UMTED STATES ENVIRONMENTAL PROTECTION AGENCYREGION •

841 Chestnut BakingPMadelpHa. PemsyJvaria 10107

June 12, 1992

Mr. George B. MarkertSenior ConsultantEnvironmental AffairsBridgestone/Firestone, Inc.1200 Firestone ParkwayAkron, Ohio 44317

Mr. Barry BelfordDirectorCecil County Department of Public WorksRoom 308 Court HouseElkton, Maryland 21921

Re: Addendum Baseline Risk Assessment and Addendum PreliminaryFeasibility Study for Septic System Drain Field Soils,Woodlawn Landfill RI/FS, Cecil County, Maryland

Dear Messrs Markert and Belford:

Enclosed please find the comments of EPA and the MarylandDepartment of the Environment (MDE) regarding the subjectdocuments.

As noted in the comments, the need for remediation of drainfield surface soils is questionable. EPA will evaluate the risksposed by this portion of the site upon review and approval ofyour responses to the enclosed comments on the Addendum BaselineRisk Assessment (BLRA). The results of the addendum BLRA mayindicate that the site poses little or no threat to human healthand the environment. However, in the event that remediation ofsurface soils in the vicinity of the abandoned drain field isdeemed necessary, remedial technologies and alternatives whichare cost-effective (possibly consolidation of contaminated drainfield soils under the proposed landfill cap) should be presentedin the Feasibility Study.

SR306063

Mr. MarkertMr. BelfordJune 12, 1992Page 2

Please note that the responses to comments on the AddendumBLRA should be submitted to EPA and MDE as expeditiously aspossible since this information is pertinent to the developmentof the final Feasibility Study Report. Please call me at (215)597-9238 so that we can discuss a delivery date for yourresponses to the enclosed comments.

Sincerely,

UJ.tW3'Debra RossiRemedial Project MangerDelaware/Maryland Section

cc: John FairbankKevin GaynorMark GrummerPat HilsingerAlan Jacobs

AR30606U

EPA'S COMMENTS ON THE ADDENDUM BASELINE RISK ASSESSMENTRI/FS. CECIL

In general, the handling of non-detects was not broached in theReport. A brief discussion addressing this issue should beincluded in the final Report.

Section 1.2, Approach and Risk Assessment Organiiation (andSection 3.1, Exposure Assessment)! According to pages l-l and 3-3 of the Report, maximum concentrations for each observedconstituent were used to approximate exposure in the baselinerisk assessment (BLRA). Please note that, when feasible, the95th percent upper confidence limit (UCL) of the arithmeticaverage for each contaminant should be used. In other words, the95th percent UCL of the mean concentration for any givencontaminant should be applied in the BLRA when that value is lessthan the maximum detected concentration. Maximum contaminantconcentrations should only be used when the calculated 95thpercent UCL of the mean exceeds the maximum.

As indicated on pages 1-2, 3-1, 3-6 and 3-9 of the Report,the risk associated with dermal contact with surface soil wasassessed in the BLRA. However, according to EPA guidanceentitled Dermal Exposure Assessment: Principles and Applications(January 1992), only exposure to 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD), polychlorinated biphenyls (PCBs) and cadmium insoil can be quantitatively assessed with any appreciable degreeof accuracy. All other contaminants in soil should be evaluatedin a qualitative mode. Therefore, consideration should be givento deleting this pathway, i.e. - dermal exposure to contaminantsin soil (except for TCDD, PCBs and cadmium), from the BLRA.

Section 2.2, General Site-Specific Data EvaluationConsiderations! According to the first paragraph of thissection, it is EPA Region Ill's recommendation that any detectedchemicals with available toxicity criteria be evaluated in theBLRA. This statement is somewhat misleading, however. The RiskAssessment Guidance for Superfund (RAGS) (December 1989) providesa framework for developing chemical data sets for BLRAs. Inaddition to these guidelines, RAGS also suggests that whendealing with large data sets, chemicals contributing less thanone percent to the total risk at a site be eliminated. RegionIII supports this approach. With regard to the addendum BLRA forthe transfer station drain field soils, as well as the March 1992BLRA, evaluating every constituent that possesses toxicitycriteria probably served to incorporate a few contaminants ofnegligible significance into the BLRA, that may have otherwisebeen excluded.

Page 2-«, first paragraph! In accordance with Work PlanAddendum No. 2 (Septic System Drain Field Investigation), twosubsurface soil samples were to be submitted by ERM to thestationary laboratory for chemical analyses, since EPA's primary

AR306065

Page 2

concern was that septic system drain field soils could becontributing to on-site ground water contamination (a concernalso expressed by Bridgestone/Firestone, Inc. and theirconsultant, IT Corporation), EPA requested that ERM submit anadditional subsurface soil sample for laboratory analyses, as areplacement for one surface soil sample. EPA's oversightsubcontractor, however, submitted two subsurface soil samples(co-located with ERM's SS-l and SS-2) for analyses. Chemicalanalytical results for these oversight samples (data enclosed)are consistent with results obtained for ERM's surface soilsample SS-2.

Page 2-7, first bullet! Selection of subsurface soil sampleTSB-5, 2 to 4 feet interval, was also based on the indication ofelevated volatile organic vapors (160 ppm PID reading).

Page 2-7, second bullett Selection of subsurface soilsample TSB-5, 4 to 6 feet interval, was not "based on depthimmediately below the 4 to 6 foot sample." In addition to theobservation of petroleum hydrocarbon odors, selection of thissample was based on an elevated PID reading (108 ppm).

Section 3.1.4, Identification of Exposure Pathways andExposure Parameters! Page 3-7 and Appendix D describe the use ofthe Summers method to predict concentrations of contaminants inground water beneath the septic system drain field based on theconcentration of these contaminants in samples of subsurfacesoil. As previously indicated (EPA's May 8, 1992 comments), IThas not used the Summers method the way EPA generally uses it,which is for determination of cleanup levels for thosecontaminants in soil that exceed background, and MCL, or health-based level in ground water. Given that VOCs are primarily ofconcern at this site, and none of the VOCs that were detected insoil were detected above their MCL in ground water collected fromTSW-l, use of the Summers method is inappropriate here, as is theneed for subsurface soil remediation.

Please refer to EPA's May 8, 1992 comments regardingassumptions used to estimate hypothetical exposure to sitecontaminants.

Page 3-«, seventh bullet! The exposure frequency assumed inthe addendum BLRA for a child trespasser is 117 days/year. Inthe March 1992 BLRA, howeyer, exposure frequency under thisscenario was assumed to be 36 days/year. Please reconcile thedifference between the two exposure scenarios, or providejustification for this discrepancy.

Page 3-11, topi An exposure time of 0.44 hours/day wasassumed for inhalation of airborne contaminants in off-site soil.The derivation of this value should be discussed in the Report.

flR306066

Page 3

Page 3-21, first paragraph! The following statement ismade: "In the case of the detected noncarcinogenic polycyclicaromatic hydrocarbons (PAHs), pyrene was used as a surrogate forchrysene, phenanthrene, benzo(b)fluoranthene,benzo(k)fluoranthene, benzo(a)pyrene and benzo(ghi)perylene.NThis statement is potentially misleading since chrysene,benzo(b)fluoranthene, benzo(k)fluoranthene and benzo(a)pyrene areclassified as Group B2 - Probable Human Carcinogens. In theBLRA, the intent of using pyrene as a surrogate for the listedPAHs may have been to assess noncarcinogenic endpoints. Pleaseclarify the Report, as necessary.

Page 3-22, first paragraph! As discussed here,gastrointestinal absorption factors were applied to certaincalculations in the BLRA. It should be clearly noted, however,that adjustments for absorption were considered for dermalexposures only.

Page 3-25, top! As previously noted (EPA's May 8, 1992comments), EPA guidelines do not state that the target risk level"should be between 10""6 and 10~*."

Page 4-4, top! Please clarify (or correct, as appropriate)the apparent discrepancy regarding bioconcentration of mercury inearthworms. The first line on page 4-4 of the Report indicatesthat the concentration factor of 0.34 is based on mercury levelsfound in earthworms, on a dry weight basis. This factor was usedto estimate a potential mercury concentration of 0.4 mg/kg ofearthworm body weight.

Table 2-4! The description of exposure point concentrationspresented in Table 2-4 (footnote "b") disagrees with thediscussion on pages 1-1 and 3-3. Table 2-4 (footnote "b")implies that average concentrations were used in the BLRA, whilepages 1-1 and 3-3 indicate that maximum observed levels wereused. Please clarify and amend the Report, as necessary>

Table 3-3s According to this table, interim inhalation andoral RfDs were derived for lead for use in the BLRA. Due to thehighly toxic nature of this heavy metal, EPA believes that it isinappropriate to apply RfD values in the assessment of leadtoxicity. For this purpose, the Integrated Uptake/Biokinetic(IU/BK) Model was developed. The IU/BK Model should be'executedfor evaluating the toxic effects associated with exposure tolead.

Appendix A, page *-5i Please refer to comments aboveregarding pages 2-6 and 2-7 of the Report.

AR3Q6067

EPA'S COMMENTS ON THE ADDENDUM PRELIMINARY FEASIBILITY STUDYFOR THE WQQDLAWN LANDFIT.T. BT/FS. CECIL COUNTY. MARYLAND

Given the results of the draft baseline risk assessment(BLRA), it appears that the need for remediation of surface andsubsurface soil at the transfer station is equivocal. Thisconclusion is based on several observations:1. For adults and children, the predicted elevated carcinogenic

risks associated with exposure to site-related contaminantsare 1.1 X 10"5 and 3.5 X 10~5, respectively. Although theserisks exceed the carcinogenic risk benchmark of 10~% byapproximately one order of magnitude, the calculated valuesfall within the target risk range of 10~6 to 10"*.

2. A portion of the calculated carcinogenic risk for thetransfer station is attributed to dermal contact withcontaminants in soil. However, recent EPA guidanceindicates that, with very few exceptions, exposure tocontaminants in soil should not be assessed quantitativelydue to the inherent uncertainty associated with suchestimates. (For details, please refer to comments providedfor the draft BLRA.) Revision of the BLRA to reflectcurrent EPA guidance should reduce risk levels associatedwith the site.

3. Approximately 45 percent of the calculated carcinogenic riskrelated to exposure to surface soil at the transfer stationis due to beryllium. However, background soil levels ofberyllium in Cecil County exceed the average berylliumlevels observed at the site.

4. For child trespassers at the transfer station, the BLRAincorporates an exposure frequency that is approximatelythree times greater than the frequency used in the BLRA forthe rest of the site. Unless this increased frequency canbe supported, the estimated risk for the transfer stationshould decline.

5. with regard to noncarcinogenic endpoints, lead at thetransfer station contributes approximately 62 percent to thetotal hazard associated with exposure to surface soil.However, the methodology employed in the BLRA to derive ahazard quotient for lead is inappropriate. (For details,please refer to comments provided for the draft BLRA.)Reevaluation of lead exposure at the site should serve toreduce the hazard index to a value less than unity.

6. Also with regard to lead, the highest level detected insurface soil at the transfer station is 86.1 mg/kg. Thisconcentration is considerably less than the remediationrange of 500 - 1000 mg/kg currently recommended for lead insoil.

QR306068

STATE COMMENTSBASELINE RISK ASSESSMENT(BLRA)/PRELIMINARY FEASIBILITY STUDYfFSl

SEPTIC SYSTEM DRAIN FIELD INVESTIGATIONWOODLAWN TRANSFER STATIONCECIL COUNTY. MARYLAND

APRIL 1992

GENERAL COMMENT

The combined cancer risks for children (3.5 x 10~s) and adults (l.ix 10~5), with respect to drain-field soils, are within the EPA's"target risk range". This point is clearly noted in the subjectdocument on page ES-1. Sites which fall within this "target riskrange" may be potentially subject to remediation depending on otherfactors such as site use, conditions at the site, location of thesite and the demographics of the area surrounding the site. Withthis in mind the Department questions the wisdom of preparing an FSfor the subject area until the BLRA and other issues mentionedabove have been fully evaluated. EPA's Guidance for ConductingRemedial Investigations and Feasibility studies Under CERCLAclearly indicates that if the BLRA indicates that the site poseslittle or no threat to human health or the environment, the FSshould be either scaled down as appropriate to that site and itspotential hazards, or eliminated altogether.

The Department wishes to note that there is a considerable amountof uncertainty associated with some of the assumptions used in theBLRA. The cumulative effect of these assumptions will tend tosignificantly over-state the potential risks to human health andthe environment. For example the Department presents thefollowing:

1) The BLRA attributes 68% of the excess cancer risk tochildren to the dermal absorption of contaminants.Approximately 43% of this risk is due to the potential dermalabsorption of Be. However, the toxicological profile for Be(ATSDR 1992) states that "it is unlikely that Be is absorbedthrough intact skin". It should also be noted that the excesscancer risk for background Be in Cecil County (as defined inthe subject BLRA) is 3.6X10' which is higher than the totalexcess cancer risk to children at the subject site.

2) The exposure frequency for children was conservativelyestimated at 117 days/year. This was a three-fold increaseover the estimated exposure frequency used in the IT BLRA forthe general site. The Department believes that thisassumption is unreasonably conservative for the subject area.

3) The hazard index, as presented in the report exceeds unitywith respect to children. However, the following should benoted:

a. The hazard index for lead in the subject soils hasbeen calculated to be 0.8. This is the major componentof the combined hazard index of 1.3 as calculated for a

RR306Q69

child/trespasser. The assumptions in the BLRA indicatethat 0.6 of the hazard index for lead is derived fromdermal absorption. It should be noted that many studiesof environmental Pb exposure on children have beenconducted. These studies have indicated that the mostsignificant route of exposure for children is throughingestion, with the secondary pathway being inhalation.Dermal absorption of lead in soil has never beenidentified as a significant exposure pathway.

2. EPA guidance for the computation of the hazard indexdictates that individual hazard indices be combined onlyfor contaminants that have similar health effectsendpoints (i.e., affect the same target organ). Thesubject BLRA appears to have disregarded this guidance.

The foregoing examples demonstrates the BLRA's tendency tooverstate the potential hazards posed by the site.

SPECIFIC COMMENTSBase Line Risk Assessment

Page / §

2-2 /2.1.2-2The discussion of the current system, specifically designed toproperly handle the waste compaction fluids, is inappropriateand should be deleted from the document. The "former" septicsystem and its potential impact on the site was the focus ofthe sub-RI and should be the focus of the unit specific BLRA.

3-12 /3.1.6-2When considering the public health it is appropriate to beconservative. However, as discussed in the general commentabove, the Department believes that some of the assumptionsapplied to this study unnecessarily accentuate the sitespecific risks.

SPECIFIC COMMENTSPreliminary Feasibility Study

The Department reserves comment on this document until the BLRA hasbeen reviewed by the EPA. Pending discussions with the EPAregarding the BLRA and site specific criteria, the scope of or theneed for a feasibility study for this area will be determined.

AR306070

APPENDIX A

GLOSSARY OF DATA QUALIFIER CODES

CODES RELATED TO IDENTIFICATION(Confidence concerning presence or absence of analytes):

U = Not detected. The associated number indicates the approximate sampleconcentration necessary to be detected.

(NO CODE) Confirmed identification.

B = Not detected substantially above the level reported in laboratory or field blanks.

R = Unreliable result. Analyte may or may not be present in the sample. Supportingdata necessary to confirm result.

N = Tentative identification. Consider present. Special methods may be needed toconfirm its presence or absence in future sampling effoils.

. RP.T.ATKD TO OUANnTATlQN(Can be used for both positive results and sample quantitation limits):

J = Analyte present Reported value may not be accurate or precise.

K = Analyte present. Reported value may be biased high. Actual value is expectedto be lower.

L = Analyte present. Reported value may be biased low. Actual value is expectedto be higher.

[ ] = Analyte present As values approach the IDL the quantitation may not beaccurate.

UJ = Not detected, quantitation limit may be inaccurate or imprecise.

UL = Not detected, quantitation limit may be higher.

OTHER CODES

Q = No analytical results.

HR3Q607I

SPLIT SAMPLE RESULTS/EM SEPTIC SYSTEM INVESTIGATION

TABLE 1IMTER SAMPLES

VOLATILES ANALYTICAL RESULTS 0/g/L)12/5/92

UOGOLAUN LANDFILL SITECASE NO.: 17S21

CXDL

10

10

10

10

10

10

10

10

10

10

10

10

10

10

10

10101010

10

101010

10101010

10

1010

10

10

10

Compound

ChloronwthaneBronooethaneVinyl Chloride*Chloroethane

Methylene Chloride*

Acetone

Carbon Oisulf ide1,1-Oichloroethene*1,1-Dfchloroethane

Total 1,2-Dichloroechene

Chloroform1,2-Dichloroethane*2-Butanone*

1,1,1-Triehloroethane*Carbon Tetrachloride*Broiwdichloroe thane

1,2-Diehloropropane*Cis-1(3-DichloropropeneTrichloroetheneDibranchloraMthane1 , 1 ,2-Trf chlorocthaneBenzene*Trans- 1 ,3-0 i ch loropropeneBroanfom4-M«thyl-2-p«ntanone2-Hexanooe

Tetrach loroethene*

1,1,2,2-TetrachloroethaneToluene*Chlorobtnzene*Ethylbenzene*Styrane*

Total Xyltncs*

CCB84 (RB) CC889 (TB)—

—

—

UJ UJ

2 J 3 J

16 J 16 J—

—

—

—

—

—

UJ UJ————UJ UJ——————UJ UJ

UJ UJ—UJ UJ——

UJ 5 J—

3 J

•Action Level Exists

/5R306072

SPLIT SAMPLE RESULTS/ERM SEPTIC SYSTEM INVESTIGATION

TABLE 2SOIL SAMPLES

VOLATILES ANALYTICAL RESULTS 0/fl/kfl)12/5/91

UOODLAUN LANDFILL SITECASE NO.: 17521

CRQL

10

10

10

10

10

10

10

10

10

10

10

10

10

10

10

10

1010

10

10

10

1010

1010

101010

10

1010

10

10

Coapound

Chloromethane

BromomethaneVinyl ChlorideChloroethaneMethylene Chloride

Acetone

Carbon Oisulfide1,1-Dichloroethene1,1-Di chloroethaneTotal 1,2-Oichloroethene

Chlorofon*

1,2-Oichloroethane2-Butanone

1 . 1 . 1 -Tri ch loroethaneCarbon Tetrachloride

Bromodich loroethane

1,2-DichloropropaneCis-1 ,3-0 ich loropropene

TrichloroetheneD i bromoch 1 oraaethane1.1,2-Tr ich loroethaneBenzeneTrartc-1,3-DichloropropeneBromofoni4-Hethyl-2-pentanone2-HexanoneTet rach I oroethene1,1,2,2-TetrachloroethaneTolueneChlorobenzeneEthylbenzeneStyrene

Total Xylenes

RE RE RECCS82 CCB83 <TM5 CCB86 CCB87 CCB88(SS-1) (SS-2) (TS85-2) (TS85-3) (TS85-4) (TS86-4)

UJ UJ UJ UJ

18 B 10 B 38 B 75 B 13 B 43 B

11 B 100 B 78 B 170 B 65 B SB

4 J

74 B 23 B 18 B 10 B

UJ

UJ

UJ 12 B UJ 7 B

UJ

UJ 81 100 6 J

UJUJ 45 B 220 7 B

UJ

UJ 380 1400 29 4 B

RE - Reanalyzed AR306073

SPLIT SAMPLE RESULTS/DM SEPTIC SYSTEM INVESTIGATION

TABLE 3SOIL SAMPLES

BNAS ANALYTICAL RESULTS12/5/91

UDODLAUN LANDFILL SITECASE NO.: 17521

CC882 CC883 CC88S CCB87 CCB87CRQL__________Coapound__________(SS-1) (SS-2) (TSBS-2) (TSBS-4) (TS86-4)

330 Phenol

330 2-Chlorophenol330 1,3-Oichlorobenzene

330 1,4-Dichlorobenzene

330 1,2-Dichlorobenzene330 2-Methylphenol330 2,2-Oxybis(1-chloropropane)330 4-Hethylphenol330 H-Nitroso-di-n-propyla«ine330 Hexachlorothane

330 Nitrobenzene330 Isophorone

330 2-Hitrophenol330 2,4-Dia*thylphenol330 bis(2-Chloroethoxy)inethane330 2,4-Oichlorophenol

330 1,2,4-Trichlorobenzene330 Naphthalene 580 J 23 J330 4-Chloroaniline

330 Hexachlorobutadiene330 4-Chloro-3-»ethylphenol

330 2-Methylnaphthalene

330 Hexachlorocyclopentadient330 2,4,6-Trichlorophenol 700 J 24 J800 2,4,5-Trichlorophenol330 2-Chloronaphthalene800 2-Nitroaniline

330 Dimethylphthalate330 Acenaphthylene330 2,6-Dinitrotoluene800 3-Nitroaniline UJ UJ UJ UJ UJ330 Acenaphthene

800 2,4-Dinitrophenol UJ UJ UJ UJ UJ

flR30607l*

SPLIT SAMPLE RESULTS/ERN SEPTIC SYSTEM INVESTIGATION

TABLE 4SOIL SAMPLES

BNAS ANALYTICAL RESULTS <pg/kg)12/5/91

UOODLAUN LANDFILL SITECASE NO.: 17521{Continued)

CRQL

800

330

330

330

330

330

800

800

330

330

Compound

4-Nitrophenol

Oibenzofuran2,4-DinitrotolueneDiethylphthalate4-Chlorophenyl-phenyl etherFluorene

4-Nitroaniline4.6-Dinitro-2-nethylphenolPhenanthrenebis(2-ethylhexyl)phthalate

CCB82 uA&S CCB85 CUJ87 CC887(SS-1) (SS-2) (TS85-2) (TS85-4) (TS86-4)

UJ UJ UJ UJ UJ

23 J

410 B 940 B 5,100 B 440 B 190 B

ftR3Q6075

SPILT SAMPLE RESULTS/ERM SEPTIC SYS1EM INVESTIGATION

TABLE 5SOIL SAMPLES

PESTICIDES/AROCLORS ANALYTICAL RESULTS O/fl/kg)12/5/91

UOOOUUM LANDFILL SITECASE NO.: 17521

CRQL

1.71.7

1.7

1.7

1.7

1.7

1.7

1.7

3.3

3.3

3.3

3.3

3.33.3

3.3

17

3.3

3.3

1.71.7

170

33

67

33

3333

33

33

Coapound

alpha-BHCbeta-BHC

delta-BHC

gamma-BHC (Lindane)

HeptachlorAldrinHeptachlor epoxide

Endosulfan I

Dieldrin4,4'-OOE

Endrin

Endosulfan II ,4,4'-DOO

Endosulfan sulfate4,4' -DOT

Hethoxychlor

Endrin fcetone

Endrin aldehyde

alpha-ChlordanegaMM-Ch lordane

ToxapheneAroclor-1016

Aroclor-1221Aroclor-1232Aroclor-1242Aroc lor- 1248Aroclor-1254

Aroclor-1260

CC882<SS-1)

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

430 J

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

1,200 J*1,300 J*

UJUJ

UJ

UJ

UJ

UJ

UJ

UJ

CCS83(SS-2)

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

90 J

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

240 J*

240 J*

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

CCUS CCB87 CCB88(TSBS-2) (TS85-4) (TSB 6-4)

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

92 J

UJ

UJ

57 J

UJ

UJ

UJ

UJ

UJ

2,200 J*370 J*

UJUJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

2.3 J

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

9.4 J

11 J

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

220 J280 J

UJ

UJ

UJ

UJ

UJ

UJ

UJ

UJ

* * 100 x Dilution value for CCB82* * 50 x Dilution value for CCB83, CCB8S

HR306076

SPLIT SAMPLE RESULTS/ERM SEPTIC SYSTEM INVESTIGATION

TABLE 6SOIL SAMPLES

INORGANIC ANALYTICAL RESULTS1Z/5/91

UOODLAUN LANDFILL SITECASE HO.: 17587

CRDl

40

12

2

40

1

1

1000

2

10

5

20

0.6

10003

0.2

8

1000

12

1000

2

10

4

2

Compound

Aluminum

AntimonyArsenic*

Barium

Beryllium

Cadmium*

CalciumChromium*

Cobalt

Copper

Iron

Lead*

Magnesium

Manganese

Mercury

Nickel*PotassiumSelenium

SilverSodium

ThalliumVanadium

ZincCyanide*

MCBB06 (SS1)

10,100

22.7 L

16.2 L

81.0

tO.50]

1.7 B

2,350

32.9

C7.4]

46.4 J

20,200

129

1,680

231

3.9

16.1

[581]...

(1.2 1 B

[67.9]...

25.0

235 J

Q

MCBB07 CSS2)

8,680

16.1 B

18.8 L

63.5

C0.49]

[0.77] B

[533]

21.6

C5.0J

39.0 J

14,300

SS.O

[957]

62.2

1.8

10.9

(4 06]...

[0.8] B.

[42.23 B...

21.4

115 J

Q

•Action Level Exists

AR306077