shenango River Sediments:

The Remedial Action Objective for Shenango River sediments is to eliminate the

13

possibility of the exposure of ecological receptors to sediments in Areas 14 and 15 having totalPCB concentrations greater than 1 ppm. According to the Pennsylvania Fish and BoatCommission, the elimination of the higher PCB concentrations from Areas 14 and 15 could leadto the elimination of a "Do not eat" advisory and, eventually, a restriction no more stringent thanthe statewide one fish meal per week restriction for the approximately 4-mile section of the Riverfrom the Shenango Reservoir downstream to the dam at the Shenango Valley Division ofConsumers Pennsylvania Water Company.

VIII. SUMMARY OF REMEDIAL ALTERNATIVES

The Superfund law (CERCLA) requires that any remedy selected to addresscontamination at a hazardous waste site must be protective of public health and welfare and theenvironment, cost-effective, in compliance with regulatory and statutory provisions that areapplicable or relevant and appropriate requirements (ARARs), and consistent with the NCP tothe extent practicable. The Superfund law also expresses a preference for permanent solutions,for treating hazardous substances onsite, and for applying alternative or innovative technologies.During the development of the Operable Unit Two FS, Viacom ultimately developed fiveremedial action alternatives for the alluvial ground water; two remedial alternatives for thedrainage way sediments; two remedial alternatives for bedrock ground water; and four remedialaction alternatives for Shenango River sediments and associated riparian soils. The alternativeswere developed assuming that the former Westinghouse transformer manufacturing facilitywould continue to be industrial property into the foreseeable future.

The following is a summary of the alternatives that were evaluated for the ShenangoRiver Sediments and associated riparian soils in the FS report:

* Shenango River Sediment and Riparian Soil Alternative 1-No Action

Under this alternative, no remedial action would be taken to remove, control migrationfrom, minimize exposure to or otherwise reduce the potential for adverse effects to ecologicalreceptors which might be caused by Site-related contaminants in the Shenango River sedimentsand riparian soils. No efforts would be made to control the future use of the contaminated areas.Because existing contaminated sediments and riparian soil would remain in place, EPA wouldconduct five-year reviews as required by Section 121 (c) of CERCLA. The conduct of five-yearreviews over a 30-year period is estimated to have a net present worth of $58,000. No capitalcosts would be incurred, and no ARARs would be considered under this alternative. The NCP,at 40 C.F.R. § 300.430(e)(6), requires the development of the No Action alternative for remedialactions.

* Shenango River Sediment and Riparian Soil Alternative 2-Limited Action/Natural Recovery

This alternative would include the natural re-sedimentation of the river. Over time, newsediments might be deposited on top of the existing sediments, thereby providing a natural

14

barrier between the PCB-contaminated sediments and ecological receptors. Additionally, naturalattenuation processes might gradually reduce PCB concentrations to levels which pose less riskto ecological receptors. The effectiveness of this alternative would be evaluated via biennial(every two years) sampling of the sediment and of fish tissue for Site-related contaminants. TheARARs are the regulations codified at 40 C.F.R. § 761.61, promulgated by EPA pursuant to theToxic Substances Control Act (TSCA). The net present worth of Alternative 2 is estimated to be$667,000.

* Shenango River Sediment and Riparian Soil Alternative 3-Institutional Controls and Cover

Under this alternative, portions of the Shenango River sediments and riparian soils whichexceed the PCB-cleanup levels (Areas 14 and 15) would be covered with a minimum of 12inches of clean granular fill or other suitable material in order to prevent the availability of thecontaminants to aquatic organisms. Routine monitoring would be performed to inspect the coverfor erosion. EPA anticipates that the Pennsylvania Fish and Boat Commission would maintainthe existing fish consumption advisories until the Commission determined through fish tissuesampling that consumption of fish no longer poses an unacceptable health risk. Monitoring ofthe surface water intake at the Shenango Valley Division of Consumers Pennsylvania WaterCompany would be performed during construction to assure that PCB-contaminated water wasnot drawn into the water supply system. The primary ARARs for this alternative would be theregulations codified at 40 C.F.R. § 761.61, promulgated by EPA pursuant to TSCA and theregulations codified at 25 Pa. Code § 102.4(b)(l) and 25 Pa. Code § 93.8a, promulgated byPADEP pursuant to the Pennsylvania Clean Streams Law. The estimated net present worth ofAlternative 3, including long-term maintenance and inspections, is $880,000.

* Shenango River Sediment and Riparian Soil Alternative 4-Remove and Treat/Dispose Offsite

Under this alternative, the sediments in Areas 14 and 15 and riparian soils in Area 15 thatexceed the respective cleanup levels (1 ppm PCBs for sediments; 10 ppm PCBs for ripariansoils) would be removed and transported to a Resource Conservation and Recovery Act (RCRA),TSCA and/or residual waste permitted offsite facility for treatment and/or disposal. ThisAlternative has two possible variations. Under Alternative 4A, a maximum of 12 inches ofimpacted sediments (estimated to be 1,125 cubic yards), and riparian soils (estimated to be 100cubic yards) would be removed. For Alternative 4B, up to 48 inches of impacted sediments(estimated to be 4,100 cubic yards) and riparian soils (estimated to be 300 cubic yards) would beremoved. Under both variations, excavated riparian areas would be backfilled with clean fillmaterials and revegetated. The intake for the Shenango Valley Division of ConsumersPennsylvania Water Company would be protected during the activities to assure that the publicwater supply system does not become contaminated. The ARARs for this alternative would bethe regulations codified at 40 C.F.R. § 761.61, promulgated by EPA pursuant to TSCA; theregulations codified at 25 Pa. Code § 102.4(b)(l) and 25 Pa. Code § 93.8a, promulgated byPADEP pursuant to the Pennsylvania Clean Streams Law; and regulations codified at 40 C.F.R.§§ 268.48-49, promulgated by EPA pursuant to RCRA. Transportation and disposal or treatment

15

of the contaminated materials would meet the requirements of the applicable state and federalregulations. The estimated net present worth of Alternative 4A is $1,840,000, and forAlternative 4B is $3,030,000.

The following is a summary of the alternatives that were developed in the FS for alluvialground water:

• Alluvial Ground Water/NAPL Alternative 1-No Action

Under this alternative, no remedial action would be taken to remove, control migrationfrom, minimize exposure to or otherwise reduce the potential for adverse effects to receptorswhich might be caused by Site-related contaminants in the alluvial ground water. No effortswould be made to control the future use of the contaminated areas. Because existingcontaminated alluvial ground water and NAPLs would remain in place, EPA will require five-year reviews as required by Section 121(c) of CERCLA. No capital costs would be incurred, andno ARARs were considered under this alternative. The NCP, at 40 C.F.R. § 300.430(e)(6),requires the development of the No Action alternative for remedial actions.

• Alluvial Ground Water/NAPL Alternative 2-InstitutionaI Controls with Monitored NaturalAttenuation

Alternative 2 for alluvial ground water and NAPLs includes the implementation ofinstitutional controls by the owners of the properties which comprise the former Westinghouseplant property, a municipal ordinance restricting the use of ground water in the area ofcontamination, and monitoring of ground water conditions on a periodic basis to demonstratewhether natural attenuation of Site-related contaminants is occurring. This alternative does notinclude the active extraction or treatment of contaminants present in the alluvial aquifer. TheARARs for this alternative include the regulations codified at 40 C.F.R. § 141.24, promulgatedby EPA pursuant to the Safe Drinking Water Act, and the regulations codified at 25 Pa. Code §§93.8a, promulgated by PADEP pursuant to the Pennsylvania Clean Streams Law. The estimatednet present worth of this alternative is $2,150,000.

• Alluvial Ground Water/NAPL Alternative 3-NAPL Source Removal with Monitored NaturalAttenuation

This alternative includes the removal of NAPLs from the subsurface using one or more ofseveral options. For Alluvial Ground Water/NAPL Alternative 3A, direct and/or enhancedrecovery methods, potentially including dual-well systems, solvent flushing, or electrical heatingalong with pumping or passive absorption of contaminants, would be implemented to collectNAPLs for appropriate off-site treatment and disposal. Alluvial Ground Water/NAPLAlternative 3A1 involves direct recovery only, while Alluvial Ground Water/NAPL Alternative3A2 involves both direct and enhanced recovery. For Alluvial Ground Water/NAPL Alternative3B, an in-situ treatment method such as enhanced biodegradation would be used to destroy the

16

NAPL constituents in the ground. The ground water use restrictions and continued monitoring ofground water for the natural attenuation of residual contaminants, as described for Alternative 2,would also be included for both 3A and 3B. The ARARs for this alternative include theregulations codified at 40 C.F.R. § 141.24, promulgated by EPA pursuant to the Safe DrinkingWater Act, and the regulations codified at 25 Pa. Code §§ 93.8a, promulgated by PADEPpursuant to the Pennsylvania Clean Streams Law. EPA has, however, chosen to invoke a waiverto the Safe Drinking Water ARARs based on technical impracticability as described more fully inSection XI (EPA's Selected Remedy) below. The estimated net present worth of Alternative3A1 (direct recovery) is $5,970,000, and for Alternative 3A2 (direct and enhanced recovery) is$9,860,000. The estimated net present worth of Alternative 3B (in-situ treatment) is$10,500,000.

* Alluvial Ground Water/NAPL Alternative 4-NAPL Source Removal with Ground WaterExtraction and Treatment

Alternative 4 includes the removal of NAPLs from the subsurface using enhancedrecovery methods described in Alternative 3A. In addition, impacted ground water containingdissolved contaminants in the South and/or Middle Sectors would be extracted and pumped to anew onsite facility for treatment by aqueous phase carbon adsorption and ultimate discharge oftreated water to the Shenango River. The ground water use restrictions and continued monitoringof ground water for natural attenuation of residual contaminants, as described for Alternative 2,would also be included in the alternative. The ARARs for this alternative include the regulationscodified at 40 C.F.R. § 141.24, promulgated by EPA pursuant to the Safe Drinking Water Act,and the regulations codified at 25 Pa. Code §§ 93.8a, promulgated by PADEP pursuant to thePennsylvania Clean Streams Law. The estimated net present worth of Alternative 4 is$17,300,000, including estimated costs associated with NAPL enhanced recovery activities.

* Alluvial Ground Water/NAPL Alternative 5-NAPL Source Removal with In-Situ GroundWater Treatment

Included in Alternative 5 is the in-situ treatment of NAPLs within the aquifer asdescribed for Alternative 3B. In addition, impacted ground water from non-NAPL areas in theSouth and/or Middle Sectors would also be subject to in-situ treatment via enhancedbiodegradation methods. The ground water use restrictions and continued monitoring of groundwater for natural attenuation of residual contaminants, as described for Alternative 2, would alsobe included in this alternative. The ARARs for this alternative include the regulations codified at40 C.F.R. § 141.24, promulgated by EPA pursuant to the Safe Drinking Water Act, and theregulations codified at 25 Pa. Code §§ 93.8a, promulgated by PADEP pursuant to thePennsylvania Clean Streams Law. The estimated net present worth of Alternative 5 is$12,000,000, including estimated costs associated with in-situ NAPL treatment.

The following is a summary of alternatives that were developed by Westinghouse in theFS Addendum for the sediments in the Site storm sewer drainageways:

17

• Storm Sewer Sediment Alternative 1-No Action

Under this alternative, no action would be taken to address impacted storm sewersediments, and the sediments would remain in place. These sediments do not currently pose anunacceptable direct threat to either human or ecological receptors, as there is no current directexposure. However, impacted sediments might be washed from the sewers into the river duringhigh-flow events, thereby posing a potential threat to ecological receptors, and to humans viapossible consumption of fish. EPA would require five-year reviews as required by CERCLA §121(c). No potential ARARs have been identified which might require the cleanup of impactedsediments in the storm sewer drainageways. No capital costs would be incurred to implementthis alternative.

• Storm Sewer Sediment Alternative 2-Remove Sediment and Dispose Offsite

Under this alternative, the estimated 20 cubic yards of PCB-contaminated (greater than 1ppm PCBs) sediments and debris in approximately 600 feet of the Wishart Court Storm Sewer(between the former transformer plant and Silver Street) would be removed and transported to aTSCA, RCRA or residual waste offsite facility for subsequent treatment and/or disposal.Removal would likely be performed by using either a vacuum truck or by high pressure washingof the inside of the sewer with collection of the washout. No potential ARARs have beenidentified which might apply to such removal of the contaminated storm sewer sediments, but theactual cleanup activities, because of their potential for unacceptable discharge of washout to theriver, would necessitate compliance with the regulations codified at 25 Pa. Code §§ 93.8a,promulgated by PADEP pursuant to the Pennsylvania Clean Streams Law. Any sediments ordebris removed from the storm sewer that would fail the Toxic Characteristic LeachingProcedure (TCLP) for metals would require treatment prior to land disposal as set forth inRCRA, 40 C.F.R. §§ 268,48-49. Actual onsite activities to implement this alternative areestimated to take one to two weeks. The estimated net present worth of this alternative is$149,000.

The following is a summary of alternatives that were developed in the FS Addendum forbedrock ground water:

• Bedrock Ground Water Alternative 1-No Further Action with Monitoring

» Under this alternative, no action would be taken to prevent exposure of humans topotentially impacted ground water. Monitoring would be performed to evaluate any furtherdegradation of the bedrock aquifer. There would be no attempt to place institutional restrictionson the use of bedrock ground water. The NCP, at 40 C.F.R. § 300.430(e)(6), requires thedevelopment of the No Action alternative for remedial actions. Under this alternative, noremedial action would be taken to remove, control migration from, minimize exposure to orotherwise reduce the potential for adverse effects to receptors which might be caused by Site-related contaminants in the bedrock ground water. No efforts would be made to control the

18

future use of the contaminated areas. Because existing contaminated bedrock ground waterwould remain in place, EPA would require five-year reviews as required by Section 121(c) ofCERCLA. This alternative has capital costs of $30,000, and a net present worth of $235,000over a 30-year period.

* Bedrock Ground Water Alternative 2-Institutional Controls with Monitoring

Bedrock ground water Alternative 2 would include EPA issuing an enforcementdocument for Operable Unit Two requiring the implementation of institutional controlsprohibiting the construction of, and the use of, ground water wells on the properties that werepart of the original Westinghouse facility and the monitoring of those wells. There are no knownusers of ground water for residential or industrial purposes in the area affected by Site-relatedcontaminants. It should be noted that EPA issued a Unilateral Administrative Order (UAO) tothree companies on September 29, 2000 relating to Operable Unit One (the "soils" cleanup).That UAO requires land use restrictions (institutional controls) such that there will be noinstallations of ground water wells for private or industrial purposes, other than ground watermonitoring, and that there will be no private or industrial usage of the ground water from any ofthe existing ground water wells. The parties to whom the Operable Unit One UAO was issuedhave informed EPA of their intent to comply with'the UAO. Also, the City of Sharon passed anOrdinance dated November 29, 2000 prohibiting the installation of, and the use of, ground watersupply wells in the area affected by Site-related contaminants. The Ordinance is currently ineffect.

The ARARs relating to this Alternative are the regulations codified at 40 C.F.R. § 141.24,promulgated by EPA pursuant to the Safe Drinking Water Act, and the regulations codified at 25Pa. Code §§ 93.8a, promulgated by PADEP pursuant to the Pennsylvania Clean Streams Law.The estimated net present worth of this Alternative is $430,000.

IX. COMPARATIVE ANALYSIS OF ALTERNATIVES

The following is a summary of the comparative analysis of the alternatives for ShenangoRiver sediments and riparian soils:

• Shenango River Sediment and Riparian Soil Alternative 1-No Action

A substantial risk to ecological receptors is posed by Site-related contaminants insediments and riparian soils in Areas 14 and 15. (The contamination was judged to be withinEPA's acceptable risk range with regard to potential human receptors.) Under the No Actionalternative, no remedial actions would be taken and, therefore, the alternative would not beprotective of ecological receptors. Also, the No Action alternative would not reduce themobility, toxicity or volume of the contaminants in sediments and riparian soils and would notcomply with the disposal requirements of TSCA since the PCB concentration in at least one ofthe sediment areas sampled exceeds 50 ppm.

19

* Shenango River Sediment and Riparian Soil Alternative 2-Limited Action/Natural Recovery

As noted previously, the risks posed to humans by sediments are within EPA's acceptablerisk range for direct contact. However, the impacted sediments and riparian soils do pose apotential risk to ecological receptors based upon the findings of the Screening Level EcologicalRisk Assessment. This alternative assumes that impacted sediments would be covered, overtime, by natural sediment deposition, and that the contaminant levels would be reduced over timedue to natural attenuation processes which would subsequently reduce potential exposures toecological receptors. Over time, if additional sediments were to be deposited over the existingsediments, then the mobility of the contaminants would be reduced. Natural biological, chemicaland physical processes might gradually reduce the concentrations of, and thereby the toxicity andvolume of, certain substances. However, there is no assurance that such natural sedimentationand natural attenuation would occur, therefore the long-term effectiveness and permanence, andtherefore the protectiveness, of the alternative are questionable. In the short term, this alternativewould not change current Site conditions, hi the small portion of the river where the PCBconcentrations in the sediment exceed 50 mg/kg, Alternative 2 might not comply with TSCAregarding the disposal of PCBs. The Alternative is readily implementable, and its cost isconsidered moderate at $677,000.

* Shenango River Sediment and Riparian Soil Alternative 3-Institutional Controls and Cover

Under this Alternative, Shenango River sediments and riparian soils in whichcontaminant levels exceed cleanup levels would be covered with a minimum of 12 inches ofgranular fill or other appropriate cover material. The existing fish consumption advisories wouldnot be changed. Regarding protectiveness, a properly designed, installed and maintained coverwould reduce the potential for ecological receptors to be impacted by contaminated sediments orriparian soils. The cover might result in a reduction of concentrations of contaminants in fishover time, thereby reducing the potential risk to humans associated with fish consumption. Theinstallation of a cover might result in the temporary resuspension of impacted sediments whichcould pose a short-term potential risk to human health due to the presence of the ShenangoValley Division of Consumers Pennsylvania Water Company water supply intake at Area 14, aswell as to ecological receptors. The actual remedial action would have to comply with theregulations promulgated under the Pennsylvania Clean Streams Law and codified at 25 Pa. Code§ 102.4(b)(l) and 25 Pa. Code § 93.8a to protect the water quality of the River, and with theregulations promulgated under the federal Safe Drinking Water Act and codified at 40 C.F.R. §141.24 to protect the water intake of the Shenango Valley Division of Consumers PennsylvaniaWater Company. The long-term effectiveness of this alternative would be dependent upon thecontinuous monitoring and maintenance of the cover materials. Mobility of the contaminantswould be reduced by a properly designed and installed cover system. Installation of a cover doesnot guarantee that the toxicity and volume of contaminants would be reduced, although overtime, natural biological, chemical and physical processes might gradually reduce concentrationsof certain contaminants. The installation of cover systems is feasible from an engineeringstandpoint. Total design and construction time frames are estimated to be five to eight months.

20

The water company intake might have to be shut down during the construction period. The costof Alternative 3 is considered to be moderate at $880,000.

* Shenango River Sediment and Riparian Soils Alternative 4-Remove and Treat/Dispose Offsite

Alternative 4 concerns contaminated sediments in Areas 14 and 15 and riparian soils inArea 15 and is subdivided into Alternative 4A and Alternative 4B. Alternative 4A involves theremoval of a maximum of 12 inches of impacted sediments (approximately 1,125 cubic yards)and riparian soils (approximately 100 cubic yards) with the backfilling of the removal areas withclean materials. Alternative 4B involves the removal of a maximum of 48 inches ofcontaminated sediments (estimated to be 4,100 cubic yards) and riparian soils (estimated to be300 cubic yards). Both 4A and 4B would not change the current fish consumption advisory andwould include the offsite disposal and/or treatment of the excavated materials. Regardingprotectiveness, the removal of impacted sediments would effectively reduce the potential for theunacceptable exposure of ecological receptors. This would in turn reduce concentrations ofcontaminants over time, thereby reducing the potential risk to humans from fish consumption.By removing and properly disposing of sediments with total PCB concentrations exceeding 50mg/kg to permitted disposal facilities, Alternative 4 would comply with TSCA. The actualremedial action would have to comply with 25 Pa. Code § 93.8a, promulgated by PADEPpursuant to the Pennsylvania Clean Streams Law to protect the water quality of the River.Disposal or treatment of the materials that are removed would require compliance with therelevant solid, residual or hazardous waste management regulations including 40 C.F.R. §761.61, promulgated by EPA pursuant to TSCA, and 40 C.F.R. §§ 268.48-49, promulgated byEPA pursuant to RCRA. All materials used to backfill excavations would meet standards forclean fill materials.

Provided that the backfill material used to replace the materials that are removed is placedproperly, Alternative 4A could be an effective long-term remedy for reducing the potentialexposure of ecological receptors to Site-related contaminants. Under Alternative 4B, it isanticipated that a substantial portion of the total Site-related contaminant mass would beremoved from the river, thereby providing a potentially effective and permanent remedy.Because of the relatively low concentrations of contaminants, treatment of removed materialswould likely not be required, and, therefore, the toxicity and volume of the contaminants wouldnot be reduced. Mobility of the contaminants would be reduced by virtue of their removal fromthe river and their deposition into, or treatment by, regulated facilities. The removal of thesediments would have to take into consideration, and would have to protect, the water supplyintake for the Shenango Valley Division of Consumers Pennsylvania Water Company which islocated in Area 14. Provisions would have to be incorporated into the remedial design andremedial action to assure that no contaminated sediments would enter the public water supplyduring the remedial action. Overall, implementation of Alternative 4 would be moderatelydifficult from an engineering and access perspective. The design and implementation of theremedial action would require an estimated 10 to 15 months. The estimated net present worth ofAlternative 4A is $1,840,000 and for Alternative 4B the estimate is $3,030,000 making these the

21

most expensive of the alternatives considered for sediments and riparian soils.

The following is a summary of the comparative analysis of the alternatives considered foralluvial ground water and NAPLs:

* Alluvial Ground Water/NAPL Alternative 1-No Action

Under the No Action Alternative, no remedial actions would be taken to remove, controlmigration of, or minimize exposure to, contaminated alluvial ground water/NAPLs at the Site. Ifit is assumed that ground water at the Site would be used in the future, then significant riskswould exist for the potential future ground water users due to the contamination in the alluvialground water. Therefore, if the ground water were to be used for potable or industrial purposesin the future, the No Action alternative would not be protective of human health and would notcomply with ARARs since EPA has judged that drinking water contaminant concentrations asestablished under the federal Safe Drinking Water Act are relevant and appropriate standards.The No Action alternative would not reduce the mobility, toxicity or volume of the ground watercontaminants.

* Alluvial Ground Water/NAPL Alternative 2-Institutional Controls With Monitored NaturalAttenuation

Alternative 2 for alluvial ground water and NAPLs includes the implementation ofinstitutional controls for properties comprising the former Westinghouse plant, a municipalordinance restricting the use of ground water within the area of contamination, and periodicmonitoring of ground water conditions relating to the contaminants in the aquifer. Althoughhypothetical future uses of ground water resulted in unacceptable risks as calculated in theHHRA, the RI found no current users of ground water in the area of ground water contamination.It is expected that natural processes would, over time, gradually reduce the concentrations ofsome of the dissolved contaminants downgradient of the Site. Ground water sampling performedat the Site in 1999 indicated that natural attenuation processes are occurring for somecontaminants in portions of the Site.

The institutional controls and ground water monitoring components of the remedy can bereadily implemented. EPA would issue an enforceable document for Operable Unit Tworequiring institutional controls which would restrict the installation of ground water wells. Inaddition, an Ordinance issued by the City of Sharon in November 2000 also prohibits the drillingof wells and the use of ground water in the Site area. It has not been demonstrated that the Site-related contaminated ground water is impacting the nearby Shenango River. Natural attenuationprocesses may continue to reduce the mobility, toxicity, and volume of some of the Site-relatedcontaminants. In the short term, there would be very minimal risk to human health since thereare no current exposures to the ground water. However, EPA is doubtful that natural attenuationprocesses would reduce the concentrations of certain contaminants, notably PCBs, which nowexceed drinking water standards, within a reasonable timeframe particularly since some of the

22

contaminants are found at high concentrations in the NAPL zones. As such, the remedy wouldnot meet the requirement to comply with ARARs since EPA has judged that maximumcontaminant levels (MCLs) and maximum contaminant level goals (MCLGs) established underthe Safe Drinking Water Act are relevant and appropriate standards relative to potential users ofthe contaminated ground water.

The estimated net present worth of Alternative 2 is $2,150,000.

• Alluvial Ground Water/NAPL Alternative 3-NAPL Source Removal with Ground WaterMonitoring

This alternative includes the removal of the contaminants that are found as NAPLs byusing any of several options. Alternative 3A1 involves direct recovery; 3A2 involves both directrecovery and enhanced recovery methods. Both scenarios under 3A include appropriate offsitetreatment or disposal of contaminated fluids. Alternative 3B involves in-situ treatment to destroythe NAPLs in the subsurface. The ground water use restrictions and continued monitoring ofground water as described for Alternative 2 would be an integral part of either 3 A or 3B.

As noted for Alternative 2, although the HHRA delineated significant potential risks tohypothetical users of ground water, there are, in fact, no present consumers of the ground waterand potable water is supplied to the area via a piped public water system. EPA would issue anenforceable document for Operable Unit Two requiring that institutional controls be placed onthe Site properties restricting the drilling of ground water wells. An Ordinance issued by the Cityof Sharon in November 2000 also prohibits the drilling of wells and the use of ground water inthe Site area. Therefore, regarding protectiveness, Alternative 3 would be at least as protective asAlternative 2. As with Alternative 2, EPA has determined that maximum contaminant levels(MCLs) and maximum contaminant level goals (MCLGs) under the Safe Drinking Water Act arerelevant and appropriate relative to future potential users of the contaminated ground water.

Any NAPLs collected under this Alternative would likely, because of the highconcentrations of PCBs, require offsite incineration to achieve compliance with TSCA. Theextraction and incineration (or other treatment) of the NAPLs would result in a reduction in thetoxicity, mobility and volume of the extracted contaminants and a reduction in the volume of thecontaminants remaining in the ground water. Short-term potential risks, such as crosscontamination of ground water aquifers, which might be associated with the installation of NAPLextraction wells could be>managed. Both 3A and 3B are implementable in that the services toperform either of these alternatives are readily available. Each of the alternatives would require aperformance period of at least six months to evaluate the effectiveness of the chosenmethodologies prior to full-scale implementation. Complete NAPL removal or treatment, if itcould be achieved, would require decades. However, as has been presented in the document"Technical Impracticability Of Groundwater Restoration Evaluation...," the total removal of theNAPLs and the actual restoration of the ground water to drinking water standards is technicallyimpracticable. That document is part of the Administrative Record for this ROD.

23

The estimated net present worth of Alternative 3A1 (direct recovery) is $5,970,000, andfor Alternative 3A2 (direct and enhanced recovery) is $9,860,000. The estimated net presentworth of Alternative 3B (in-situ treatment) is $10,500,000.

* Alluvial Ground Water/NAPL Alternative 4-NAPL Source Removal with Ground WaterExtraction and Treatment

This Alternative includes the removal of NAPLs using enhanced recovery methodsdescribed in Alternative 3A. Impacted ground water containing dissolved contaminants wouldbe extracted and pumped to an onsite treatment facility for ultimate discharge to the ShenangoRiver. The ground water use restrictions and monitoring, as described for Alternative 2, wouldalso be part of Alternative 4. As noted for Alternatives 2 and 3, although the HHRA delineatedsignificant potential risks to hypothetical users of ground water, there are, in fact, no presentusers of the ground water and potable water is supplied to the area via a piped public watersystem. Therefore, regarding protectiveness, Alternative 4 would be at least as protective asAlternatives 2 and 3. Also, as noted in the discussions for Alternatives 1, 2 and 3, EPA hasdetermined that maximum contaminant levels (MCLs) and maximum contaminant level goals(MCLGs) under the Safe Drinking Water Act are relevant and appropriate standards relative topotential consumers of the contaminated ground water.

Any NAPLs collected under this Alternative would likely require offsite incineration toachieve compliance with TSCA. Assuming that it is implementable, Alternative 4 would beeffective far into the future. As with Alternative 3, the ground water use restrictions incombination with the existing public water supply would effectively prevent unacceptable humanexposure to contaminated ground water. As noted in the discussion for Alternative 3, it isunlikely that NAPL recovery and ground water extraction would effectively remove allcontaminants from the aquifer, although these actions would reduce contaminant availability.Because collected NAPLs would be incinerated or otherwise treated, and dissolved contaminantswould also be treated, Alternative 4 would result in a reduction of the mobility, toxicity, andvolume of the contaminants. As with Alternative 3, any short-term risks associated withAlternative 4 would involve minor risks associated with the installations of extraction wells andother equipment. These short-term risks could be easily managed. Also, as with Alternative 3,services are readily available to perform the activities included in this alternative. Here again,however, EPA has determined that complete NAPL removal or treatment and restoration of thealluvial aquifer are judged to be technically impracticable, as noted in the discussion forAlternative 3. The estimated net present worth of Alternative 4 is $17,300,000. *

* Alluvial Ground Water/NAPL Alternative 5-NAPL Source Removal with In-Situ GroundWater Treatment

This Alternative includes the in-situ treatment of NAPLs as described for Alternative 3B.In addition, dissolved contaminants in the alluvial ground water would be subject to in-situtreatment via enhanced biodegradation methods. The ground water use restrictions and

24

continued ground water monitoring, as described for Alternatives 2, 3, and 4, above, would alsobe included. The overall aspects of protectiveness; long-term effectiveness and permanence;reduction in mobility, toxicity, or volume of contaminants; short-term effectiveness; andimplementability are similar to those aspects as noted under Alternative 4, above. Also, as withAlternatives 1, 2, 3 and 4, EPA has determined that maximum contaminant levels (MCLs) andmaximum contaminant level goals (MCLGs) under the Safe Drinking Water Act are relevant andappropriate standards relative to potential users of the contaminated ground water. Here again,however, EPA determined that complete NAPL removal or treatment and restoration of thealluvial aquifer are technically impracticable, as noted in the discussions for Alternatives 3 and 4.The estimated net present worth of Alternative 5 is $12,000,000.

The following is a comparative analysis of the two alternatives for storm sewersediments:

* Storm Sewer Sediment Alternative 1-No Action

The No Action Alternative is required for consideration by the NCP and this alternativewas, accordingly, considered for storm sewer sediments. Under the No Action Alternative, noremedial actions would be taken to remove, control migration of, or minimize exposure to,contaminated storm sewer sediments at the Site. The No Action alternative would not reducethe mobility, toxicity or volume of the storm sewer contaminants. Because contaminatedsediments would remain in the storm sewers and would retain the potential to be washed into theShenango River, the No Action alternative might not be protective of ecological receptors. EPAwould require five-year reviews to assess protectiveness as required by Section 121(c) ofCERCLA. No capital costs would be incurred for the No Action alternative.

•Storm Sewer Sediment Alternative 2-Remove Sediment and Dispose Offsite

Under this alternative, approximately 20 cubic yards of sediment and debris containingPCS contamination exceeding 1 ppm would be removed from approximately 600 feet of theWishart Court Storm Sewer and transported to an appropriate offsite facility for proper disposal.During the sediment removal, measures would be taken to prevent the flow of potentially-contaminated runoff from the work area. Removal of the impacted sediments from the WishartCourt Sewer would effectively remove a substantial portion of the total Site-related PCB massfrom the drainageways and would substantially reduce the potential for unacceptable exposure ofecological receptors to the contaminated sediments. The alternative would be easily »implemented using standard cleaning methods, such as high pressure water cleaning . Byremoving the PCB-contaminated sediments for proper offsite disposal, the mobility and thevolume of the PCBs would be reduced. The estimated net present worth of this Alternative is$149,000.

The following is a comparative analysis of the two alternatives analyzed for bedrockground water:

25

* Bedrock Ground Water Alternative 1-No Further Action With Monitoring

Under this Alternative, no actions would be taken to prevent human exposure tocontaminated bedrock ground water and no actions would be taken to reduce the contaminationof the ground water. The Alternative would not reduce the mobility, toxicity or volume ofcontaminants in the bedrock ground water. Monitoring of bedrock ground water would beperformed on a periodic basis to assess the quality of the bedrock ground water and the status ofany contamination. The costs associated with this Alternative are essentially the costs of thelong-term monitoring. The net present worth of the long-term monitoring of the bedrock groundwater is estimated to be $235,000.

* Bedrock Ground Water Alternative 2-Institutional Controls With Monitoring

Alternative 2 for bedrock ground water includes the implementation of institutionalcontrols for the properties that comprise the former Westinghouse facility and continued periodicmonitoring of ground water conditions to assess the condition of the ground water, the status ofthe contamination and the potential for any further degradation of the bedrock aquifer. Becausethere are no current users of the ground water as the area is served by a public water supply, andthe City of Sharon has passed an Ordinance prohibiting the drilling of ground water wells and theuse of ground water in the area affected by Site-related contamination, this Alternative would beprotective of human health both in the short term and the long term. There is no evidence thatthe contaminants in the ground water are impacting ecological receptors or the Shenango River.There are no statutory nor regulatory standards that are directly applicable to the contamination inthe bedrock ground water. EPA has judged that MCLs and non-zero MCLGs under the SafeDrinking Water Act are relevant and appropriate relative to potential future users of the groundwater for potable purposes in this industrialized area. However, the only area of bedrock groundwater contamination of note is in the immediate area of former monitoring well M-l IB. Thealluvial aquifer directly over that extremely small area of bedrock contamination consists ofDNAPL, high-concentration dissolved contaminants and LNAPL. EPA believes that it istechnically impracticable to address the small amount of contamination in the bedrock aquiferbecause of the risk of causing further contamination of that aquifer if the overlying alluvialaquifer is penetrated with extraction wells.

The Alternative would not actively reduce the mobility, toxicity nor volume ofcontaminants in the bedrock ground water, although natural attenuation processes, which are notconsidered to be part of this alternative, may gradually reduce the concentrations of certain »substances. The Alternative is readily implementable. Capital costs for this Alternative wouldconsist primarily of legal fees, filing fees and associated costs. Long-term costs associated withcontinued monitoring of the ground water are dependent on the sampling frequency and theparameter list. The current estimated net present worth is $430,000.

26

X. PRINCIPAL THREAT WASTES

EPA does not believe that the PCS contamination in the riparian soil, Shenango Riversediments and Wishart Court drainageway sediments constitutes a principal threat requiringtreatment because these media are not liquid wastes, PCBs are not highly mobile substances, andthe PCB concentrations in these media are not at high concentrations. In addition,implementation of the remedial action will eliminate unacceptable exposure to anycontamination left in place.

The alluvial ground water at the Site could be categorized as a principal threat because itis liquid and contains high concentrations of Site-related contaminants, particularly in the form ofDNAPLs and LNAPLs. However, EPA believes that the ground water contaminants, includingthe DNAPLs and LNAPLs, have reached a steady state whereby the geographic area of groundwater contamination is not increasing. Also, because there are no exposures to the ground watercontamination, the contaminants do not pose a potential risk several orders of magnitude greaterthan the risk level that is acceptable for the current or reasonably anticipated future industrialland use, given realistic exposure scenarios.

XL EPA'S SELECTED REMEDY

After carefully considering the available options for the various components of OperableUnit Two, EPA's selected remedy for Operable Unit Two is as follows:

* For Shenango River Sediments and Riparian Soils

EPA's selected alternative for river sediments and contaminated floodway soils isShenango River Sediments and Riparian Soils Alternative 4B. Under this alternative, anestimated 4,100 cubic yards of PCB-contaminated (greater than 1 ppm PCBs) river sedimentswill be removed from Areas 14 and 15 of the Shenango River, and an estimated 300 cubic yardsof PCB-contaminated (greater than 10 ppm PCBs) riparian soils will be removed from theRiver's floodway in Area 15. The sediments and soils removed will be properly disposed of atpermitted RCRA and/or TSCA offsite facilities and will be replaced, where it is judged to beappropriate during the remedial design, with clean, imported materials. It is anticipated that theremoval of the PCB-contaminated materials could allow the current fish consumption advisoryregarding the PCB contamination of muskellunge and carp to be withdrawn, in time, from theapproximately four-mile section of the Shenango River extending from the dam at the Shenango *Reservoir downstream to the dam at the Shenango Valley Division of Consumers PennsylvaniaWater Company. The intake of the Water Company will be monitored during the removal of thesoils. As part of this alternative, EPA has concluded that it is appropriate to conduct monitoringof fish tissue to determine the edibility of the fish tissue. A fish tissue monitoring plan will berequired as part of the remedial design. Six fish tissue monitoring events over a 30-year periodwill add an estimated $150,000 to the $3,030,000 remedy. The net present worth of thisAlternative, including fish tissue monitoring, is estimated to be $3,180,000.

27

* For Alluvial Ground Water and Bedrock Ground Water

EPA's selected alternative for alluvial and bedrock ground water is "No Further Actionwith Monitoring." This alternative takes into account the land use restrictions (institutionalcontrols) required by EPA's September 29, 2000 Unilateral Administrative Order for OperableUnit One as being existing requirements. EPA also considered other existing conditions at theSite including the Ordinance restricting ground water use issued by the City of Sharon inNovember 2000 and the fact that the entire area is served by a public potable water system.

As noted previously, a number of Site-related contaminants including PCBs,trichloroethene, and 1,2,4-trichlorobenzene have impacted the alluvial (upper) ground wateraquifer as DNAPL, as LNAPL and as dissolved contaminants. The bedrock (lower) aquifer isimpacted to a very minor extent, and only by dissolved Site-related contaminants, includingPCBs, primarily in a very restricted area in the immediate vicinity or former monitoring well M-1 IB, just west of the Middle Sector and directly beneath the NAPL zone. There are no currentusers of the impacted ground water and the entire area is served with potable water supplied viapipeline by the Shenango Valley Division of Consumers Pennsylvania Water Company. Groundwater studies done during, and subsequent to, the RI indicate that the ground water contaminantsare not reaching and are not expected to reach the Shenango River. The River is about 2000 feetwest of the highest concentrations of ground water contaminants in the Middle Sector and theSouth Sector. There is evidence that natural attenuation processes are acting to reduce the •concentrations of some dissolved contaminants. The contamination that exists today is the resultof spillage decades ago. For example, the use of PCBs, one of the many ground watercontaminants, was discontinued at the Site in 1976. No continuing sources such as leakingstorage tanks or improper chemical off-loading practices exist today that might add to thecontaminant burden, and there is no reason to believe that the degree of ground watercontamination will increase. Indeed, the Operable Unit One (OU1) soils cleanup required underEPA's February 18, 2000 ROD can only serve to lessen the availability of contaminants to theground water. Also, there are at least two other industrial sources of ground water contaminationlocated between the former Westinghouse facility and the Shenango River which are not relatedto the former Westinghouse plant.

The area is industrial and commercial and will remain so into the foreseeable future. Theformer Westinghouse facility and its immediate vicinity are currently undergoing furtherindustrial development. Even though there are no current ground water users in the area andnone are anticipated, the City of Sharon has added an additional level of protectiveness byenacting an Ordinance that prohibits the drilling of wells and the use of ground water in the areathat is, or could possibly be, affected by the Site-related contaminants.

As part of the remedy review process, EPA evaluated MCLs and MCLGs under the SafeDrinking Water Act (SWDA) and has judged these requirements to be "relevant and appropriate"standards for remedy selection at the Site. However, conditions at the Site preclude the actualability to clean the ground water to drinking water standards.

28

The presence of NAPLs, both floating (LNAPL) and sinking (DNAPL), in the alluvial(upper) aquifer, in the general vicinity of the former Tank Farm located along the western portionof the former plant's Middle Sector is clearly documented in, among other things, the RemedialInvestigation. This NAPL source zone is acting as a latent source for dissolved phasecontamination of the alluvial aquifer. This aquifer is vertically and laterally heterogeneous withrespect to its hydraulic properties and sedimentary textures. There are no indications that theNAPL constituents (these include PCBs and trichlorobenzene) have migrated downward throughthe glacial till aquifer to the bedrock aquifer, and lateral downgradient migration has beendemonstrated to be limited because of the hydrophobic nature of the constituents and naturalattenuation processes. Substantial monitoring of the ground water over a number of yearssupports these findings.

Aquifer restoration to drinking water quality is technically impracticable within areasonable or foreseeable time frame. This conclusion is based upon experience at other siteswhere it has been demonstrated that aquifer restoration has never been accomplished if NAPLsource zones cannot be removed or contained. NAPL containment, removal, and treatmentmethods were evaluated for the Site. Containment using slurry walls, sheet piling, or otherstructures was determined to be technically impracticable due in part to the large area requiringcontainment and the presence of active off-property industrial buildings and an active railroadline within the NAPL source area. Removal and in-situ treatment of NAPLs is technicallyimpracticable due to the heterogeneity of the alluvial aquifer, and the lack of technologies with ademonstrated ability to remove or treat more than 60 percent of the NAPLs. Such methods donot provide an increase in protectiveness of human health that is proportional to the associatedincrease in cost, and could prove to be less protective of the environment due to the increasedpotential for contaminant migration that might result because of the disturbance of the NAPLsthat would result using active remedies.

EPA has, therefore, chosen to invoke a waiver of the drinking water ARARs for certainchemicals of concern (COCs), pursuant to CERCLA Section 121(d)(4)(C) because of thetechnical impracticability of attaining drinking water standards. The justification for the ARARwaiver is presented in the document titled, "Technical Impracticability OfGroundwaterRestoration Evaluation " dated March 22, 2002 and prepared by Cummings/Riter Consultants,Inc. That document is included in the Administrative Record for the Site. The COCs affected bythe ARAR waiver are listed in Tables 3-1, 3-2, and 3-3 of that document. The area affected bythe ARAR waiver is shown on Figure 4-2 of the document. The Technical ImpracticabilityWaiver Zone (TI Zone) is described using surfioial features and is bounded to the north by ClarkStreet, to the east by Sharpsville Avenue, and to the south by Wishart Court continuing west tothe intersection of Reno Street and Shenango Avenue. The western boundary extends alongShenango Avenue (from Reno Street) north to Broad Street, then due east to the NorfolkSouthern railroad tracks, and finally, north along the railroad tracks to Clark Street (Figure 9).

As part of EPA's selected remedy, additional monitoring wells will be established alongthe west and southwest portions of the perimeter of the TI Zone, and a regimen of periodic

29

ground water sampling will be established as part of the Remedial Design. The monitoring willbe accomplished to determine whether contaminants of concern are exceeding the limits of the TIZone in concentrations that might be considered not to be protective of public health and welfareand the environment.

The estimated net present worth of the monitoring of the ground water over a 30-yearperiod is $2,385,000.

As previously noted, EPA issued a UAO to Westinghouse in February 1994 requiringWestinghouse to monitor LNAPL and implement LNAPL extraction. Paragraph 8.3(g) of theUAO allows EPA to terminate the LNAPL extraction upon implementation of a Record ofDecision addressing the ground water contamination subject to the UAO. As part of EPA'sselected No Further Action With Monitoring remedy for Site ground water, the LNAPLextraction required by the 1994 UAO will be terminated.

* For Storm Sewer Drainagewavs

EPA's selected alternative for storm sewer drainageway sediments is "Storm SewerSediment Alternative 2-Remove Sediment and Dispose Offsite" as outlined above. Under thisalternative, approximately 600 feet of the Wishart Court Sewer line north of Silver Street will becleaned of existing PCB-contaminated sediments. The sediments, estimated to have a totalvolume of approximately 20 cubic yards, will be disposed offsite at permitted RCRA and/orTSCA facilities. EPA believes that the removal of the sediments containing 1 ppm PCBs orgreater from the Wishart Court Sewer will significantly reduce the probability of PCBs beingflushed into the Shenango River from the Site drainageways. (It should be noted that, althoughcertain portions of some drainageways contain sediments with elevated concentrations of metals,there is no evidence to indicate that these concentrations of metals are related to the formerWestinghouse facility, but rather, are likely due to a combination of historic and currentindustrial and other anthropogenic activities in the area.) The estimated net present worth ofStorm Sewer Alternative 2 is $149,000.

The total estimated net present worth of EPA's Selected Alternative is $5,714,000.

Based upon information currently available to EPA, the Selected Remedy is necessary toprotect the public health or welfare or the environment from actual or threatened releases ofhazardous substances into the environment. Additionally, but separate from this remedy, therewill be the five-year reviews of the entire Site, including the ground water component, forprotectiveness as required by CERCLA Section 121(c).

The selection of EPA's Selected Remedy under the authority of CERCLA does notpreclude the Commonwealth of Pennsylvania from pursuing additional cleanup actions understate authorities.

30

XII. PERFORMANCE STANDARDS

Samples will be obtained, where practicable, of any remaining riparian soils andShenango River sediments to confirm that the remaining riparian soils and sediments meet thecleanup criteria as noted above. Satisfactory riparian soil and River sediment cleanup will bedetermined by using one of, or a combination of, the following methods:

1. Contaminated riparian soil and River sediment removal will be considered to be satisfactorywhen the confirmatory samples demonstrate that the PCB levels remaining in the riparian soiland the River sediments provide a statistical confidence level of at least 95 percent that therequired cleanup levels have been attained, or, alternatively,

2. Contaminated riparian soil and River sediment removal will be considered to be satisfactorywhen the confirmatory samples demonstrate that no PCBs remain above the allowableconcentrations in any sample of the soil or sediments, or alternatively,

3. Contaminated riparian soil removal will be considered to be satisfactory when theconfirmatory samples demonstrate that no PCBs remain above the allowable concentrations inany sample of the soil while River sediment removal will be considered to be satisfactory whenat least 48 inches of the sediment have been removed.

The Remedial Design of the cleanup will delineate which methods or combination ofmethods noted above will be utilized for riparian soils and for sediments. The Remedial Designwill provide the details of the sampling frequencies, the sampling methods, the analyticalmethods, and any statistical methods that will be used to assure that the required cleanupconcentrations are achieved. The Remedial Design will also describe the types and amounts ofmaterials, if any, that will be used for backfill of the areas from which River sediments andriparian soils are removed.

The removal of PCB-contaminated sediments and debris from the Wishart Court sewerwill be accomplished so that no sediments having PCB concentrations exceeding one part permillion (1 ppm) PCBs remain in the sewer line. It is currently estimated that approximately 600feet of the sewer line containing approximately 20 cubic yards of sediment and debris is affected.It will be assumed that the contaminated sediments and debris have been satisfactorily removedwhen visual inspection finds the section of the sewer that has been cleaned is free of debris andsediments. *

No cleanup of the ground water will be undertaken, therefore, no cleanup performancestandards apply to ground water.

XIII. COMMUNITY PARTICIPATION

31

Pursuant to 40 C.F.R. § 300.430(c), a Community Relations Plan was developed for theSite. In compliance with Sections 113(k)(2)(B)(i-v) and 117 of CERCLA, the AdministrativeRecord, including the Proposed Remedial Action Plan, was placed for public consideration at theShenango Valley Community Library in the City of Sharon, Pennsylvania. An announcement ofthe availability of the Administrative Record was published in the Sharon Herald on November1, 2002. The Administrative Record included the FS Report and the FS Supplemental Reportwhich listed the alternatives considered for the contaminated ground water, Shenango Riversediments, riparian soils and drainageways at the Site. The Administrative Record also includedthe "Technical Impracticability Of Groundwater Restoration" report. A period of public reviewand comment on the Proposed Remedial Action Plan was held from November 1 throughNovember 30, 2002. A public meeting regarding the Proposed Remedial Action Plan was heldon November 14, 2002 at the City of Sharon Municipal Building. A transcript of that meeting isincluded in the Administrative Record. A summary of the written public comments received andEPA's responses to those comments is attached to this Record of Decision as a ResponsivenessSummary. All documents relevant to the development of the Remedial Investigation, theFeasibility Study, the Supplemental Feasibility Study and the "Technical Impracticability OfGroundwater Restoration" report pertinent to this Record of Decision were produced under theauspices of, or in cooperation with, the Pennsylvania Department of Environmental Protection(PADEP).

XIV. STATUTORY DETERMINATIONS

The selected remedial alternative satisfies the requirements of CERCLA and the NCP.EPA believes that the remedy is protective of public health and welfare and the environment. Inaddition, the selected remedy complies with ARARs (except in the instance in which ARARs arewaived), is cost-effective, and utilizes permanent solutions to the maximum extent practicable.The remedy does not satisfy the statutory preference for treatment as a principal element of theremedy because treatment would result in extraordinarily high costs with no significant increasein protectiveness. Because the selected remedy will result in hazardous substances, pollutants orcontaminants above levels that allow for unlimited use and unrestricted exposure remaining atthe Site, a review under Section 121(c) of CERCLA, 42 U.S.C. § 9621(c), will be conductedwithin five years after initiation of the first operable unit, Operable Unit One (soils cleanup),remedy to ensure that the remedies selected for Operable Unit One and Operable Unit Two areproviding protection of public health and welfare and the environment.

• The following sections discuss how the selected remedy for Operable Unit Two meets thestatutory requirements of CERCLA:

A. Protection of Human Health and the Environment

EPA has determined, based upon the baseline Human Health Risk Assessment for theSite, that measures should be undertaken to reduce potential risk from ground watercontaminants, including PCBs and trichlorobenzene. The contaminants in Site ground water were

32

selected because potential health risks for some exposure scenarios exceed EPA's target range ofl .Ox 10~"and l.Ox 10"6 for lifetime cancer risk or a non-cancer Hazard Index of one (1.0). EPAhas determined that the ground water contaminants do not pose an unacceptable risk toecological receptors. EPA has further determined that Site-related PCB contamination indrainageway sediments, Shenango River sediments and riparian soils does not pose anunacceptable risk to human receptors but does pose unacceptable risks to ecological receptors.

The River sediment and riparian soil excavations and the drainageway sediment removalrequired under this Operable Unit, OU-2, the institutional controls previously required as part ofthe selected remedy for Operable Unit One, the Pennsylvania Fish and Boat Commission's fishconsumption advisory already in effect for the Shenango River and the Ordinance restrictingground water usage in the Site area passed by the City of Sharon in November 2000 will reduceexposures of potential human and ecological receptors to the contaminants currently posing apotential risk at the Site. This determination is based upon the assumption that the Site area willremain under industrial and commercial usages into the foreseeable future.

Implementation of the selected remedy will be designed so as to not pose anyunacceptable short term risks or cross media impacts to the Site or to the community.

B. Compliance with and Attainment of Applicable or Relevant and AppropriateRequirements (ARARs)

The selected remedy will comply with all applicable or relevant and appropriatechemical-specific and action-specific ARARs except for those chemical-specific ARARs whichare waived as noted below. In addition, the selected remedy will meet all To Be ConsideredStandards (TBCs). Those ARARs and TBCs are outlined in Table 3 and summarized below:

Location-Specific ARARs

The Pennsylvania Flood Plain Management Act and the Dam Safety and EncroachmentAct (PL 851, No. 155 and PL 1375) relating to construction, earthmoving, filling and excavationwithin the 100-year flood plain and within wetlands as well as regulated waters of theCommonwealth.

Chemical-Specific ARARs

The Toxic Substances Control Act (TSCA), 15 U.S.C. § 2605, and its implementingregulations, 40 C.F.R. § 761.61, with respect to standards for the cleanup of PCB remediationwaste.

Maximum Contaminant Levels (MCLs) and Maximum Contaminant Level Goals(MCLGs) for drinking water under the federal Safe Drinking Water Act (SDWA) are herebywaived for certain Site-related ground water contaminants within the Technical Impracticability

33

Zone which is depicted herein on Figure 9, and on Figure 4-2 of the document titled "Report;Technical Impracticability Of Groundwater Restoration Evaluation..." dated March 22, 2002which is part of the Administrative Record. The specific elements and compounds for which theMCLs and MCLGs are waived are listed in Table 2 of this ROD.

CERCLA 121(d)(2)(A)(ii) requires a state standard, requirement, criteria, or limitationunder state law, must be more stringent than the federal standard to be considered an ARAR atfederal cleanups. PADEP has identified the Land Recycling and Environmental RemediationStandards Act, 95 Pa. Laws 2 (Act II), and 25 Pa. Code Chapter 250, Administration of the LandRecycling Program, as ARARs for the selected remedy. EPA has determined, through a sitespecific evaluation, that Act II and Chapter 250 for Operable Unit 2 are either equivalent to, orless stringent than the federal standards, and therefore, does not recognize the State standards asARARs.

Action-Specific ARARs

The Land Disposal Restrictions of the Resource Conservation and Recovery Act, 40C.F.R. § 268.48-49, to address treatment of lead- and arsenic-contaminated soil failing TCLP.

The Pennsylvania Water Quality Standards, 25 Pa Code § 93.1 et. seq. which addresseswater quality criteria and the designated water use protection for the waters of theCommonwealth.

Pennsylvania Special Water Pollution Regulations, 25 Pa Code §101.2(a) and (b) relatingto incidents causing or threatening pollution of waterways.

To Be Considered Standards (TBC)

EPA's "Management of Remediation Waste Under RCRA," EPA530-F-98-026, October14, 1998, addressing Areas of Contamination in which contaminated soils are to be consolidated.

The Fish and Boat Code, Act of October 16, 1980, P.L. 996, as amended, 30 Pa. C.S.§101 et. seq. and its implementing regulations relating to fish consumption advisories.

C. Cost-Effectivenesst r

The selected remedy is cost-effective in providing overall protection in proportion to costand meets all other requirements of CERCLA. Section 300.430(f)(l)(ii)(D) of the NCP requiresEPA to evaluate cost-effectiveness by comparing all the alternatives which meet the thresholdcriteria-protection of human health and the environment and compliance with ARARs--againstthree additional balancing criteria: long-term effectiveness and permanence; reduction oftoxicity, mobility, or volume through treatment; and short-term effectiveness. EPA hasconsidered these criteria and has determined that the selected remedy provides the best balance

34

for overall effectiveness in proportion to its cost. EPA estimates the net present worth of theselected remedy to be $5,714,000.

D. Utilization of Permanent Solutions and Alternative Treatment Technologies to theMaximum Extent Practicable

None of the remedial alternatives considered would, from a practicability standpoint,provide a permanent remedy for all aspects of contamination at the Site. All alternatives, whenconsidering the entire Site, would rely to some extent upon contaminant containment, the relativeimmobility of the contaminants, institutional controls and/or the long-term maintenance andmonitoring that would necessarily accompany these measures to provide the required level(s) ofprotection of human health and the environment. EPA has determined that the selected remedyrepresents the maximum extent to which permanent solutions and treatment technologies can beutilized while providing the best balance among the other evaluation criteria.

E. Preference for Treatment as a Principal Element

The selected remedy addressed the potential risks due to dermal contact, ingestion andinhalation of Site-related contaminants in Site drainageways, Shenango River sediments, ripariansoils and ground water. Treatment as a principal element of the remedy was not selected basedupon an evaluation of the alternative selection criteria as these relate to Site-specific conditions.In particular, EPA believes that treatment as a principal element of the selected remedy wouldvery significantly increase the cost of the remedy, would increase the time frame of the remedy,and would increase the complexity of the remedy without increasing the protectiveness of theremedy.

Figures

, 4MT^~- f v _

REFERENCE:7.5-MiN. TOPOGRAPHIC QUADRANGLE; ORANGEV1LLE, OH-PA.1961 PHOTOREV1SED 1979; SHARON EAST, PA. 1958PHOTOREV1SED 1981; SHARON WEST. OH-PA, 1962PHOTOREVISED 1979; AND SHARPSVILLE. PA, 1958PHOTOREV1SED 1981. SCALE 1:24000.

4000 FT.

Figure 1

Westinghouse Sharon Site

Location Map

y //////////an a r /////////' A1/--/.!l/!!l///7//M// MM,III J//////// /$$•<i V//////r/// vm'i

Tables

TABLE 1SUMMARY OF BASELINE HUMAN-HEALTH RISK ASSESSMENT

FOR GROUND WATER

Medium1'

Southern AlluvialGroundwater

Central AlluvialGroundwater

HypotheticalExposure

Scenarios'1'

Adult Resident^Child ResidentWorker

Adult Resident'11'Child ResidentWorker

Relevant ExposurePathway(s)

IngestionDermal ContactInhalation

IngestionDermal ContactInhalation

SignificantlyContributingChemicals'"'

Aroclor-1254Arsenic2,3,7,8-TCDD (teq)Vinyl chloride1 ,4-DichlorobenzeneTrichloroethene1,1-Dichloroethene1 ,3-DichlorobenzeneIron1 .2-DichloroetheneManganeseChromiumAluminumNickelVanadium1 ,2 ,4-Tric hlorobenzeneChlorobenzeneMercuryBariumCopperCadmiumZinc2 ,4- DichlorophenolBeryllium1 .2-DichlorobenzeneTotal of All Chemicals

Aroclor-1254Aroclor-1248Aroclor- 1 242Aroclor- 1 260TrichloroetheneArsenic2,3,7,8-TCDD (teq)Benzene1 ,4-DichlorobenzeneTetrac hloroethenel.l-Dichloroethenel.2-Dichloroethane1 ,2,4-TrichlorobenzeneManganeseIron1 ,3-Di chlorobcnzeneAluminumCadmiumZincChromiumVanadium

TotalCarcinogenic

Risk'"

1. IE-028.7E-031.3E-035. IE-043.5E-048. IE-052.3E-05

---~-----------«---~----

2.2E-02

3.1E+002.8E+004.4E-034.4E-033.2E-037.8E-047.3E-043.2E-042.8E-047.9E-056. IE-05I.5E-05

---»»------—

TotalNon-Care.

Hazard Index'"

140084——1.55.3

00273662524156.J2.31.81.51.0LO0.80.6 -0.60.40.40.3

0.161710

5.0E-H)6-----

1227.5--101.20.8

0.0400167016010066109.07.77.13.0

Page 1 of2

TABLE 1SUMMARY OF BASELINE HUMAN-HEALTH RISK ASSESSMENT

FOR GROUND WATER

Medium"Central AlluvialGroundwater(continued)

BedrockGroundwater.

HypotheticalExposure

Scenarios1*1

Adult Resident^Child ResidentWorker

Relevant ExposurePatbway(s)

IngestionDermal Contact

SignificantlyContributingChemicals'*

CopperChlorobenzene1 ,2-DichlorobenzeneBariumNickelMercuryBerylliumSilverCyanide1,2-DichloroetheneTotal of All Chemicals

Aroclor-1260Aroclor-12542,3.7,8-TCDD (teq)ArsenicBenzo( a (anthraceneBis(2-ethylhexy t )phthalateAluminumBariumCadmiumManganeseIronTotal of All Chemicals

TotalCarcinogenic

Risk"-~-—«---------

l.OE+00

2.8E-032.7E-033. IE-042.2E-041.5E-055.9E-06

--—---

6. IE-03

TotalNon-Care.

Hazard Ind«(c|

1.51.31.01.0

0.900.600.50.200.100.07

5.0E+06

..340--

2.0-

0.090.50.20.2'0.43.1347

Notes:a. Only those media and exposure scenarios for which the calculated carcinogenic risk or non-caremogemc hazard index

exceeds the target range (10"4 and 1.0, respectively) are shownb Only those chemicals which have a total carcinogenic nsk of greater than 10"6 or a hazard index of greater than 0 I are shownc Total risks and hazard indices are the approximate values calculated by USEPA, and include each relevant exposure pathwayd. Carcinogenic risks are for the combined Adult/Child Resident scenario Noncarcmogenic risks are for the Child Resident scenario

Page 2 of2

TABLE 2

Elements And Compounds For WhichMCLs And MCLGs Are Waived

Elements and Compounds

1 ,2-Dichlorobenzene1 ,4-DichIorobenzene1 ,2-Dichloroethane

1 ,2-Dicholoroethene2,3,7,8-TCDD (teq)1 ,2,4-Trichlorobenzene

PCBAroclor 1242PCBAroclorl248PCBAroclor 1254

PCBAroclor 1260TetrachloroetheneTrichloroethene

Vinyl ChlorideBis(2-ethylhexyl)phthalateBenzene

ArsenicBariumBeryllium

CadmiumChromiumCyanide

Mercury

SDWA MCL*

600755

70 (cis-)3.00E-570

0.50.50.5

0.555

265

102,0004

5100200

2

SDWA MCLG*

600750

70070

000

000

000__

2,0004

5100200

2

* MCLs and MCLGs are shown in micrograms per liter (ug/1)

T D

rain

way

s.

..2*w01

ow•T-l

Q

"3o.

•III

J^"HX C^ 11CO If

ILE3

ppro

pria

te R

equi

rem

ents

(ARA

B.si

dere

d M

ater

ial f

orim

ents,

Rip

aria

n So

ils a

nd S

torm

™ ^ § U^^ r"1

Sum

mar

y of

Req

uire

men

t

co« ,£ fc 1 1 '-P+_, CQ £ I g

J3 S o 1 '§'w S ^1 ^3o4 d al u* l|^—— ~1 1u cK»- "^wD- Frt*

< gJJ22

"TJ<uS

CO

-rHB|| ta£• §•§11 Gc/a"

UCQ^

•<r

CM

• • •d

>«'oa

COBO13oOhJM

oC^3 ^^COD _H

w 2OH Q^<N r-

1ST3Oo S

nsyl

vani

a Fl

nage

men

t A

<U yno, 2-1

p3 00 ).o 9 ^'•g '> ^"a § O$M S 05*" « M c1 1 81o a 2 *

The

subs

tantiv

e sta

ndar

dsar

e re

levan

t and

appr

opria

activ

ities

in th

e Sh

enan

goflo

od p

lain

and

asso

ciated

-aSt

anda

rds

rela

ting

to c

onstr

uctio

n,ea

rthm

ovin

g, fi

lling

and

exc

avati

onw

ithin

100

-yea

r flo

od pl

ain,

weti

ands

regu

lated

wate

r.

T3i sM «

f tf . nJJ &•JS S1oi •<

l_i

'cd^m

ta rO '"^o ^. 1*O

(0 OO-i — <"Y~l tO^CN *&>

.a ^S s•a §g U)

HH S

CO S

g_o

" &*1-1 o >-itfl *j flj

0 & 0

The

subs

tant

ive

stand

ards

will

be

cons

ider

ed w

ith re

:di

scha

rges

to th

e Sh

enan

g*

ja[A

1*3

Impl

emen

ts re

gula

tions

per

tain

ing

toco

nsum

ptio

n ad

viso

ries.

•eS3

13

'IoUCQ

§

«x>

. OOu ®ffl 10 O

OU13opaT3§X</)£

J

OH

(N

OSO

aCO

oSuU

S

^^ i"^ ow ' °OH ^ ^i/~i ON C\f^ \O ^D

1

wCiu-ta

COfl«Ja>U

j

O-i

•""

d_ort

& 0 g)

« -5 K* 15 .528 | 53 ^?

Any

poi

nt o

r non

-poi

nt so

idi

scha

rges

at t

he S

ite sh

allsu

bstan

tive

requ

irem

ents

c

S3 S

Sets

forth

sta

ndar

ds fo

r the

qua

lity

ofPA

's w

aters

and

inclu

des s

pecif

ic w

aiqu

ahty

crite

ria a

nd d

esig

nated

wate

r ipr

otec

tion

for e

ach

strea

m in

PA.

a>3oaa.a.<

•S

f-on

•3oU« at

CL, oqi/*i r*~\r* <*

wO

H3

OH<a

a v.5 g"S 'o"3 y oIts

o £ c

The

subs

tantiv

e sta

ndar

dsar

e re

leva

nt a

nd ap

prop

riaw

hich

may

pol

lute

the

She

Rel

ates

to in

cide

nts

caus

ing

orth

reat

enin

g po

llutio

n of

wat

erw

ays.

'a1 -rt egn?i >-JJ a,u &Pi <

l-H

13

"O eUO ^"^u ^ A

t r— i 1^TS

rt o ^rLPH ^ „y-j t^3 C<N «>= a

C_oo ^2

fe §)

"^ c•3 g

. "oJ2 OH

^L) °°

- c- ^</3 H •—

• ,® '"^ U V>

rn CO —

--.

an W

ater

Ac

CJ

uri

ov-* -4-J "Ti iv

> "I, s § -cS "g g £ So O P _i rt* .2 a g -o§ « " « ' • £ S

J3 <L> 2« & •§ "^ Io 2 t2^ tj >

t+H -fcj —— 4>M y 3^ o *2 i^^ n _§ '~l S3 O C ^ SH ',3T3 o (M * 05Ji h -al'C « O« JB ^ B O 00a « D. .±i '-tf 9fe CX c w roS w S •>, tJ) u

*ri "O i_ J- 3 -*3^ =1 53 ;=; -^ o]u o S ^3 -^ u

r** i H ? cr" H ^j

0>*£] fH

Thes

e ar

e no

n-en

forc

eabl

e gu

idel

ines

esta

blish

ed p

ursu

ant t

o Se

ctio

n 30

4 of

tCl

ean

Wate

r Act

that

set t

heco

ncen

tratio

ns o

f pol

luta

nts w

hich

are

cons

ider

ed a

dequ

ate

to p

rote

ct h

uman

heal

th ba

sed

on w

ater a

nd fi

sh in

gesti

oian

d to

pro

tect

aqu

atic

life

. Fe

dera

lam

bien

t wat

er q

uaht

y cr

iteria

may

be

rele

vant

and

appr

opria

te to

CER

CLA

clea

nups

bas

ed o

n th

e us

es o

f a w

ater

body

.

a £« «.. . - F-ls i -i> IHJi &i> d.PA <

u.JUrt£

^

r i ^*w/ ,_^O m

1-1u ,_

^ 01 O

SSJU13 5 s 2"« "n " Pjj b L» a*uli-ra

ucn

o ^CO (

^ 0*/i >o" ^

*o-fa

Toxi

c Su

bsta

nces

Con

Act

C-S

S o^ "^**>

« .2 *S"O o M

"^ «a H| 1 2

J3 &1 *"^ t^ to'g O CQ

rrt *^ Cj

W O Ti<l> CL >3

_> tn -g" • *r1 ^

w 9 ±iJ5 ™ 99 P

ft rt o &l~* .**1 w PIRe

quire

men

ts fo

r han

dlin

g an

d di

spos

aof

PCB

cont

amin

ated

mate

rials

with

conc

entra

tions

of P

CBs g

reate

r tha

n 50

ppm

.

o3

"o.§,<

"ow

&h ?*^ ^H

O ^•t r-

uT

a. Po

lych

lorin

ated

Bip

heny

ls (P

CBs)

Man

ufac

turin

g Pr

oces

Dist

ribut

ion

inC

omm

erce

, and

Use

Proh

ibiti

ons

. Act

ion

Spec

ific

i— il-H1— •

^* S o U *n" OQ CO •— ) •— '•^ i— i i— < "~" Omoo 1-1 <N ONf*~j \Q \Q Q ^J- l/~i

(U w« art cJ <ut> O _ i C£>• -S i*-i *D R•rt cd ^ 3 (-1>H *i. •**• TO «^2 •— C o 01 H>r2 ii U < 3 Ec/j •<, "* o jS•2s o fc**2 "^1 g (J g 1 1

f rrt 3 rs/ • ^— 9Pg O ^ ^O 2

"

OJ (j

2 >"S

•^ -t^l

S ws>-§S M(4 OJ6^3Ji ^^^ &^3 „j3 u-J^ f -vM aw S2i T30) JH

s? R •* t> «}i> o -d3 2 S§ .g g

*2 « Sb ^ -!aS 'S SS i crT1 9 »i-U O k->

(A

Prov

ides

def

initi

ons

for w

hen

haza

rdou

was

te m

anag

emen

t req

uire

men

ts ar

etri

gger

ed.

V.0<fl

"a.B,<:

"oCO

°2?BI O &•

•0 ^ M(N «w^_-

a. H

azar

dous

Was

teM

anag

emen

t Sys

tem

-G

ener

al D

efin

ition

_flj <]_>

1 I

»ltj)-§a viS "5

Jo ^^H ?rt

^ gKu -St/1 *"*c« OS B aeo ra §

*O (i u!3 *"" l3a g's-a S aDO

Con

tain

s cr

iteria

and

lists

for i

dent

ifyin

char

acter

istics

and

liste

d wa

ste.

33o

"&^

'ow

^ <^TJ ^O ,O (N <

(2 1^»H «3 .£)

l/^ **•* 3(N O C/l

b. H

azar

dous

Was

teid

entif

icat

ion

OJ u1-5ar

dous

was

tes sh

all b

e m

anag

ed w

ite in

acc

orda

nce

with

the

subs

tani

.irem

ents.

T1 S *>ht| O U

^4—1Ow1-O

SdDO!-.

^S•31 «c -S« 2*-; fflM ?cfl **U (A^ 3_wi O

S Nr°i

<DIDu"o.a.

"3CO

o — •O ^ni CN

PH ^C

CN <O5

O+-• tn-OJ ^

^ 1-10 S

Stan

dard

s ap

pli

ener

ator

s of

Haz

aste

d O S

3 •!*o -*•*Si^S w

(DS-3

1to >Hc3 o .

1 I I.2 iS a•O o> |2

' rrt ' *"4

ffi O 1—

13COo.1*sg4-

S

1-£3 ruQJ 2

1-13 3in "rtU H'tS ™ra u

1)-1^ ? .erf o

5j3

cQ.y"B,a,

"SCO

u $ S « ^O — % g ^ ° 'C

O c a , _ (OT r~~ r3 i> -"ti iT S.1 ^" 2 'M ' — ' 2 -ts ^ .•'" cP i C N S r g ^ j - O c r ' ^ o O ' w ;w - l c c o S S ^ r ^ ^ S S d Srs co^ PQ 3 f^4 ^^ p^ (^_i i_i b ]' j£

t/1^^ T3

! ^ & w^4 ^ ^J Oij Q>

,- W B) O -3W k-< > *S -r*T3 O !* w OIP1"!

^O ^J -G i3 "T3

s|^

e re

med

y in

volv

es p

lacem

ent o

ftrd

ous w

aste

on

land,

exc

ept w

ithii

of co

ntai

nmen

t ("A

OC

") o

n-sit

e,ire

men

ts w

ill ap

ply

prio

r to

disp

oi

S| 1 1

o~e900O

O (3w ^

"'o °B H

<Qfll Ej

erf .S

0>

-sra-M

*clo.^

'SCO

«»; ^w ,•

fc °°• ^"O 00

O ^O

Land

Disp

osal

estri

ction

s

(t-i Crf

o•P *dS w

guid

ance

will

be

cons

ider

ed in

•essin

g A

reas

of C

ontam

inati

on in

amin

ated

soi

ls a

re to

be

cons

olid

ai

j3 «Q ot-1 Pl O

Tl

i.s<*H rts a8 3 ^ED jfrf

•^13BO <$ *3• 9 * 18-s Be u

• S o wT3 -5 43« g Oy '3 4>

T3 £J M

3 O " £?O 0 «

u•a'aovj4)

CQoH

'oCO

[T . »-H

O urn "O V* CN Q f^fl^ ? t> CNW ££2

uT3

o_ U

Man

agem

ent o

emed

iatio

n W

asi

CRA

oh#; &

t°"> ^H'^ OCO ^ 0

^ — I .— •rCJ S S

ft

_J

L Cle

an S

tream

s ;

<:&-

CN

u «<-»CO 05

earth

dist

urba

nce

activ

ities

at t

heI m

eet d

ie su

bsta

ntiv

e re

quire

men

tre

gulat

ion.

111*"O tUd on dd ^2 *bM 3u -34> j-

fi Mii4 & K(L) C (^>y 1J *J3

fl^ *? "t\erf M *

139 -n* nj-a "C9 o.> S

"w D.erf *^

IHu13^

?~O •— 'U y'. i.-C3 ^f

&H ^w-> OfN !-•

r*(D

•a u

Eros

ion

and

Seon

trol R

equi

rem

^ U

°1 (-19 S<r cd

3 (c

ontin

ued)

ppro

pria

te R

equi

rem

ents

(AR

jsid

ered

Mat

eria

l for

luvi

al an

d Be

droc

k G

roun

d W

S < § ^" T3 CJ 1ta a ^^ >- 1^ s u ,o •S 2 « tlS £ •§"> H £- "2 §rt^ r^ Uv M jCH S DitH -O0 J2(U O3 JScd D.0 (/)i— H fl\* u**& J3fi, *-<,

G0

• r- .COCO30CO• 1—1QCJ

II—1<£H• I— 1o(UDHc/aID

t/3

•ttc

Sum

mar

y of

Req

uire

me:

co• -•«ts-<— •

EgJSO

-'*$n>sco• 1— 1+->ed.•sO

UCQHIHo

pel^*

I^H^H^J

o1C• i— io0>p.w-3o• i-HsuJ3UI-H

1

- _-,

V so(/) O,_• oP m(N £05•^f =<»

fctsfer-^

SP• i— itj^aG•cQ-w<3C/3 •*-•

• 3^ «;

T3<U

'I£QDI<D43

Ctt13cdcd

"C•«->'8UCOU

S^~i I-,-* ,.,..

« > » " ° C c o ^ r t ^ - i D O1 g-2"S t 3-£a|.S•§ §•- 3 ^1 s §• i! §•«§ E a S " o g B » P ^ - 3 g| f e « ! 3 S 2 | » S « S > f e- s f a S f S ^ l s I 2 S"8 ai M s ^ N M I i iI l l l iMlldll!8 ^ ^ | f t | - § | > B § S 8 |15^ sa i^tuj l - l Satii i i i^ii inUMM C -^ & & o ^ o R - o o^,O > > < D - y <D &^ c n ± i QnH H,

( < C i c o c o c d j i c d ' i 3 c d 3 H « j c d b x )

*O3 UH ^_>cd nj

I'&1 s*D Q.r— H JT^

S S-& <

I£oiS3S§s;S

CO13>

IDh-1

G H-^

§ .9 ^N"3 g CO

^ H tHs s^. o 2cd U ^

T3U>•a£00.sU&£&cdcd•c<u

-4->•co<L>to0>s

>^,0IT) T3r^ <U

MCL

Gs

are

non-

enfo

rcea

ble

heal

th g

oals

for p

ublic

wat

ersu

pplie

s whi

ch h

ave

at le

ast

serv

ice

conn

ectio

ns o

r are

us

25 p

erso

ns.

*° „,G ^cd td•y "CS CL> 2E\ *-<W p,

"S &CH <

S3td&

d ^

S^O i— iO =0o £Tt <*r> ^J

13>S t?

§ - °3 S r~\

•§|S•1 S JES^ G «

0 O^ U O

ResponsivenessSummary

RESPONSIVENESS SUMMARYWESTINGHOUSE SHARON SITE

OPERABLE UNIT TWO(GROUND WATER, DRAINAGEWAYS, RIVER SEDIMENTS AND RIPARIAN SOILS)

A newspaper ad announcing the availability of the Proposed Remedial Action Plan(PRAP) for Operable Unit Two and inviting public comment on that PRAP was published in theSharon Herald on November 1, 2002. A public comment period was held from November 1,2002 through November 30, 2002. On November 14, 2002, a public meeting was held at theCity of Sharon Municipal Building. As a result of the public comment period, EPA receivedletters of comments from seven interested parties. Those comments, along with EPA's responsesto the comments, are summarized below.

Comment by the U.S. Department of the Interior:

1. Comment: The U.S. Department of the Interior (DOI) reviewed the PRAP and expressed thatit believes the preferred alternatives identified in the PRAP are protective of ecological and DOItrust resources.

Response: EPA appreciates DOl's input.

Comments bv Cu minings Riter Consultants. Inc. on behalf of Viacom Inc.:

1. Comment: Cummings Riter expressed its belief that a statement in the PRAP relating to theelimination of a Pennsylvania Fish and Boat Commission "Do not eat" advisory for certain fishin the Shenango River section between the Shenango Reservoir and the dam at the ConsumersPennsylvania Water Company as a result of the PCB-contaminated sediment cleanup called forin the PRAP is highly speculative given that the actual relationship between current fish tissuequality and the current sediment contaminant concentrations is unknown. Cummings Riterexpressed that fish tissue contaminant concentrations might not change as a result of the cleanupdue to other potential contamination sources that are not being addressed by the PRAP.

Response: EPA and the Pennsylvania Fish and Boat Commission believe that the preferredsediment cleanup scenario, as expressed in the PRAP, will eliminate the greatest portion of thePCB mass in the section of the River described in the comment. Coincidentally with the removalof the PCBs, additional contaminants including lead and zinc will also be removed from theRiver under EPA's selected alternative. While EPA acknowledges that other sources ofcontamination exist that are not related to the Westinghouse Sharon Site, EPA and thePennsylvania Fish and Boat Commission believe that the selected alternative could lead to lowercontaminant levels in future fish tissue samples. Only long-term sampling offish tissue, whencompared to baseline tissue contaminant levels, will reveal the actual effects of the cleanup.EPA has, therefore, written the pertinent portions of the Record of Decision to reflect a greaterdependance upon future tissue sampling results in determining whether the future edibility of fish

Page 2 of 5

tissue would be improved.

2. Comment: Cummings Riter expressed its belief that fish tissue monitoring will notnecessarily indicate the actual effectiveness of the sediment removal prescribed in the preferredalternative expressed in the PRAP. Cummings Riter does believe, however, that fish tissuemonitoring is appropriate for determining if the fish consumption advisory can be relaxed.

Response: (See EPA's response to Comment 1, above.)

3. Comment: Cummings Riter pointed out that inorganic contaminants unrelated to theWestinghouse Sharon Site are coincident with the PCB contamination in the River sediments andthat the removal of these inorganic contaminants might be of considerable ecological benefit.

Response: EPA acknowledges that the removal of inorganic contaminants in the sediments willoccur as a coincidental benefit with the removal of Site-related PCB-contaminated sediments.

Comments by the Shenango River Watchers. Inc.:

1. Comment: The Shenango River Watchers, Inc. (SRW) recommends that a communityoversight board consisting of representatives from several named and unnamed entities beformed.

Response: EPA intends to involve the relevant entities, including SRW, the ConsumersPennsylvania Water Company, the Pennsylvania Fish and Boat Commission, the PennsylvaniaDepartment of Environmental Protection and the U.S. Fish and Wildlife Service during theremedial design stage of the project to elicit helpful input that will contribute to a more complete,efficient, protective and cost-effective remedial action.

2. Comment: SRW expressed its belief that ground water monitoring should continue beyondthe 30 years called for in the PRAP. SRW also suggested that a clause be added to the RODaddressing the cleanup of the ground water should it be found to be a possible threat to the Riverin the future.

Response: CERCLA Section 121(c) requires that reviews of the protectiveness of a remedy beconducted at least once every five years after the startup of a remedial action. There is no limit tothe duration of the five-year review process. In the event that it is determined that the groundwater is posing a threat to the River in the future, EPA will determine what course to pursue atthat time.

Comments by an individual citizen:

1. Comment: A citizen expressed that he had personally witnessed the pollution of theShenango River by local industries and noted that pollution of the Shenango River from Sources

Page 3 of 5

other than the Westinghouse Sharon Site continues.

Response: EPA acknowledges that there are continuing sources of pollution to the ShenangoRiver but also believes that a significant and positive impact will result within the approximatelyfour-mile section of the River between the Shenango Reservoir and the dam at the ConsumersPennsylvania Water Company by the removal of PCB-contaminated sediments and riparian soilsbetween Clark Street and the dam at the Water Company.

Comments by Cozen O'Connor Attorneys on behalf of Wheatland Tube Company:

1. Comment: Cozen O'Connor clarified certain Site-related property relationships noting thatAK Steel Corporation actually owns the portion of the Site designated as the North Sector andthat the North Sector is currently being leased by the John Maneely Company (of whichWheatland Tube Company is a division) from AK Steel. Wheatland Tube Company actuallyowns the property which is west of the Middle Sector and west of the Norfolk Southern Railroadtracks.

Response: EPA acknowledges these real estate interests.

2. Comment: Cozen O'Connor expressed that Wheatland Tube is concerned that the presence ofground water contaminants, including NAPLs, on Wheatland property (west of the MiddleSector) could result in restrictions on future construction on that property. Wheatland is alsoconcerned about the potential impact of the ground water contamination on its existingoperations. Wheatland acknowledged that it is technically impracticable to achieve ground watercleanup standards. Wheatland will look to the responsible parties for any additional costs andliabilities associated with the ground water contamination.

Response: EPA believes that the Site-related ground water contamination that exists on theWheatland Tube property, including LNAPL, DNAPL and dissolved contaminants, is notcurrently impacting the company's operations and that the ground water contamination is notexpected to worsen in the future. Because the ground water contamination is an existingcondition on the Wheatland Tube property, any future construction that might encounter theground water must take into account that ground water contamination. Wheatland's potentialpursuit of recoupment of additional costs relating to any future construction that might beimpacted by the ground water contamination would be a private matter between Wheatland andthe potentially responsible parties.

3. Comment: Cozen O'Connor notes that Wheatland's process water intake is locatedapproximately 150 feet downstream from the Clark Street Outfall within Shenango River Area15. Wheatland is concerned that the sediment removal activities might impact the process waterintake system and the production equipment and believes that protections are needed for theprocess water intake.

Page 4 of 5

Response: EPA agrees that the process water intake should be protected and will assure that suchprotections are incorporated into the remedial design. EPA will invite Wheatland TubeCompany to review and comment on the remedial design of the sediment and riparian soilremedial actions so as to protect their process water intake.

Comments by Fox Rotbchild attorneys on behalf of Norfolk Southern Railway Companyand Pennsylvania Lines LLC:

1. Comment: Fox Rothchild questioned whether EPA has adequately considered the health andsafety of railroad workers in its selection of the No Further Action With Monitoring alternative.Fox Rothchild objects to the selection of the alternative inasmuch as it leaves significant amountsof NAPL beneath the Railroad Property. Fox Rothchild expressed its belief that the HumanHealth Risk Assessment for the Site should be revised to include potential risks to railroadworkers from the NAPLs beneath the railroad. Fox Rothchild also expressed its belief that PCB-contaminated soils beneath the railroad are a continuing source contributing to the ground waterNAPL. Fox Rothchild also expressed that EPA should confirm in writing to the railroads that thepresence of NAPL in the ground water and PCBs in the soils underlying the Railroad Property donot pose any risks to railroad workers performing ordinary intrusive work.

Response: The Operable Unit One (soils cleanup) Record of Decision required that the PCB-contaminated soils on the Railroad property be remedied such that no greater than 25 parts permillion (ppm) PCBs would remain in the top ten inches of soil, and no greater than 71 ppm PCBswould remain in soils from 10 inches to 24 inches in depth. That cleanup activity has beencompleted. Areas covered with railroad track on railroad ballast were left undisturbed so as notto disrupt the functionality of the railroad. EPA believes that the soil cleanup is protective inthis industrial/commercial setting. Additionally, since all soils on the Railroad Propertydisplaying PCB concentrations of 689 ppm or greater were removed to a depth often feet inorder to be protective of workers who might occasionally be engaged in the construction or repairof underground utilities, there is no need to revise the Human Health Risk Assessment for theSite. EPA believes that the PCB concentrations remaining in the soils following the OperableUnit One cleanup of the Railroad Property are not a significant source of further degradation ofthe ground water in the area given that the ground water is already significantly impacted byPCBs and also considering that PCBs are relatively insoluble in water and immobile in soil. Theground water table in the NAPL area seasonally fluctuates from about 8 feet below the groundsurface to about 12 feet below the surface and is not likely to be encountered by railroad workersperforming ordinary intrusive activities.

Comments by the Consumers Pennsylvania Water Company:

1. Comment: The Consumers Pennsylvania Water Company expressed agreement with EPA'sPreferred Alternative for Shenango River sediments and riparian soils. The Water Companywishes to be involved in reviewing the remedial design of the project as it relates to theCompany's interests.

Page 5 of 5

Response: EPA will assure that Consumers Pennsylvania Water Company is involved in thereview of the remedial design of the cleanup of the Shenango River sediments and riparian soils.

StateConcurrence

Letter

Pennsylvania Department of Environmental Protection

230 Chestnut StreetMeadvffle, PA 16335-3481

February 11,2003

Northwest Regional Office 814-332-6816Fax: 814-332-6125

Mr. Abraham FerdasDirectorHazardous Site Cleanup Division (3HSOO)Environmental Protection AgencyRegion III1650 Arch StreetPhiladelphia, PA 19103-2029

Re: Record of Decision (ROD)Westinghouse Sharon Superfund SiteCity of SharonMercer County

Dear Mr. Ferdas:

The Department has reviewed the Record of Decision ("ROD") for Operable Unit 2 ("OU-2")for the Westinghouse Sharon Site ("Site") received in this office on February 7, 2003.

The selected remedy for OU-2 addresses the threats to public health and safety posed by theactual or potential release of hazardous substances to the groundwater, Shenango River sediments,riparian soils, and storm sewer drainage ways. The selected remedy for the Site includes the followingcomponents:

For the Site Groundwater

* No further action with monitoring.

* Institutional controls as previously required under the Operable Unit 1 ("OU-1") Recordof Decision and the OU-1 Unilateral Administrative Order.

* The waiver of drinking water standards in accordance with CERCLA Section121(d)(4)(c) because such standards are technically impracticable to attain.

* The installation of additional monitoring wells and the development of a groundwater-monitoring regimen. The number and placement of the additional wells and themonitoring required will be established during the Remedial Design.

An Equal Opportunity Employer www.dep.state.pa.us Printed on Recycled Paper

Mr. Abraham Ferdas -2- February 11, 2003

For Shenango River Sediments

* Removal, by a method or methods to be established during the Remedial Design, of anestimated 4,100 cubic yards of up to 48 inches (in depth) of sediments containing PCBconcentrations greater than one part per million (ppm) in the Shenango River betweenClark Street and the dam at Consumers Pennsylvania Water Company.

* Treatment of any sediments exhibiting the characteristic of toxicity and constituting aLand Disposal Restriction hazardous waster under the Resource Conservation andRecovery Act ("RCRA") prior to disposal.

* Offsite disposal of the sediments removed, including any treated sediments.

* The protection of, and the monitoring of, the water intake of the Consumers PennsylvaniaWater Company during the Remedial Action to assure that the public water supply is notcontaminated as a result of the Remedial Action.

* The establishment of a fish tissue monitoring plan as part of the Remedial Design.

* The amounts and types of backfill materials will be established during the RemedialDesign and modified, if required, during the Remedial Action.

For Riparian Soils

* Removal, by a method or methods to be established during the Remedial Design, of anestimated 300 cubic yards of soils containing PCB concentrations greater than ten ppm inthe floodway along the eastern edge of the Shenango River downstream from ClarkStreet (River Area 15).

* Treatment of any of the soils removed which exhibit the characteristic of toxicity andwhich constitute a Land Disposal Restriction hazardous waster under RCRA prior todisposal.

* Offsite disposal of the riparian soils removed, including any treated soils.

* The protection of, and the monitoring of, the water intake of the Consumers PennsylvaniaWater Company during the Remedial Action to assure that the public water supply is notcontaminated as a result of the Remedial Action.

Mr. Abraham Ferdas -3- February 11, 2003

For Site Storm Sewer Drainage ways

* The removal of an estimated 20 cubic yards of PCB contaminated debris and sedimentsfrom approximately 600 feet of the Wishart Court sewer line north of Silver Street by amethod or methods to be established as part of the Remedial Design.

* Treatment of any of the soils removed which exhibit the characteristic of toxicity andwhich constitute a Land Disposal Restriction hazardous waster under RCRA prior todisposal.

* Offsite disposal of the sediments and debris removed, including any treated materials.

Based upon the understanding set forth above, the Department concurs with the remedy chosenfor the Site.

I wish to thank your staff for your cooperation in this matter. Should you have any questionsregarding this matter, please call Chuck Tordella, the site Project Manager, or me, at this office.

Sincerely,

Kelvin A. BurchRegional Director

cc: Mr. JanosikMr. GormanMr. MoorheadMr. Olewiler

KAB:lsl:jb

AdministrativeRecordIndex

WESTINGHOUSE ELECTRIC (SHARON PLANT)QU2ADMINISTRATIVE RECORD FILE * **

INDEX OF DOCUMENTS

I- SITE IDENTIFICATION

1. Excerpt from the Federal Register, Vol. 55 No. 169,re: National Priorities List for uncontrolledhazardous waste sites, 8/30/90. P, 100001-100005.

Administrative Record File available 2/7/01, 10/30/02and 2/21/03.

All other documents pertaining to the WestinghouseElectric (Sharon Plant) Site can be found in theWestinghouse Electric {Sharon Plant) RemedialAdministrative Record File dated 3/3/00 and are herebyincorporated by reference into this OU2 RemedialAdministrative Record File Index of Documents.

II. REMEDIAL ENFORCEMENT PLANNING

1. Letter to Mr. Albert Dombrowski, Winner DevelopmentCompany, Inc., from Mr. Abraham Ferdas, U.S. EPA, re:Special Notice letter notifying the company ofpotential liability for Remedial Action/Remedial DesignCosts (RD/RA) at the Westinghouse Sharon Site, 5/19/00;P. 200001-200160. The following enclosures areattached:

a) "Enclosure 1," a February 18, 2000, Record ofDecision (ROD), Westinghouse Electric (SharonPlant) Site, Operable Unit One (Soils);

b) "Enclosure 2," an undated proposed ConsentDecree In The Matter Of: United States ofAmerica, Commonwealth of Pennsylvania,Plaintiffs, v. CBS Corporation, WinnerDevelopment Company, Inc., AK SteelCorporation, Defendants;

c) "Enclosure 3," an undated document entitled,"List of Special Notice Recipients,Westinghouse (Sharon) Superfund Site";

d) "Enclosure 4," a September, 1999, U.S. EPAInformation Sheet regarding small businessregulatory enforcement and fairness actnotification;

2. Letter to Mr. Richard Wardrop, Jr., AK SteelCorporation, from Mr. Abraham Ferdas, U.S. EPA, re:Special Notice letter notifying the company ofpotential liability for RD/RA costs at the WestinghouseSharon Site, 5/19/00. P. 200161-200167.

The attachments to entry number 1 of this section(enclosures 1-4), were also attached to this letter,but are not physically present in the AR in order toconserve paper.

Letter to Mr. Louis Briskman, CBS Corporation, from Mr.Abraham Ferdas, U.S. EPA, re: Special Notice letternotifying the company of potential liability for RD/RAcosts at the Westinghouse Sharon Site, 5/19/00.P. 200168-200174.

Letter to Mr. Gordon Taylor, CBS Corporation, from Mr.Victor Janosik, U.S. EPA, re: Transmittal of SpecialNotice letters that were sent to the PotentiallyResponsible Parties (PRPs) for the Westinghouse SharonSite, which includes a copy of the draft ConsentDecree, 5/24/00. P. 200175-200178. The following areattached:

a) A May 24, 2000, letter to Mr. CharlesTordella, Pennsylvania Department ofEnvironmental Protection (PADEP), from Mr.Victor Janosik, U.S. EPA, re: Transmittal ofSpecial Notice letters that were sent to thePRPs for the Westinghouse Sharon Site, whichincludes a copy of the draft Consent Decree;

b) A May 24, 2000, letter to Mr. Peter Knight,National Oceanographic and AtmosphericAdministration, from Mr. Victor Janosik, U.S.EPA, re: Transmittal of Special Noticeletters that were sent to the PRPs for theWestinghouse Sharon Site, which includes acopy of the draft Consent Decree,-

c) A May 24, 2000, letter to Mr Robin Burr, U.S.Department of the Interior, from Mr. VictorJanosik, U.S. EPA, re: Transmittal ofSpecial Notice letters that were sent to thePRPs for the Westinghouse Sharon Site, whichincludes a copy of the draft Consent Decree.

Ordinance No. 28-00, City of Sharon, re: Prohibitionof drilling or use of private groundwater wells as asource of water for either potable or industrialpurposes within certain areas of the City of Sharon,1/4/01. P. 200179-200180.

The attachments to entry number 1 of this section(enclosures 1-4) , were also attached to this letter,but are not physically present in the AR in order toconserve paper.

Ill- REMEDIAL RESPONSE PLANNING

1. Report: Feasibility Study Supplemental Sampling andAnalysis Plan, Groundwater. Sediment and Non-AqueousPhase Liquids. Westinahouse Electric fSharon Plant).Sharon, Pennsylvania, prepared by Cummings RiterConsultants, Inc., 10/23/98. P. 300001-300044. AnOctober 23, 1998, transmittal letter to Mr. CharlesTordella, PADEP, from Mr. Patrick O'Hara, CummingsRiter Consultants, Inc., is attached.

2. Report: Data Summary Report Feasibility StudySupplemental Sediment Sampling Westinghouse Electric(Sharon Plant) Sharon, Pennsylvania, prepared byCummings Riter Consultants, Inc., 5/21/99.P. 300045-300530. A May 21, 1999, transmittal letterto Mr. Charles Tordella, PADEP, from Mr. Bryan Maurer,Cummings Riter Consultants, Inc., and a May 25, 1999,memorandum to Mr. Victor Janosik, U.S. EPA, from Ms,Jennifer Hubbard, U.S. EPA, regarding verification thatappropriate validation procedures were used for datavalidation reports, are attached.

3. Report: Data Summary Report Supplemental Sampling andAnalysis of Groundwater, CBS Corporation, FormerWestinghouse Transformer Facility. Sharon.Pennsylvania. prepared by Cummings Riter Consultants,Inc., 10/29/99. P. 300531-301147. An October 29,1999, transmittal letter to Mr. Charles Tordella,PADEP, from Mr. Matthew Valentine, Cummings RiterConsultants, Inc., is attached.

4. Report: NAPL Bench-Scale Test Reports FormerWestinghouse Transformer Facility. Sharon.Pennsylvania. prepared by Cummings Riter Consultants,Inc., 11/11/99. P. 301148-301463.

5. EPA newsletter entitled "Tech Trends," Issue No. 36,re: Ongoing field and laboratory demonstrationsconcerning the remediation of contaminated sediments,2/00. P. 301464-301467.

6. Report: Phase I Interior Cleanup Completion Report.Middle Sector Buildings. Former Sharon TransformerPlant, Sharon. Pennsylvania, prepared by Cummings RiterConsultants, Inc., 2/10/00. P. 301468-302346. AFebruary 10, 2000, transmittal letter to Mr. CharlesTordella, PADEP, from Mr. Bryan Maurer, Cummings RiterConsultants, Inc., is attached.

7. Letter to Mr. Gordon Taylor, CBS Corporation, from Mr.Charles Tordella, PADEP, re: PADEP and EPA comments onthe Feasibility Study Report for OU2, 3/9/00.P. 302347-302360.

8. Report: Data Summary Report Area 14 SupplementalSediment Sampling Westinahouse Electric (Sharon Plant)Sharon. Pennsylvania. prepared by Cummings RiverConsultants, Inc., 5/19/00. P. 302361-302427. A May19, 2000, transmittal letter to Mr. Charles Tordella,PADEP, from Mr. Bryan Maurer, Cummings RiterConsultants, Inc., is attached.

9. Report: Data Validation. Lancaster Laboratory Report.SDG No SHA 03. prepared by Validata, Inc., 6/15/00.P. 302428-302479. A June 26, 2000, transmittal letterto Mr. Charles Tordella, PADEP, from Mr. Bryan Maurer,Cummings Riter Consultants, Inc., is attached.

10. Report: Feasibility Study Report - Operable Unit 2Sediment, Groundwater. and NAPLs Westinghouse ElectricfSharon Plant) Sharon. Pennsylvania, prepared byCummings River Consultants, Inc., 6/26/00.P. 302480-302810. A June 26, 2000, transmittal letterto Mr. Charles Tordella, PADEP, from Mr. Bryan Maurer,Cummings Riter Consultants, Inc., is attached.

11. Memorandum to Mr. Victor Janosik, U.S. EPA, from Mr.Bruce Pluta, Biological Technical Assistance Group,(STAG), re: PADEP and EPA comments on the FeasibilityStudy Report for OU2, Sediment, Groundwater and NAPLS,for the Westinghouse Sharon Site, 7/24/00.P. 302811-302812.

12. Letter to Mr. Victor Janosik, U.S. EPA, from Mr. MarkHartle, Pennsylvania Fish and Boat Commission, re:Commission's recommendation for preferred riversediment remedial alternatives, 8/14/00.P. 302813-302814.

13. Letter to Mr. Robert Price, Mayor, City of Sharon, fromMr. Victor Janosik, U.S. EPA, re: Request that City ofSharon create an ordinance that would restrict thedrilling of ground water wells near the WestinghouseSharon Site, 8/21/00. P. 302815-302816.

14. Memorandum to file from Mr. Victor Janosik, U.S. EPA,re: Documentation that industrial operations of WinnerSteel Services are generating rubble and soil wasteswhich contain PCBs, 9/26/00. P. 302817-302817.

15. Letter to Mr. Charles Tordella, PADEP, from Mr. BryanMaurer, Cummings Riter Consultants, Inc., re: Submittalof Work Plan for inspection and sampling of stormsewers at the Westinghouse Sharon Site, 11/7/00.P. 302818-302821.

16. Report: Letter Report - Installation of AdditionalBedrock Groundwater Monitoring Wells - WestinghouseElectric (Sharon Plant). Sharon, Pennsylvania, preparedby Cummings Riter Consultants, Inc., 1/25/01. AJanuary 25, 2001, letter to Mr. Charles Tordella,PADEP, from Mr. William Baughman, Cummings RiterConsultants, Inc., transmitting the report and asummary of tasks and findings, is attached.P. 302822-302879.

17. Report: Letter Report - Former Groundwater Supply WellInvestigation Sharon Transformer Plant - Sharon,Pennsylvania. prepared by Cummings Riter ConsultantsInc., 3/14/01. A March 14, 2001, report summary letterto Mr. Charles Tordella, PADEP, from Mr. WilliamBaughman, Cummings Riter Consultants, Inc., and a March23, 2001, letter to Mr. Gordon Taylor, Viacom, Inc.,from Mr. Charles Tordella, PADEP, regarding PADEP'sreview and approval of the report, are attached.P. 302880-302915.

18. Report: Addendum - Feasibility Study Report. OU2 -Storm Sewer Sediments & Bedrock Groundwater.Westinghouse Electric (Sharon Plant). Sharon.Pennsylvania, prepared by Cummings Riter Consultants,Inc., 5/18/01. A May 18, 2001, transmittal letter toMr. Charles Tordella, PADEP, from Mr. Bryan Maurer,Cummings Riter Consultants, Inc.,and a May 30, 2001,letter to Mr. Gordon Taylor, Viacom, Inc., from Mr.Charles Tordella, PADEP, documenting PADEP's acceptanceof the report as final, are attached. P. 302916-303121.

19. Report: Technical Impracticability of GroundwaterRestoration Evaluation, Westinghouse Electric (SharonPlant). Sharon, Pennsylvania, prepared by CummingsRiter Consultants, Inc., 3/22/02. The following areattached: P. 303122-303340.

a) a March 22, 2002, transmittal letter to Mr. VictorJanosik, U.S. EPA, from Mr. William Baughman,Cummings Riter Consultants, Inc.;

b) an April 1, 2002, transmittal memorandum to Mr.Ken Lovelace, PADEP, from Mr. Victor Janosik, U.S.EPA;

c) a July 18, 2002, letter to Mr. Victor Janosik,PADEP, from Mr. William Baughman, Cummings RiterConsultants, Inc.;

d) a July 22, 2002, letter to Mr. Richard Smith,Viacom, Inc., from Mr. Victor Janosik, U.S. EPA;

e) a July 22, 2002, letter to Mr. Victor Janosik,U.S. EPA, from Ms. Jen Jones, EPA Headquarters.

20. Memorandum to Mr. Gordon Taylor, Viacom, Inc., from Mr.Patrick O'Hara and Mr. Bryan Maurer, Cummings RiterConsultants, Inc., re: Preliminary cost estimate forShenango River fish study (one event), Pennsylvania.,5/29/01. P. 303341-303341.

21. Letter to Mr. Gordon Taylor, Viacom, Inc., from Mr.Charles Tordella, PADEP, re: Notification that PADEPhas accepted the June 26, 2000, Feasibility StudyReport - OU2, and the May 18, 2001, Addendum,Feasibility Report - OU2, 5/30/01. P. 303389-303389.

22. Memorandum to Mr. Vie Janosik, U.S. EPA, from Ms.Jennifer Hubbard, PADEP, re: Proposed Plan for River &Groundwater remediation, 8/14/02. P. 400001-400035.

23. Superfund Proposed Remedial Action Plan Operable Unit2, Westinghouse Electric {Sharon) Site, 11/1/02,P. 303344-303388.

24. Letter to Mr. Victor Janosik, U.S. EPA, from Mr. MarkHartle, Pennsylvania Fish and Boat Commission, re:Pennsylvania Fish and Boat Commission concurrence withthe proposed Remedial Action Plan, 9/13/02. P. 303389-303389.

25. Letter to Mr. Michael Chezik, U.S. Department of theInterior, from Mr. Victor Janosik, U.S. EPA, re:Transmittal of Proposed Remedial Action Plan forOperable Unit 2 for Westinghouse Electric (Sharon),10/23/02. P. 303390-303390.

26. Letter to Mr. William Young, Shenago Valley Division ofConsumers Pennsylvania Water Co., from Mr. VictorJanosik, U.S. EPA, re: Transmittal of ProposedRemedial Action Plan for Operable Unit 2 forWestinghouse Electric (Sharon), 10/24/02. P. 303391-303391.

27. Letter to Mr. John Hornbostel, Jr., Winner DevelopmentLLC, from Mr. Victor Janosik, U.S. EPA, re:Transmittal of Proposed Remedial Action Plan forOperable Unit 2 for Westinghouse Electric (Sharon),10/24/02. P. 303392-303392.

28. Letter to Ms. Karin Stamy, Norfolk Southern RailwayCo., from Mr. Victor Janosik, U.S. EPA, re:Transmittal of Proposed Remedial Action Plan forOperable Unit 2 for Westinghouse Electric (Sharon),10/24/02. P. 303393-303393.

29. Letter to Mr. John Kuzman, AK Steel Corp., from Mr.Victor Janosik, U.S. EPA, re: Transmittal of ProposedRemedial Action Plan for Operable Unit 2 forWestinghouse Electric (Sharon), 10/24/02. P. 303394-303394.

30. Letter to Mr. David Grande, Shenago Valley IndustrialDevelopment Corporation, from Mr. Victor Janosik, U.S.EPA, re: Transmittal of Proposed Remedial Action Planfor Operable Unit 2 for Westinghouse Electric (Sharon),10/24/02. P. 303395-303395.

31. Letter to Honorable David Ryan, City of SharonMunicipal Building, from Mr. Victor Janosik, U.S. EPA,re: Transmittal of Proposed Remedial Action Plan forOperable Unit 2 for Westinghouse Electric (Sharon),10/24/02. P. 303396-303396.

32. Letter to Mr. Richard Smith, Viacom Inc., from Mr.Victor Janosik, U.S. EPA, re: Transmittal of ProposedRemedial Action Plan for Operable Unit 2 forWestinghouse Electric (Sharon), 10/24/02. P. 303397-303397.

33. Letter to Mr. Charles Tordella, PADEP, from Mr. VictorJanosik, U.S. EPA, re: Transmittal of ProposedRemedial Action Plan for Operable Unit 2 forWestinghouse Electric (Sharon), 10/24/02. P. 303398-303398.

34. Memorandum to Ms. Robin Anderson, U.S. EPA, from Mr.Victor Janosik, U.S. EPA, re: Transmittal of ProposedRemedial Action Plan for Operable Unit 2 forWestinghouse Electric (Sharon), 10/24/02. P. 303399-303399.

35. Letter to Ms. Olivia Lazor, Mercer CountyCommissioners, from Mr. Victor Janosik, U.S. EPA, re:Transmittal of Proposed Remedial Action Plan forOperable Unit 2 for Westinghouse Electric (Sharon),10/28/02. P. 303400-303400.

36. Letter to Mr. Arthur Hall, Wheatland Tube Co., from Mr.Victor Janosik, U.S. EPA, re: Transmittal of ProposedRemedial Action Plan for Operable Unit 2 forWestinghouse Electric (Sharon), 10/28/02. P. 303401-303401.

37. Letter to Mr. Bob Clarke, Shenago Valley Initiative,from Mr. Victor Janosik, U.S. EPA, re: Transmittal ofProposed Remedial Action Plan for Operable Unit 2 forWestinghouse Electric (Sharon), 10/29/02. P. 303402-303402.

38. Letter to Mr. Victor Janosik, U.S. EPA, from Mr.Michael Chezik, U.S. Department of the Interior, re:U.S. Department of the Interior concurrence with theproposed Remedial Action Plan for Operable Unit 2 forWestinghouse Electric (Sharon), 11/1/02. P. 303403-303403.

39. Letter to Mr, Victor Janosik, U.S. EPA, from Ms.Jennifer Barborak, Mr. Rick Barborak, Mr. Tom Amundsen,Ms. Babs Quincy, Ms. Joyce Cuff, Mr. Mike McLaughlin,Ms. Janet Smith, Ms. Del Williams and Mr. Bob Price,Shenago River Watchers, Inc., re: Comments to includein ROD for Westinghouse Electric (Sharon)clean up,11/25/02. P. 303404-303404.

40. Letter to Mr. Victor Janosik, U.S. EPA, from Mr. JoelBolstien, Fox, Rothchild, 0'Brian & Frankel, re:Comments on Proposed Remedial Action Plan for OperableUnit 2 for Westinghouse Electric (Sharon), 11/26/02.P. 303405-303406.

41. Letter to Mr. Victor Janosik, U.S. EPA, from Mr. RobertLiptak, Consumers Water Company, re: Comments onProposed Remedial Action Plan for Operable Unit 2 forWestinghouse Electric (Sharon), 11/27/02. P. 303407-303408.

42. Letter to Mr. Victor Janosik, U.S. EPA, from Mr. BryanMaurer, Cummings Riter Consultants Inc., re: Commentson Proposed Remedial Action Plan for Operable Unit 2for Westinghouse Electric (Sharon), 11/27/02. P.303409-303410.

43. Letter to Mr. Victor Janosik, U.S. EPA, from Mr. PeterFontaine, Cozen 0'Conner, re: Comments on ProposedRemedial Action Plan for Operable Unit 2 forWestinghouse Electric (Sharon), 11/27/02. P. 303411-303412.

44. Letter to Mr. Michael Chezik, U.S. Department of theInterior, from Mr. Victor Janosik, U.S. EPA, re:Request for comments on draft ROD for Operable Unit 2for Westinghouse Electric (Sharon), 1/14/03. P.303413-303413 .

45. Letter to Mr. Charles Tordella, PADEP, from Mr. VictorJanosik, U.S. EPA, re: Draft ROD for Operable Unit 2for Westinghouse (Sharon) Superfund Site, 1/14/03. P.303414-303414.

46. Electronic Memorandum to Mr. Victor Janosik, U.S. EPA,,from Mr. Charles Tordella, PADEP, re: PADEP comments ondraft ROD for Operable Unit 2 for Westinghouse Electric(Sharon), 2/5/03. P. 303415-303415.

47. Letter to Mr. Charles Tordella, PADEP, from Mr. VictorJanosik, U.S. EPA, re: Request for comments on draftROD for Operable Unit 2 for Westinghouse Electric(Sharon), 2/6/03. P. 303416-303416.

48. Letter to Mr. Abraham Ferdas, U.S. EPA, from Mr. KelvinBurch, PADEP, re: PADEP comments on draft ROD forOperable Unit 2 Westinghouse Electric (Sharon),2/11/03. P. 303417-303419.

10

49. Letter to Mr. Victor Janosik, U.S. EPA, re: Publiccomments on proposed plan for Operable Unit 2 forWestinghouse Electric (Sharon), 11/16/02. P. 303420303424. A September 21, 2000, notice regarding thedischarging of raw sewage into Shenago River and aNovember 22, 2002, response letter from Mr. VictorJanosik, U.S. EPA, are attached.

11

IV, REMOVAL RESPONSE PROJECTS

1. Report: Progress Report No. 79, LNAPL Response ActionViacom Inc.. Former Sharon Transformer Plant Site.Sharon. Pennsylvania. prepared by Shaw Environmental &Infrastructure, Inc., 5/13/02. A May 13, 2002,transmittal letter to Mr. Victor Janosik, U.S. EPA,from Shaw Environmental & Infrastructure, Inc., isattached. P. 400001-400035.

12

V. COMMUNITY INVOLVEMENT

1. U.S. EPA Fact Sheet: Westinghouse Electric SuperfundSite, Sharon, Pennsylvania, re: EPA Announces ProposedCleanup Plan, Invites Public Input, 11/02. P. 500001-500002.

2. Transcript of Public Meeting Minutes, WestinghouseElectric Superfund Site Operable Unit 2, 12/19/02.November 14, 2002, U.S. EPA meeting agenda, isattached. P. 500003-500087.

A

13

GUIDANCE DOCUMENTS

1. EPA's Contaminated Sediment Management Strategy,prepared by Office of Water, 4/98.

2. Memorandum to Superfund National Policy Managers andRegional Counsel Superfund Branch Chiefs, from Mr.Stephen Luftig and Mr. Barry Breen, U.S. EPA, re:Implementation of FY2000 Appropriations Report languageon sediment dredging, 1/19/00. A May 17, 1999,memorandum to Superfund National Policy Managers andRegional Counsel Superfund Branch Chiefs, Regions 1-10,from Mr. Stephen Luftig and Mr. Barry Breen, U.S. EPA,regarding implementation of FY1999 AppropriationsReport language on sediment dredging; An October 5,1998, document entitled, "FY'99 VA-HUD AppropriationsConference Report pp. 271-272," and an undated documententitled, "Colloquy Between Senator Lutenberg andSenator Bond Clarifying The Statement Of The ManagersAccompanying The VA-HUD Conference Report," areattached

3. EPA's Drinking Water Standards and Health Advisories.prepared by the Office of Water, Summer/2000.

4. Current Drinking Water Standards, prepared by theOffice of Ground Water and Drinking Water, 10/00.

5. Engineering Forum Issue: Determination of BackgroundConcentrations of Inorganics in Soils and Sediments atHazardous Waste Sites, prepared by the Office of SolidWaste and Emergency Response, 12/95. EPA 5A05-96/500.

14