final feasibility study report - superfund records … · · 2018-03-27table 1 response to epa...

ONE POINTE DRIVE, SUITE 320, BREA, CALIFORNIA 92821T: (714) 388-1802 F: (714) 388-1839 www.projectnavigator.com

June 13, 2008

Project No. 03-115

Mr. C. David AbshireRemedial Project ManagerU.S. Environmental Protection Agency, Region 61445 Ross AvenueDallas, Texas 75202-2733

VIA FEDERAL EXPRESS

TransmittalFinal Feasibility Study Report

Malone Service Company Superfund Site

Dear Mr. Abshire:

Enclosed please find three copies of the Final Feasibility Study Report for the Malone ServiceCompany Superfund Site located in Texas City, Texas. This document has been prepared asspecified in the Statement of Work (SOW) of Administrative Order on Consent No. 06-18-03.

The Final Feasibility Study Report has addressed and incorporated agency comments received onMay 14, 2008. Responses to the agency comments are summarized on Table 1, attached.

Please call or e-mail me with any questions or comments.

Very Truly Yours,

Roberto PugaMalone Cooperating Parties Project Coordinator

Enclosures (3)

cc: Fay Duke, TCEQMCP Technical Committee Members

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Table 1

Response to EPA Comments on Draft Final Feasibility Study

Malone Service Company Superfund Site (TXD980864789)

Texas City, Galveston County, Texas

1 6/12/08

Comment

No.Section Comment Response/ Notes

General Subject Area: Human Health Risk

EPA GeneralComment 1

On 6 March 2008, EPA, the Texas Commission on Environmental Quality (TCEQ), the Site Trustees, and EA participated in ateleconference with MCP representatives to discuss the “Draft Response to EPA Comments on the Draft FS Report.” Participating SiteTrustees included TCEQ, National Oceanic and Atmospheric Administration (NOAA), U.S. Fish & Wildlife Service (USFWS), TexasParks & Wildlife Department (TPWD), and Texas General Land Office (TGLO). During the teleconference, MCP reported that it hasobtained full control over the MSC property and intends to establish its future use as a land conservancy. This will provide MCP withcontrol over future land use and institutional controls. Up until June 2007, the property was owned by an investment group that wantedindustrial future land use.

In response to an inquiry regarding how future use as a nature conservancy would impact remedial action objectives (RAOs),preliminary remedial goals (PRGs), or volumes subject to remediation based on recreational rather than future industrial/commercial re-use, MCP responded that there would be no changes to the RAOs, PRGs, or volumes subject to remediation; however, upon review ofthe Draft Final FS Report, it appears that all three (i.e., RAOs, PRGs, and volumes subject to remediation) were revised. The change insoil volumes is unsubstantiated; a rationale for the surface area and depth increases/decreases and soil volumes subject to remediationshould have been presented. However, due to a conservancy most probably using the property as a temporary research area or otheractivities (e.g., greatest elevation in the salt water marsh area), the classification must remain industrial/commercial.

During the meeting on May 14, 2008 among EPA, TCEQ, the NR Trustees, and MCPrepresentatives, the parties agreed to a compromise position regarding the appropriate humanheath receptor for the Site. Although the MCP believes that the most appropriate human healthreceptor for the Site is the recreational bird watcher, the MCP will use a higher exposurefrequency to calculate PRGs to recognize that the Site may have higher usage for volunteerworkers when it is under the control of the nature conservancy. The PRGs have been recalculatedusing 150 days per year for exposure frequency instead of the 15 days per year used to calculaterisk in the BHHRA. These final PRGs are presented in revised Table 1 in the Final FeasibilityStudy, and are attached to this table.

Comparing the recalculated PRGs to the sample concentrations in the RI Report and BHHRAyields a final estimated soil volume for remediation of 160,000 cy. The table in Section 3.4.3 andFigure 3 are modified to reflect these additional areas.

EPA SpecificComment 1

Table 1, Response toEPA, Trustee, EAEngineering andTCEQ Comments onDraft FeasibilityStudy, EPA-EASpecific Comment 1

The response provided in the “Response/Notes” column does not accurately reflect the associated revisions to the Draft Final FS Report.Please rectify.

Comment is noted.


Section 3.4.3, page 3-12

The text states, “The estimated volumes, rounded to the nearest whole number of 160,000 cubic yards (cy), were used for screeningtechnologies, cost estimates, and alternatives analysis.” However, 82,000 cy is used throughout Section 5. Please rectify.

Please see response to EPA General Comment 1 above. The Final Feasibility Study uses a figureof 160,000 cy consistently throughout.


Section 2.10.1,2.10.2, 2.11, etc

Discussions for the Maintenance Area present the findings that the buried pits in the Maintenance Area (Maintenance Area – Pits) willbe excavated to a depth of 15 feet to remove buried sludge. However, this area sited for remediation is not presented on Figure 3 (Soiland Sludge Remediation Areas)

The area in questions has been added to Figure 3.

AdditionalComment 14

General

There is concern that PRGs developed based on the trespasser scenario may not be sufficiently protective for the anticipated future landuse. Our major concern with the trespasser/recreational bird watcher scenario is the assumed exposure duration of 15 days per year.The assumed exposure durations do not reflect our understanding of the anticipated usage by the Scenic Galveston or similarenvironmental nonprofit organizations for conducting conservation activities and bird watching events by its members. There were onlythe two scenarios (Industrial Worker and Trespasser) performed in the human health baseline risk assessment. Absence of a scenariothat is representative of the anticipated land use as a conservatory, the agency intends to error on the side of conservatism. The PRGsare to be developed using the Industrial Worker scenario. (Similar to General Comment 1 above).

Please see response to EPA General Comment 1 above.


General

EPA noted that for some chemicals, the calculated surface soil PRGs are substantially higher than the subsurface soil PRG for the sameconstituent. Please provide an explanation and example of the PRG calculations for benzene in the Cemetery Area surface soil andsubsurface soil. In addition, please explain how will the two PRGs be implemented in the case where response actions are determinednecessary for both surface soil and subsurface soil.

An error in the algorithm for the volatilization factor (VF) and particulate emission factor (PEF)terms for the surface soils was identified in the original PRG calculations. This error led to theconfusing values that prompted this comment. The error has been corrected, and the recalculatedPRGs are shown on revised Table 2 of the Final Feasibility Study report and are attached to thistable.

To clarify how the human health and ecological PRGs will be utilized during the soil remediation,a soil remediation decision tree has been added to Sections 3.2 and 3.4 of the Final FeasibilityStudy Report and is summarized below (please note that ecological PRGs are only applied to 0 to6 inches deep surface soils):

1. If surface soils from 0 – 6 inches exceed ecological or human health PRGs, compareconfirmation samples to the lower of ecological or human health surface soil PRGs.

2. If surface soils from 6 inches to 2 feet are impacted and subsurface soil are not, excavate to 2

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Table 1




2 6/12/08

Comment


feet and compare confirmation samples to surface soil human health PRGs.

3. If only subsurface soils are impacted and surface soils are not, excavate to the bottom depth ofthe impacted soils and compare confirmation samples to subsurface soil human health PRGs.

4. If both surface and subsurface soils are impacted, excavate to the bottom depth of the impactedsoils and compare sidewall confirmation samples from the 0 – 2 ft depth interval to surface soilhuman health PRGs and sidewall and bottom confirmation samples greater than 2 ft to subsurfacehuman health PRGs.

General Subject Area: Ecological


The Malone Cooperating Parties are encouraged to carefully evaluate the potential for impacts to natural resources and their serviceswhich may occur as a result of remedial activities at the site, and when practicable, to select alternatives or design considerations thatminimize the potential for injury to natural resources. This will reduce the compensation necessary to offset these losses. The trustees’inclusion in the remedial design phase will allow further input.

The MCP looks forward to discussions with the Trustees with regard to techniques to includeecological restoration during remedy design and remedy implementation. We would like toinitiate these discussions with the Trustees after submittal of the Final Feasibility Study, and lookforward to working together so that any potential natural resource damages can be offset to thedegree possible through design and implementation of the remedy.


As was done in the responses, the FS should more concisely state that where the proposed remedy will not eliminate the ecologicalexposure pathway, COPC concentrations will be remediated to ecologically-protective levels. After all, it makes no sense to propose aremedy that will create a future land use designed to attract ecological receptors if remedial action objectives and/or PRGs will not beprotective of those receptors.

The text from the response cited has been added to Section 4.2.6 (General Site Improvements) ofthe Final Feasibility Study Report.

The extent to which areas that were not estimated to present an ecological risk in the BERA, suchas the Unused and Borrow Areas, will be needed for staging areas during remedial action isunknown. At this time, it is the MCP’s intent to avoid use of these areas during remedyimplementation. However, full examination of the potential uses and post-remediation restorationof these areas will occur during Remedial Design and in future discussions with the Trustees.


Table 1, Response toEPA, Trustee, EAEngineering andTCEQ Comments onDraft FeasibilityStudy, EPA-EASpecific Comment 5

The Draft Final FS Report states that destruction of the Unused and Borrow Area habitats by remediation would be more deleterious toecological services than could be expected from the chemicals of concern (COCs) in these areas. Please verify that these areas will notbe used as a work area and will remain un-impacted during implementation of the preferred remedy. The MCP responded that, “Theextent to which the Unused and Borrow Areas will be needed for staging areas during remedial action is unknown. Examination of thepotential uses and post-remediation restoration of these areas should occur during Remedial Design and in future discussions with theTrustees.” Restoration of habitats is acceptable if the appropriate preliminary remediation goals/restoration plans are utilized. It is alsoacceptable to include restoration costs in the FS for alternatives (e.g., Alternative 4) where it is likely that this area will be needed toconduct remedial activities. Finally, it is also acceptable to provide detailed restoration plans during the RD and conduct a post-remediation ecological risk assessment for the Unused or Borrow Areas, if these areas are used during the implementation of theremedial action.

See response to EPA General Comments 2 and 3, above, for discussion of the MCP’s intent asregards the Unused and Borrow Areas.

Restoration costs, other than typical remedial costs with restoration functions (general grading, fillsoil, etc), are not included in this Feasibility Study. Site restoration specific to enhancing the Siteas a nature conservancy is dependent upon discussions with the Trustees as to the extent of anypotential natural resource damages and potential compensation requirements. Upon restoration ofimpacted areas in accordance with specifications approved by EPA in an RD/RA Work plan, theMCP does not anticipate that an ERA would be required for restored areas.


General

Although we are concerned that the ecological PRGs were not developed for the shrew and deer mice, we noted that the Laydown Area(the area where the owls were determined to be at risk) will be under the Subtitle C land fill. However, to ensure that the materials usedfor the landfill cap would be protective, and possible other exposure areas, ecological PRGs must be developed for the shrew and thedeer mice. Also, a shrew is an insectivore (Order Insectivora), not a rodent (Order Rodentia).

Table 2 in the Feasibility Study has been modified to include ecological PRGs for the least shrewand deer mouse. Revised Table 2 of the Feasibility Study is attached to this response. Referenceto least shrew as a rodent has been removed from text. In addition, the text in Section 3.2.2 ismodified to discuss the two different PRG calculations.


Table E-1 Summaryof RemedialInvestigation andRisk AssessmentResults and P. 3-2,Section 3.1.3 On-SiteSoils

Regarding the Remedial Action Goals for surface soils in Table E-1, the word “ingestion” in #3 should be changed to “exposure”. Thissame word substitution should be made in the last bullet in Section 3.1.3.

This RAO initially used ingestion, which was the primary pathway evaluated in the EPA-approved BERA, to apply to all ecological receptors. However, based on a discussion with TCEQduring the May 14, 2008 meeting, the RAO could be misinterpreted to mean that food chaineffects were not evaluated. To clarify the point, an additional RAO has been added to Table E.1and Section 3.1.3, as follows:

Mitigate ingestion by avian and mammalian receptors of soil invertebrates, terrestrial plants,and/or other prey that have accumulated COPCs from the soil.


Table 2 PreliminaryRemediation Goalsfor EcologicalReceptors andassociated text

Some aspects of this table need to be clarified or refined. For example, although mg/kg is assumed, no actual identification of the unitsappears. In addition, each numerical value other than those for TCDD TEQs and zinc should be footnoted to identify the specificecological receptor for which the PRG was developed. Also, the previous comment regarding PCLs for the Least shrew and Deer mousemay affect this table.

Table 2 of the Feasibility Study has been revised to address this comment.

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3 6/12/08

Comment



Table 2Were any COCs eliminated in the FS that were only showing risk to the deer mouse and least shrew? If so, these COCs need to beadded back to Table 2 and an ecological PRG calculated.

The COCs on revised Table 2 of the Feasibility Study has been compared to COPCs listed inSection 7.2 (Terrestrial Ecological Risk) in the approved BERA. The COPCs for the areasrecommended for further evaluation in the Feasibility Study (i.e., Laydown Area, Cemetery Area,Tank 800, and Oil Pit) are included in revised Table 2.

General Subject Area: ARARs


Section 4.2.6;Alternative 4, Phase3, Abandon DeepWells (2)

The plugging and abandonment of the onsite non-potable well and the hazardous waste injection wells are presented. Table 5 presentsUnderground Injection Control requirements; for 40 CFR 146, please list the plugging and abandonment requirement of Class 1hazardous waste wells (MSC operated wells for injection of restricted hazardous waste). In addition, due to subsurface soil and shallowaquifer contamination, the non-potable well will have to be plugged and abandoned appropriately so no vertical avenues forcontamination of deeper aquifers exist.

Table 5 references 40 CFR 146 Subpart A and includes the plugging and abandonmentrequirements for Class I injection wells.

Texas Administrative Code 76.1004. Technical Requirements--Standards for Capping andPlugging of Wells and Plugging Wells that Penetrate Undesirable Water or Constituent Zones hasbeen added as an ARAR to Table 5 (Groundwater Management).




Table 8, page T-13,Alternative 2,Compliance withARARs

Alternative 2 would not meet the requirements of Title 40, Code of Federal Regulations (40 CFR), Part 264.228 for closure of surfaceimpoundments.

A statement has been added to Sections 5.2.2, 5.6.2 and Table 8 that Alternative 2 does not meetthe 40 CFR 264.228 closure requirements for surface impoundments.


Table 5, overallcomment

With regard to the onsite surface impoundments, 40 CFR Part 264.228, Closure and Post-closure Care, should be included in this tableas an Applicable or Relevant and Appropriate Requirement (ARAR).

40 CFR 264.228 has been added to Table 5 as an ARAR (under Landfills, although it is relevantto surface impoundments).


Table 5, page T-5,Land DisposalRestrictions

The text only discusses the applicability of Land Disposal Restrictions (LDRs) to offsite shipments of hazardous wastes. LDRs wouldalso apply onsite, if placement occurs. Specifically, Alternative 6 would include placement and would, therefore, trigger LDRs.

The description in Table 5 has been modified to include that placement of treated materials occursafter thermal desorption treatment.


GeneralThe EPA and the TCEQ have reached a consensus on the issues of the TRRP requirements as they apply to the Malone Service site. Webelieve that the TCEQ standards can be used for the Malone site. The EPA and TCEQ also agreed that, relative to Table 2 in thedocument, the reference to the requirements as TBC should be deleted.

Please see response to EPA General Comment 1, above for a discussion of how the human healthreceptor has been modified to TCEQ’s satisfaction.

The references to 30 TAC 350 are removed from Tables 3 through 5 (Location-Specific, Action-Specific and Chemical-Specific ARARs and TBCs, respectively). References to 30 TAC 350 areremoved from Section 3.3 (ARARs and TBCs).

General Subject Area: Groundwater


GeneralA Plume Management Zone (PMZ), to ensure that the contaminated ground water would not migrate, should be developed. The agencybelieves that the TCEQ Class 3 PCLs should be used as the standard to define the PMZ.

Section 3.8.1 discusses a PMZ for groundwater as one of the possible process options and Section4.2.7 discusses how the PMZ would be implemented as part of the remedy. The text in Table E-1and Section 3.2.1 is modified to state that the remedial action objective for groundwater is to“mitigate the potential migration of COPCs in groundwater beyond the MSC Superfund Siteboundaries in concentrations exceeding the TCEQ Class 3 Groundwater PCLs.”

In addition, “exceeding risk-based levels” is removed from Section 4.2.7 (GroundwaterMonitoring) and replaced with “exceeding the Class 3 groundwater PCLs”.

General Subject Area: Text / Figure Changes/Other



Please detail all institutional controls that may be employed for the Site in this section of the FS Report, including the following:

Section 2.2, page 2-2, 3rd full paragraph: “The MSC Superfund Site was subsequently acquired by Regor Properties in December 2001.In November 2007, the MCP reached a court-approved settlement agreement with Southeast Texas Environmental LLC and RegorProperties. The court approved settlement enables the MCP to impose on the property an institutional control prohibiting residential,commercial and industrial development. The settlement further requires that the land eventually be transferred to Scenic Galveston or asimilar environmental non-profit organization or, if such a transfer cannot be completed, requires that the land be used in the future onlyto complete the response action and for purposes not inconsistent with final use as a natural preservation or conservation area.”

Language from Section 2.2 has been added to Section 4.2.8 as requested. A sentence was alsoadded to Section 4.2.8 stating that if a transfer to an environmental non-profit organization cannotbe completed an institutional control would be implemented that requires the land be used in thefuture only for purposes not inconsistent with final use as a natural preservation or conservationarea. In addition a sentence is added to the text stating that the institutional control plan willdescribe mechanisms for monitoring compliance with the institutional controls.

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4 6/12/08

Comment




The text states, “This institutional control would effectively prohibit the construction of facilities or buildings in the vicinity of anycontaminated areas of the Site.” The EPA Subsurface Vapor Intrusion Guidance (Guidance for Evaluating the Vapor Intrusion toIndoor Air Pathway from Groundwater and Soils [Subsurface Vapor Intrusion Guidance], November 2002) generally recommends thatbuildings within 100 feet of a volatile organic chemical source area be considered a potentially complete migration pathway. Therefore,it is suggested that “in the vicinity” be replaced with either “within 100 feet,” or the institutional control prohibiting construction of afacility or building be applied to the entire Site.

Text modified to include “within 100 feet”.


Section 4.6.2; Section5.6.1

Although the text in Section 4.6.2 does state that Alternative 4 will incorporate a barrier wall to minimize infiltration of ground waterinto the sludge, the barrier wall is not depicted on Figure 9 (Containment Design Layout) as it is on other Alternatives/Figures. The textin Section 5.6.1 states that the barrier wall is incorporated in Alternative 5; however, Figure 12 (Bioremediation and Containment) doesnot contain the barrier wall. Please place the barrier wall on all Figures (Alternatives) requiring the wall.

The barrier wall has been added to Figures 9, 12 and 13. It should be noted that for AlternativesNos. 4 and, the barrier wall is used for ground water infiltration control during excavation of theEarthen Impoundment, and not as a long-term remediation component.


Section 3.2.3 PRGSummary, Page 3-6

Text states that any surface water remaining in the Sludge Pit would need to meet the Texas Water Quality Standards (30 TAC 307).This is correct, but please note that such standards are available for a limited number of chemicals and that other values such as thoseused to evaluate surface water in the BERA should be used in order to attain the remedial action objectives for sludge wastes to“mitigate the potential release of COPCs from sludge to surface water above ecological risk-based cleanup levels.” Text should berevised to reflect this understanding.

The section has been modified to include text stating that other values such as those used toevaluate surface water in the BERA should be used in order to attain the remedial actionobjectives for sludge wastes, in case that the all or a portion of the Sludge Pit is not backfilled tocreate a pond.


Section 5.4.5 ShortTerm Effectiveness,-16

Considering the description on Page 2-10 that “Visual observations demonstrate the discharge/runoff from on-site drainage ditches iscurrently channeled to the Freshwater Pond and the Laydown area. Standing water from the Laydown Area drains through the drainageswale into the Freshwater Pond.” It is important for the referenced Storm Water Management Plan to adequately consider and preventreleases to the freshwater pond that result in exceedances of risk-based values for surface water, particularly considering the extent ofexpected activity at the Laydown Area. It also seems appropriate to consider sediment load in discharges to surface water. Monitoringrequirements should include waters entering the freshwater pond. It may be necessary to make adjustments to site drainage as part of theremedial phase in order to meet remedial action objectives for protection of surface water. Also, note Comment No. 2 above.

The comment is noted and will be taken into consideration during the development of theRemedial Action Storm Water Management Plan. The following text has been added to Sections5.2.5, 5.3.5, 5.4.5 and 5.5.5:

In addition, the Storm Water Management Plan would include criteria for management of on-sitedischarge of storm water to the Freshwater Pond during construction activities.

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Revised Table 1 Human Health Preliminary Remedial Goals for Nature Conservancy Worker

5 6/12/08

Preliminary Remedial Goal 10-5 Individual Risk and/orHQ < 1 and cumulative risk < 10-4 and/or HQ < 10Exposure Point Chemical of Potential Concern

PRG Units Rationale

Surface Soil 1,1,2,2-Tetrachloroethane 1.2 mg/kg

Surface Soil 1,1,2-Trichloroethane 2.2 mg/kg

Surface Soil 1,2-Dibromoethane 0.80 mg/kg

Surface Soil 1,2-Dichloroethane 7.0 mg/kg

Surface Soil 2,3,7,8-TCDD TEQ (Mammal) 0.005 mg/kg EPA Guidance

Surface Soil Aldrin 1.0 mg/kg

Surface Soil Arsenic 32 mg/kg

Surface Soil Benzene 20 mg/kg

Surface Soil Benzo(a)anthracene 22 mg/kg

Surface Soil Benzo(a)pyrene 4.5 mg/kg

Surface Soil Benzo(b)fluoranthene 4.5 mg/kg

Surface Soil bis(2-Ethylhexyl)phthalate 315 mg/kg

Surface Soil Chloroform 0.65 mg/kg

Surface Soil Dibenz(a,h)anthracene 2.2 mg/kg

Surface Soil Hexachlorobenzene 13 mg/kg

Surface Soil Hexachlorobutadiene 18 mg/kg

Surface Soil Indeno(1,2,3-cd)pyrene 4.5 mg/kg

Surface Soil Methylene chloride 27 mg/kg

Surface Soil Naphthalene 70 mg/kg

Surface Soil Tetrachloroethene 112 mg/kg

Surface Soil Total PCBs 15 mg/kg TSCA

Surface Soil Total Xylenes 225 mg/kg

Surface Soil Trichloroethene 83 mg/kg

Surface Soil Vinyl chloride 4.8 mg/kg

Subsurface Soil 1,2-Dichloroethane 7.0 mg/kg

Subsurface Soil 2,3,7,8-TCDD TEQ (Mammal) 0.005 mg/kg EPA Guidance

Subsurface Soil 2-Methylnaphthalene 6750 mg/kg

Subsurface Soil Aldrin 11 mg/kg

Subsurface Soil Arsenic 75 mg/kg

Subsurface Soil Benzene 20 mg/kg

Subsurface Soil Benzo(a)anthracene 280 mg/kg

Subsurface Soil Benzo(a)pyrene 78 mg/kg

Subsurface Soil Benzo(b)fluoranthene 425 mg/kg

Subsurface Soil bis(2-Ethylhexyl)phthalate 1000 mg/kg

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6 6/12/08


PRG Units Rationale

Subsurface Soil Chloroform 6.5 mg/kg

Subsurface Soil Dibenz(a,h)anthracene 285 mg/kg

Subsurface Soil Hexachlorobenzene 25 mg/kg

Subsurface Soil Hexachlorobutadiene 39 mg/kg

Subsurface Soil Indeno(1,2,3-cd)pyrene 730 mg/kg

Subsurface Soil Methylene chloride 275 mg/kg

Subsurface Soil Naphthalene 70 mg/kg

Subsurface Soil Tetrachloroethene 240 mg/kg

Subsurface Soil Total PCBs 20 mg/kg TSCA

Subsurface Soil Total Xylenes 225 mg/kg

Subsurface Soil Trichloroethene 83 mg/kg

Subsurface Soil Vinyl chloride 5.0 mg/kg

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Revised Table 2 Preliminary Remedial Goals for Ecological Receptors

7 6/12/08

Preliminary Remedial Goals (mg/kg)

Exposure PointChemical of Potential

ConcernMidpoint

LOAEL/NOAEL(all receptors)

MidpointLOAEL/NOAEL(mobile receptors)

Comment

Laydown Area 2,3,7,8-TCDD TEQ (Mammal) 3.19E-05 2.80E-04 4 Borrow Pit Background

Laydown Area 2,3,7,8-TCDD TEQ (Avian) 5.20E-05 5.20E-05 Borrow Pit Background

Laydown Area 2-Methylnaphthalene 8.1 1 8.1 1

Laydown Area Hexachlorobenzene 8 2 9.5 1

Laydown Area Hexachlorobutadiene 2.5 3 60 1

Laydown Area High Molecular Weight PAHs 5 3 5.6 1

Laydown Area Phenanthrene 10.5 1 10.5 1

Laydown Area Total PCBs 0.055 3 1.35 1

Oil Pit Area Hexachlorobutadiene 2.5 3 725 1

Oil Pit Area High Molecular Weight PAHs 5 3 70 1

Cemetery Area High Molecular Weight PAHs 5 3 19.2 1

Tank 800 Area bis(2-Ethylhexyl)phthalate 33 1 33 1

Tank 800 Area Cadmium 1.3 3 9.5 1

Tank 800 Area Chromium 30 5

90 1State Background is 30mg/kg

Tank 800 Area Copper 115 3 4100 1

Tank 800 Area High Molecular Weight PAHs 5 3 14 1

Tank 800 Area Nickel 10 3


Tank 800 Area Zinc 30 5


Applies to surface soils: 0 - 6 inches1 - Red-winged blackbird2 – Deer Mouse3 – Least Shrew4 – Raccoon5 – State Background

See Appendix B for Ecological PRG Calculations

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6 6/12/08


PRG Units Rationale

Subsurface Soil Chloroform 6.5 mg/kg

Subsurface Soil Dibenz(a,h)anthracene 285 mg/kg

Subsurface Soil Hexachlorobenzene 25 mg/kg

Subsurface Soil Hexachlorobutadiene 39 mg/kg

Subsurface Soil Indeno(1,2,3-cd)pyrene 730 mg/kg

Subsurface Soil Methylene chloride 275 mg/kg

Subsurface Soil Naphthalene 70 mg/kg

Subsurface Soil Tetrachloroethene 240 mg/kg

Subsurface Soil Total PCBs 20 mg/kg TSCA

Subsurface Soil Total Xylenes 225 mg/kg

Subsurface Soil Trichloroethene 83 mg/kg

Subsurface Soil Vinyl chloride 5.0 mg/kg

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Revised Table 2 Preliminary Remedial Goals for Ecological Receptors

7 6/12/08

Preliminary Remedial Goals (mg/kg)

Exposure PointChemical of Potential

ConcernMidpoint

LOAEL/NOAEL(all receptors)

MidpointLOAEL/NOAEL(mobile receptors)

Comment

Laydown Area 2,3,7,8-TCDD TEQ (Mammal) 3.19E-05 2.80E-04 4 Borrow Pit Background

Laydown Area 2,3,7,8-TCDD TEQ (Avian) 5.20E-05 5.20E-05 Borrow Pit Background

Laydown Area 2-Methylnaphthalene 8.1 1 8.1 1

Laydown Area Hexachlorobenzene 8 2 9.5 1

Laydown Area Hexachlorobutadiene 2.5 3 60 1

Laydown Area High Molecular Weight PAHs 5 3 5.6 1

Laydown Area Phenanthrene 10.5 1 10.5 1

Laydown Area Total PCBs 0.055 3 1.35 1

Oil Pit Area Hexachlorobutadiene 2.5 3 725 1

Oil Pit Area High Molecular Weight PAHs 5 3 70 1

Cemetery Area High Molecular Weight PAHs 5 3 19.2 1

Tank 800 Area bis(2-Ethylhexyl)phthalate 33 1 33 1

Tank 800 Area Cadmium 1.3 3 9.5 1

Tank 800 Area Chromium 30 5


Tank 800 Area Copper 115 3 4100 1

Tank 800 Area High Molecular Weight PAHs 5 3 14 1

Tank 800 Area Nickel 10 3


Tank 800 Area Zinc 30 5


Applies to surface soils: 0 - 6 inches1 - Red-winged blackbird2 – Deer Mouse3 – Least Shrew4 – Raccoon5 – State Background

See Appendix B for Ecological PRG Calculations

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8 6/12/08

Example Human Health PRG Calculations for Benzene

014200

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