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UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III

841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

OCT 3 1 1989

David P. Steele, Project CoordinatorEnvironmental Resources Management, Inc.855 Springdale DriveExton, PA 19341

Dear Mr. Steele:

Enclosed are EPA's comments on the Remedial Investigation andEndangerment Assessment Reports for the Eastern Diversified MetalsSite located in Hometown, Schuylkill County, PA.

In light of our schedule for submission of the final RI report, 1would like to meet with ERM to discuss these comments as soon aspossible. Please -contact me as soon as you receive these commentsto arrange a meeting date.

Sincerely,

Christine ChulickRemedial Project Manager

cc: Marilyn Hewitt, P.G.

AR302309

EPA COMMENTS ON THE RI AND EA FOR THEEASTERN DIVERSIFIED METALS SITEHOMETOWN, SCHUYLKILL COUNTY, PA

HYDROGEOLOGICAL COMMENTS

Remedial Investigation ReportEXECUTIVE SUMMARY

1. Provide documentation and detailed descriptions regarding thedesign and operation of the shallow ground water interceptor trenchsystem. How was it determined that the system does, indeed,intercept the shallow ground water in overburden and the shallowperched ground water at the southern and western ends of the pile?Did previous studies by others confirm this? The effectiveness ofthe shallow ground water interceptor trench system is questionedgiven the issuance of several leachate seeps, one of whichcontained TCE, from the banks of the intermittant stream oppositethe collection trench. Additionally, the effectiveness of thesystem is not proven by existing monitoring well data. Only onewell is located downgradient of the interceptor trench: MW 3/0.The data from that well indicated the presence of 59 ppb TCE in11/88 and 91 ppb TCE in 4/89.

Moreover, Page 1-3 indicates that the interceptor trench is only6 to 10 feet deep, which would not intercept bedrock ground waterflow to an appreciable extent. If what is indicated on page 4-42is true, that "much of the ground water which enters the overburdenlikely recharges the bedrock rather than flowing laterally", thereseems to be considerable possibility for site-contaminated groundwater to flow beneath the interceptor system.

2. Is an ongoing operations and maintenance program in place forupkeep of the drainage/diversion ditch system to the north andsouth of the fluff pile? If not properly maintained, systemfailure due primarily to accelerated erosion could result insurface water runoff and leachate seeps bypassing the treatmentplant entirely, dispersing contaminants to various media. Providea detailed description of the existing operations and maintenanceprogram.

SECTION I "

1. Page 1-3. Clearly display and label the secondarycollection/interceptor trench on all appropriate site drawings.

2. It is indicated that the equalization lagoon is lined, however,no details are provided. Provide available documentation regardingdesign and construction of the liner.

3. Further investigation regarding the nature of the moperation prior to 1966 would provide insight into the presence of

contaminants in ground water not previously anticipated,principally VOC's. Provide further documentation on Siteoperations prior to 1966.

SECTION II

1. Page 2-2. Did surface water flowing through the valley whichhas since been filled with fluff flow on a continual orintermittant basis? Provide more information on the exteriordiversion ditch which was used to divert this flow.

2. A summary of local geology and hydrogeology should be added tothis section and should describe the on-site subsurface conditionsrelated to the suspected contamination sources.

3. Page 2-8. Can it be safely assumed that the vast majority ofresidences within a one mile radius of the site not identified ashaving an individual water supply well are connected to the publicwater system?

4. Figure 2-4. This figure implies that the residential area tothe south of the site is not supplied by individual wells, althoughthe text does not specifically mention what the source of watersupply is for the residences. The residential water supply sourceneeds to be clarified.

SECTION III

1. -4. To better assess the areal distribution ofcontaminants and mechanisms of contaminant transport in surfacesoils throughout the site and surrounding environs, samples shouldbe collected at the following locations:

a) near outfall (discharge) of inner diversion ditch intorunoff lagoon

b) opposite the intermittant stream from the site in thevicinity of the equalization lagoon and wastewater treatment plant

c) exterior drainage ditch along northwest border of site

2. Page 3-6.-" Of the 29 sjrrface soil samples collected, only threewere analyzed" for TCL volatile organic and semi-vQia^i ig» organiccompounds. The areal distribution of such constituents cannot bedetermined on the basis of three samples, one of which was takenfrom a background location.

3. Regarding the basin flooding technique for estimation of soilpermability, how was a tight seal around the metal flashing usingbentonite produced and verified? Provide a more detaileddescription of this technique including an explanaJpLo/Ort /afi icumulative intake versus infiltration rate plots corftaiAso^Hn '

Appendix I.

4. Page 3-7. Was consideration given to the placement ofsoil/pile boring(s) in the vicinity of the main and/or secondaryleachate seeps (?). This would provide useful information regardingthe vertical migration of leachate through soil and overburden.

5. Page 3-8. Did screening of selected subsurface soil cores fororganic vapors using an OVA meter detect any positive readingsabove background? If yes, provide location, depth intervals andresults. Were any soil samples selected for laboratory analysison the basis of results from this field screening procedure?

6. Why were subsurface soil samples from the five borings locatedalong the outside perimeter of the pile analyzed for TCL VOC's yetsimilar samples from the two pile borings were not?

7. Page 3-9. Isn't it possible to locate test pits between thepile and the ground water interceptor trench without fear ofbreaching the system or is its location that uncertain? Whatattempts have been made to verify the location of the ground waterinterceptor trench?

8. Perched water encountered in test pits was tested in the fieldfor specific conductance only. Was laboratory analysis of perchedwater for specific constituents such as TAL metals or TCL semi-volatile compounds considered? Such data would be valuable inevaluating surface water/ground water interactions, and fate andtransport of contaminants in the unsaturated zone.

9. Page 3-16. The database regarding fluff chemistry is limitedwith respect to organic constituents, particularly VOC's and semi-VOC's. Given the apparent uncertainty regarding the ultimatesource of VOC's detected in ground water, such analytical datawould be of value. Additional fluff analysis should be done withrespect to VOCs.

10. Page 3-18. How was it verified that an impermeable seal wascreated at the fluff-soil interface by the introduction ofbentonite clay pellets onto the split spoon hole prior topiezometer "construction? If not properly sealed, the hole couldact as a seco"hdary pathway for accelerated leachate migration.

11. Page 3-18. The Remedial Investigation (RI) states four testpits were used for sampling. Although the text specifically stateswhat tests were performed on test pits PP-1, PP-2, and PP-3, thereis no mention as to what PP-4 was tested for. This should beexplained.

12. Page 3-22. At locations where water beariwgp 'zone® ii-overburden were absent, how was screen setting Ana re nqVdetermined? Are differences in screen length a e~~ ~~

overburden thickness?

13. Page 3-23. Results of TCL VOC analysis of samples from theTamaqua Borough Water Authority need to be provided. Results couldnot be located in the report or appendicies.

14. Page 3-34. With respect to well cluster #8, for reasonsstated above it is questionable whether development waterdischarged to the interior surface water, collection swale wouldultimately be intercepted by the ground water interceptor trench.

15. Other than visual appearance of water, were other fieldmethods such as measurement of specific conductivity, temperatureand pH utilized to determine whether development was complete?Relying solely on visual appearance of water can be deceiving.Have wells experienced any turbidity problems upon follow-upsampling?

16. Page 3-25. Application of the Hvorslev method of slug tes.tanalysis to calculate hydraulic conductivity and transmissivityvalues may not be the most appropriate given the fractured bedrocksetting which implies anisotropic/non-homogenous conditionsinconsistant with assumptions implicit in this method. Results arebased upon the performance of slug addition and withdrawal testsperformed on the majority of monitoring wells. Anotherconsideration is that conductivity values varied widely (2 ordersof magnitude). The same comment applies to the application of theCooper-Jacob straight line method of interpretation for the shortduration pump test performed on well MW-S/I. An alternative methoddeveloped by Boulton and Streltsova (1977) considers non-steadystate conditions in fractured rock aquifers. Considering, as isstated in the report, that the data is questionable, another pumptest should be conducted using a_new piezometer nest .

17. Page 3-28. It is unclear whether dedicated or non-dedicatedbailers were used to sample monitoring wells. The QAPP indicatesthat dedicated equipment will be used while the RI report simplystates "a stainless steel bailer was used to collect the samples".The use of dedicated sampling equipment as opposed to one bailerfor all wells.ishould have been used. Explain the process and typeof sampling equipment used to sample monitoring wells. Providejustification-if this was a deviation from the RISOP.

18. Table 3-3. The last category in the top table, "End ofBoring", shows values which are the same as the ground elevation.These should be corrected.

SECTION IV————— AR3023131. Page 4-3. Field notes associated with the drilling- log forpile boring #1 indicates that the spoon was oily on the outside ata depth of 25 feet. How do you explain this? Why was this not

investigated further?

2. Little mention is made of the fact that the fluff by allindications has a characteristic of hazardous waste given thedetection of lead in numerous samples above the EP toxicitystandard of 5 mg/1 (Table 4-2). This could have significantbearing upon the ultimate fate of the pile. However, ERM questionsthe appropriateness of the EP toxicity test procedure intended tomimic conditions at a sanitary landfill and believes that resultsare deceptively elevated. EPA does not necessarily agree withthis.

3. Page 4-5. It is concievable that concentrations of PCB' sdetected in soils below the fluff pile are representative and arenot due to cross contamination caused by sampling equipment mixingfluff with soils. It is likely that PCBs have leached from thefluff, and are therefore not as tightly bound to the plastic matrixas the report suggests. PCBs in fluff should be considered justas mobile as in any other type of waste.

4. Page 4-9. The effectiveness of the shallow ground waterinterceptor trench system is called into question given theissuance of several leachate seeps from the banks of theintermittant stream opposite the collection trench (see alsoComment #1, Executive Summary).

5. Page 4-12. Leachate seep #4 needs to be resampled to confirmthe presence or absence of cyanide detected after the initial roundof sampling.

6. The prescence of low level VOC's detected in leachate seep #1below the equalization lagoon strongly suggests the source of theseconstituents to be the fluff itself. However, direct correlationis not possible since analysis of the fluff for VOC's has neverbeen performed. As stated in comment #9 above, the fluff needs tobe analyzed for VOCs.

7. Page 4-14. Limited evidence is presented to supportconclusions regarding the lateral extent of fragipans in overburdengiven observations from only six test pits excavated around theperimeter of—the fluff pile. More evidence needs to be provided.

8. How was it verified that the ground water interceptor systemindeed collects shallow perched ground water along the southernand western sides of the pile? (see also Comment #1, ExecutiveSummary)

9. Page 4-15. See comment #1, Page 3-6.

10. Table 4-10. The lack of semi-volatile data for AR 30 2 3 I kis another critical data gap- It is obvious from otBEHP contamination is widespread, and these missi^y uata were

necessary for adequate characterization.

11. Page 4-16. As with other constituents, the observation ismade that the prescence of phthlates in surface soils is the resultof unavoidable mixing with minute fluff particles during samplingand is not indicative of free phthalates in the environment. EPAdoes not necessarily agree with this interpretation since it tendsto minimize the impact of low mobility/solubility constituents.

12. Page 4-17. Attributing the source of PCB's detected in soilslocated to the north of the fluff pile to train traffic along theadjacent rail line lacks supporting evidence. It is more likelythe result of crosswind or wind-aided transport of fluff in variousdirections. This interpretation needs to be corrected.

13. Figure 4-8. This map shows 764 ug lead/1 at the mouth of theintermittent stream. Table 4-14 indicates this concentration isfor iron. This discrepancy should be fixed. (Note that if the mapis correct, the risk assessment would need some changes).

14. Page 4-40. There is insufficient evidence to support theobservation that, for the most part, the pile is well drained, someportions are more well drained than others, being a function ofcompaction, permeability, porosity, homogeneity, etc., of thefluff.

15. Page 4-42. Ground water flow conditions are evaluated fortwo time periods, October 1988 and June 1989, however,potentiometric surface diagrams are presented for only June 1989.Provide the potentiometric surface diagram for October 1988 also.

16. Conflicting statements are made with regard to thepredominance of lateral versus vertical flow within overburdenduring periods of high and low recharge. At one point it is statedthat lateral flow may not be significant because other ground waterflow may bypass the intermittant stream altogether and directlyrecharge the Little Schuylkill River (LSR). This implies lateralflow is significant. To verify if ground water is recharging theLSR, bedrock wells need to be installed to the south-southwestacross the intermittent stream from the site.

17. Page 4-43j. There is little doubt that the intermittant streamis representative of a zone of structural weakness (fracture zone).However, without knowledge of the lateral and vertical extent, andorientation of the fracture system, it is difficult to state withany degree of certainty that ground water underflowing theintermittant stream would be intercepted by this fracture systemand diverted towards the LSR discharge basin. Additionally, onlytwo cross-sections were developed which are not enough to show thecomplexity of the on-site fractured rock system.sections and information on the lateral and verticorientation of the area fracture systems needs to be provided.

18. It is not entirely clear that intermediate ground water flowis west-southwest. Figure 4-13 delineates flow directly southwest.Do the dashed lines show that a good amount of interpretation hasgone into the flow determination? This needs to be clearer.

19. Page 4-45. See comment #1, Page 3-25 regarding theapplication of aquifer analysis techniques not appropriate foranistropic ground water flow conditions in bedrock.

20. It is questionable whether the radius of influence created bythe pumping of MW-5/I is as extensive as suggested in Figure 4-14.It is more likely that the greatest influences are highlylocalized. The accuracy of maximum drawdown values for non-pumpingwells where measurements were taken manually on an hourly basis isalso questionable. Maximum drawdown values are so slight (.02 to.05 feet) that it is doubtful that there were any.

21. EPA disagrees with the observation that a strong correlationexists between relative hydraulic conductivity values and verticalhead relationships. For some well clusters this is true, but notin all cases. For example, similar head values are observed inwells MW-5/S and MW-5/I (slight upward gradient) yet a one orderof magnitude difference in conductivity is observed. Also (K)values for MW-2/I are not significantly higher than MW-2/S, despitestatements to the contrary.

22. Page 4-48. The relationship between chemical concentrationsin shallow and intermediate bedrock and head values is tenuousgiven that:

a) ground water elevations and measurements and samples werenot collected concurrently

b) given slight upward or downward gradients exhibited in thevast majority of well clusters, a fairly uniform distribution ofcontaminants throughout the saturated thickness mentioned would beexpected. Given slight upward gradients in well clusters, onewould expect organic constituents in the intermediate bedrockinterval as Sell.

23. Page 4-49. The observation that, in general, concentrationof metals and VOC's decrease with depth is not supported bychemical concentrations in well clusters #1 and #2 which tend todeviate from this percieved trend.

24. Ground water analyses indicate many analytes are left out ofthe sampling effort. An explanation for this should be included.In addition, some analytes found in soil, leachate, fan r o o i /•

I Dpiles are not detected. Is this due to sarnplanalytical failures, or to insufficiently detailed _. — *-~-~ —procedures? This appears to be an inconsistency and discrepancy

in the Sampling & Analysis effort.

25. Pile boring PB-1 accumulated greater than 10 feet of leachate.It should have been sampled, without purging or filtering, toidentify the concentration of contaminants.

SECTION V

1. Page 5-1. Figure 1 fails to show the hydraulic connectionbetween the drainage ditch/interceptor trench system and theshallow ground water.

2. Page 5-2. Analytical data from well cluster #7 does not fullysupport the opinion that it is located along the suspected verticalfracture. Analytical data also does not support the statementthat, "given the apparent decrease in major ion concentrations withdepth, enhanced leachate discharge occurs along it despite thestrong downward gradient". EPA fails to see significant decreasein major ion concentrations with depth.

3. The evaluation of results of the leachate sample at theequalization lagoon fails to mention the prescence of phenols at700-13,000 ppb which, relative to the phthalates, has a much highersolubility in water. This should be mentioned.

4. Anomalously high concentrations of metallic ions were detectedin well nest #1 which was assumed to be representative ofbackground water quality. Is this considered to be a naturalcondition? Also, TCE was detected (12 ppb) in MW-l/S during theNovember 1988 sampling event. Bromodichloromethane (2 ppb) wasdetected and both chloroform (4 ppb, J) and dichlorohexane (18 ppb,J) were quantitatively estimated in MW-l/I during the same samplingevent. Both the high metals readings and the organic contaminationsuggest that well cluster #1 may not always be in an upgradientposition to the waste pile. Attachment 1.0 demonstrates therecontouring of overburden water levels in the pile (PB-1 and PB-2). MW-1/0 and MW-2/0 were dry during the June 1989 sampling, sothe water levels had to be lower than the bottom of each well.This recontouring shows that a portion of the waste pile ispotentially upgradient from well nest #1. The RI report makes thecase that vertical communication exists between the overburden andthe shallow bedrock, and between the shallow and intermediatebedrock zones. With this in mind, TCE and dichlorohexane and theother compounds may have moved from the pile into MW-l/S and MW-l/I. Because it is potentially contaminated by leachate from thepile, the analysis of the sample data from this well cluster doesnot provide an indication of the natural ground water quality inthe area. Comparisons between other downgradient wells and thiswell nest cannot be made in order to correctly assesson ground water.

Another well needs to be installed and monitored in order to assess

background water quality.

5. Page 5-3. EPA disagrees with the position that since metalsconcentrations in background well nest #1 are above secondarydrinking water standards that this somehow minimizes or lessensobserved site impacts.

6. Page 5-4. The statement that ground water flow withinoverburden in the east-central portion of the site is limited issomewhat misleading. To be more accurate, vertical rather thanlateral flow predominates, thereby recharging bedrock. Thiscondition is a function of many factors including overburdenthickness, permeability (conductivity), and recharge rates.

?• Page 5-5. A consistent trend of decreasing concentration ofmajor ions has not been established, despite claims to thecontrary.

8. In my estimation, it is more plausible that the source of VOC'sdetected in well nests #2 and #5 originates on-site. There is noevidence at present regarding upgradient sources of suchconstituents nor is this suggested by analytical data frombackground/upgradient well nests.

The presence of TCE in overburden, shallow bedrock, andintermediate bedrock zones on-site suggests that the site cannotbe eliminated as the source of TCE without further investigation(i.e., upgradient monitoring well data from the three zones).

SECTION VI

1. The statement regarding the effectiveness of the ground waterinterceptor trench system would not pertain to the bedrock flowsystem, but rather the shallow flow system in overburden underconditions where lateral flow occurs during periods of increasedrecharge.

2. Ground water transport of metals, TCL volatiles, and TCL semi-volatiles is a clear mode, and a major mechanism of off-sitemigration. .TCE contamination in MW-3/0 and in the surface seepLS-1 demonstrate that the ground water interceptor system is notcompletely effective. Attachments 2.0 and 2.1 demonstrate thedistribution of TCE in the ground water system for the April 1989and November 1988 sampling events. A concentration of TCE, 10 to20 times the proposed MCL of 5 ppb poses a significant off-sitehazard and greatly decreases the value and impair the usefulnessof the area ground water.

3. Ground water frow from the Site provides the bas«intermittent stream below the area of MW-3/0. TC R D O n Q Q I Qother contaminants are being loaded into this surf a Hit JUcO I Ocan affect the food chain through bioaccumulation and/or direct

10exposure. Ground water and surface water will continue to bedegraded and pose a potential risk to the biosphere as long as thecontaminants in the waste piles remain on-site. Data presented inthe RI Report can be used to clearly demonstrate that ground watertransport is a critically important mechanism for off-sitemigration of metals, volatiles, and semi-volatiles that may posea risk to the environment and to the food-chain.

4. To better assess the contamination plume from the pile,equalization lagoon, and runoff lagoon, a monitoring well shouldbe installed downgradient (west to southwest) of these units nearexisting MW-6/0.

5. The extent of contamination was not defined and needs to be tofully study remedial alternatives.

TOXICOLOGY/RISK ASSESSMENT

Remedial Investigation

1. The RI narrows the Compounds of Interest (COI) to lead, copper,iron, and zinc, and does not include metals such as chromium andcadmium. While their concentrations were small as compared to theCOI chosen and their values were qualified, they should not bedismissed.

2. In Chapter 4, where the data is presented in discussion,mention of the data being qualified is not always present for allconstituents i.e. cadmium, chromium.

Endangerment Assessment

1. Table 3-1, Indicator Chemicals. The following substances,listed below with the media in which they were found atconcentrations of concern, should be added to the list of indicatorchemicals:

Surface GroundChemical___Media; Soil Sediment Leachate Water___Water

Manganese - H HAntimony H H HPhenol E2,4-Dimethylphenol H4-Methylphenol HToluene E

H:found at levels of concern to human healthE: found at levels of concern to ecosystems AR3023 i 9

Add a new Table that shows all of the indicator chemicals (60) in

11the format and with the information above.

2. Page 4-3, Lead. This section reports that lead wasincorporated into the plastic insulating material in lead phthalateplasticizers. Earlier discussion in the RI argued that the leadoriginated in pigments used for color-coding, with no mention ofplasticizers. The various sections of the report should be revisedto be consistent on this issue.

3. Table 4-3, Exposure Pathways. It is not apparent whyincidental ingestion of leachate should be rejected as unlikely,when similar ingestion of water in the intermittent stream wasevaluated as a possibility. Leachate ingestion should be added tothe risk assessment as an exposure pathway.

4. Page 4-14, Averaging. The method for calculating averageexposure point concentrations should be described. An acceptablemethod would be an arithmetic mean, using 1/2 the detection limitfor undetected indicator chemicals. An allowable, but moreconservative, alternative would be to omit non-detects from theaverage. For ground water data, only downgradient samples shouldbe averaged.

5. Table 4-5, etc. Air concentrations should be listed in mg/m3,not ppm.

6. Page 4-15. The application of an absorption factor of 0.3 fordioxin and PCBs is not justified. Reference doses and carcinogenicpotency facotrs for these compounds are based on administeredrather than absorbed doses. It is necessary, therefore, to comparethese toxicity reference values to exposure estimates that alsorepresent administered, not absorbed, doses.

Application of an absorption factor for lead is justified, but onlyfor samples extracted by ashing. No absorption facotr should beapplied to lead measurements by the hot acid digestion method.

7. Table 4-6, Site-Specific Parameters. Incidental ingestion offluff and soil should be lOOmg, not 50 mg, per event for adultsand large children. The dust adherence figure of 0.51 mg/cm2 istoo low. EEA's recommended value of 1.45 mg/cm2 (for commercialpotting soil; from the Superfund Exposure Assessment Manual, 1988)should be used instead.

8. Tables 4-8 to 4-10, Daily Intakes. The equations used tocalculate these intakes (Appendix F) appear correct (with theexception of (a) dust adherence, (b) absorption factors foringestion, and (c) the point addressed in the next comment.However, spot checks of several calculations showed that^ thefollowing numbers in Table 4-8 could not be reprodfi Ir\j0"2 3 2 0equations: - - - ,

12

i. Fluff, maintenance workers, dermal contact, lead, shouldbe 9.77E-3, not 8.32e-3.

ii. Same scenario, ingestion (with 0.3 absorption facotr) .should be 8.80e-3, not 6.84e-3.

iii. Soil, children, dermal contact, lead, should be 9.06e-5,not 8.99e-5.

iv. Same scenario, ingestion, should be 1.42e-4, not 7.07e-5.

Of five calculations checked, only four agreed with the equationin Appendix F. Finding three significant errors in five tries, allunderestimates, suggests that the risk assessment is riddled withsimilar mistakes. To the extent that this is true, it is a majorflaw in the work, in effect a betrayal of trust. EPA lacks theresources to check every calculation in an assessment this complex,and we necessarily expect the contractor to perform them reliably.

The table of daily intakes should be checked thoroughly and revisedto conform to the equations in Appendix F.

9. Tables 4-8 to 4-10, Daily Intakes. Daily intakes should becalculated differently for assessing carcinogenic and non-carcinogenic risks. To calculate the non-carcinogenic hazardindex, averaging exposures over one year (as done in these tables)is appropriate. To calculate carcinogenic risk, exposure shouldbe averaged over a 70-year lifetime", not one year. The 1-yearaverages used in this risk assessment produce a substantialoverestimate of carcinogenic risk.

10. Table 5-1, Toxicological Information. The reference dose forlead has been withdrawn by EPA, and the obsolete value from SPHEMis now believed to be too high. For this risk assessment, Isuggest using a reference dose of 1.4e-4 mg/kg/d, derived fromEPA's proposed MCL of 5 ug lead/1.

Since IRIS contains no inhalation CPF for BEHP, the oral valueshould be used.

11. The lack ri>f manganese and antimony data for the fluff pile isa serious data gap. Since these metals appear at highconcentrations in soil and water samples around the pile, theyshould be presumed present at even greater levels in the pileitself.

12. Although teratogenicity is seen at very low doses (e.g. cleftpalate after oral gavage administration of a single 6 ug/kg doseto pregnant mice) of 2,3,7,8-TCDD (see Toxicol. Appl. Pharmacolo99:276-286 for a review), this critical toxic ef fft<ft3 2 3mentioned in the summary of p. 5-4 or in the detailed-review -inAppendix B.

13

13. Page 6-7 characterizes the carcinogenic risk range of IE-7 toIE-4 as "the U.S. EPA guideline for acceptable total lifetimecarcinogenic risk" associated with a Superfund site. However, theimplication that carcinogenic risks are acceptable if they do notexceed IE-4 is inappropriate and misleading. The Superfund PublicHealth Evaluation Manual, pp. 91 and 93, does not indicate that thecarcinogenic risk range of IE-7 to IE-4 is a guideline foracceptable total lifetime carcinogenic risk but rather indicatesthat the remedial action target total individual carcinogenic riskresulting from exposures at a Superfund site may range anywherebetween IE-4 to IE-7. It also indicates that EPA encouragesdevelopment of alternatives that eliminate carcinogenic risk wheresuch a remedy is feasible.

BIOASSESSMENT

1. A wetlands delineation was not performed. Information providedon page 4-14 of the RI indicate that fragipans are present fairlyclose to the soil surface in some areas and that mottling occurswithin one foot of the surface. Such areas are prime candidatesfor the occurrence of wetlands. An on-site survey should beconducted by a wetlands specialist. In addition, statements madeon page 2-2 concerning a review of national wetlands inventory mapsis incorrect. The national wetlands inventory maps contain noinformation concerning critical or unique habitats. The maps arenot all inclusive as a result of the large scale of the aerialphotography used, and wetlands could occur where none are shown onthese maps. For this reason, an on-site wetlands delineation wasrecommended in previous comments relative to this site.

2. Page 2-1 of the Remedial Investigation (RI) and Page 1-3 ofthe Endangerment Assessment (EA) state that no threatened orendangered species are known to exist in Schuylkill County. ThePennsylvania Natural Diversity Inventory (PNDI) indicated thatthere was a record of a rare clam species reported from StillCreek, north of the study area. In a letter from PNDI (AppendixG of EA) , they suggest that a field survey be conducted to verifythe presence of this species. PNDI also makes it clear that theinformation they provide is not a substitute for on-site surveys.Therefore, a field survey should be conducted and, also, the Fishand Wildlife Service should be consulted to determine the occurenceof threatened and endangered species in this area and the impact,if any, this site has on those species.

3. The ecological assessment of the terrestrial habitat associatedwith this site has not been adequately characterized and,therefore, potential impacts of contaminants to the terrestrialecosystem have not been evaluated. The RI should include athorough description of the site including ecology, i-efauna of the site and the vicinity around the site wimpacted by the contamination from the site or the

14

remedial measures.- A description is needed of the class type ofthe intermittent stream, i.e., recreational, water supply, warmwater, fishing, etc. A description is also needed of the followingareas which may be associated with or impacted by the site:floodplains, recreational areas, farmlands, historicbuildings/areas, archaeological sites, etc.

4. Page 7-9 states that the fence prevents large animals fromentering the site and that small animals are expected to be limiteddue to the absence of habitat. However, as stated above, there isno indication that the site and its surroundings were evaluated forthe presence of animals. Therefore, data supporting this claim isneeded.

5. It is inappropriate to use E-P Toxicity to dismiss potentialtoxic contaminants for bioavailability and potential impacts.E-P Toxicity methodology is not a rational characterization ofpotential pathways or for evaluating toxicity.

Stream Quality

6. The characterization of the intermittent stream has not beenthoroughly developed. The uses of the stream and the potentialmigration pathways have a bearing on the significance of the PCBconcentrations measured in the sediments. What definition is usedto designate the stream as intermittant? It is important to notethat the definition is evolving from one based solely upon flowsto one based on flows coupled with the ecological values. Theecological values now being used relate to stream conditions andcommunities of the riffles and pools as well as the bank andfloodplain. It is now considered appropriate to investigate streambed for facultative aquatic species to a depth of 10 cm in thestream bed. It is not clear that this level of ecologicalassessment was done in conjunction with the stream evaluation.

7. On page 7-3, it is incongruous that from finding only oneorganism in the intermittent stream on site that the conclusionsof "no significant impacts ..." can be reached. Using thedefinition above, one could conclude just the opposite, i.e., thatimpacts are .severe and thorough for the drainage area simplybecause only -one organism was found.

8. EPA questions the conclusion that "no measurable effect onriver water quality from the EDM site was found because ofprevailing acid mine drainage-related degradation in this sectionof the river". The metals found in the intermittent stream couldbe expected to be physically moved into the Little SchuylkillRiver, where they would go into solution as a result of the low pH.The trout fishery, about 3 miles downstream, may be iigDBcJtadb byp Othese metals in solution. ?!.--Td . °

9. The conclusion that the metals content in the sediments

15

upstream from the confluence of the intermittent stream with theLittle Schuylkill River do not differ from downstream levels isunderstandable in light of the pH of the Little Schuylkill. Themetals are in solution and will not precipitate until the pH israised, probably well downstream.

10. The RI should indicate the potential for improvement of waterquality and related aquatic life populations and consider potentialeffects of the site contaminants to such conditions.

Inorganics:

11. It may be concluded from reading and comparing Tables 7-2 and4-17 in Appendix E that some other metals along with copper andzinc are present at toxic levels in component parts of theanalytical environment. These include arsenic, iron, manganese,and lead.These fail to be acknowledged.

Organics:

12. Tables 7-2 and 4-14 of Appendix E do not agree with regard tophenol: the latter show toxic levels of phenol are found atsampling station BIO-2, while none is reported in Table 7-2.

13. The non-carcinogenic indicators (p. 3-2) should be expandedto include arsenic, cadmium, iron, manganese and possibly aluminum,as they are all at toxic levels to aquatic life as reported inSection 7 and Appendix E. They should be included in Table 3-1,"Justification for Indicator Chemical Selection" or in a separatetable showing indicator chemicals with regard to aquatic life.

The following metals should be included (see Table 4-14)

Metal___________________________Rationale______

As Present at toxic levels in sediment andleachate at BIO-1 & in the sediment at BIO-2.

C<3 Present in toxic levels in leachate at BIO-1.

Fe Present in toxic levels in sediments &leachate at BIO-1 & BIO-2 (see tables 4-10thru 4-14).

Mn Present at toxic levels in sediment at BIO-1.

Al Present at toxic levels in sediment at BIO-1and BIO-2 and in leachate at BIO-la.nCflajMf o o /element may be ubiquitous dependift|« Maiarexrc 4type and conditions.

16

Sufficient discrepancies exist among these in the analyses reportedto justify comprehensive sampling and analyses to determine preciselevels of contamination.

AIR

Remedial Investigation

1. Executive Summary. The last page states that, "The very lowconcentrations detected indicate that the potential for transportof this compound from the fire area by wind or erosion isunlikely." EPA questions the relationship between lowconcentration and potential for transport. Did the report intendto state that the potential impact from transport would be low dueto the low concentrations?

2. The presence of VOCs in air is dismissed in the report.However, this conclusion is based on the fact that no qualityassured data was obtained to substantiate the presence of VOCs.There is not enough information to draw this conclusion and,therefore, additional air monitoring and/or modeling should beperformed to establish whether or not significant emissions of VOCexist. Same thing for the conclusions drawn in Section 5.4.

3. What was the rationale for the phenol sampling locations? Whydon't any of the locations sampled coincide with the earlier TATassessment of the site? The rationale should be explained in thereport.

4. Data sheets from the earlier TAT assessment do not include anexplantion on how to interpret them. An explantion is needed toshow how they should be used.

5. The method of sampling used for dioxin and dibenzofurans willnot necessarily yield the highest concentrations since the soilconcentrations of these chemicals are a result of theiraccumulations during the fires. The soil concentrations dependnot only on the intensity of the fires, but also on the prevailingwind directions during all periods when the fires were present.If the prevailing wind direction on the day of the worst fires wasnot the prevailing wind direction throughout the fire events, thenlocations other than the one sampled could contain higherconcentrations. No information is provided on the number of fires,their locations, or the duration of the episodes. A judgment asto whether or not the area of highest concentration was sampled cannot be made without further information.

Endangerment Assessment

1. Table' '4-2. Inhalation from surface soil shoulda major fate and transport process for lead, PCBs, and dioxins.'

17

2. Table 4-3. This table indicates that inhalation of fugitivedust from surface soil was not analyzed because "surroundingvegetation limits wind transport from the site." Thisjustification for not considering this pathway is not appropriateor acceptable.

Fugitive Dust Modeling3. ABE meteorological data was used for the analysis of the fireevents, but Scranton meteorological data was used to determine theemission rate of fugitive dust. Since the site is located in avalley, neither of these data sets may be representative of the onsite meteorology. Explain why different data sets were used forthese situations and why you think these are representative.

4. The ISCST model was run in a screening mode to determine shortterm concentrations. These short term concentrations were thenscaled to obtain annual concentrations. Scaling factors can notbe used to determine annual concentrations from hourlyconcentrations. In order to obtain an annual concentration, oneyear of meteorological data must be used. Also, it is not clearwhy screening meteorology was used instead of the ABE or Scrantondata.

5. The report indicates that only three receptors were modeledand presents these simply as downwind distances without referenceto azimuth. These locations do not necessarily represent the mostexposed individual (MEI) since the frequency of occurrence of winddirection as well as proximity determines long term exposure.Also, a receptor grid should be developed that has enoughresolution to locate the maximum concentrations independent of thelocations you wish to examine.

6. Section 6.5 discusses potential risks due to existing siterelated exposures and states that fugitive dust modeling was usedto help determine these risks. However, the footnotes in Table C-4 and C-5 state "The stability class used was D and a wind speedof 1 m/s since the activity on the site will only occur during thedaytime hours." Therefore, it is unclear whether the Cowherdcalculations~and the modeling are being done to estimate baselineemissions and baseline concentrations or emissions andconcentrations during a clean up. Clarification of theseuncertainties and a more complete modeling procedure and analysisshould be provided.

7. On page C-5, the report states that the concentrations in TableC-4 were used for risk assessment. However it is not clear if theprobable concentrations or the maximum concentrations modeled wereused for this analysis.

AR302326

18

QUALITY ASSURANCE/QUALITY CONTROL

Remedial Investigation Report

Organic Review

1. Table 4-10. In the Quality Assurance Review in Appendix forsample SS-26 it was stated that acetone was present but isqualified with a "B"; however, acetone was not listed in Table 4-10 for sample SS-26.

2. Page 6-1. In the conclusion, DEHP is stated to be due toplastic fluff particles in samples but should say probably due.

3. Page 6-1. The TCE sentence is incomplete.

Inorganic review

4. Table 4-7. This table omits both silver and antimony from themetals section.

5. Table 4-14. Sample SW-6 (dissolved) should have a "B"qualifier.

6. Brackets should be placed around results that are greater thanInstrument Detection Limits (IDLs) and less than Contract RequiredDetection Limits (CRDLs) . This was not done in any of thetabulations.

7. Data on Table 4-14, p. 2, for phenols, total organic carbon,TPS, hardness, and alkalinity does not correspond with the Tablein Appendix D. For example, TOC for SW-4 is 3100 ug/1 in Table 4-14 and 3.1 ug/1 in Appendix D. The same type of error existsacross the entire table for those categories.

General

8. Data for Table 4-13 is not referenced/found in Appendix D. TheQA that was used for Surface Water Flow should be covered in theAppendix-. ~r

9. Field parameter measurements, such as those shown in Table 4-15, should be presented in Appendix D.

SURFACE WATER QUALITY


These comments should be considered when considerialternatives:

19

1. Discharges from a Superfund site must meet the substantiverequirements of the Clean Water Act (CWA). Section 301(b)(l)(c)requires that pollutants contained in direct discharges becontrolled beyond Best Conventional Technology (BCT) or BestAvailable Technology (BAT) equivalent when necessary to meetapplicable Water Quality Standards. The Pennsylvania Water QualityStandards (WQS)-Rules and Regulations (Chapter 93, PA Bulletin,Vol. 19, No. 12) and the Pennsylvania Water Quality ToxicManagement Strategy (TMS) (Chapter 16, PA Bulletin, Vol. 19, No.10) establish the water quality based requirements to assurecompliance with the CWA.

2. The hazardous substances which exceed the Water QualityCriteria (WQC) established by the PA Water Quality Standards orthe PA Water Quality Toxic Management Strategy for human healthand/or aquatic life appear in one or more of the sampled locations(e.g., effluent discharge, leachate/seep, surface water, groundwater). These hazardous substances of concern are listed below:

HAZARDOUS SUBSTANCES_____________________WQC (ug/1)___________-__

VOLATILESchloroform HH .4carbon tetrachloride HH .2tetrachloroethene HH .3trichloroethene HH 3.0

SEMI-VOLATILES2,4-dimethylphenol A/L 130.0

METALScopper A/L 6.5lead A/L 1.3mercury A/L .012iron (total) A/L 1500.0iron (dissolved) A/L 300.0zinc A/L 59.0

HH - Human HealthA/L - Aquatic Life Limits

-*.l-

3. Since the" receiving stream is an intermittent stream, there islittle available dilution flow. Therefore, appropriate effluentlimitations for any discharge to this stream should be equal to theapplicable water quality criteria cited above. Furthermore, EPA'sNational Policy on the Development of Water Quality-Based PermitLimitations for Toxic Pollutants (Federal Register VOL. 49, No. 48,Friday, March 9, 1984, attached) requires that biomonitoring beconsidered in an NPDES Permit. Because of the complex chemicalmake-up of this wastewater, this discharge is considgood candidate for biomonitoring. At least quai

20

testing using Ceriodaphnia dubia and fathead minnow will berequired. The permit must specify a whole effluent toxicitylimitation of a NO OBSERVED EFFECT CONCENTRATION (NOEC) of 100%effluent as required in Part 122.44(d) (1) (V) of EPA's regulations.

GENERAL RI COMMENTS

1. Page 1-3, Fourth Paragraph. Who is the site caretaker? Is ita company? a person? What are this company's/person'sresponsiblities as caretaker of the site? This should beexplained.

2. Page 1-4, First Paragraph. "Stonelake, 1986" is referenced.A copy of this report should be included in the RI.

3. Page 3-19. The text states that "A visual reconnaissance ofthe site was performed to inventory trash, rubbish and any otherwaste materials present on the site." The RI should specify whatthe other waste materials consist of.

4. Page 4-17, Second Sentence. SS-3 in located on the interiorditch at the southeast side of the pile. Should this read SS-1 at3.3 mg/kg?

5. Leachate treatment system. This system, and the leachatecharacteristics that made it necessary, should be more completelydescribed.

6. Fluff fires. The text describes several small fires in 1979.However, temperature monitoring of the pile was begun in 1977.Thus, by implication, there must have been fires earlier than 1979.The earlier fires should also be discussed.

7. Page 4- 6. The text states that "Composite samples wererelatively consistent in metal concentrations both horizontally andvertically (Table 4-4)." Table 4-4 does not depict the consistencyclaimed, therefore further clarification is needed on thisstatement.

GENERAL EA COMMENTS

1. Figure 1-5. This figure does not clearly represent the patternof surface soil organic analytical results. In addition, thefigure does not easily designate the distribution of organiccompounds, including PCBs, detected in the surface soils. As aresult, the map should be altered to better illustrate it'spurpose. In particular, a legend is recommended «<fv @<£ 3"-2 9interpreting the figure. - - -

2. Figure 1-8. This figure shows the distribution of site-related

21

metals in the streambed sediments." Page 1-20 states that"Aluminum was slightly more abundant in the site-related samplesthan in the Little Schuylkill River." It^also states that iron wassignificantly higher in concentration if the Equalization Lagoonthan in any other sample. Figure 1-8 should list the results ofthese two metals as ifone for the other site-related metals.

3. Page 4-2. The text states that on-site exposures to thegeneral populace are not considered "...since the site is fairlyremote from housing clusters and there is a high fence around theproperty." The EA should provide a better description of the sitein relation to the general populace. In particular, it shouldevaluate the exposure of soil blowing off site.

4. Page 6-7. The text states that "The maximum carcinogenic riskfor the above exposures also exceeds the upper bound of the riskrange acceptable under the Superfund program." The EA shouldspecifically state the documents which reference the acceptablerange.

APPLICABLE, RELEVANT, AND APPROPRIATE REQUIREMENTS (ARARS)


1. A listing of potential ARARs (all applicable, relevant orappropriate regulations) should be included. Attachment 3.0 is achecklist and listing of ARARs which provides some guidance indetermining which ARARs are applicable to this particular site.In addition, some potential air ARARS are detailed below:

The PM-10 National Ambient Air Quality Standard (NAAQS). The PM-10 NAAQS is an annual (expected arithmetic mean) of 50 ug/m3, anda 24-hour standard of 150 ug/m3 (not expected to be exceeded morethan once per year). Compliance with this standard should bedetermined through ambient air modeling and/or monitoring for theno-action scenario as well as during disturbed conditions.

The Ozone NAAQS. This is a 1-hour standard of 0.12 parts permillion, concentration not to be exceeded more than once per year.Compliance wltth this standard should be determined for the no-action scenario, as well as during disturbed conditions.

The Vinyl Chloride National Emission Standard for Hazardous AirPollutants (NESHAP). This may be relevant if emissions of vinylchloride are generated on-site. This emission standard allows 10parts per million concentration over a 3-hour period.

The State Air Office should be informed prior to gemissions bn-site.

22

TEXT/TYPO ERRORS


1. Work Plan approved 18 March 1988 in Table 1.1 and 25 March 1988on page 1-8 of text.

2. Page 3-11 mentions that "Flow rates were measured in theintermittent stream at three weirs built across the channel." Weir3 is labeled as Weir 2 in Figure 3-3. Thus, there are two Weir 2'sin Figure 3-3.

3. Table 3-2 indicates that the italicized entries represent"samples not taken due to lack of flow". Distinguishing betweenthe italicized and regular print is difficult. These entriesshould be printed in a different type such as bold type for easieridentification.

4. Page 3-18 makes reference to the locations of four test pitsas illustrated in Figure 3-5. The locations of these pits is notapparent on the figure. Either the wrong figure is referenced ornew labeling should be applied to Figure 3-5 to make this clearer.

5. Page 3-21 states that "the location of existing site well M-2is shown in Figure 3-6." M-2 is not labeled in Figure 3-6. Alsothe downgradient well, MW-7/I, is not visible in Figure 3-6. Inaddition, the last sentence of Section 3.9.4.1 is incomplete.

6. Water level monitoring reported for 9 dates in Section 3.9.5.1(p. 3-25) and as ten occasions in Section 4.6.4.1 (p. 4-39).

7. Page 4-9 states that the locations of four seeps, designatedLS-1 through LS-4 are shown in Figure 3-5. These seeps are notindicated in Figure 3-5.

8. MW-2/5 on Figure 4-11, -12, and -13 is printed MW-S/S.

9. MW-4/0 on Figure 4-11 has 1103.23 for overburden water tableelevation while Table 4-24 states 1103.18.

10. Figures -4-11 through 4-13 reflect the water table elevationsas measured oai 19 June 1989, not for 28 October 1989 as referencedin Section 4.£.6 (p. 4-42).

11. Figure 4.15 illustrates TCE distribution, not volatileorganics across the site.

12. List of Figures. On applicable figures, correct the followingto read, "The property line...represent..." and not repersent".

A p o n p o o I13. .The tables in the appendices should have table- numbers andpage numbers.

3. Oi

Checklist for Environmental and Community Relations Factors in

RI/FS/ROD Documents

OR

NEPA. Functional Equivalency Documentation

The objective of this form is to document that the require-ments of the National Contingency Plan (NCP) (40 CFR 300.68)which address environmental concerns and community relationshave been met and that, as a result, the National EnvironmentalPolicy Act (NEPA) functional equivalency has been achieved.This form may also be useful to a project manager in develop-ing a site work plan for the Remedial Investigation.

The following list of questions are organized into fivemain sections. These sections include those environmentalfactors which, if addressed, in the RI/FS/ROD process as re-quired by the National Contingency Plan, will ensure that theRI/FS/ROD document is functionally equivalent to the NationalEnvironmental Policy Act. The fifth section in particulardocuments the public participation requirements of the NCP andNEPA. The sections, including the subsections under theNatural Environment Section, are each followed by a seriesof questions. Each series of questions is followed by blankspaces where appropriate response concerning the presence ofa feature, the possibility of impacts (beneficial or adverse)as a result of remediation, and the consideration for mitiga-tive measures may be noted. Federal and state requirementswhich are applicable, relevant, and appropriate are listedto the extent possible beneath each environmental factor(Requirements). The project manager may list the pertinentrequirements in the spaces provided below. Spaces are alsoprovided for referencing the appropriate section of RI/FS/RODwhere detailed documentation can be found (References).The project manager may use this space to describe impacts, mitigative measures, or beneficial consequences (for futurereference). The questions listed under the Community Relationssection are derived directly from the NCP (40 CFR 300.67).

After the form is completed, a copy should be sent tothe NEPA Compliance Section.

AR302335

Site Name:Project Manager:

I. NATURAL ENVIRONMENT

A. Air Quality

1. Does the site violate air quality standards?Yes__ No__ Mitigative measures__

2. Will the proposed action create violations of airquality standards?Yes__ No__ Mitigative measures__

Requirements: Clean Air Act, RCRA, State regulations

References:

B. Water Quality

1. Will the proposed action result in altered flow ordecline in quality of surface water, ground water, or apublic water supply or result in the long or short termacceleration of erosion?Yes__ No__ Mitigative measures__

2. Will the proposed action create violations of Statewater quality standards and/or applicaable State sedimentand erosion control standards? Is the proposed actionconsistent with EPA's Ground Water Protection Strategy,designated MCLs, or other contaminant specific standardsor limitations, and/or current U.S. EPA Policy?Yes__ No__ Mitigative__

Requirements: CWA, State Water Quality Standards, Fish andWildlife Coordination Act, SDWA

References:

C. Wetlands

1. Are there wetlands/floodplains present at the siteand has an assessment been performed?Yes__ No__ Mitigative measures__

AR302336


2. Will the proposed action result in a change (positiveor negative) in the functional value of the wetlands/floodplains?Yes__ No__ Mitigative measures__

Requirements: Protection of Wetlands (EO 11990) , FloodplainManagement (EO 11988), CWA (404), State wet-land regulations

References:

D. Environmentally Sensitive Areas

1. Describe the important features of the site and brieflydescribe any impacts of the site or any proposed reme-dial action to the following sensitive areas: a) wildand scenic rivers, b) coastal zones, c) wildlife refugesand/or santuaries, d) parks, beaches, recreational areas,e) areas of unique aesthetic value, f) historic and/orarchaelogic sites listed on the Federal Register oridentified by the State Preservation Officer, g) signifi-cant agricultural lands, and h) mineral resources.

Description:

2. Are there any adverse impacts associated with the aboveidentified areas?Yes__ No__ Mitigative measures__

Requirements: Wild and Scenic Rivers Act, Coastal Zone Manage-ment Act, Wilderness Protection Act, Fish andWildlife Conservation Act, Marine Protection,Research and Sanctuaries Act, Conservation ofWildlife Resources, National Historic Preser-vation Act, Significant Agricultural Lands (LESA)

References:-

AR302337


II. BIOTA

1. Are endangered or threatened species or their habitatat the site or in the area considered for remedialaction?Yes__ No__ Mitigative measures__

2. Will the proposed action impact vegetation or wildlifeand aquatic life and/or their habitat (i.e., coastalzone, wetlands, nursery areas)?Yes__ No__ Mitigative measures__

Requirements: Endangered Species Act, Fish and WildlifeCoordination Act, Fish and Wildlife Improve-ment Act, Fish and Wildlife Conservation Act,Marine Mammal Protection Act, Conservation ofWildlife Resources, coastal Zone ManagementAct (CZMs)

References:

III. ENVIRONMENTAL LAWS

1. Does the project create violations of other applicable,relevant and/or appropriate requirements (Federal,State, or local laws or requirements)?Yes__ No__ Mitigative measures__

Requirements: RCRA, TSCA, FIFRA, DOT, Marine Protection,Research and Sanctuaries Act

References:

IV. INSTITUTIONAL CONSIDERATIONS1. Does the site or proposed remedial action impact land

use plans or community services?Yes_L. No Mitigative measures__

Requirements: NEPA, NCP, County Management and Land Use Plans

References:

AR302338


V. COMMUNITY RELATIONS

1. Has the community relations plan been prepared?Yes __ No __

2. Has the public had the opportunity to comment on theFeasibility Study?Yes __ No __

3. Has a responsiveness study been prepared?Yes __ No __

Requirements: NCP (40 CFR 300.67)

References:

AR302339