26
UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 841 Chestnut Building - Philadelphia, Pennsytvania 19107 Office ofSupetfund Direct Dial (215) 597-8257 SE Pennsylvania Remedial Section Mafl Code 3HW21 Re: 3b, 3d May 25, 1993 FEDERAL EXPRESS Mr. Mark Travers, Designated Project Coordinator deMaximis, Inc. 2045 Lincoln Highway Number 308 St. Charles, IL 60174 SUBJECT: Novak Sanitary Landfill Final RI/FS Approval Dear Mr. Travers, By letter dated February 11, 1993, EPA stated that your final Remedial Investigation and Feasibility Study report ("RI/FS") submittal, dated January 28, 1993, was approved on the condition that certain itemized revisions were made. EPA has subsequently reviewed all of the relevant tables in the RI/FS and inserted corrected tables where necessary. EPA approves the final RI/FS submitted under cover letter dated January 28, 1993 with the following modifications: 1. Table 1-4A as corrected by EPA (see Attachment A). 2. Table 2-58A as corrected by EPA (see Attachment A). 3. Contents of Geraghty and Miller's letter dated April 26, 1993 containing "TABLES (Continued)" and Figure A-l. 4. Contents of deMaximis letter dated May 4, 1993 containing sections of Appendix H. 5. Tables 5-7, 5-8, 5-9, 5-11, 5-16, 5-17 & 5-18, which were missing in the final RI dated January 21, 1993, but were contained in the June 1992 draft version. The modified RI/FS is approved pursuant to Section VIII.G of the Administrative Order by Consent, Docket No. III-89-10-DC, ("Consent Order"). RR308375

UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

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Page 1: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

UMTED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III

841 Chestnut Building- Philadelphia, Pennsytvania 19107

Office of Supetfund Direct Dial (215) 597-8257SE Pennsylvania Remedial Section Mafl Code 3HW21

Re: 3b, 3d

May 25, 1993

FEDERAL EXPRESSMr. Mark Travers, Designated Project CoordinatordeMaximis, Inc.2045 Lincoln HighwayNumber 308St. Charles, IL 60174

SUBJECT: Novak Sanitary LandfillFinal RI/FS Approval

Dear Mr. Travers,

By letter dated February 11, 1993, EPA stated that yourfinal Remedial Investigation and Feasibility Study report("RI/FS") submittal, dated January 28, 1993, was approved on thecondition that certain itemized revisions were made. EPA hassubsequently reviewed all of the relevant tables in the RI/FS andinserted corrected tables where necessary. EPA approves thefinal RI/FS submitted under cover letter dated January 28, 1993with the following modifications:

1. Table 1-4A as corrected by EPA (see Attachment A).

2. Table 2-58A as corrected by EPA (see Attachment A).

3. Contents of Geraghty and Miller's letter dated April 26,1993 containing "TABLES (Continued)" and Figure A-l.

4. Contents of deMaximis letter dated May 4, 1993 containingsections of Appendix H.

5. Tables 5-7, 5-8, 5-9, 5-11, 5-16, 5-17 & 5-18, which weremissing in the final RI dated January 21, 1993, but werecontained in the June 1992 draft version.

The modified RI/FS is approved pursuant to Section VIII.G ofthe Administrative Order by Consent, Docket No. III-89-10-DC,("Consent Order").

RR308375

Page 2: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

Mr. Mark Travers 2 May 25, 1993

The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller'sletter dated April 26, 1993.

Rationale for Correction of Table 2-58A

1. Your facsimile dated April 30, 1993 (Attachment B) did notjustify using "Preliminary Remediation Goals ("PRGs") forTarget Risk (a)n values when Proposed MCLs or Non-Zero MCLGswere available.

2. Your facsimile overlooked page 1 of the same guidance(Attachment C) , OSWER Directive 9285.7-01B, which cites thefollowing:

"The recommended approach for developing remediation goalsis to identify PRGs at scoping, modify them as needed at theend of the RI or during the FS based on site-specificinformation from the baseline risk assessment, andultimately select remediation levels in the Record ofDecision (ROD) ..."

3. Pages 2-19 and 2-20 of the January 21, 1993 final FS citesthat you must follow the "Decision Tree" on Figure 2-1(Attachment D) in obtaining the values for Table 2-53.

Based on the above1 rationale, EPA has revised your submittedTable 2-53 (Attachment E) to reflect values that EPA deemsappropriate. We are also revising the chemical chart to reflectthe newer MCLs that were effective since July 17, 1992. Thevalues obtained for Risk Based Calculations ("RBCs") are asdemonstrated in Attachment F using Acetone as a typical example.

Rationale for Correction of Table 1-4A

1. A November 3, 1992 draft FS (Attachment G) has been includedto show the accurate values.Since the above issues do not require resubmittal by

deMaximis, no further response is necessary. Please call if youhave any questions.

AR308376

Page 3: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

Mr. Hark Travers 3 May 25, 1993

Sincerely,

Cesar Lee (3HW21)Remedial Project Manager

Attachments

cc: P. Anderson (3HW21)R. Smith (3HW13)R. Davis (3HW13)J. Newbaker (3HW13)E. Lukens (3RC21)C.K. Lee (3HW51)P. Flores (3AT11)M. Heffron, DynamicM. Mustard, PADERD. Henne, DOIA. Conte, USDIK. Erickson, NOAA

CL:EL:PA:cl/052593.NOV

Page 4: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

ATTACHMENT "A"

AR308378

Page 5: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

Revision No. 04 to July 1992 FS ReportMay 24,1993

Table 1-4A. Potential Federal Chemical-Specific To-Be-Considered Criteria for Remediation, if Necessary, atthe Novak Sanitary Landfill (Phase V National Primary Drinking Water Regulations)

PHASE VNPDWR PHASE VNPDWRTBC CRITERIA (ug/L) TBC CRITERIA (ug/L)

Chemical Name (PENDING MCL) (PENDING MCLG)

Adipates 400 400piethylhexyl)adipate]Dalapon 200 200Dichloromethane 5 0 (a)Dinoseb 7 7Diquat 20 20Endothall 100 100Endrin 2 2Glyphosate 700 700Hexachlorobenzene 1 0 (a)Hexachlorocyclopentadiene SO 50Oxamyi (Vydate) 200 200PAHs (Benzo(a)pyrene] 0.2 0 (a)Phthalates 6 0 (a)[Di(ethylhexyl)phthalate]Piclorara 500 500Simazine 4 41,2,4-Trichlorobenzene 70 701,1,2-frichlorethane 5 323,73-TCDD 3x10* 0 (a)

Inorganics

Antimony 6 6Beryllium 4 4Cyanide 200 200Nickel 100 100Sulfate Deferred DeferredThallium____________________2_______________________0£_________

(a) Maximum Contaminant Level Goals of zero are not be considered relevant and appropriate.

Note: These Phase V NPDWR Final Rule was published on July 17,1992. These NPDWR wfll become effectiveJanuary 17,1994. Therefore, these NPDWRs are potentially relevant and appropriate requirements untilthe effective date, January 17, 1994 has passed. After that date these NPDWRs may be relevant andappropriate requirements.

AR308379

Page 6: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

Table 2-58A. Summary of Preliminary Remediation Goals for Ground Water, NovakSanitary Landfill, South Whitehall Township, Pennsylvania

Constituent PreliminaryRemediationGoal (ug/1)

Source

Volatile Organic Compounds:

AcetoneBenzeneChlorobenzeneChloroethane1,1-Dichloroethylene1,2-Dichloroethane1,2-Dichloropropanetrans-l,3-DichloropropyleneEthylbenzeneMethylene Chloride4-Methyl-2-PentanoneStyreneTetrachloroethylene

Toluene1,1,1-Trichloroethane

TrichloroethyleneVinyl ChlorideXylene(s) total

3,2005100NE755

0.0347005.4NE1005

1,000200

52

10,000

RBCSD WA MCL; PADER WSCPADER WSC

SDWA MCL; PADER WSCSDWA MCL; PADER WSCPhase II NPDWRPRG for Target Risk (a)Phase H NPDWRRBC

Phase H NPDWRPhase H NPDWR; PADERWSCPhase II NPDWRSDWA MCL; SDWA Non-Zero MCLG; PADER WSCSDWA MCL; PADER WSCSDWA MCL; PADER WSCPhase H NPDWR

Semi-Volatile Oreanic Comtxmnds:

1,2-Dichlorobenzene 600 PADERWSC

1,3-Dichlorobenzene 600 PADER WSC1,4-Dicnlorobenzene 75 PADER WSCDiethylphthalate 29,000 RBCDi-N-butylphthalate 3,700 RBCBis(2-ethylhexyl)phthalate 0.43 PRG for Target Risk (a)4-Methylphenol 180 RBCNaphthalene 1,500 RBC1,2,4-Trichlorobenzene 70 SDWA MCL & Non-Zero

MCLG

ftR308380

Page 7: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

Table 2-58A(Cont). Summary of Preliminary Remediation Goals for Ground Water, NovakSanitary Landfill, South Whitehall Township, Pennsylvania

Constituent Preliminary SourceRemediation

______________________ Goal (ugA)_________________Metals and Inorganics:

Aluminum NEAntimony 6 SDWA MCL & Non-Zero

MOjGArsenic 50 SDWA MCL; PADER WSCBarium 1,000 SDWA MCL; PADER WSCBeryllium 4 SDWA MCL(p)Cadmium 5 Phase n NPDWR; SDWA

Non-Zero MCLGCalcium NEChromium 50 SDWA MCL, PADER WSCCobalt NECopper 1,300 SDWA Non-Zero MCLG(1)Iron NELead 15 SDWA MCL; PADER WSCMagnesium NEManganese 200Mercury 2 SDWA MCL; SDWA Non-

Zero MCLG; Phase HNPDWR; PADER WSC

Nickel 100 PADER WSCPotassium NESelenium 10 SDWA MCL, PADER WSCSilver 50 SDWA MCL, PADER WSCSodium . NEThallium 2 SDWA MCLVanadium 260 RBCZinc 11,000 RBCCyanide 200 PADER WSC________

lA0UOS&.11iL/NUVAJUM6I (f) • ftofotea V) • UHfa I

(a) A risk-based preliminary remedial goal was selected as the Preliminary Remedial Goal(PRG) for this constituent because an ARAR-based preliminary remedial goal (i.e., SDWAMCL, PADER WSC, etc.) was not established for the constituent at the time the FS Reportwas submitted to the USEPA (Jury 8,1992). A constituent concentration corresponding toa target risk point of departure of 1x10* was utilized for establishing the PRG. Constituentconcentrations corresponding to various target risks protective of human health are providedin Tables 2-5 through 2-38.

NE - ARAR remedial goals and health-based remedial goals are not established.flR30838f

Page 8: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

\J

ATTACHMENT "B"

AR308382

Page 9: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

04-30-1993 10: 24AM FROM de maximis CHICAGO TO 12155979890 P. 01

de maximis, inc.2045 Uncoln Highway

_. _ 5ufte308St. Charles, Dlinoie 60174(708)879-3919

{708)879-0830 facsimile

FACSIMILE COVER SHEET

DATE:,

, FILE#:_Sod9

TO: "-- '

ORGANIZATION:

FACSIMILE*: /PAGES: > fittdadbit this cover aart\

FROM:

ORGANIZATION: _

f /eaje <&//ver this facsimile immediately. If you have difficulty with this transmission, please call (70S)87P'39l9

NOTES: " ~~ —————— " ————

CONFIDENTIALITY NOTICE "ni***uagtlfliuenJt<to>ifyforilMiueifanMMAut(V to whom tt Is cddivsud, may coiaaiit Womatten fat Is priviltgtdmd/or eortfltttntlat. Jftkt rtatttr qfthls mtaage It not Kit tatexdid ncipttnt or tht mpbyte or aytnt mperuibltfor delivering themutagt la Hit intended rtelpttitt. you an ktarby notified that ay dUstmtnatton, distribution, or ct&ytog «f Ms eetaHaatieeOon Itttrlctfy pnhtbittd. if you hne rtatvtd Oils communication la trror. pitta* notify to Hnmtdiattty at (703)979-3919 end ntura Atoriginal mtaaft to At edJrfjxabmt. Thank You

AR308383

Page 10: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

J4-30-1993 10'24fiM FROM de max mis CHICAGO TO 12155979890 P.02*»

'"' (RECEIVED JAN 1 3 1392

gfi 13)961

SOUO WATTf ANO CMtnSlNCV AMf ONSI

OSM2R DiTQOtiV* 9283.7-013

T0, W»to H««g«.nt Divi-ion Director.

, , r w d i nBamediation Goml»" Joj*. "JS-S.study <8 B*lin« Hit* A««««nent,

proctit.RR30838U

Page 11: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

<34-30-1993 10:25flM FRQM deT0 12155979890 P.03

8712-8715 for using ARARs as PRGs; see also (FWQO are common ARARs (and, therefore,53F«fe«i//feji«*r.,31394);and , potential PRGs) for ground water. Other types of

laws, such as state anti-degradation laws, may be• CERCLA Compliance Manuals (EPA 1988a PRGs if they are accompanied by allowable

and 1989a). concentrations of a chemical (Although stateanti-degradation laws that are expressed as

2.4.1 CHEMICAL-, LOCATION-, AND qualitative standards may also be potentialACTION-SPECIFIC ARARs ARARs, they generally would not be considered

PROs.)The Agency has identified three general types

of federal and state ARARs: As detailed in the NCP (see next box), the firststep in identifying ground-water PRGs is to

• chemical-specific, are usually health- or risk determine whether the ground water is a currentmanagement-based numbers or methodologies or potential source of drinking water. If thethat, when applied to site-specific conditions, aquifer is a potential source of drinking water,result in the establishment of numerical values then potential ARARs generally will include the(e.g., chemical-spedfic concentrations in a federal non-zero MCLG, MCL, or state drinkinggiven medium); water standard, and the most stringent (i.e., the

lowest concentration) is identified as the mostt location-specific, are restrictions placed upon likely ARAR-based PRO.

the concentration of hazardous substances orthe conduct of activities solely because theyare in special locations (e.g., wetlands); and

• action-specific, are usually technology- oractivity-baaed requirements or limitations onactions taken with respect to hazardous wastes.

This guidance primarily addresses only chemical-specific ARARs since it focuses on theidentification of chemical-spedfic concentrationsthat represent target goals (e.g., PROs) for a givenmedium. necemry to address environmental concerns or

SELECTION OF THE MOST UKELY «Do«r far other btacGclal UK»; ...).-ARAR-BASED PRO FOR EACHCHEMICAL

NCP ON GROUND-WATER GOALS(NCP Preamble;

55 Fetttn! Register 8717, March 8,1990)

"Ground water that fe not currently a drinkingwater source but b potentially a drinking watersource in the future would De protected to levelsappropriate to tat use as a drinking water source.Ground water that b not an actual or potentialsource of drinking water may not requireremediation to a UP to Iff* level (except when

If the aquifer is not a potential source ofThis section briefly describes which, if any, of drinking water, then MCLs,MCLGs, state drinking

several potential ARAR value* for a given water requirements, or other health-based levelschemical Is generally selected as the most likely generally are not appropriate as PROs. Instead,ARAR-based PRO (and therefore the most likely environmental considerations (Le., effects onPRO at this point). Although the process for biological receptors) and prevention of plumeidentifying the most likely ARAR-based PRO Is expansion generally determine clean-up levels. Ifspecific to the medium, in general the process an aquifer that is cot a potential source ofdepends on two considerations: (1) the drinking water is connected to an aquifer that b aapplicability of the ARAR to the site; and (2) the drinking water source, it may be appropriate to usecomparative stringency of the standards being PROs to set clean-up goals for the point ofevaluated. The previously ctyed documents should interconnection.be carefully considered for specfflcrecommendations on identifying ARARs. For chemicals without MCLs, state standards,

or non-zero MCLOs, the FWQC may beGround Waur. SDWA maximum contaminant potentially relevant and appropriate for ground

levels (MCLa), non-zero MCLOs, state drinking water when that ground water discharges to surfacewater standards, and federal water quality criteria water that is used for Cshing or sncUfishing.

Page 12: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

ATTACHMENT "C"

Page 13: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

Publication 8285.7-01 BDecember 1991

Assessment Guidancefor Superfund:Volume I —

Human Health Evaluation Manual(Part B, Development ofRisk-based PreliminaryRemediation Goals)

Interim

Office of Emergency and Remedial ResponseU.S. Environmental Protection Agency

Washington, DC 20460

flft308387

Page 14: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

CHAPTER 1INTRODUCTION

The purpose of this guidance is to assist risk selection of remedial alternatives. Ideally, suchassessors, remedial project managers (RPMs), and goals, if achieved, should both comply withothers involved with risk assessment and decision- applicable or relevant and appropriatemaking at Comprehensive Environmental requirements (ARARs) and result in residual risksResponse, Compensation, and Liability Act that fully satisfy the National Oil and Hazardous(CERCLA) sites in developing preliminary Substances Pollution Contingency Plan (NCP)remediation goals (PRGs). This guidance is the requirements for the protection of human healthsecond part (Part B) in the series Risk Assessment and the environment By developing PRGs earlyGuidance for Superfitnd: Volume I — Human in the decision-making process (before the RI/FSHealth Evaluation Manual (RAGS/HHEM). and the baseline risk assessment are completed),

design staff may be able to streamline thePart A of this series (EPA 19S9d) assists in consideration of remedial alternatives.

defining and completing a site-specific baseline riskassessment; much of the information in Part A is Chemical-specific PRGs are concentrationnecessary background for Part B. Part B provides goals for individual chemicals for specific mediumguidance on using U.S. Environmental Protection and land use combinations at CERCLA sites.Agency (EPA) toxicity values and exposure There are two general sources of chemical-specificinformation to derive risk-based PRGs. Initially PRGs: (1) concentrations based on ARARs anddeveloped at the scoping phase using readily (2) concentrations based on risk assessmentavailable information, risk-based PRGs generally ARARs include concentration limits set by otherare modified based on site-specific data gathered environmental regulations (e.g., non-zero maximum \ Jduring the remedial investigation/feasibility study contaminant level goals [MCLGs] set under the(RI/FS). Part C of this series (EPA 1991d) assists Safe Drinking Water Act [SOWA]). The secondRPMs, site engineers, risk assessors, and others in source for PRGs, and the focus of this document,using risk information both to evaluate remedial is risk assessment or risk-based calculations thatalternatives during the FS and to evaluate the set concentration limits using carcinogenic and/orselected remedial alternative during and after its noncarcinogenic toxicity values under specificimplementation. Exhibit 1-1 illustrates how the exposure conditions.three parts of RAGS/HHEM are all used duringthe RI/FS and other stages of the site remediation 1.2 SCOPE OF PART Bprocess.

•\/ The recommended approach for developingThe remainder of this introduction addresses V< remediation goals is to identify PRGs at scoping,

the definition of PRGs, the scope of Part B, the notify them as needed at the end of the RI orstatutes, regulations, and guidance relevant to during tne pg bascd on site-specific informationPRGs. steps in identifying and modifying PRGs, from e baseline risk assessment, and ultimatelythe communication and documentation of PRGs, 5 ^ remediation levels in the Record of Decisionand the organization of the remainder of this (ROD). In order to set chemical-specific PRGs indocument a site-specific context, however, assessors must

answer fundamental questions about the site.1.1 DEFINITION OF Information on the chemicals that are present

PRELIMINARY onsite, the specific contaminated media, land-useREMEDIATION GOALS " assumptions, and the exposure assumptions behind

pathways of individual exposure is necessary in

JSSSSXSSSSS

flR308388

Page 15: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

ATTACHMENT "D"

Page 16: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

Revision No. 01 to Vly 1992 FS ReportNovember 3,1992

o Whether environmental effects are adequately addressed.

o Whether the exposure analysis conducted as part of the baseline riskassessment adequately addresses each significant pathway of human exposure.

USEPA Guidance on Remedial Actions for Contaminated Ground Water atSuperfund Sites provides decision trees for selecting between ARAR-based and health-basedpreliminary remediation goals for carcinogens and non-carcinogens in ground water. This

|| guidance was utilized in developing the decision tree presented in Figure 2-1. This decisiontree includes a comparison of the final remedial goal for a given constituent with the

tf background concentration for that constituent This consideration has been made to ensurethat the preliminary remediation goals for the site are not less than naturally occurring or

M background concentrations. Since ground water was the only medium for which bothARAR-based and risk-based potential preliminary remediation goals were identified, a

• decision tree for selecting preliminary remediation goals was prepared only for the ground*water.

I2J.4.1 Preliminary Remediation Goals For Ground Water

Ground-water quality at the residential wells currently attains ARAR-basedH preliminary remediation goals for drinking water supplies and exhibits human health risks— below the respective remediation-based risk benchmarks for excess lifetime cancer risks andm non-carcinogenic health risks. Therefore, from a. potable water perspective, ground water

at the residential wells currently attains preliminary remediation goals and does not warrantremediation.

jemediation goals for the aquifer were determined using the logicresults of the evaluation, including the criteria which directed

III

Page 17: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

Revision No. 01 to July 1992 FS ReportNovember 3,1992

the selection of the preliminary remediation goals, are presented inCTable 2-S& In addition.x.^.^x' ^Table 2-59 presents the results of the evaluation with comideration given to 25 PA code

§264.90 (0 and 0) and 264.100 (a) (9). However, as stated previously, the PRP Group doesnot consider that 25 PA code §264.90 (i) and (j) and 264.100 (a) (9) are ARARs or thatthese regulations require all ground water to be remediated to background levels. Assuminghowever that this requirement continues to be considered an ARAR by the USEPA forpurposes of any ground water remediation (active or passive) at the site, the PRP Groupbelieves that this ARAR should be waived under Section 121 of CERCLA.

23.42 Preliminary Remediation Goals For On-Site Surface-Water

Since there are no ARAR-based preliminary remediation goals for on-site surface*waters and estimated health risks were below remediation-based risk benchmarks, there areno preliminary remediation goals established for on-site surface water at the NSLTherefore, evaluation of remedial alternatives for surface-water at the NSL will be directedby the general and site-specific remedial action objectives previously identified for surfacewater at the NSL

13.4.3 Preliminary Remediation Goals For Soils

Since there are no ARAR-based preliminary remediation goals for on-site soils andestimated health risks associated with on-site soils were below either remediation-based riskbenchmarks or estimated health risks associated with background soils, there are nopreliminary remediation goals established for soils at the NSL.

2-20

GERAGHTY^ MILLER. INC. AR30839I I

Page 18: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

QR ypRQPOSED) MCL? / ^X STATE STANDARD? /5 '

(M

II

I

I

1 iI

I

I

^ < STRINGENT STATE£^ X STANDARD?

5

' i

(START)i i j/ JS JHgggr jriNAL X N0 /"__IS_ THERE A X N°

YES

5 / IS THERE A MORE X YESH x eranus»rur crnre \_____

YP.TE5

STATE STANDARD ISTENTATIVE REMEDIAL

GOAL

THERE ARE NOARAR- BASED

REMEDIAL GOALS

MCL IS THE TENTATIVEREMEDIAL GOAL

MCLG IS THETENTATIVEREMEDIAL GOAL

IS THE CUMULATIVE X YES^*n^iliA/»Pfcti^ Ol tS X_________CARCINOGENIC RISKwtN»inwwtni\» ni n s-UNACCEPTABLE? /

3ACKCALCULATETENTATIVE GOALS FROMACCEPTABLE RISK

•x,

1IS THE HAZARDQUOTIENT FOR X YES TFNTATivr COALS

NON-CARCINOGENS >—*• e J I??rSSSrcFOR A GIVFN TARGET / FROM ACCEPTABLEORWN UNACCEPTABLE? '/ NON-CARC.NOCEN.C HAZARD

BACKCALCULATE

"9PAOER WSC. MCL'S OR MCLG'S ARE

( T E N T A T I V E REMEDIAL GOALS

V

SELECT LESSER OF ARAR- BASEDAND HEALTH-BASED TENTATIVE

REMEDIAL GOALSI _iI NO

§

i iNO / IS THE TENTATIVE X YES /CONCoSrSSfifiN IS\r——< REMEDIAL COAL LESS >——-———-4 CONS?55SJN IS )

X THAN BACKGROUND? / VREMEOtAL COAL/

II

( TENTATIVE GOAL IS AV. THE RNAL GOAL J

M

j» 1 GERAGHTYf AW & MILLER,. INC.

rnvirontrutUal 3*rvici*

DECISION TRS FORRSUHXAL GOALS FOR GROUND WATH!

NOVAX SANITARY LANDFILLSOUTH WWrTFWAl I T/tWNCWlO

,

OQo

Page 19: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

ATTACHMENT "E"

AR308393

Page 20: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

Table 2-58. Summary of Preliminary Remediation Goals for Ground Water, NovakSanitary Landfill, South Whitehall Township, Pennsylvania

Constituent PreliminaryRemediationGoal (ug/1)

Source

Volatile Organic Compounds:

Acetone 3,Zoo K K.6C.Benzene 5 SDWA MCL; PADER WSCChlorobenzene 100 PADER WSCChloroethane NE1,1-Dichloroethylene 7 SDWA MCL; PADER WSC1,2-Dichloroethane 5 SDWA MCL; PADER WSC1,2-Dichloropropane 5 Phase II NPDWRtrails-1,3-Dichloropropylene 0.034 PRG for Target Risk (a)Ethylbenzene 700 Phase II NPDWRMethylene Chloride £.ft ^4-Methyl-2-Pentanone NEStyrene 100 Phase II NPDWRTetrachloroethylene 5 Phase II NPDWR; PADER

WSCToluene 1,000 Phase II NPDWR1,1,1-Trichloroethane 200 SDWA MCL; SDWA Non-

Zero MCLG; PADER WSCTrichloroethylene 5 SDWA MCL; PADER WSCVinyl Chloride 2 SDWA MCL; PADER WSCXylene(s) total 10,000 Phase II NPDWR

Semi-Volatile Organic Compounds;

1,2-Dichlorobenzene 600 Phase II NPDWR; PADERWSC

1,3-Dichlorobenzene / 600 PADER WSC1,4-Dichlorobenzene/ 75 PADER WSC

Bis(2-etByffiS3)phthalate 0.43 PRG for Target Risk (a)4-MethylphenolNaphthalene1,2,4-Trichlorobenzene

GERAGHTY & MILLER. INC

4 308394

Page 21: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

Table 2-58 (Cont). Summary of Preliminary Remediation Goals for Ground Water, NovakSanitary Landfill, South Whitehall Township, Pennsylvania

Constituent

Metals and Inorganics:

AluminumAntimonyArsenicBariumBerylliumCadmium

CalciumChromiumCobaltCopperIronLeadMagnesiumManganeseMercury

NickelPotassiumSeleniumSilverSodiumThalliumVanadiumZincCyanide

TABL2-5S.TBUNOVAK.N46I

PreliminaryRemediationGoal (ug/1)

NE6 X50

1,000£|. OJ&Q£2

5

NE50NE,

l,3oo $<NE

15 *(^ NE

2oo }&£2

100NE1050NE

ZTtoff*****£<»£> $£.11/00^^5

200

CfV frof*

Source

Sp (AA, UCU4- WBe<b MCl€jSDWA MCL; PADER WSCSDWA MCL; PADER WSC£R8"foTTS?f8*=Bisk *£l>uM\ UPhase II NPDWR; SDWANon-Zero MCLG

SDWA MCL, PADER WSC

*&P(* KW-"2ew> |UlCL

SDWA MCL; PADER WSC

£t>lOA, Kic*"Zfefo M^LGrO)SDWA MCL; SDWA Non-Zero MCLG; Phase IINPDWR; PADER WSCPADER WSC

SDWA MCL, PADER WSCSDWA MCL, PADER WSC

$P^ MCL£6CKI5CPADER WSC

«i 00= ktkiCr r«juUloA

UCM>,

(a) A risk-based preliminary remedial goal was selected as the Preliminary Remedial Goal (PRO)for this constituent because an ARAR-based preliminary remedial goal (i.e., SDWA MCL,PADER WSC, etc.) was not established for the constituent at the time the FS Report wassubmitted to the USEPA (July 8,1992). A constituent concentration corresponding to a targetrisk point of departure of IxlO"6 was utilized for establishing the PRO. Constituentconcentrations corresponding to various target risks protective of human health are providedin Tables 2-5 through 2-38.

NE - ARAR remedial goals and health-based remedial goals are not established.GERAGHTY & MILLER. INC flR308395

Page 22: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

ATTACHMENT "F

4R308396

Page 23: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

f-fi

S

§. .» .§ .8 -8 -8 -8 -5 -| -2 .«.g .§ -2 .£ -S -8 -8 -8 -2 -2 -8 -8 -S -8. .8 -8 -2 -2 .§ -2 -2.8 .2 -2 . .». 1.1.«.§ .81 .* J .w. | » «.«* I.«,11 *.«.81 .1. I *.».« 8 5 T I .= « -.

8: ?*?«a.lli:3|l*931*?.-i135.4S*l?-oO

c* •*- -s g - -2 -2 ^ - -2 •

•K-

Page 24: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

ATTACHMENT "G"

Page 25: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

Table 1-4. Potential Federal Chemical-Specific To-Be-Considered Criteria for Remediation, if Necessary, at theNovak Sanitary Landfill (Phase V National Primary Drinking Water Regulations)

PHASE V NPDWR PHASE V NPDWRTBC CRITERIA (ug/L) TBC CRITERIA (ug/L)

Chemical Name_________(PENDING MCL)____________(PENDING MCLG) _____

Organic*

Adipates[Diethyihexyl)adipate]Dalapon 200 200Dichloromethane 5 0 (a)DinosebDiquai ./ €*ji«&-«SK 20 2O /£EndothaiJC 100 100Endrin 2 2Glyphosate • 700 700Hexachlorobenzene \.\QJ - ' ° (a)Hexachlorocyclopentadjfce 50, SOOxamyl (Vydate) 2*>O 5& 2.°O#£PAHs [Benzo(a)pyrene] 0.2 0 (a)Phthalates £ K ° («)[Di(ethylhexyi)phthalate]Pidoram ,. 500 .. 500Simazine T

ichlorobenzene To5s • • 3

) OJW005 0 (a)

Inorganics

AntimonyBerylliumCyanide ' 200 200Nickel 100 100Sulfate 400.000/500.000Thallium__________________>f 2____________________0-5

(a) Maximum Contaminant Level Goals of zero are not be considered relevant and appropriate.

ubl-4/navikab»

GERAGHTY & MILLER. INC. AR308399

Page 26: UMTED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III · The following are in reference to your resubmitted Tables 1-4 and 2-53 (Attachment A) as attached to Geraghty and Miller's

aRevision No. 01 to July 1992 FS Report

November 3. 1992

Table 1-4. Potential Federal Chemical-Specific To-Be-Considered Criteria for Remediation, if Necessary, atthe Novalc Sanitary Landfill (Phase V National Primary Drinking Water Regulations)

PHASE V NPDWR PHASE V NPDWRTBC CRITERIA (ug/L) TBC CRITERIA (ug/L)

Chemical Name______________(PENDING MCL)_______(PENDING MCLG)_____

Organics

Andipates 400 400[Diethylhexyl) adipate]Dalapoa 200 ' 200DichJoromethane 5 0 (a)Oiaoseb 7 . 7Diquat 20 20Endothall 100 100Endria 2 2Glyphosate 700 700Hexachlorobeazene 1 0 (a)Hexacalorocyclopeatadine 50 50 \*SOxamyl (Vydate) 200 200PAHs (Beazo(a)pyreneJ 0.2 0 (a)Phthalates(Di(ethylhe.xyl)phthalate) 6 0 (a)Picloram 500 500Siaaziae 4 41.2.4.Trichlorobenzene 70 701.1.2-Trichlorethane 5 313.'S-TCDD 3x10* 0 (a)

Inorganic?

Antimony 6 (>Bcr> Ilium 4 4Cvunidi 200 200Nickel 100 100Sdt'aic Deferred DeferredThallium____________________2_______________________0.5_________

• ji Maximum Contaminant Level Goals of zero ar; not r; considered relevant and appropriate.

Note: These Phase V NPDWR Final Rule was published on JuK 1" 1992. These NPDWR will become effectiveJanuary 17.1994. Therefore, these NPDWRs arc poier.ti.illy relevant and appropriate requirements until theeffective date, January 17,1994 has passed. After that dits these NPDWRs may be relevant and appropris"*requirements.