Attachment 8
(Attachments 34-53 to Clean Air Council Comments on Proposed Act 2 Rulemaking, dated April 30, 2020)
Attachment 34
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Attachment 35
From: Maddigan, Michael Sent: Friday, December 20, 2019 3:39 PM To: Brown, C David Subject: RE: public question on proposed lead MSCs Attachments: lead model comparison handout.docx; Table 7.doc
David,
The difference between the models used to calculate the current lead values and the proposed lead values can be found in the “Lead Model Comparison” document we provided to the CSSAB at the February 13, 2019 meeting (attached). Also, there are some major differences between the default exposure parameters used in the SEGH model and the ALM which are illustrated in a comparison of the current Table 7 and the proposed Table 7 (attached).
I’m assuming the ALM was used to calculate the non‐residential site‐specific lead standard at the Philadelphia Refinery which resulted in a value of 2,240 mg/kg. When we calculated the non‐residential direct contact value for the proposed rulemaking using the ALM default exposure factors we ended up with a very similar number of 2,500 mg/kg. Thus, it is probably safe to say that the differences in the default exposure factors from the SEGH model and the ALM resulted in the difference between the current non‐residential direct contact lead value and the site‐specific value calculated for the Philadelphia Refinery.
Keep in mind that the non‐residential direct contact numeric value will never be the MSC because it is higher than the generic soil to groundwater numeric value of 450 mg/kg. So in cases where the SHS is being used, the soil MSC for lead will always be 450 mg/kg. For site‐specific analyses, such as the Philadelphia Refinery, the ALM is almost always used which results in a value closer to our proposed direct contact non‐residential soil lead value.
If you need me to pinpoint more specifically what caused the differences in the numbers let me know and I can work through it.
Mike
From: Brown, C David
Mike,
At the Philadelphia Refinery, we approved a site-specific lead standard of 2240 mg/kg. This has raised some questions with the public scrutiny of the Act 2 work.
Would you be able to prepare a brief response to the question below?
Why, when the DEP is decreasing proposed residential standards by 16% (from 500 to 420 ppm), are the nonresidential standards increasing 250% (from 1000 to 2500 ppm)?
I’ll let him know that we won’t have an answer until after the holidays.
Thanks for your help.
1
-David
From: Peter Winslow
David,
Thank you for your quick response to my question Monday concerning the lead standards that have been approved by the DEP for the refinery remediation. This question is of prominent concern to the environmental justice community for several reasons:
The standard for lead is the only standard for a contaminating substance at the refinery that has been approved to date by the DEP. Because 2240 mg/kg is 2.24 times the current nonresidential statewide standard (and 4.48 times the residential statewide standard), we are concerned about the adequacy of the site specific standard for lead ‐ and by implication for other contaminants ‐ to be achieved by the refinery remediation. The public has become alarmed about vectors for lead contamination ‐ paint, toys, drinking water ‐ and is aware that lead was formerly added to gasoline (as an anti‐knocking agent). Because the refinery operated for such a long period of time, we suspect that substantial amounts of lead are present in the soil and groundwater at the refinery. The public has been educated (by Clean Water Action and other members of our coalition) about the adverse health impacts of lead poisoning. We are aware that an experience similar to that of Flint, MI, could occur in Philadelphia. So, lead is a contaminant of specific concern for neighbors of the refinery.
Why, when the DEP is decreasing proposed residential standards by 16% (from 500 to 420 ppm), are the nonresidential standards increasing 250% (from 1000 to 2500 ppm)?
We appreciate that the DEP is looking forward in setting standards that are most appropriate based on best and most current scientific evidence. Nevertheless, as the public witnesses erosion of environmental protections under the Trump administration, we are skeptical of changes that, on their surface at least, weaken environmental protections. We are particularly sensitive to the application of lowered standards in an environmental justice zone such as the vicinity of the refinery.
Although I have taken issue with the adequacy of EPA methodology and/or the way it has been applied in other contexts (specifically, use of the CHP calculator in relation to SEPTA’s Nicetown power plant), I haven’t formed an opinion concerning the health‐based methodology being used. Please point me in the direction of research reports and otherwise help us better understand the basis and the implications of the DEP decision to allow 2240 ppm lead contamination in soil at the refinery site.
Furthermore, to better understand the implications of 2240 ppm in post‐remediation soil at the refinery, we would like to know the following:
2 1. Where is it? Where are the hot spots and other areas of lead contamination located? 2. How bad is it? How much lead is currently present in total amount and in ppm? 3. What can be done? What methods are available to remediate the site? What will each alternative cost? How effective would each method be? 4. What will be done? What methods does/will Evergreen propose? What criteria will DEP/EPA use to evaluate Evergreen’s plans? 5. When will it be done? What remediation has been done so far (since 2012)? When will what additional remediation be done? When will remediation be completed? 6. What will the results be? What levels of lead will remain where? How much additional remediation would be required to bring the property to residential standards, and at what cost? What will the effects of climate disruption have on conditions on‐ and off‐site?
We will also be asking these or similar questions with respect to contaminants other than lead. We believe meaningful “Public Involvement” in the remediation process is impossible without an understanding by citizen representatives and their technical advisors sufficient to answer the common sense questions of ordinary people. Such understanding relies upon transparency and accountability from Evergreen and its regulators.
With respect to the lead standards, we know what DEP has approved. Next, we want to know why the 2240 ppm level is appropriate and what the implications are for the future of the refinery site.
Peter
On Dec 19, 2019, at 11:54 AM, Brown, C David
Peter,
In response to your question Monday, below and attached is some information on DEP’s standards for lead in soil. I’ve listed the Act 2 Statewide health standard medium specific concentrations (MSCs), and I’ve provided both the current and the proposed new standards. The revised MSCs will be published for public comment in the coming months, and we anticipate they’ll be finalized by early 2021.
In 2015 DEP approved a nonresidential site-specific soil lead standard of 2240 mg/kg for the refinery. Evergreen used the same EPA health-based methodology to derive this value as DEP is using in the proposed rulemaking. However, Evergreen used somewhat different inputs that give a slightly lower (i.e., more protective) standard than what DEP has proposed.
Please let me know of any questions.
Current MSC Proposed MSC Lead Soil Standards (mg/kg) (mg/kg) Soil-to-groundwater 450 450 Residential direct contact, 0–15′ 500 420 Nonresidential direct contact, 0–2′ 1000 2500 Nonresidential direct contact, 2–15′ 190,000 190,000
1 mg/kg = 1 ppm
3
C. David Brown P.G. | Professional Geologist Manager Department of Environmental Protection | Southeast Regional Office 2 East Main Street | Norristown, PA 19401 Phone: 484.250.5792 | Fax: 484.250.5961 www.dep.pa.gov
From: James Mullison
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Good Evening Mr. O'Neill, et al.,
The attached letter addresses your questions regarding attendance and a concise agenda for Monday's meeting. I expect that the majority of our time will be spent discussing the concerns and demands contained herein, and the ways that we can address them. We look forward to our discussion.
Thank you, James 4 Attachment 36 HUMAN HEALTH RISK ASSESSMENT REPORT PHILADELPHIA ENERGY SOLUTIONS Refining & Marketing, LLC PHILADELPHIA REFINERY PHILADELPHIA, PENNSYLVANIA and SUNOCO PARTNERS Marketing & Terminals, LP BELMONT TERMINAL PHILADELPHIA, PENNSYLVANIA and MARCUS HOOK INDUSTRIAL COMPLEX MARCUS HOOK, PENNSYLVANIA Prepared for: Evergreen Resources Group, LLC 2 Righter Parkway, Suite 200, Wilmington, Delaware 19803 Prepared by: Langan Engineering & Environmental Services, Inc. 30 South 17 th Street Suite 1300 Philadelphia, Pennsylvania 19103 February 24, 2015 2574601 HUMAN HEALTH RISK ASSESSMENT REPORT PHILADELPHIA ENERGY SOLUTIONS Refining & Marketing, LLC PHILADELPHIA REFINERY PHILADELPHIA, PENNSYLVANIA and SUNOCO PARTNERS Marketing & Terminals, LP BELMONT TERMINAL PHILADELPHIA, PENNSYLVANIA and MARCUS HOOK INDUSTRIAL COMPLEX MARCUS HOOK, PENNSYLVANIA Prepared by: Langan Engineering & Environmental Services, Inc. 30 South 17 th Street Suite 1300 Philadelphia, Pennsylvania 19103 ______Emily Strake Project Risk Assessor Langan Engineering and Environmental Services, Inc. ______Kevin J. McKeever, PE, PG Senior Project Manager Langan Engineering and Environmental Services, Inc. February 24, 2015 2574601 TABLE OF CONTENTS Page No. 1.0 EXECUTIVE SUMMARY ...... 1 2.0 INTRODUCTION ...... 2 2.1 PES Philadelphia Refinery Current Site Conditions ...... 2 2.2 Belmont Terminal Current Site Conditions ...... 3 2.3 MHIC Current Site Conditions ...... 3 2.4 Act 2 Context ...... 3 3.0 DATA ANALYSIS ...... 4 4.0 APPLICABILITY OF THE ADULT LEAD MODEL ...... 4 5.0 CONCEPTUAL SITE MODEL ...... 5 6.0 EXPOSURE ASSESSMENT ...... 6 6.1 Intake Calculations ...... 6 6.2 Exposure Frequency ...... 7 6.3 Averaging Time...... 7 6.4 Daily Soil Ingestion Rate ...... 7 7.0 TOXICITY ASSESSMENT ...... 8 8.0 RISK CHARACTERIZATION ...... 9 8.1 Uncertainty ...... 12 9.0 SUMMARY AND CONCLUSIONS ...... 13 10.0 REFERENCES ...... 13 LIST OF TABLES Table1 Calculation of a Site-Specific Lead Standard LIST OF FIGURES Figure 1 Site Plan for PES Philadelphia Refinery Figure 2 Site Plan for Belmont Terminal Figure 3 Site Plan for Marcus Hook Industrial Complex LIST OF APPENDICES Appendix A Notices of Intent to Remediate and Report Notifications ACRONYMNS AOC Area of Concern AT Non-carcinogenic Averaging Time bgs Below Ground Surface CSM Conceptual Site Model EF Exposure Frequency HHRA Human Health Risk Assessment IR Intake Rate MHIC Marcus Hook Industrial Complex MSC Medium-Specific Concentration PADEP Pennsylvania Department of Environmental Protection PES Philadelphia Energy Solutions PRG Preliminary Remediation Goal RCRA Resource Conservation and Recovery Act RfD Reference Dose RME Reasonable Maximum Exposure SEGH Society for Environmental Geochemistry and Health SHS Statewide Health Standard SSS Site-Specific Standard TRW Technical Review Workgroup for Lead USEPA United States Environmental Protection Agency Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 1 1.0 EXECUTIVE SUMMARY On behalf of the Philadelphia Refinery Operations and Marcus Hook Refinery Operations, series of Evergreen Resources Group, LLC (Evergreen), Langan Engineering and Environmental Services, Inc. (Langan) has prepared this Human Health Risk Assessment (HHRA) report for the Philadelphia Energy Solutions Refining & Marketing, LLC Philadelphia Refinery (PES Refinery), the Sunoco Partners Marketing & Terminals, LP Belmont Terminal (Belmont Terminal) and the Sunoco Partners Marketing & Terminals, LP Marcus Hook Industrial Complex (MHIC). The objectives of this study are to: 1) evaluate potential human health risks posed by residual concentrations of lead in soil under a non-residential-use scenario for the PES Refinery, Belmont Terminal and the MHIC, and 2) calculate a site-specific risk-based standard that is protective of this scenario. Although a variety of human receptor populations are potentially exposed to soil at each facility under site-specific exposure conditions, the United States Environmental Protection Agency (USEPA) default assumptions for assessing non-residential adult risks from lead exposure are adopted to provide a conservative assessment and develop a site-specific soil screening level applicable to both sites. The rationale for application of the USEPA default non-residential exposure scenario is to support the future use of each property for non-residential purposes and for attaining Act 2 closure under the Non-Residential Site Specific Standard (SSS) for lead. This HHRA was performed in accordance with the requirements and technical guidance of the Pennsylvania Land Recycling and Environmental Remediation Standards Act (Act 2) and the regulations promulgated by the Pennsylvania Department of Environmental Protection (PADEP) as Title 25, Chapter 250 of the Pennsylvania Code. In addition, technical guidance related to risk assessment from the USEPA was applied, as appropriate. The technical approach for the HHRA consisted of the following basic steps: identification of chemicals of potential concern, exposure assessment, toxicity assessment, risk characterization, and uncertainty analysis. The exposure assessment, toxicity assessment, and risk characterization sections of the HHRA evaluated potential risk from direct and/or indirect exposure to soil. The primary assumption in the USEPA’s Adult Lead Model (ALM) is that the most sensitive receptor in the workplace is the developing fetus of a female worker. Based on the results of this HHRA, Langan has concluded that no unacceptable risks are posed to generic non-residential populations potentially exposed to soil concentrations equivalent to 2,240 milligrams per kilogram (mg/kg). Evaluation of the generic exposure scenario is protective of all receptors identified at each site. Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 2 2.0 INTRODUCTION On behalf of Philadelphia Refinery Operations and Marcus Hook Refinery Operations, series of Evergreen Resources Group, LLC (Evergreen), Langan Engineering and Environmental Services, Inc. (Langan) has prepared this Human Health Risk Assessment (HHRA) report for the Philadelphia Energy Solutions Refining & Marketing, LLC (PES) Philadelphia Refinery, the Sunoco Partners Marketing & Terminals, LP Belmont Terminal (Belmont Terminal) and the Sunoco Partners Marketing & Terminals, LP Marcus Hook Industrial Complex (MHIC). The objectives of this study are to: 1) evaluate potential human health risks posed by residual concentrations of lead in soil under a non-residential-use scenario for the PES Refinery, Belmont Terminal and the MHIC, and 2) calculate a site-specific risk-based standard that is protective of this scenario. The rationale for this exposure scenario is to support the continued use of the PES Philadelphia Refinery as a refining complex and the Belmont Terminal as an active fueling terminal and the industrial redevelopment of MHIC under the Act 2 Site-Specific Standard (SSS). This HHRA was performed in accordance with the requirements and technical guidance of the Pennsylvania Land Recycling and Environmental Remediation Standards Act (Act 2) and the regulations promulgated by the Pennsylvania Department of Environmental Protection (PADEP) as Title 25, Chapter 250 of the Pennsylvania Code. In addition, technical guidance related to risk assessment from the United States Environmental Protection Agency (USEPA) was also used, where applicable. In accordance with Act 2, Langan, on behalf of Evergreen, has prepared the required public and municipal notices as part of this report submittal. Appendix A includes copies of each facility notice of intent to remediate (NIR), as well as the Act 2 report notices and their proof of receipt/publication for this report. 2.1 PES Philadelphia Refinery Current Site Conditions The PES Philadelphia Refinery is located on approximately 1,295 acres in southwest Philadelphia (Figure 1). The PES Philadelphia Refinery is a Resource Conservation and Recovery Act (RCRA)-permitted facility that is actively managed. The refinery is zoned for heavy industrial use and is expected to remain so in perpetuity. The refining complex produces a wide range of fuels for markets in the United States. Among PES’ various products are gasoline, low-sulfur diesel, jet fuel, kerosene, butane, propane, Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 3 home heating oil and the petrochemical cumene. PES currently processes approximately 330,000 barrels of crude oil per day. 2.2 Belmont Terminal Current Site Conditions The Belmont Terminal is located on approximately 100 acres in southwest Philadelphia (Figure 2). The Belmont Terminal is comprised of primarily gasoline and diesel loading racks. The area is utilized for blending gasoline and additives, as well as wholesale distribution through the terminal. There are numerous underground process lines at the terminal. The Belmont Terminal is owned by Sunoco Partners Marketing and Terminals, LP. 2.3 MHIC Current Site Conditions The MHIC is a RCRA-permitted facility that is actively managed. The MHIC is zoned for heavy industrial use and is expected to remain so in perpetuity. The MHIC is primarily located in Marcus Hook, Delaware County, Pennsylvania (Figure 3). A section of the southwest portion of the facility is located in New Castle County, Delaware. As of April 1, 2014, the MHIC is owned by Sunoco Partners Marketing and Terminals L.P. (SXL). On December 1, 2011, Sunoco Inc. (R&M) announced the indefinite idling of the main processing units at the former refinery due to deteriorating refining market conditions. Since the idling of processing units, select demolition and deconstruction has occurred. In 2013, SXL began redevelopment of the former Lube Service Center for the processing, storage, and distribution of ethane and propane. The future use of the remainder of the facility is uncertain; however, the future use will be non-residential. 2.4 Act 2 Context Evergreen and Langan will prepare a Final Act 2 Closure Report for Areas of Interest (AOI) at each site in accordance with the existing Work Plan for Sitewide Approach Under the One Cleanup Program (Sunoco 2011). The purpose of the Final Act 2 Reports is to document the framework for attaining Act 2 closure and to receive a release of liability from the PADEP for lead detected in soil. Specifically, Evergreen will demonstrate attainment of the Non-Residential Statewide Health Standards for site chemicals of concern (COCs) and Site-Specific Standard for soil in the Final Reports. For lead, soil concentration data will be compared to the SSS derived in this HHRA to evaluate the attainability of Act 2 Standards. Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 4 3.0 DATA ANALYSIS Maximum concentrations of lead detected in soil samples collected at the PES Philadelphia Refinery, the Belmont Terminal and the MHIC were compared to Pennsylvania’s Act 2 Non- Residential Direct Contact Medium-Specific Concentration (MSC) for soil of 1,000 milligrams per kilogram (mg/kg) to establish lead as a constituent of potential concern at each facility. The SSS for lead is independent of the cumulative risks and hazards that will be evaluated in subsequent risk assessment reports submitted for the PES Refinery, the Belmont Terminal and the MHIC. Therefore, this HHRA does not consider chemical data for other site-related COCs. 4.0 APPLICABILITY OF THE ADULT LEAD MODEL The PADEP published a Non-Residential MSC for lead calculated on the basis of soil ingestion as presented in 25 Pa. Code § 250.306(e), Appendix A, Table 7. The Non-Residential MSC was derived using the Society for Environmental Geochemistry and Health (SEGH) model, which was developed by the SEGH “Lead in Soil” Task Force (Wixson, 1991). In the SEGH model, a blood lead concentration (PbB) is equated to a baseline level plus an increment resulting from exposure to lead in soil or dust. The slope of the blood lead/environmental lead relationship used in calculating the increase in PbB over the baseline value, and, hence the soil screening level, can vary depending on a multitude of factors. The SEGH model permits adjustment of the target blood lead concentration (T), geometric mean background blood lead concentration (B), and geometric standard deviation (GSD) of blood lead distribution in consideration of site- specific conditions, but precludes adjustments on the basis of exposure and lead bioavailability. The PADEP has endorsed the use of alternative uptake biokinetic models for the evaluation of lead toxicity (PADEP, 2013). Given that the Integrated Exposure Uptake Biokinetic (IEUBK) Model does not apply to adult exposure in nonresidential scenarios, the PADEP maintains: “For adult exposure in either the residential or nonresidential scenario… other models, such as the Bower [sic] model (Bowers et al. , 1994), or the physiologically-based pharmacokinetic model (O’Flaherty, 1995, 1997) developed to determine the effects of lead on adults may be used to determine site- specific cleanup numbers.” In response to the need for a scientifically defensible approach for assessing soil-borne human health lead risks at non-residential hazardous waste sites, the USEPA adapted the Bowers et al. model to develop the Adult Lead Model (ALM) using the same basic algorithms. The ALM is a widely-accepted approach to risk characterization for commercial and industrial adult worker exposure scenarios. In 2001, the USEPA conducted a review of six biokinetic adult lead models for assessing human health risk associated with non-residential exposure. The study concluded Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 5 that no single model, including the O’Flaherty model, represented a significant improvement to the ALM. Consequently, USEPA recommended continued use of the ALM (EPA, 2001). 5.0 CONCEPTUAL SITE MODEL Current and known or potential future land use plays a significant role in the development of the Conceptual Site Model (CSM). The land use must also be assessed before receptor populations can be identified. For this analysis, non-residential use was assumed to be the only probable future use based on the industrial setting and current zoning in the vicinity of each facility. Based on an evaluation of the current and likely future use of each facility, a list of receptor populations was identified for evaluation in human health risk assessments (Langan, 2014a and 2014b). In general, risk assessments should be based upon realistic exposure scenarios. Site-specific information on exposure pathways, receptors and exposure factors, including actual data, should be used to the maximum extent possible (PADEP, 2013). However, not all exposure parameters need to be site-specific. Overall, it is important to consider whether using default exposure scenario assumptions will result in the calculation of a SSS that reflects the receptors and exposure pathways that are both currently occurring and that could reasonably occur in the future. Given that the default exposure assumptions developed by USEPA for the ALM are not entirely inconsistent with the receptors and exposure pathways identified at the PES Philadelphia Refinery, the Belmont Terminal and the MHIC, application of site-specific alternatives to the default assumptions was not necessary to develop a SSS for lead. The ALM uses biokinetic slope factor to represent lead biokinetics and a relatively simplistic exposure model in which all exposure pathways, other than soil ingestion, are represented by a background blood lead concentration. For the purposes of the CSM, potentially complete exposure pathways associated with lead in soil include incidental ingestion of soil, dermal contact with soil, and inhalation of indoor and outdoor dust. Each site was identified as a single unit of exposure that may be accessed by future non- residential receptors. A summary of the receptors, exposure media, and potentially complete exposure pathways assessed in this HHRA are provided below: Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 6 Potentially Complete Soil Exposure Receptor Exposure Media Pathways Surface soil Generic Non- Incidental ingestion, dermal contact, and Residential Worker 0-2 feet below inhalation of indoor and outdoor dust ground surface (bgs) 6.0 EXPOSURE ASSESSMENT This section presents the framework used by Langan to derive the potential exposures from lead for the default non-residential worker evaluated in this HHRA. Specifically, this framework was used to assess an exposure pathway, which is the course a chemical takes from its source to the exposed receptor. In order for an exposure pathway to be complete, it must contain a source, a transport medium (e.g., soil, air), a point of contact (receptor), and an exposure route (e.g., ingestion, dermal, or inhalation). If any of these elements is missing, an exposure pathway is deemed incomplete and can be excluded from the quantitative evaluation of risk (USEPA 1989). 6.1 Intake Calculations Chemical exposure/intake is expressed as the amount of the agent at the exchange boundaries of an organism (e.g., skin, lungs, and intestinal tract) that is available for systemic absorption. The term “soil” refers to that portion of the soil to which adults are most likely to be exposed. Exposure to soil-derived dust occurs both in outdoor and indoor environments, the latter occurring where soil-derived dust has been transported indoors. Other types of dust, in addition to soil-derived dust, can contribute to adult lead exposure. The general equation for exposure to lead from soil (direct and through indoor soil- derived dust) as defined by USEPA (2003): × × = where: Intake = Daily average intake (ingestion) of lead from soil taken over the averaging time in micrograms per day (µg/day) Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 7 PbS = Soil lead concentration in micrograms per gram (µg/g) (appropriate average concentration for individual) IR = Intake rate of soil, including outdoor soil and indoor soil-derived dust in grams per day (g/day) EF = Exposure frequency for contact with assessed soils and/or dust derived in part from these soils in days per year (days/year) AT = Averaging time in days (the total period during which soil contact may occur) Lead uptake is the daily average uptake of lead from the gastrointestinal tract into systemic circulation ( µg/day) and is derived by multiplying intake by the dimensionless absolute gastrointestinal absorption fraction (AF) for ingested lead in soil and lead in dust derived from soil. 6.2 Exposure Frequency The exposure frequency (EF) describes the number of times per year an event is likely to occur. Variables such as weather, vacations, and institutional controls are considered when determining reasonable and realistic exposure frequencies. The USEPA’s Technical Workgroup for Lead (TRW) recommends a default value of 219 days/year. This is the same as the central tendency occupational exposure frequency recommended by USEPA, which is based on data from the Bureau of Labor Statistics. This estimate corresponds to the average time spent at work by both full-time and part- time workers. The default central tendency EF represents reasonable maximum exposure (RME) at the PES Philadelphia Refinery, the Belmont Terminal and MHIC. 6.3 Averaging Time The AT parameter is the period over which exposure is averaged. For non-carcinogenic effects, AT is used in calculating an average daily exposure, and is 365 days/year for continuing, long-term exposures. 6.4 Daily Soil Ingestion Rate The ingestion rate (IR) is the soil ingestion rate for oral exposures to soils. The USEPA’s TRW recommends a default value of 0.05 g/day as a plausible point estimate of the central tendency for daily soil intake from all occupational sources, including soil in indoor dust resulting from non-contact intensive activities. In adopting the single IR parameter to describe all sources of ingested soil, the methodology is consistent with Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 8 the recommendations of the Superfund program and the default PADEP adult non- residential soil ingestion rate. 7.0 TOXICITY ASSESSMENT This section presents the toxicity assessment for the PES Refinery, the Belmont Terminal and MHIC site-wide lead HHRA. The toxicity assessment provides a summary of the critical toxicity values (CTVs) that have been developed by USEPA to evaluate potential adverse health effects associated with chemical exposure. The non-carcinogenic CTV is known as the reference dose (RfD). RfDs used to evaluate non- cancer effects are based on the premise that non-carcinogenic (i.e., toxic) effects exhibit a threshold. As long as the chronic daily intake of a chemical is less than the reference dose, exposure is unlikely to result in any adverse non-carcinogenic health effect. Reference doses are developed using human and animal studies, and incorporate safety factors to ensure health protection in the most sensitive population. Inorganic lead does not currently have an RfD. Instead the potential health hazard from exposure to environmental lead can be estimated based on predicted blood lead levels in sensitive populations. The epidemiological investigations of the health effects of lead were discussed in the Air Quality Criteria for Lead Volumes I-IV (USEPA, 1986a) and the 1990 Addendum (USEPA, 1990). Based on an assessment of these studies, the USEPA concluded that fetal lead exposure could have undesirable effects on infant mental development, length of gestation, and possibly other aspects of fetal development, specifically neurobehavioral deficits. In particular, the USEPA determined that, “All of these studies taken together suggest that neurobehavioral deficits, including declines in Bayley Mental Development Index scores and other assessments of neurobehavioral function, are associated with prenatal blood lead exposure levels on the order of 10 to 15 micrograms per deciliter ( µg/dl)” (USEPA, 1986b). The USEPA’s TRW has developed an interim guidance for assessing lead risks and establishing action levels for lead that are protective of both adults and the fetus of a pregnant adult. Action levels and target blood lead levels are estimated using USEPA’s ALM (USEPA, 2003). The primary assumption in the ALM methodology is that the most sensitive receptor in the workplace is the developing fetus of a worker exposed in the workplace, since the USEPA identified the developing fetus as part of the sensitive U.S. population. For the PES Refinery, the Belmont Terminal and MHIC, this would be defined as a commercial/industrial worker that becomes pregnant at some point during the work year. The lead model does not assume that a pregnant worker is present at the site for the entire pregnancy, rather, that the worker has Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 9 worked at the site long enough to result in an elevated blood lead level to which the fetus could be subsequently exposed. The ALM methodology is designed to estimate an average soil lead concentration that is not expected to result in a greater than 5% probability that the fetus of a female worker of child- bearing age has a blood lead level exceeding the level of concern of 10 g/dL of blood (USEPA, 2003). This represents a conservative approach, as the PADEP applies a target blood lead level of 20 g/dL as the default value in deriving the MSC for lead (PADEP, 1997). 8.0 RISK CHARACTERIZATION This section presents the risk characterization for lead in soil at the PES Philadelphia Refinery, the Belmont Terminal and MHIC. The objective of the risk characterization is to calculate a generic SSS protective of all receptors by combining the results of the exposure and toxicity assessments. The approach used to calculate a SSS for lead is presented below. In order to ensure that the SSS for both sites is adequately protective, the lead soil standard presented in this risk assessment was calculated using the default values and assumptions recommended by USEPA. The ALM methodology relates site lead concentrations to blood lead concentration in the mother and developing fetus based on the following additional assumptions: • Fetal blood lead levels are proportional to maternal blood lead levels; • Maternal blood lead levels can be predicted based on starting blood lead concentrations and an expected site-related increase; • The site-related increase in maternal blood lead concentrations can be estimated using a linear biokinetic slope factor (BKSF) which is multiplied by the estimated lead uptake; • Lead uptake can be estimated based on site concentrations of lead and assumptions regarding adult ingestion rates and the estimated AF of ingested lead; and • A log-normal model can be used to estimate the distribution of blood lead concentrations in a population of individuals who contact similar environmental lead levels. The basis for the calculation of the blood lead concentration for women of child-bearing age is given by: ∗ ∗ ∗ ∗ , , = , + Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 10 where: PbB adult, central, goal = Goal for central estimate of blood lead concentration PbB adult,0 = Typical blood lead concentration PbS = Soil lead concentration (appropriate average concentration for individual) BKSF = Biokinetic slope factor IR = Intake rate of soil AF = Absolute gastrointestinal absorption fraction EF = Exposure frequency AT = Averaging time Given that the effects of lead are well understood, and the mean PbB is recognized as an acceptable predictor of the potential health effects associated with lead exposure, the approach outlined in the ALM derives a soil lead concentration that is considered protective of all employees. The foundation for the SSS calculation is the relationship between the mean soil lead concentration and the blood lead concentration in the developing fetus expressed by the following equation: ( , , − , ) ∗ = ∗ ∗ ∗ where: PRG = Preliminary Remediation Goal, implemented as the SSS Consistent with the USEPA’s 2009 Update of the Adult Lead Methodology's Default Baseline Blood Lead Concentration and Geometric Standard Deviation Parameters (USEPA 2009), the most current background blood lead level and geometric standard deviation parameter made available from the 1999-2004 National Health and Nutrition Examination Survey (Center for Disease Control, 2005) is utilized in the ALM. An action level of 2,240 g/g (ppm) lead in soil for the generic non-residential site worker was estimated using Equations 1 and 2 and parameter values as shown below: Exposure Description of Exposure Units Value Rationale/Source Variable Variable 95 th percentile fetal blood PbB µg/dL 10 USEPA 2003 fetal, 0.95 lead concentration Fetal/maternal blood lead R -- 0.9 USEPA 2003 fetal/maternal concentration Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 11 Exposure Description of Exposure Units Value Rationale/Source Variable Variable µg/dL BKSF Biokinetic slope factor per 0.4 USEPA 2003 µg/day Geometric standard Updated from analysis GSD deviation blood lead -- 1.8 i of NHANES concentration Adult baseline blood lead Updated from analysis PbB µg/dL 1.0 adult,0 concentration of NHANES Soil ingestion rate PADEP 2013, EPA IR (including soil-derived g/day 0.05 2003 indoor dust) Based on absorption factor of soluble lead of Oral absorption of lead in AF -- 0.12 0.2 and soil matrix soil effect of 0.6 (USEPA 2003) EF Exposure frequency days/yr 219 USEPA 2003 AT Averaging time days/yr 365 USEPA 2003 Based on the parameters used, the USEPA model predicts that exposure to lead in soil at a concentration of 2,240 mg/kg (2,240 g/g * 1,000 g/kg * 1 mg/1,000 g = 2,240 mg/kg) would result in a typical developing fetus of a site worker exposed at either facility having an estimated risk of approximately 5 percent of exceeding the 10 g/dL blood lead level of concern. This is the target fetal blood lead distribution identified in USEPA guidance as posing an acceptable level of risk (USEPA, 2003). The SSS for lead in soil at the PES Philadelphia Refinery, the Belmont Terminal and MHIC is shown in the following table and attached as Table 1: Medium Receptor SSS Units Basis Soil Generic Non-residential Receptor 2,240 mg/kg ALM Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 12 8.1 Uncertainty Although the methods used to calculate the SSS for lead in soil at the PES Philadelphia Refinery, the Belmont Terminal and the MHIC comply with USEPA and PADEP standards, there are uncertainties associated with the procedures discussed above. This section discusses the following sources of uncertainties in the HHRA for the lead SSS: • Data collection and evaluation; • Exposure assessment; • Bioavailability; and • Risk characterization. In the HHRA, it is assumed that samples collected will be representative of the area to which human populations will be exposed. However, the samples may not be completely representative due to biases in sampling and to random variability of samples. Soils are not homogenously distributed in the environment; therefore, characterization and delineation of soil to the SSS lead standard may result in an over- or under-estimation of actual concentrations and, thus, site risks. The exposure assessment relied on a number of assumptions regarding the RME scenario used to provide an upper bound estimate of risk. Use of the USEPA’s default exposure assumptions for exposure frequency and ingestion rate is highly likely to over- estimate potential risks. Uncertainty is also compounded with regard to assumptions about scenario settings and availability of contaminated soil for contact. For example the derivation of a SSS does not take into account that walkways, parking areas, and other structures preclude contact with contaminated soil, thus potentially resulting in an incomplete exposure pathway. The default AF parameter is based, in part, on the assumption that the relative bioavailability of lead in soil compared to soluble lead is 0.6. The default AF represents a weight of evidence determination based on experimental estimates of the bioavailability of ingested lead in adult humans with consideration of three major sources of variability that are likely to be present in populations, but are not always represented in experimental studies. These include: variability in food intake, lead intake, and the lead form and particle size. The TRW considers 0.6 to be a plausible default point estimate for the relative bioavailability of lead in soil when site-specific data are not available. Because there are uncertainties in each step in the derivation of a SSS, these uncertainties are often magnified in the final risk characterization. Because of the Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 13 conservative approaches used in each step, the overall SSS may be significantly lower, and thus overly conservative, than actual conditions at each facility would support. 9.0 SUMMARY AND CONCLUSIONS Based on the results of this HHRA, Langan has concluded that a SSS for lead in soil of 2,240 mg/kg is protective of all receptor populations at the PES Philadelphia Refinery, the Belmont Terminal and MHIC. This derived value will be utilized for future reports submitted by Evergreen under the One Cleanup Program and/or the PADEP Act 2 program for the above referenced facilities. 10.0 REFERENCES USEPA. 1986a. Air Quality Criteria for Lead. Office of Health and Environmental Assessment, EPA-600/8-83/028aF-df USEPA. 1986b. Lead Effects on Cardiovascular Function, Early Development, and Stature: an Addendum to the USEPA Air Quality Criteria for Lead (1986). Office of Health and Environmental Assessment, EPA-600/8-83/028aF USEPA. 1989. Risk Assessment Guidance for Superfund. Volume I, Human Health Evaluation Manual (Part A). Interim Final. EPA/540/1-89/002. Office of Emergency and Remedial Response. Washington, DC. USEPA. 1990. Supplement to the 1986 EPA Air Quality Criteria Document for Lead – Volume 1 Addendum. Office of Research and Development, Office of Health and Environmental Assessment, Washington, DC. EPA-600/8-89/049A. Wixson, B.G., (1991). The Society of Environmental Geochemistry and Health (SEGH) Task Force Approach to the Assessment of Lead in Soil. Trace Substances in Environmental Health. 11-20. PADEP. 1997. Appendix A, Table 7, Default Values for Calculating Medium-Specific Concentrations for Lead . Pennsylvania’s Land Recycling Program Technical Guidance Manual. §250.203. August 15, 1997. USEPA. 2001. Evaluation of Models for Assessing Human Health Risks Associated with Lead Exposures at Non-Residential Areas of Superfund and Other Hazardous Waste Sites. EPA-OSWER #9285.7-46. Office of Solid Waste and Emergency Response. Washington, DC. August 2001. Human Health Risk Assessment Report February 24, 2015 PES Refinery, Belmont Terminal and MHIC Page 14 USEPA. 2003. Recommendations of the Technical Review Workgroup for Lead for an Approach to Assessing Risks Associated with Adult Exposures to Lead in Soil. EPA- 540-R-03-001. Technical Review Workgroup for Lead. Washington, DC. January 2003. CDC. 2005. National Center for Health Statistics. National Health and Nutrition Examination Survey Data. Hyattsville, MD. Sunoco. 2011. Work Plan for Sitewide Approach Under the One Cleanup Program. Sunoco, Inc. (R&M). Revision Date: November 30, 2011. PADEP. 2013. Land Recycling Program Technical Guidance Manual, General Guidance . December, 2013. Langan. 2014a . Receptor Evaluation for the PES Philadelphia Refinery. Langan. 2014b. Receptor Evaluation for the Marcus Hook Industrial Complex. \\langan.com\data\DT\data6\2574601\Office Data\Reports\Lead Human Health Risk Assessment\HHRA\Final Lead HHRA 022415.docx Attachment 37 Attachment 38 Attachment 39 STATE OF MARYLAND DEPARTMENT OF THE ENVIRONMENT CLEANUP STANDARDS FOR SOIL AND GROUNDWATER OCTOBER 2018 INTERIM FINAL GUIDANCE (UPDATE No. 3) TABLE 1 - GENERIC NUMERIC CLEANUP STANDARDS FOR GROUNDWATER AND SOILS Groundwater Soil Standards Soil Standards Standards Residential Non-Residential Protection of Type I and II Clean-up Clean-up Standard Groundwater Chemical (RSL Name) CAS Number Aquifers (ug/L) Standard (mg/Kg) (mg/Kg) (a) (mg/Kg) Inorganic Compounds Aluminum 7429-90-5 2000 7700 110000 60000 Antimony (metallic) 7440-36-0 6.0 3.1 47 0.07 Arsenic, Inorganic 7440-38-2 10 0.68 3.0 0.03 Barium 7440-39-3 2000 1500 22000 320 Beryllium and compounds 7440-41-7 4.0 16 230 38 Cadmium (Water& diet) 7440-43-9 5.0 7.1 98 1.4 Chromium (III), Insoluble Salts 16065-83-1 2200 12000 180000 80000000 Chromium(VI) (e) 18540-29-9 0.035 0.3 6.3 0.013 Chromium, Total 7440-47-3 100 Copper 7440-50-8 1300 310 4700 56 Cyanide (CN-) 57-12-5 200 2.3 15 0.030 Iron 7439-89-6 1400 5500 82000 700 Lead and Compounds 7439-92-1 15 400 800 Manganese (Non-diet) 7439-96-5 43 180 2600 560 Mercuric Chloride 7487-94-7 2.0 2.3 35 Mercury (elemental) (d) 7439-97-6 2.0 1.1 4.6 0.066 Methyl Mercury 22967-92-6 0.2 0.78 12 Nickel Soluble Salts 7440-02-0 39 150 2200 52 Perchlorate and perchlorate 14797-73-0 15 5.5 82 salts Selenium 7782-49-2 50 39 580 1.04 INTERIM FINAL GUIDANCE 24 TABLE 1 - GENERIC NUMERIC CLEANUP STANDARDS FOR GROUNDWATER AND SOILS Groundwater Soil Standards Soil Standards Standards Residential Non-Residential Protection of Type I and II Clean-up Clean-up Standard Groundwater Chemical (RSL Name) CAS Number Aquifers (ug/L) Standard (mg/Kg) (mg/Kg) (a) (mg/Kg) Inorganic Compounds Silver 7440-22-4 9.4 39 580 1.6 Thallium (Soluble Salts) 7440-28-0 2.0 0.078 1.2 0.028 Tin 7440-31-5 1200 4700 70000 6000 Vanadium and Compounds 7440-62-2 8.6 39 580 17 Zinc and Compounds 7440-66-6 600 2300 35000 740 Petroleum Hydrocarbon (TPH) Diesel Range Organics (DRO) 47 230 620 Gasoline Range Organics 47 230 620 (GRO) INTERIM FINAL GUIDANCE 25 Attachment 40 REMEDIATION STANDARDS GUIDANCE UNDER THE DELAWARE HAZARDOUS SUBSTANCE CLEANUP ACT Revised DECEMBER 1999 DNREC Remediation Standards Guidance December 1999 4.0 UNIFORM-RISK BASED STANDARD The uniform risk standard approach is useful for sites where it is not possible to achieve background standards because of the volume of the contamination or a site-specific risk assessment was not performed (i.e., a simplified evaluation of site-specific risks is more appropriate and cost effective than a baseline risk assessment). Attainment of the uniform risk standard will provide a limited level of liability release. This may include complete release of liability on a case-by-case basis for cleanups attaining the unrestricted use URS. Also, the Department will not require any deed notice or restriction for cleanups attaining the unrestricted use URS. Uniform-risk based standards have been developed for the protection of human health and the environment -- separate standards have been developed for each. The URS approach is intended to be a generic conservative approach to the protection of human health and the environment, and as such, does not take into consideration site-specific elements which change the assumptions used to derive the URS values. Site-specific elements are considered in the site-specific standard approach methodologies discussed later in this document. The URS are also intended to replace the Interim Guidance on Screening Levels for Hazardous Substances Discovered during Site Assessments Under the Delaware Hazardous Substance Cleanup Act (last revised March 1996) as a site assessment screening tool. It is recommended that any substance detected at concentrations in exceedance of the applicable URS be reported to the Department's Site Investigation and Restoration Branch as soon as practicable, and that interested parties participate in the Department's Voluntary Cleanup Program (VCP) to determine if further investigation and action is warranted. 4.1 DEFINITIONS Definitions which are important to, and exclusively applicable to the implementation of the URS follow: Restricted Use Setting: A restricted use setting is any setting where current or future use will be restricted in some way (either through deed restriction, risk management or engineering control measures) to ensure the protection of human health. A restricted use setting will have, at a minimum, a land-use which provides a human health exposure scenario that is consistent with the exposure scenario assumed by EPA to derive the human health RBC values for industrial soil ingestion, which are the basis for a portion of the URS (see April 1999 RBC Table Background Information for description of exposure scenario). Restricted use settings would typically include any setting on which commercial, industrial, manufacturing, agriculture, or any other activity is done to further either the development, manufacturing, or distribution of goods and services, intermediate and final products, including but not limited to: administration of business activities, research and development, warehousing, shipping, transport, remanufacturing, stockpiling of raw materials, storage, repair and maintenance of commercial machinery and equipment, and solid waste management. 12 DNREC Remediation Standards Guidance December 1999 Unrestricted Use Setting: An unrestricted use setting is any setting where current or future use will not be restricted in any way to ensure the protection of human health. An unrestricted use setting will have a land-use which provides a human health exposure scenario that is consistent with the exposure scenario assumed by EPA to derive the human health RBC values for residential soil ingestion, which are the basis for a portion of the URS (see April 1999 RBC Table Background Information for description of exposure scenario). Unrestricted use settings would typically include residential landuses, as well as landuses where there is potential for more extensive soil ingestion, such as playgrounds, recreational areas, parks, etc. Unrestricted use settings could also include agricultural landuse associated with the propagation of vegetation or livestock under certain conditions. Surface Soil: Surface soil is all soil between the land surface and a depth of 2 feet below grade. Subsurface Soil: Subsurface soil is all unsaturated soil between 2 feet below grade and the seasonally-low water table surface, bedrock, or 15 feet below grade, whichever is less. Critical Water Resource Area: A critical water resource area is: • Any area within a designated New Castle County Water Resource Protection Area (WRPA) or other areas in New Castle County within any delineated wellhead or ground-water protection area; • Any area in Kent or Sussex County within any delineated wellhead or ground-water protection area as mapped by DNREC or other state or local government entity; • Any area within 500 feet of a public or private water supply well; and • Any area within 500 feet of a public or private surface water supply source. Non-Critical Water Resource Area: By default, a non-critical water resource area is any setting that does not meet the definition of a critical water resource area. Ecologically Sensitive Areas: An ecologically sensitive area is an area that has been identified to be of some ecological importance. The following are considered ecologically sensitive areas: 1. Critical Habitat, including breeding areas, migratory areas, and wintering areas for State or Federal designated endangered or threatened species, or habitat known to be used by designated, proposed, or under review endangered or threatened species. 2. Federal or State Park, Preserve, Forest, Wildlife Refuge or other Federal or State administered natural or recreational area, as well as other recognized parklands, open space, or other mapped natural areas managed by local government, non-profit organizations, or others. 3. Coastal Barrier, both developed and undeveloped, including private and public beaches 4. Spawning, migration, and feeding areas critical for the maintenance of anadromous fish/shellfish species within river, lake, or coastal tidal waters 5. Wetlands and waterways, including associated floodplains and riparian zones 6. Recognized critical habitats for State listed species having the Delaware Natural Heritage Program Ranking of S1, S2, S3, S4, SU, SH, SX, and SE. 7. Woodlands/forest in excess of 20 acres in size A listing of references/sources that are available to assist in the identification of these sensitive areas is included in Attachment 2. 13 DNREC Remediation Standards Guidance December 1999 ATTACHMENT 3 REMEDIATION STANDARDS DEFAULT BACKGROUND REMEDIATION STANDARDS UNIFORM RISK-BASED REMEDIATION STANDARDS Attachment 3-1 DELAWARE UNIFORM RISK-BASED REMEDIATION STANDARDS 8 December 1999 LEGEND C = Carcinogenic/ N= Non-Carcinogenic PQL - Practical Quantitation Level - value presented is RBC, RBM, or calculated value (CALA, or CALB) CALA - Ground-Water Standard x 100 which may be at, or below, the most applicable PQL. PQL may be used for demonstrating attainment . CALB - Derived from Soil to Ground-Water Equation See Attachment 5 for applicable PQLs. PQL designation applied to URS <0.1 ug/l or <0.5 mk/kg. EPA - EPA recommendation/guidance RBC - EPA Risk-Based Concentration Table Value, April 1999 HAL - EPA Health Advisory Level RBC values equal to risk of 10E-6 MAG - Massachusetts Guidance for TPH (no RBC data) RBM - Modified RBC Value equal to a Hazard Index of 0.1 MAX - Maximum Ceiling Value is 1000 mg/kg for unrestricted use SMCL - EPA Secondary Maximum Contaminant Level and 5000 mg/kg for restricted use - actual RBC, RBM SSLI - EPA SSL Guidance Inhalation Value values are higher than ceiling. (a) Some analytes have two ground water URS values presented (e.g., 2 /1); the lowest value is to be used MCL - EPA Maximum Contaminant Level for screening purposes. PAG - Pennsylvania Guidance (no RBC data) All surface and subsurface soil values are dry weight basis/ground water values are total or dissolved concentration, depending on application URS for Protection of Human-Health Critical Water Resource Area Non-Critical Water Resource Area V Unrestricted Use Restricted Use Unrestricted Use Restricted Use O Ground Water (a) Surface Soil Subsurface Soil Surface Soil Subsurface Soil Surface Soil Subsurface Soil Surface Soil Subsurface Soil Contaminant CAS C µg/L mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg Isopropyl methyl phosphonic acid N 1832548 370 RBM 37 CALA 37 CALA 37 CALA 37 CALA 780 RBM 780 RBM 5000 MAX 5000 MAX Lead N 7439921 15 EPA 400 EPA 400 EPA 1000 EPA 1000 EPA 400 EPA 400 EPA 1000 EPA 1000 EPA Lithium N 7439932 73 RBM 7 CALA 7 CALA 7 CALA 7 CALA 160 RBM 160 RBM 4100 RBM 4100 RBM Malathion N 121755 200 HAL 67 CALB 67 CALB 67 CALB 67 CALB 160 RBM 160 RBM 4100 RBM 4100 RBM Maleic anhydride N 108316 370 RBM 37 CALA 37 CALA 37 CALA 37 CALA 780 RBM 780 RBM 5000 MAX 5000 MAX Manganese and compounds N 7439965 50 SMCL 160 RBM 160 RBM 4100 RBM 4100 RBM 160 RBM 160 RBM 4100 RBM 4100 RBM Mephosfolan N 950107 0.3 RBM 0.03 PQL 0.03 PQL 0.03 PQL 0.03 PQL 1 RBM 1 RBM 18 RBM 18 RBM Mepiquat chloride N 24307264 110 RBM 11 CALA 11 CALA 11 CALA 11 CALA 230 RBM 230 RBM 5000 MAX 5000 MAX Mercuric chloride N 7487947 1 RBM 0.1 PQL 0.1 PQL 0.1 PQL 0.1 PQL 2 RBM 2 RBM 61 RBM 61 RBM Mercury (inorganic) N 7439976 2 MCL 10 CALB 10 CALB 10 CALB 10 CALB 10 SSLI 10 SSLI 610 RBC 610 RBC Mercury (methyl) N 22967926 0.4 RBM 0.04 PQL 0.04 PQL 0.04 PQL 0.04 PQL 1 RBM 1 RBM 20 RBM 20 RBM Methacrylonitrile N 126987 ⌧ 0.1 PQL 0.01 PQL 0.01 PQL 0.01 PQL 0.01 PQL 0.8 RBM 0.8 RBM 20 RBM 20 RBM Methanol N 67561 1800 RBM 180 CALA 180 CALA 180 CALA 180 CALA 1000 MAX 1000 MAX 5000 MAX 5000 MAX Methidathion N 950378 4 RBM 0.4 PQL 0.4 PQL 0.4 PQL 0.4 PQL 8 RBM 8 RBM 200 RBM 200 RBM Methoxychlor N 72435 40 MCL 39 RBM 39 RBM 630 CALB 630 CALB 39 RBM 39 RBM 1000 RBM 1000 RBM Methyl acetate N 79209 ⌧ 610 RBM 61 CALA 61 CALA 61 CALA 61 CALA 1000 MAX 1000 MAX 5000 MAX 5000 MAX Methyl acrylate N 96333 ⌧ 18 RBM 2 CALA 2 CALA 2 CALA 2 CALA 230 RBM 230 RBM 5000 MAX 5000 MAX 2-Methylaniline C 95534 0.3 RBC 0.03 PQL 0.03 PQL 0.03 PQL 0.03 PQL 3 RBC 3 RBC 24 RBC 24 RBC 4-(2-Methyl-4-chlorophenoxy) butyric acid N 94815 37 RBM 4 CALA 4 CALA 4 CALA 4 CALA 78 RBM 78 RBM 2000 RBM 2000 RBM 2-Methyl-4-chlorophenoxyacetic acid N 94746 2 RBM 0.2 PQL 0.2 PQL 0.2 PQL 0.2 PQL 4 RBM 4 RBM 100 RBM 100 RBM 2-(2-Methyl-14-chlorophenoxy)propionic acidN 93652 4 RBM 0.4 PQL 0.4 PQL 0.4 PQL 0.4 PQL 8 RBM 8 RBM 200 RBM 200 RBM Methylene bromide N 74953 ⌧ 6 RBM 1 CALA 1 CALA 1 CALA 1 CALA 10 SSLI 10 SSLI 5000 MAX 5000 MAX Methylene chloride C 75092 ⌧ 5 /4 MCL 0.5 CALA 0.5 CALA 0.5 CALA 0.5 CALA 13 SSLI 13 SSLI 760 RBC 760 RBC 4,4'-Methylene bis(2-chloroaniline) C 101144 0.5 RBC 0.05 PQL 0.05 PQL 0.05 PQL 0.05 PQL 5 RBC 5 RBC 44 RBC 44 RBC 4,4'-Methylene bis(N,N'-dimethyl)aniline C 101611 2 RBC 0.2 PQL 0.2 PQL 0.2 PQL 0.2 PQL 14 RBC 14 RBC 120 RBC 120 RBC Methyl ethyl ketone N 78933 ⌧ 190 RBM 19 CALA 19 CALA 19 CALA 19 CALA 1000 MAX 1000 MAX 5000 MAX 5000 MAX Methyl hydrazine C 60344 0.06 PQL 0.006 PQL 0.006 PQL 0.006 PQL 0.006 PQL 0.6 RBC 0.6 RBC 5 RBC 5 RBC Methyl isobutyl ketone N 108101 ⌧ 14 RBM 1 CALA 1 CALA 1 CALA 1 CALA 630 RBM 630 RBM 5000 MAX 5000 MAX Methyl methacrylate N 80626 ⌧ 140 RBM 14 CALA 14 CALA 14 CALA 14 CALA 1000 MAX 1000 MAX 5000 MAX 5000 MAX 2-Methyl-5-nitroaniline C 99558 2 RBC 0.2 PQL 0.2 PQL 0.2 PQL 0.2 PQL 19 RBC 19 RBC 170 RBC 170 RBC Methyl parathion N 298000 2 HAL 0.4 PQL 0.4 PQL 0.4 PQL 0.4 PQL 2 RBM 2 RBM 51 RBM 51 RBM 2-Methylphenol (o-cresol) N 95487 180 RBM 18 CALA 18 CALA 18 CALA 18 CALA 390 RBM 390 RBM 5000 MAX 5000 MAX Attachment 41 DEPARTMENT OF NATURAL RESOURCES AND ENVIRONMENTAL CONTROL DIVISION OF WASTE AND HAZARDOUS SUBSTANCES Site Investigation & Restoration Section Guidance for Human Health Risk Assessments (HHRA) under the Hazardous Substance Cleanup Act (HSCA) October 2017 3.2 Exposure Assessment The purpose of the exposure assessment is to estimate the magnitude of actual and/or potential human exposures, the frequency and duration of these exposures, and the pathways by which humans are potentially exposed. This is specific to the environmental medium and receptor for each exposure unit. When fate and transport models are used to estimate exposure, the text of the report shall present pertinent information needed to verify the model and to recreate the output. Required information includes, but not limited to, input parameters and assumptions. The model should be submitted as well. Risk assessments performed under HSCA shall retain the default RAIS exposure assumptions. However, DNREC-SIRS will review requests to substitute site-specific assumptions. Variations to the default assumptions should be submitted for approval within the CSM-SAP. Also, any changes to previously approved risk calculators should be reviewed and approved by DNREC- SIRS prior to its use and on a site by site basis. 3.2.1 Exposure Point Concentrations The Exposure Point Concentrations (EPCs) are the concentrations of the COPCs in the environmental media at the point of human exposure. DNREC-SIRS recommends the use of EPA’s most current version of the ProUCL software to calculate the EPC of COPCs due to its wide availability, ease of use, and the regular updates provided by US EPA. Statistical software other than ProUCL should be preapproved by DNREC-SIRS prior to their use and on a site by site basis. ProUCL is available as a free download from the US EPA. The ProUCL output pages shall be included in the appendices of the report. The ProUCL input files shall be submitted in electronic format with descriptive file names. Selection of the EPCs should be summarized in Table C: Exposure Point Concentration (EPC). The RAIS output file includes all of the factors included in the risk calculation. Therefore, DNREC-SIRS does not require separate tables for this purpose as does RAGS. However, the RAIS output file is not labeled. Therefore, the RAIS output file should be manually labeled with the site name, exposure unit, exposure scenario and risk scenario. The labeled output shall be included in an appendix to the risk assessment report. 3.2.2 Exposure Point Concentrations for Soil The EPCs to be used in risk calculations for soil should be the 95% UCL of the mean of the COPC analytical data set. The ProUCL software takes into account non-detects and calculates the 95% UCL using various methods and recommends the most appropriate UCL to use based on the data. DNREC-SIRS requires the number of soil samples collected and analyzed to be based on the Data Quality Objectives (DQOs). A minimum of 10 soil samples is recommended to calculate a more reliable UCL but the minimum number of samples may vary depending on site conditions and as determined by DNREC-SIRS. The ProUCL guidance recommends the use of the detection limit (DL) for non-detects and use of an indicator column with a value of 0 for all non-detects and 1 for all detects. Using certain statistical methods, ProUCL calculates a UCL for data sets with non-detects. If ProUCL recommends an EPC that is above the MOC, then the MOC should be used or other alternatives such as resampling or hot spot elimination can be used with DNREC-SIRS pre-approval. 18 Confirmatory results from a fixed laboratory should be used in estimating EPCs. However, on a case by case basis, and in consultation with DNREC-SIRS prior to use, analytical screening results from the DNREC-SIRS laboratory may be incorporated in the calculation of the EPCs. Please note that if the calculated 95% UCL is greater than the MOC, then the MOC should be used as the EPC. However, DNREC-SIRS may allow other statistical results to be used as EPCs on a site specific basis and with pre-approval. Lead shall be evaluated separately from other analytes and does not affect the cumulative cancer risk or the Hazard Index. Therefore, lead should not be evaluated in RAIS. Lead should be retained as a COPC if the average is greater than 400 mg/kg. The screening level for restricted use sites shall be 800 mg/kg. For the evaluation of lead in the base line risk assessment, the EPC for lead shall be determined by calculating an average or other approved methods. Remediation for lead will normally be required if the EPC is greater than 400 mg/kg (or 800 mg/kg for restricted use sites). DNREC-SIRS does not anticipate that the child or adult Integrated Exposure Uptake Biokinetic Model (IEUBK) models will be routinely used to evaluate risks due to lead. The models are most useful when the input parameters (in addition to lead in soil concentration) can be established for the exposed population. However, DNREC-SIRS may allow the use of the IEUBK model on a site specific basis with pre-approval from DNREC-SIRS. Additionally, at its discretion, DNREC-SIRS may require modeling lead exposures if conditions, such as knowledge of elevated lead in drinking water, warrant it. A special procedure can apply to aluminum, arsenic, chromium, cobalt, iron, manganese and vanadium in soil. Please refer to Appendix 1.3 “Two Sample Hypothesis Testing” for more specific information. In June 2016, RAIS modified the assumptions for chromium. As a result, the assessment of chromium within the soil risk assessment has changed as well. Unless a site has a history of chromium use, total chromium results in soil should be evaluated as Chrome III, insoluble salts in the risk assessment. If a site has a history of chromium use and the concentration to be used in the human health risk evaluation is above the DNREC-SIRS developed background screening value, valent-specific data should be collected and used for risk assessment. 3.2.3 Alternative Methods for Calculating Exposure Point Concentrations- Soil DNREC-SIRS will accept alternative methods of calculating EPCs for soil provided that DNREC-SIRS determines that the approach is relevant and appropriate for the Site conditions and is pre-approved by the DNREC-SIRS. 3.2.4 Exposure Point Concentrations for Sediment The EPCs for sediment are based on the MOC observed in the samples representing loading from the site and not from an upstream location. The MOC is then inputted into the risk calculator to determine if the contaminant poses a risk to human health. However, if adequate sample results are available to calculate 95% UCL then it can be used for EPC. For both the recreator and trespasser exposure scenario, the sediment and soil sample results can be combined to determine the EPCs for risk evaluation except for site specific concerns. Impact of the 19 Attachment 42 NOTE: THIS IS A COURTESY COPY OF THIS RULE. ALL OF THE DEPARTMENT'S RULES ARE COMPILED IN TITLE 7 OF THE NEW JERSEY ADMINISTRATIVE CODE. N.J.A.C. 7:26D REMEDIATION STANDARDS Statutory authority N.J.S.A. 13:1D-1 et seq., 58:10-23.11a et seq., 58:10A-1 et seq. and 58:10B-1 et seq. Date last amended September 18, 2017 For the regulatory history and effective dates see the Administrative Code Rule expiration date April 27, 2022 NOTE: THIS IS A COURTESY COPY OF THIS RULE. ALL OF THE DEPARTMENT'S RULES ARE COMPILED IN TITLE 7 OF THE NEW JERSEY ADMINISTRATIVE CODE. Non- Ingestion- Residential Dermal Inhalation Direct Health Health Contact Soil Based Based Remediation Contaminant CAS No. Criterion Criterion Soil PQL Standard Endosulfan sulfate 1031-07-8 6,800 NA 0.003 6,800 Endrin 72-20-8 340 120,000 0.003 340 Ethyl benzene 100-41-4 110,000 NA 0.005 110,000 Fluoranthene 206-44-0 24,000 300,000 0.2 24,000 Fluorene 86-73-7 24,000 300,000 0.2 24,000 alpha-HCH (alpha-BHC) 319-84-6 0.5 2 0.002 0.5 beta-HCH (beta-BHC) 319-85-7 2 620 0.002 2 Heptachlor 76-44-8 0.7 18 0.002 0.7 Heptachlor epoxide 1024-57-3 0.3 13 0.002 0.3 Hexachlorobenzene 118-74-1 1 4 0.2 1 Hexachloro-1,3-butadiene 87-68-3 25 35 0.2 25 Hexachlorocyclopentadiene 77-47-4 4,100 110 0.2 110 Hexachloroethane 67-72-1 48 NA 0.2 48 Indeno(1,2,3-cd)pyrene 193-39-5 17 5,500 0.2 17 Isophorone 78-59-1 2,000 NA 0.2 2,000 Lead 7439-92-1 800 12,000 1 800 Lindane (gamma-HCH) (gamma-BHC) 58-89-9 2 10 0.002 2 Manganese 7439-96-5 160,000 5,900 2 5,900 Mercury 7439-97-6 340 65 0.1 65 Methoxychlor 72-43-5 5,700 NA 0.02 5,700 Methyl acetate 79-20-9 NA NA 0.005 NA Methylene chloride (Dichloromethane) 75-09-2 230 NA 0.005 230 2-Methylnaphthalene 91-57-6 2,400 300,000 0.17 2,400 2-Methylphenol (o-Creosol) 95-48-7 3,400 NA 0.2 3,400 4-Methylphenol (p-Creosol) 106-44-5 340 NA 0.2 340 Methyl tert-butyl ether 1634-04-4 11,000 320 0.005 320 Naphthalene 91-20-3 25,000 17 0.2 17 Nickel (Soluble salts) 7440-02-0 23,000 23,000 4 23,000 2-Nitroaniline 88-74-4 NA 23,000 0.3 23,000 Nitrobenzene 98-95-3 1,400 14 0.2 14 N-Nitrosodimethylamine 62-75-9 0.06 0.05 0.7 0.7 N-Nitrosodi-n-proplyamine 621-64-7 0.3 0.5 0.2 0.3 N-Nitrosodiphenylamine 86-30-6 390 130,000 0.2 390 Pentachlorophenol 87-86-5 3 1,700 0.3 3 Phenanthrene 85-01-8 NA 300,000 0.2 300,000 Phenol 108-95-2 210,000 NA 0.2 210,000 Polychlorinated biphenyls (PCBs) 1336-36-3 1 57 0.03 1 Pyrene 129-00-0 18,000 300,000 0.2 18,000 Selenium 7782-49-2 5,700 NA 4 5,700 Silver 7440-22-4 5,700 NA 1 5,700 19 Attachment 43 ÿÿ ÿ !ÿ"#$ÿ%ÿ&# @(( ÿ#! 9 ÿÿAÿÿB ÿ@ 9 & (Cÿ@ 9' ÿ ÊC #½( Å ÿÿB88 9 ÅÿÝ & ( Þ ÿÿ»9( Ç ÊÿÅÿ¸ß &(9( ÿDEÿGÿHIPQGRSTUVGIWÿIPEHUVEPÿSUÿXY`abcdefÿYgTUÿhiDÿTEÿQRIIPVSpWÿUHPIGSTVqÿrTSgÿsUESÿESGttÿrUIuTVqÿIPsUSPpWvÿatÿWURÿGIPÿrUIuTVqÿrTSgÿURIÿESGttÿUVÿG QRIIPVSÿHIUwPQSÿGVxÿWURÿuVUrÿSgPÿVGsPÿUtÿSgPÿPsHpUWPPÿWURÿGIPÿrUIuTVqÿrTSgfÿPsGTpÿSgPsÿGSÿtTIESVGsPvpGESVGsPyPHGvUgTUvqUÿUIÿQGppÿSgPsÿxTIPQSpWvÿgP DqPVQWÿrPETSPÿgGEÿQUVSGQSÿTVtUIsGSTUVÿtUIÿPPIWÿxTESITQSfÿxTTETUVfÿGVxÿUttTQPvÿaVÿUIxPIÿSUÿIPGQgÿREfÿHpPGEPÿQUVSGQSÿYgTUÿhiDEÿsGTVÿHgUVPÿpTVPÿGSÿ dÿ c ÿUIÿSgPÿsGTVÿpTVPÿtUIÿSgPÿxTTETUVÿUIÿUttTQPÿWURÿGIPÿSIWTVqÿSUÿIPGQgv DtSPIÿGIQgÿfÿURIÿxTESITQSÿUttTQPEÿGVxÿXPVSIGpÿYttTQPÿrTppÿPÿSPsHUIGITpWÿQpUEPxÿGVxÿrTppÿgGPÿTVQIPGETVqpWÿpTsTSPxÿGTpTSWÿSUÿIPQPTPÿxPpTPITPEfÿHpGVEfÿPSQvÿDpp PVSTSTPEÿGIPÿPVQURIGqPxÿSUÿERsTSÿHpGVEfÿHPIsTSÿGHHpTQGSTUVEfÿPSQvfÿPpPQSIUVTQGppWÿrgPIPÿSgPIPÿGIPÿPTESTVqÿGPVRPEÿSUÿxUÿEUfÿERQgÿGEÿSgPÿPRETVPEEÿXPVSPI PTvÿipPGEPÿIPtPIÿSUÿSgPÿpTESÿUtÿGGTpGpPÿEPITQPEÿUVÿSgPÿsGTVÿPTÿrPHGqPvÿPÿPVQURIGqPÿWURÿSUÿsGuPÿREPÿUtÿGppÿSgGSÿGHHpWfÿPPVÿTtÿWURÿgGPÿVUSÿREPx PTÿTVÿSgPÿHGESvÿipGVEÿRVxPIÿÿÿQGVÿPÿPsGTpPxvÿUIÿpGIqPÿHpGVEÿUPIÿÿfÿPVSTSTPEÿEgURpxÿrUIuÿrTSgÿSgPÿIPTPrPIxTTETUVÿSUÿRHpUGxÿTGÿTdRTxTpPEv bTIPQSTUVEÿtUIÿERsTSSTVqÿxUQEÿTGÿTdRTxTpPEÿTEÿGGTpGpPÿUVÿeURRPvÿPÿGHUpUqTPÿtUIÿSgPÿTVQUVPVTPVQPÿGVxÿSgGVuÿWURÿTVÿGxGVQPÿtUIÿWURI RVxPIESGVxTVqv UÿIPHUISÿGÿEHTppÿUIÿPVTIUVsPVSGpÿPsPIqPVQWfÿQUVSGQSÿSgPÿEHTppÿgUSpTVPÿfÿfcegfÿUIÿ dÿce vÿ hijklÿnopÿqnrlÿstukvowoxÿyzkÿ{tjioynv|ÿ}~ywtoÿvtxvn ÿ ÿÿÿÿÿÿÿ ÿÿ ÿÿÿÿ ÿ¡¢ {}ÿhijklÿ£¤¤k~ywukÿ¥n|ÿ¦§¨ÿ¦©ª§ÿyzvtixzÿ«~yt¬kvÿª§¨ÿ¦©ª {}ÿhijklÿ£¤¤k~ywukÿ}ixilyÿª¨ÿ¦©ª®ÿyzvtixzÿ¥n|ÿ¦¯¨ÿ¦©ª§ {}ÿhijklÿ£¤¤k~ywukÿ}°vwjÿª±¨ÿ¦©ª²ÿyzvtixzÿ³ij|ÿ²ª¨ÿ¦©ª® {}ÿhijklÿ£¤¤k~ywukÿ}°vwjÿ¦²¨ÿ¦©ª¦ÿyzvtixzÿ}°vwjÿª´¨ÿ¦©ª² {}ÿhijklÿ£¤¤k~ywukÿ¥nv~zÿª¨ÿ¦©©ÿyzvtixzÿ}°vwjÿ¦¦¨ÿ¦©ª¦ {}ÿhijklÿ£¤¤k~ywukÿ«~yt¬kvÿª®¨ÿ¦©©§ÿyzvtixzÿ¥nv~zÿª¨ÿ¦©© {}ÿhijklÿ£¤¤k~ywukÿ³ij|ÿª¨ÿ¦©©§ÿyzvtixzÿ«~yt¬kvÿª®¨ÿ¦©©§ {}ÿhijklÿ£¤¤k~ywukÿ}°vwjÿª¨ÿ¦©©§ÿyzvtixzÿ³ij|ÿª¨ÿ¦©©§ {}ÿhijklÿ£¤¤k~ywukÿ«~yt¬kvÿ¦ª¨ÿ¦©©¦ÿyzvtixzÿ}°vwjÿª¨ÿ¦©©§ {}ÿhijklÿ£¤¤k~ywukÿ¥nv~zÿ®¨ÿ¦©©¦ÿyzvtixzÿ«~yt¬kvÿ¦ª¨ÿ¦©©¦ {}ÿhijklÿ£¤¤k~ywukÿµk~k¬kvÿª§¨ÿª§ÿyzvtixzÿ¥nv~zÿ®¨ÿ¦©©¦ Å»ÿ@¸Æ»ÿÇ#"¸#ƸBÇÿ¸ÇÈ@ {tjioynv|ÿ}~ywtoÿvtxvnÿ¶{}·ÿhijkl @ 9(ÿÿ ( Cÿÿ9 9¾ÿÉÉÿ(ÿ !( ÿÿ ¸ÿ999 ÿ ('ÿB' ÿ ÿ& ÿ&')( ÿ¹ 5ºÿB' ÿ»$#ÿ ) ÿ(' ÿ 9 ¼ÿ ÿ ('ÿ9 ½ ÿ )(ÿ8Cÿÿ ( !ÿ9CC (( ÿÿ( 9' 9 ½9CC (( ÿ ) ( !ÿ ÿ ( ( ºÿ 9'ÿ ÿ C (ÿ99¼ !) ºÿC89( ºÿ C (ÿ9 (( ºÿ9 ( ÿÿ9( ºÿ½¾ ÿ C 9ÿ)8 1 ÌÍÎÏÿÑÒÿÓÔÕÿÖÿ×ÑØÙÔÚÛÕÿÌÑÜ ¿ (' ÿ(' ÿ»88 9( ÿ ÿ(½ºÿ¼ÿC¼ÿ9 9¾ÿÿ¼ÿ ÿC½ ÿÿ ÿ(' ÿ ( ( 2(ÿ8ÿ(' ÿ ÿÿ¼ÿ9C)( ÿ 9 1ÿÿ ¾ ÿÿ(' ÿ 9(¼ÿ ½ ÿ¿ ½ÿ9C ( ºÿ¼ÿC¼ÿ ÿ) ( (ÿ(' ÿ ( ÿ ÿ( 2(ÿÿ ÿ8 ÿ(ÿ¼ÿ$&ÿ'ÿ ÿ' ÿ¼ÿ ÿ ( ÿ!! 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'(() 0 )1' 1! 1 )234445667 88 9( 7 ACTION: Final ENACTED DATE: 10/07/2019 1:02 PM Appendix 3745-300-08 Appendix A to rule 3745-300-08 of the Administrative Code In this appendix, mg/kg means milligrams per kilogram, NA means not applicable, µg/m3 means micrograms per cubic meter, and µg/L means micrograms per liter. Table I: Generic numerical direct-contact soil standards (residential land use category) Table I Chemical Standard for a Standard for a Generic Direct- Abstract Service Single Chemical Single Chemical Soil Contact Soil Standard Number Non-Carcinogen Carcinogen Saturation for a Single Chemical Chemical of Concern (CAS #) (mg/kg) (mg/kg) (mg/kg) (mg/kg) Acenaphthene 83-32-9 7,200 NA NA 7,200 Acetaldehyde 75-07-0 210 280 110,000 210 Acetone 67-64-1 120,000 NA 110,000 110,000 Acetonitrile 75-05-8 2,000 NA 130,000 2,000 Acetophenone 98-86-2 16,000 NA 2,500 2,500 Acetylaminofluorene, 2- 53-96-3 NA 2.9 NA 2.9 Acrolein 107-02-8 0.36 NA 23,000 0.36 Acrylamide 79-06-1 250 4.9 NA 4.9 Acrylic acid 79-10-7 250 NA 110,000 250 Acrylonitrile 107-13-1 40 6.1 11,000 6.1 Alachlor 15972-60-8 1,300 190 NA 190 Aldicarb 116-06-3 130 NA NA 130 Aldicarb Sulfone 1646-88-4 130 NA NA 130 Aldrin 309-00-2 3.8 0.62 NA 0.62 Allyl Alcohol 107-18-6 630 NA 110,000 630 Allyl Chloride 107-05-1 4.1 18 1,400 4.1 Aluminum Phosphide 20859-73-8 63 NA NA 63 Aminobiphenyl, 4- 92-67-1 NA 0.52 NA 0.52 APPENDIX p(183883) pa(328481) d: (740126) ra(563826) print date: 11/25/2019 11:28 AM Table III: Generic numerical direct-contact soil standards (commercial or industrial land use category) 42 Table III Chemical Standard for a Standard for a Generic Direct-Contact Abstract Service Single Chemical Single Chemical Soil Soil Standard for a Number Non-Carcinogen Carcinogen Saturation Single Chemical Chemical of Concern (CAS #) (mg/kg) (mg/kg) (mg/kg) (mg/kg) Hexane, N- 110-54-3 6,400 NA 140 140 Hexanedioic Acid 124-04-9 1,000,000 NA NA 1,000,000 Hydrazine 302-01-2 250,000 44 NA 44 Hydrogen Chloride 7647-01-0 1,000,000 NA NA 1,000,000 Hydrogen Cyanide 74-90-8 400 NA 1,000,000 400 Hydrogen Fluoride 7664-39-3 190,000 NA NA 190,000 Hydrogen Sulfide 7783-06-4 1,000,000 NA NA 1,000,000 Hydroquinone 123-31-9 100,000 1,200 NA 1,200 Indeno[1,2,3-cd]pyrene 193-39-5 NA 620 NA 620 Isobutyl Alcohol 78-83-1 760,000 NA 10,000 10,000 Isophorone 78-59-1 510,000 75,000 NA 75,000 Kerb 23950-58-5 190,000 NA NA 190,000 Lead Acetate 301-04-2 NA 8,300 NA 8,300 Lead and Compounds * 7439-92-1 NA NA NA 800 Lead Phosphate 7446-27-7 NA 15,000 NA 15,000 Lead Subacetate 1335-32-6 NA 8,300 NA 8,300 Malathion 121-75-5 51,000 NA NA 51,000 Maleic Anhydride 108-31-6 240,000 NA NA 240,000 Maleic Hydrazide 123-33-1 1,000,000 NA NA 1,000,000 Malononitrile 109-77-3 250 NA NA 250 Manganese Compounds 7439-96-5 88,000 NA NA 88,000 Mercury and Compounds 7439-97-6 92 NA 3.1 3.1 Methacrylonitrile 126-98-7 390 NA 4,600 390 Attachment 44 ÿ ÿ ÿ 3ÿ4% 5ÿ6'&'5ÿ7ÿ8 ÿ3'$ 3' ÿ9@ÿ6A0 ÿ 6A0ÿ8)) ÿ7ÿ4% 5ÿu &'5ÿ7ÿÇ# ÿ7ÿ8&&Èÿ9(ÿ4 ÿ7ÿ6A0ÿÉ ' ÿ7ÿ1ÿ Êÿ4ÿÿ4ÿÿ4 BCDEFGHIPQRÿTRRHRUVFWI u&ÿvÿ6$ & ÿ&)ÿw ÿx &'& ÿvÿ8))ÿ&)ÿA $'& ÿx& ÿvÿy'&# ) ÿ3& ÿvÿ XCDYCV` ÿ ÿ ÿgIWsFHWVPÿtiHQVFWIÿVFQÿgI`rPVUIR abcTdeafgÿXCDYCV` hDPiFUVCpÿqI`IQHVUHDF XCDYCV` ÿ ÿ defgÿijkjlmedmÿelÿijljnjokjdÿpqdÿrstÿetÿuljÿvÿwwxwwy eHWIFRIQÿqI`IQHVUHDF frIWHVPHRUÿXCDYCV` defgÿijkjlmedmÿelÿijljnjokjdÿijÿrstÿetÿzj{m|edmnjÿijÿ}~uiy gIWsFHWVPÿtiHQVFWIÿVFQ mfkÿnmfkjdeÿunjed|ÿpqdÿrstÿetÿuljÿvÿwwxwwy gI`rPVUIR ÿ jÿmmkm|ÿejÿrjjqdmnjÿ~}~w~y jÿmmkm|ÿelÿijjnedÿjqkef| ijqjodfÿo|fjÿp||kodm| )&'ÿA $'& ÿ&$ ÿ4ÿA4ÿ0'& ÿ&#ÿ ' defgÿijkjlmedmÿf{fekÿmleqjÿee defgÿijkjlmedmÿf{fekÿfqj||ÿÿuefd defgÿijkjlmedmÿf{fekÿfqj||ÿdmj sÿmÿeq{flÿej sziiÿemdgÿp||feqjÿf{fekÿeÿrpy ÿ pÿmljÿdÿzelÿ|jÿunjed|ÿmÿsj|dÿmf{mme zmqj|jlÿijkjlmedmÿojqmem|dÿf{fekÿmlj ¡¢ £¤¥ÿ§¨¨©ªªÿ«©¬®§«©ª¯ÿ°±²³«ÿ¨®±¨´ÿ¥µÿ¶©ª±°©¶ÿ¶¥¨·¬©µ«ÿ§µ¶ÿ¨³¥¥ª©ÿ¸¹§º©ÿ«§°²©«ÿ§ª»»»¸¼ÿ ÿÿÿÿ½¾¿ÀÁ½Â ÿá ÿÿÿÿtÿÿupxzÿÄdmqjÿÿÅdjdÿdÿdjfÿf{fek ÿÿÿÿwtÿÿupxzÿp{fjjkjd ÿÿÿÿtÿÿupxzÿp{fjjkjdÿlmmqedm ÿÿÿÿÆtÿÿzelÿ|jÿunjed !"#$"%&$'&'('&# ) & % 0% )" 12 ÿ ÿ ÿ 2345ÿ789ÿ@AB9434CÿD48CEFGCHA48 2345ÿ789ÿ@AB9434CÿD48I9GCHA4ÿPAEQ 2345ÿ789ÿ@AB9434CÿD48I9GCHA4ÿPAEQÿD48CEFGCHA48 ÿÿÿÿRSÿÿTFUVHGÿWACHG9 ÿ ÿ ÿÿÿÿY`abcdefgÿhipiqredr`cÿsf`tfep ÿÿÿÿuSÿÿvAVF4C3Ewÿx9Q95H3CHA4ÿTEAyE3QÿIIVHG3CHA4 ÿÿÿÿSÿÿvAVF4C3Ewÿx9Q95H3CHA4ÿyE99Q94C8 C3453E5ÿyE99Q94C WAÿPFEC9EÿGCHA4ÿ WPÿD4B98CHy3CHA4ÿGCHBHCH98ÿyE99Q94C EA4H9V58ÿx9BAVBH4yÿPF45ÿ xPÿIIVHG34CÿyE99Q94C ÿÿÿÿSÿÿvAVF4C3Ewÿx9Q95H3CHA4ÿyE99Q94CÿA5HHG3CHA4 ÿÿÿÿSÿÿTFUVHGÿWACHG9 ÿÿÿÿRSÿÿ2345ÿ789ÿ@AB9434C 2345ÿ789ÿ@AB9434CÿD48CEFGCHA48 2345ÿ789ÿ@AB9434CÿD48I9GCHA4ÿPAEQ 2345ÿ789ÿ@AB9434CÿD48I9GCHA4ÿPAEQÿD48CEFGCHA48 ÿÿÿÿSÿÿ@9ECHHG3C9ÿAÿ@AQIV9CHA4 ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿÿÿÿ ÿ ÿ ÿÿÿ 0ÿ)) ÿÿ& ÿ ÿÿ0ÿd))ÿ'&'eÿÿdÿfÿÿ0'$eÿg&ÿÿ0ÿh&%ÿÿ0ÿi eÿj & 0'$ekÿd'eÿ ÿj (eÿÿli"%&$ÿÿdj"%&$ÿÿmÿÿdÿ&)ÿl ÿi'% !"#$"%&$'&'('&# ) & % 0% )" 1 Attachment 45 Department of Environmental Conservation Division of Environmental Remediation 6 NYCRR PART 375 Environmental Remediation Programs Subparts 375-1 to 375- 4 & 375-6 Effective December 14, 2006 New York State Department of Environmental Conservation (b) Restricted use soil cleanup objectives. Table 375-6.8(b): Restricted Use Soil Cleanup Objectives Protection of Public Health Protection Protection CAS of of Contaminant Number Restricted- Ecological Ground- Residential Commercial Industrial Residential Resources water Metals Arsenic 7440-38-2 16f 16f 16f 16f 13f 16f Barium 7440-39-3 350f 400 400 10,000 d 433 820 Beryllium 7440-41-7 14 72 590 2,700 10 47 Cadmium 7440-43-9 2.5f 4.3 9.3 60 4 7.5 Chromium, hexavalent h 18540-29-9 22 110 400 800 1e 19 Chromium, trivalent h 16065-83-1 36 180 1,500 6,800 41 NS Copper 7440-50-8 270 270 270 10,000 d 50 1,720 Total Cyanide h 27 27 27 10,000 d NS 40 Lead 7439-92-1 400 400 1,000 3,900 63f 450 Manganese 7439-96-5 2,000f 2,000f 10,000 d 10,000 d 1600f 2,000f Total Mercury 0.81j 0.81j 2.8j 5.7j 0.18f 0.73 Nickel 7440-02-0 140 310 310 10,000 d 30 130 Selenium 7782-49-2 36 180 1,500 6,800 3.9f 4f Silver 7440-22-4 36 180 1,500 6,800 2 8.3 Zinc 7440-66-6 2200 10,000 d 10,000 d 10,000 d 109f 2,480 PCBs/Pesticides 2,4,5-TP Acid (Silvex) 93-72-1 58 100a 500b 1,000c NS 3.8 4,4’-DDE 72-55-9 1.8 8.9 62 120 0.0033 e 17 4,4’-DDT 50-29-3 1.7 7.9 47 94 0.0033 e 136 4,4’- DDD 72-54-8 2.6 13 92 180 0.0033 e 14 Aldrin 309-00-2 0.019 0.097 0.68 1.4 0.14 0.19 alpha-BHC 319-84-6 0.097 0.48 3.4 6.8 0.04g 0.02 beta-BHC 319-85-7 0.072 0.36 3 14 0.6 0.09 Chlordane (alpha) 5103-71-9 0.91 4.2 24 47 1.3 2.9 6-10 Table 375-6.8(b): Restricted Use Soil Cleanup Objectives Protection of Public Health Protection Protection CAS of of Contaminant Number Restricted- Ecological Ground- Residential Commercial Industrial Residential Resources water delta-BHC 319-86-8 100a 100a 500b 1,000c 0.04g 0.25 Dibenzofuran 132-64-9 14 59 350 1,000c NS 210 Dieldrin 60-57-1 0.039 0.2 1.4 2.8 0.006 0.1 Endosulfan I 959-98-8 4.8i 24i 200i 920i NS 102 Endosulfan II 33213-65-9 4.8i 24i 200i 920i NS 102 Endosulfan sulfate 1031-07-8 4.8i 24i 200i 920i NS 1,000c Endrin 72-20-8 2.2 11 89 410 0.014 0.06 Heptachlor 76-44-8 0.42 2.1 15 29 0.14 0.38 Lindane 58-89-9 0.28 1.3 9.2 23 6 0.1 Polychlorinated biphenyls 1336-36-3 1 1 1 25 1 3.2 Semivolatiles Acenaphthene 83-32-9 100a 100a 500b 1,000c 20 98 Acenapthylene 208-96-8 100a 100a 500b 1,000c NS 107 Anthracene 120-12-7 100a 100a 500b 1,000c NS 1,000c Benz(a)anthracene 56-55-3 1f 1f 5.6 11 NS 1f Benzo(a)pyrene 50-32-8 1f 1f 1f 1.1 2.6 22 Benzo(b)fluoranthene 205-99-2 1f 1f 5.6 11 NS 1.7 Benzo(g,h,i)perylene 191-24-2 100a 100a 500b 1,000c NS 1,000c Benzo(k)fluoranthene 207-08-9 1 3.9 56 110 NS 1.7 Chrysene 218-01-9 1f 3.9 56 110 NS 1f Dibenz(a,h)anthracene 53-70-3 0.33e 0.33e 0.56 1.1 NS 1,000c Fluoranthene 206-44-0 100a 100a 500b 1,000c NS 1,000c Fluorene 86-73-7 100a 100a 500b 1,000c 30 386 Indeno(1,2,3-cd)pyrene 193-39-5 0.5f 0.5f 5.6 11 NS 8.2 m-Cresol 108-39-4 100a 100a 500b 1,000c NS 0.33e Naphthalene 91-20-3 100a 100a 500b 1,000c NS 12 6-11 Table 375-6.8(b): Restricted Use Soil Cleanup Objectives Protection of Public Health Protection Protection CAS of of Contaminant Number Restricted- Ecological Ground- Residential Commercial Industrial Residential Resources water o-Cresol 95-48-7 100a 100a 500b 1,000c NS 0.33e p-Cresol 106-44-5 34 100a 500b 1,000c NS 0.33e Pentachlorophenol 87-86-5 2.4 6.7 6.7 55 0.8e 0.8e Phenanthrene 85-01-8 100a 100a 500b 1,000c NS 1,000c Phenol 108-95-2 100a 100a 500b 1,000c 30 0.33e Pyrene 129-00-0 100a 100a 500b 1,000c NS 1,000c Volatiles 1,1,1-Trichloroethane 71-55-6 100a 100a 500b 1,000c NS 0.68 1,1-Dichloroethane 75-34-3 19 26 240 480 NS 0.27 1,1-Dichloroethene 75-35-4 100a 100a 500b 1,000c NS 0.33 1,2-Dichlorobenzene 95-50-1 100a 100a 500b 1,000c NS 1.1 1,2-Dichloroethane 107-06-2 2.3 3.1 30 60 10 0.02f cis-1,2-Dichloroethene 156-59-2 59 100a 500b 1,000c NS 0.25 trans-1,2-Dichloroethene 156-60-5 100a 100a 500b 1,000c NS 0.19 1,3-Dichlorobenzene 541-73-1 17 49 280 560 NS 2.4 1,4-Dichlorobenzene 106-46-7 9.8 13 130 250 20 1.8 1,4-Dioxane 123-91-1 9.8 13 130 250 0.1e 0.1e Acetone 67-64-1 100a 100b 500b 1,000c 2.2 0.05 Benzene 71-43-2 2.9 4.8 44 89 70 0.06 Butylbenzene 104-51-8 100a 100a 500b 1,000c NS 12 Carbon tetrachloride 56-23-5 1.4 2.4 22 44 NS 0.76 Chlorobenzene 108-90-7 100a 100a 500b 1,000c 40 1.1 Chloroform 67-66-3 10 49 350 700 12 0.37 Ethylbenzene 100-41-4 30 41 390 780 NS 1 Hexachlorobenzene 118-74-1 0.33e 1.2 6 12 NS 3.2 Methyl ethyl ketone 78-93-3 100a 100a 500b 1,000c 100a 0.12 6-12 Table 375-6.8(b): Restricted Use Soil Cleanup Objectives Protection of Public Health Protection Protection CAS of of Contaminant Number Restricted- Ecological Ground- Residential Commercial Industrial Residential Resources water Methyl tert-butyl ether 1634-04-4 62 100a 500b 1,000c NS 0.93 Methylene chloride 75-09-2 51 100a 500b 1,000c 12 0.05 n-Propylbenzene 103-65-1 100a 100a 500b 1,000c NS 3.9 sec-Butylbenzene 135-98-8 100a 100a 500b 1,000c NS 11 tert-Butylbenzene 98-06-6 100a 100a 500b 1,000c NS 5.9 Tetrachloroethene 127-18-4 5.5 19 150 300 2 1.3 Toluene 108-88-3 100a 100a 500b 1,000c 36 0.7 Trichloroethene 79-01-6 10 21 200 400 2 0.47 1,2,4-Trimethylbenzene 95-63-6 47 52 190 380 NS 3.6 1,3,5- Trimethylbenzene 108-67-8 47 52 190 380 NS 8.4 Vinyl chloride 75-01-4 0.21 0.9 13 27 NS 0.02 Xylene (mixed) 1330-20-7 100a 100a 500b 1,000c 0.26 1.6 All soil cleanup objectives (SCOs) are in parts per million (ppm). NS=Not specified. See Technical Support Document (TSD). Footnotes a The SCOs for residential, restricted-residential and ecological resources use were capped at a maximum value of 100 ppm. See TSD section 9.3. b The SCOs for commercial use were capped at a maximum value of 500 ppm. See TSD section 9.3. c The SCOs for industrial use and the protection of groundwater were capped at a maximum value of 1000 ppm. See TSD section 9.3. d The SCOs for metals were capped at a maximum value of 10,000 ppm. See TSD section 9.3. e For constituents where the calculated SCO was lower than the contract required quantitation limit (CRQL), the CRQL is used as the SCO value. f For constituents where the calculated SCO was lower than the rural soil background concentration as determined by the Department and Department of Health rural soil survey, the rural soil background concentration is used as the Track 2 SCO value for this use of the site. g This SCO is derived from data on mixed isomers of BHC. h The SCO for this specific compound (or family of compounds) is considered to be met if the analysis for the total species of this contaminant is below the specific SCO. i This SCO is for the sum of endosulfan I, endosulfan II, and endosulfan sulfate. j This SCO is the lower of the values for mercury (elemental) or mercury (inorganic salts). See TSD Table 5.6-1. 6-13 Attachment 46 New York State Brownfield Cleanup Program Development of Soil Cleanup Objectives Technical Support Document Prepared By: New York State Department of Environmental Conservation and New York State Department of Health September 2006 i These default relationships assume the same absorption fraction by both exposure routes. In cases where the relative absorption fraction by the oral and inhalation routes is known, an additional factor is applied to account for absorption differences between the two routes. In cases where adequate chemical-specific toxicity data and adequate data for a route-to-route extrapolation were both unavailable, toxicity data from structurally related chemicals were considered as the basis for a toxicity value. The structure of a chemical largely determines its pharmacokinetics in the body, and therefore is an important determinant of its toxicity. Chemicals with very similar structures often have similar toxic properties. In cases where toxicity information for a chemical was unavailable, but toxicity data from a structurally similar chemical was available and satisfied the general selection criteria described above, the surrogate toxicity data were considered for use as the toxicity value in lieu of chemical-specific data. 5.1.1.8 Toxicity Values for Inorganic Lead Non-Cancer Lead and inorganic lead compounds cause a variety of health effects in humans, and can damage the nervous, cardiovascular, gastrointestinal, hematopoietic, and reproductive systems. The database on lead toxicity is unusual because it contains a large amount of data on dose-response relationships in humans (ATSDR, 1999). Consequently, the degree of uncertainty about the non- cancer human health effects of lead is relatively low compared to almost all other contaminants (US EPA, 2005c). In most studies, however, the measure of dose is an internal one (most commonly, blood lead level or PbB). In addition, most studies cannot attribute blood lead levels to one single route, pathway, or source of exposures or exposures during a limited, defined time. This is because lead can accumulate in the human body, and blood lead at any given time is dependent on current and past exposures to lead. Current exposures (e.g., food, water, air, and soil) are important because absorbed lead goes into the blood before distributing to other parts of the body. Past exposures are important because the body stores absorbed accumulated lead in bones. The lead in bones can be released into the blood under certain circumstances. Thus, 38 blood lead is considered the most reliable measure of a person’s risk of non-cancer health effects from lead. Experimental studies of the toxicity of lead in animals provide support for observations in humans. Current knowledge of lead pharmacokinetics indicates that toxicity values derived by the application of default risk assessment procedures (e.g., using administered, ingested, or inhaled dose) to animal dose-response data might not accurately estimate the potential risk (US EPA, 2005c). This stems from concerns that an adequate animal model for lead toxicity in humans is not available and because of the difficulty in accounting for pre-existing body burdens of lead (US EPA, 2005c). Moreover, an animal-based analysis would overlook the significant body of toxicological literature on human toxicity and blood lead levels (ATSDR, 1999). Thus, animal data on lead toxicity have not been used by the ATSDR (1999), US EPA (2001, 2005c), or other public health agencies to evaluate the potential human non-cancer health effects of lead exposures. Neither ATSDR (1999), nor the US EPA (2005c), nor other authoritative bodies have proposed or developed a lead reference dose or reference concentration based on animal data. Public health agencies recognize that the primary population, dose measure, and health concern associated with environmental exposures to lead are children, blood lead levels, and neurotoxicity, respectively (e.g., ATSDR, 1999; FL DEP, 2004; NJ DEP, 2004; MN PCA, 1999; US EPA, 2001; WHO, 1996). Young children are especially vulnerable to the toxic effects of lead for at least two reasons: (1) Increased Exposures Relative to Adults. Children are likely to be exposed to environmental lead in many more ways than are adults (e.g., more hand-to-mouth activity, more contact with dirt, more mouthing/ingestion of non-food items). Children also have greater food, water, and inhalation rates per unit body weights than do adults. In addition, young children absorb a greater percentage of ingested lead than do adults, and might absorb a greater percentage of inhaled lead than do adults (ATSDR, 1999). (2) Increased Sensitivity Relative to Adults. For many effects, the lead blood levels that cause toxicity in children are lower than the levels that cause effects in adults, and the effects may be 39 more severe than those in adults (ATSDR, 1999). This suggests that children are more sensitive to the toxic effects of absorbed lead than adults. The toxicological data on the effects of lead on young children support concern for the increased sensitivity of fetuses, neonates, and infants to the toxicological effects of elevated blood lead levels (ATSDR, 1999). Much of the concern over lead exposure in women of child-bearing age stems from concerns that the exposures could lead to elevated blood lead levels in the fetus (US EPA, 2003). Many environmental guidelines or standards for lead are based on children as the sensitive population (e.g., CA EPA, 1997; Health Canada, 1992; RIVM, 2001; US EPA, 2000a, 2001; WHO, 1996). The derivations of these guidelines, however, are different from the derivation of guidelines for most contaminants. The guidelines are not based directly on a daily intake of lead from one route of exposure (for example, a reference dose for oral intake or a reference concentration for air intake), but are based on a blood lead level. The blood lead level is typically 10 mcg/dL (micrograms of lead per deciliter of blood), which is the Centers for Disease Control and Prevention (CDC) level of concern for blood lead in young children (ATSDR, 1999; CDC, 1991). In most cases, the guidelines are derived so that the blood levels of almost all children exposed at the guideline would be below 10 mcg/dL. This is the approach taken in the derivation of the SCOs for lead (see Section 5.3.4 Chronic Lead SCOs). Thus, toxicity values (reference dose or reference concentration) for the non-cancer effects of lead are not proposed. Cancer The National Toxicology Program (NTP, 2005) classifies lead and lead compounds as “reasonably anticipated to be human carcinogens” based on limited evidence from studies in humans and sufficient evidence from studies in experimental animals. Similarly, the International Agency for Research on Cancer (IARC, 2004) classifies inorganic lead compounds as “probably carcinogenic to humans (Group 2A)” based on limited evidence for the carcinogenicity to humans and sufficient evidence for the carcinogenicity to experimental animals. 40 According to the NTP (2003, 2005) reviews, lead exposure has been associated with increased risks of lung, stomach, and bladder cancer in human populations. The epidemiological evidence is strongest for lung and stomach cancer. The evidence is not conclusive because most of the studies have limitations. These include poor exposure assessment and failure to control for confounders (other factors that could increase the risk of cancer, including lifestyle factors and concurrent occupational exposure to other carcinogens). In addition, they did not demonstrate relationships between the amount of exposure (e.g., concentration or duration) and the magnitude of cancer risk. Thus, the epidemiological data on lead are inadequate to develop cancer toxicity values (i.e., oral cancer potency factor or inhalation unit risk) for lead. Long-term exposures to soluble (lead acetate and lead subacetate) or insoluble (lead phosphate, lead chromate) inorganic lead compounds have caused cancer in laboratory animals (NTP, 2003, 2005). Kidney tumors were most frequently associated with lead exposure, but tumors of the brain, hematopoietic system, and lung were reported in some studies. However, only two lead compounds (lead acetate and lead subacetate) have caused cancer in animals after oral exposures. Other lead compounds have caused cancer in animals after subcutaneous injection (lead phosphate or lead chromate), subcutaneous injection followed by intraperitoneal injection (lead phosphate), or intramuscular injection (lead chromate). The possibility that the carcinogenicity of lead chromate is caused by exposure to hexavalent chromium (chromate), which is an animal carcinogen, cannot be excluded. Lead naphthenate (dermal exposures), lead carbonate (diet), lead arsenate (diet), lead nitrate (drinking water), and metallic lead, as lead powder) (intramuscular or gavage) did not significantly increase tumor incidences in experimental animals. Studies of the carcinogenicity of inhaled lead were not found. Only one of the authoritative bodies reviewed, the CA EPA, has derived oral cancer potency factors and inhalation unit risks for inorganic lead compounds (CA EPA, 1992, 1997, 2002, 2004). Most recently, the oral potency factor for lead was restricted to lead acetate, one of the two lead compounds shown to cause cancer via the oral route (CA EPA, 2005). In contrast, the US EPA (2005c) lead database for risk assessment in the Integrated Risk Assessment System, which is the peer-reviewed source for US EPA toxicity values for chemicals, contains the following statement: 41 Quantifying lead's cancer risk involves many uncertainties, some of which may be unique to lead. Age, health, nutritional state, body burden, and exposure duration influence the absorption, release, and excretion of lead. In addition, current knowledge of lead pharmacokinetics indicates that an estimate derived by standard procedures would not truly describe the potential risk. Thus, the Carcinogen Assessment Group recommends that a numerical estimate not be used. Given the problems associated with extrapolating animal data on lead to humans, animal-based oral cancer potency factors and inhalation unit risks for lead are not proposed. 5.1.1.9 Summary Toxicity values (i.e., reference dose, reference concentration, cancer potency factor, and air unit risk) for evaluating chronic exposures were selected for priority list contaminants (Table 5.1.1- 2). These values will be used to derive contaminant-specific SCOs based on chronic toxicity data and chronic exposure scenarios (see Section 5.3 Calculation of Chronic Human Health- based Soil Cleanup Objectives). 42 Attachment 47 Attachment 48 TABLE OF CONTENTS SECTION II: ACT 2 REMEDIATION PROCESS ...... II-1 A. Applying Land Recycling Remediation Standards to Your Property ...... II-1 1. Classifying your Site and Considering Options for Remediation ...... II-1 a) Background Standard ...... II-2 b) Statewide Health Standard ...... II-2 c) Site-specific Standard ...... II-2 d) Combination of Standards...... II-2 e) Special Industrial Areas ...... II-3 2. Immediate Response ...... II-3 3. Notice Requirements and Procedures ...... II-4 a) Notice of Intent to Remediate ...... II-4 b) Notice of Proposal for Nonuse Aquifer Determination ...... II-6 c) Public Involvement Plan ...... II-6 d) Remediation Report Notification Requirements ...... II-7 i) Background and Statewide Health Standards ...... II-7 ii) Site-specific Standard ...... II-9 iii) Special Industrial Areas ...... II-10 e) Fees ...... II-10 4. Site Characterization ...... II-11 a) Importance of Site Characterization Step ...... II-11 b) Scope of Characterization ...... II-11 i) Soils...... II-12 ii) Groundwater ...... II-15 iii) Sediment ...... II-16 iv) Conceptual Site Model Including Soil and Groundwater ...... II-16 v) Conceptual Site Model Example ...... II-17 c) Applying Site Characterization to an Act 2 NIR – Example ...... II-21 B. Remediation Standards ...... II-27 1. Background Standard ...... II-27 a) Introduction ...... II-27 b) Process Checklist for the Background Standard ...... II-28 c) Point of Compliance (POC) for the Background Standard ...... II-29 d) Establishing Background Concentration(s) ...... II-30 i) Background from a Known Upgradient Release of a Regulated Substance ...... II-35 (a) Groundwater ...... II-35 (b) Soil ...... II-35 ii) Background from Naturally Occurring or Area-wide Contamination ...... II-36 (a) Groundwater ...... II-36 (b) Soil ...... II-36 (c) Historic Fill ...... II-37 e) Final Report Requirements for the Background Standard ...... II-37 i) Summary ...... II-39 ii) Site Description ...... II-39 iii) Site Characterization ...... II-39 261-0300-101 / January 19, 2019 / Page II-i iv) Background Standard ...... II-43 v) Remediation ...... II-44 vi) Attainment...... II-44 (a) Soil Background Standards ...... II-45 (b) Groundwater Background Standards ...... II-45 vii) Fate and Transport Analysis ...... II-46 viii) Postremediation Care Plan (if applicable) ...... II-47 ix) References ...... II-48 x) Attachments ...... II-48 xi) Signatures ...... II-49 2. Statewide Health Standard ...... II-49 a) Introduction ...... II-49 b) Process Checklist for Remediations Under the Statewide Health Standard ...... II-49 c) Selection of MSCs ...... II-51 i) Determining Groundwater MSCs ...... II-51 ii) Determining Soil MSCs ...... II-51 (a) Choosing the Soil-To-Groundwater Numeric Value ...... II-53 (b) Considering Direct Contact Value in Relation to the Soil-to-Groundwater Value and Soil Depth ...... II-54 (c) Selecting Applicable MSCs – Example ...... II-54 d) Nonuse Aquifer Determinations ...... II-60 i) General ...... II-60 ii) Request Initiated by a Remediator as Part of an NIR ...... II-61 iii) Nonuse Aquifer Conditions to be Met in the Area of Geographic Interest ...... II-61 iv) Request for Certification of a Nonuse Aquifer Area Initiated by a Local Government ...... II-62 v) Example ...... II-63 e) Ecological Screening ...... II-63 i) Step 1: Presence of Light Petroleum Product Constituents ...... II-69 ii) Step 2: Site Size ...... II-69 iii) Step 3: Obvious Pathway Elimination ...... II-70 iv) Step 4: Presence of Constituents of Potential Ecological Concern ...... II-70 v) Step 5: Preliminary Onsite Evaluation ...... II-71 vi) Step 6: Detailed Onsite Evaluation and Identification of Species and Habitats of Concern ...... II-72 vii) Step 7: Identification of Completed Exposure Pathways ...... II-75 viii) Step 8: Attainment of Standard and Mitigative Measures ...... II-75 ix) Step 9: Final Report - No Further Ecological Evaluation Required ...... II-76 f) Final Report Requirements for the Statewide Health Standard ...... II-77 i) Summary ...... II-80 ii) Site Description ...... II-80 iii) Site Characterization ...... II-80 iv) Selection of the Applicable Statewide Health Standard ...... II-82 v) Ecological Screening ...... II-83 vi) Remediation ...... II-83 261-0300-101 / January 19, 2019 / Page II-ii vii) Attainment...... II-84 (a) Point of Compliance ...... II-85 (b) Statistical Tests ...... II-86 viii) Fate and Transport Analysis ...... II-89 ix) Postremediation Care Plan (if applicable) ...... II-90 x) References ...... II-91 xi) Attachments ...... II-91 xii) Signatures ...... II-92 g) References ...... II-92 3. Site-Specific Standard ...... II-93 a) Introduction ...... II-93 b) Process Checklist for the Site-Specific Standard ...... II-96 c) Site Investigation ...... II-98 i) Site Characterization ...... II-98 ii) Pathway Identification (§ 250.404 of the Regulations) ...... II-101 (a) Groundwater ...... II-102 (b) Soil ...... II-103 (c) Cases Where No Complete Current or Future Exposure Pathway Exists ...... II-103 (d) Cases Where Institutional or Engineering Controls Are Needed to Eliminate Pathways ...... II-104 d) Risk Assessment and Development of Site-Specific Standards (§ 250.402) ...... II-105 e) Cleanup Plan ...... II-110 f) Remediation and Demonstration of Attainment ...... II-111 g) General Report Guidelines for the Site-Specific Standard ...... II-113 i) Remedial Investigation Report (25 Pa. Code § 250.408) ...... II-113 ii) Cleanup Plan (25 Pa. Code § 250.410) ...... II-114 iii) Final Report (25 Pa. Code § 250.411) ...... II-114 iv) Combined Remedial Investigation Report/Final Report ...... II-114 v) Risk Assessment Report (25 Pa. Code § 250.409) ...... II-114 h) Detailed Report Requirements for the Site-Specific Standard ...... II-115 i) Summary (RIR, FR, RIR/FR) ...... II-115 ii) Introduction (CP, RA) ...... II-115 iii) Site Description (RIR, RIR/FR) ...... II-115 iv) Site Characterization (RIR, RIR/FR, RA) ...... II-115 v) Source and Identification of Constituents of Concern (Part of Characterization) ...... II-115 vi) Nature and Extent of Contamination (Part of Characterization) ...... II-116 vii) Other Information Required Under the Site-Specific Standard (RIR, RIR/FR) ...... II-116 viii) List of Contacts (ALL)...... II-116 ix) Remedial Alternative (CP) ...... II-116 x) Treatability studies (CP) ...... II-117 xi) Design plans and Specifications (CP) ...... II-117 xii) Remediation (FR)...... II-118 xiii) Attainment (FR) ...... II-118 xiv) Fate and Transport Analysis (RIR, FR, RIR/FR, RA) ...... II-120 261-0300-101 / January 19, 2019 / Page II-iii xv) Conclusions and Recommendations (RIR, RIR/FR) ...... II-121 xvi) Postremediation care plan (if applicable) and other postremedial obligations (such as monitoring or institutional controls) (CP, FR, RIR/FR) ...... II-121 xvii) Cooperation or Agreement of Third Party (CP) ...... II-122 xviii) Public comments (ALL) ...... II-122 xix) References (ALL) ...... II-122 xx) Attachments (ALL) ...... II-122 xxi) Signatures (ALL) ...... II-123 4. Special Industrial Areas ...... II-131 a) Introduction ...... II-131 b) Eligibility Determination ...... II-131 c) Process Checklist for Special Industrial Areas ...... II-132 d) Aspects of Special Industrial Areas ...... II-134 i) Immediate, Direct, or Imminent Threats to Human Health and the Environment ...... II-134 ii) Consideration of Chronic Exposure in Evaluation of the Reuse of a Special Industrial Area ...... II-135 iii) Contaminant Migration Off-Property ...... II-136 iv) Contamination Identified Subsequent to Remediation and Agreement Conditions ...... II-136 v) Storage Tank Closure and Corrective Action at Special Industrial Areas ...... II-136 vi) Consent Orders and Agreements ...... II-136 vii) Remediation ...... II-137 viii) Environmental Covenant ...... II-137 e) Work Plan for Baseline Remedial Investigation and Baseline Environmental Report ...... II-138 i) Work Plan for Baseline Remedial Investigation ...... II-138 ii) Baseline Environmental Report ...... II-139 Figure II-1: Site Characterization Decision Tree ...... II-14 Figure II-2: Graphic Example of Conceptual Site Model ...... II-19 Figure II-3: Flow Chart Example of Conceptual Site Model ...... II-20 Figure II-4: Site Characterization of Soil Contamination ...... II-23 Figure II-5: Site Characterization of Groundwater Contamination No Off-Property Groundwater Concentrations > MSC ...... II-24 Figure II-6: Site Characterization of Groundwater Contamination Under Statewide Health Standard ...... II-25 Figure II-7: Point of Compliance for the Background Standard Compliance with Background Standard from Upgradient Release with No On-Property Release ...... II-31 Figure II-8: Point of Compliance for the Background Standard Off-Property Migration with an Upgradient Groundwater Source Area Release ...... II-32 Figure II-9A and 9B: Areawide Contamination Scenarios ...... II-33 Figure II-10: Background Standard Attainment with Areawide Fill ...... II-38 Figure II-11: Decision Tree for Selecting Statewide Health Standard MSCs for Groundwater and Soil ...... II-52 Figure II-12: Application of the MSC Selection Process ...... II-55 261-0300-101 / January 19, 2019 / Page II-iv Figure II-13: Nonuse Aquifer Screening Area (Parallel Flow) ...... II-65 Figure II-14: Nonuse Aquifer Screening Area (Convergent Flow) ...... II-66 Figure II-15: Nonuse Aquifer Screening Area (Divergent Flow) ...... II-67 Figure II-16: Ecological Screening Decision Tree ...... II-68 Figure II-17: Site-Specific Assessment Decision Tree ...... II-95 Table II-1: Suggested Outline for a Final Report under the Background Standard...... II-40 Table II-2: Suggested Outline for a Final Report under the Statewide Health Standard ...... II-78 Table II-3: List of Ecological Risk Assessment Guidances...... II-109 Table II-4: Suggested Outline for Remedial Investigation Report under the Site-Specific Standard ...... II-124 Table II-5: Suggested Outline for a Cleanup Plan under the Site-Specific Standard ...... II-125 Table II-6: Suggested Outline for a Final Report under the Site-Specific Standard ...... II-126 Table II-7: Suggested Outline for the Combined Remedial Investigation Report/Final Report under the Site-Specific Standard When No Current and Future Complete Exposure Pathways Exist ...... II-128 Table II-8: Suggested Outline for a Risk Assessment Report under the Site-Specific Standard ...... II-129 261-0300-101 / January 19, 2019 / Page II-v xi) Signatures If any portions of the submitted report were prepared or reviewed by or under the responsible charge of a registered professional geologist or engineer, the professional geologist or engineer in charge must sign and seal the report. 2. Statewide Health Standard a) Introduction The SHS is established by Sections 301 and 303 of Act 2 (35 P.S. §§ 6026.301 and 6026.303) and includes MSCs that must be attained to achieve the liability protection provided for in the Act. The MSCs are calculated in accordance with the methodologies in § 250.304 through 250.310 of the regulations. The numerical MSCs are contained in Appendix A to Chapter 250, Tables 1 through 6. Cleanup liability protection provided under Act 2 is contingent upon the attainment of the appropriate MSCs determined using the procedure described in Section II.B.2(c) below. This guidance presents the procedures to be used in assessing site contamination and demonstrating attainment of the SHS. Use of this guidance and data submission formats should simplify reporting on the site and reduce delays in obtaining final report approval by the Department. This guidance is designed to aid in understanding and meeting the requirements of the SHS under Act 2 and the regulations in Chapter 250. ECB staff in the Regional Office are a valuable resource and will assist as requested in answering questions on the SHS. Failure to demonstrate attainment of the SHS may result in the Department requiring additional remediation measures to be taken to meet the SHS; or the remediator may elect to attain one of the other standards. b) Process Checklist for Remediations Under the Statewide Health Standard ☐ Review the historical information and present use of regulated substances at the property. ☐ Begin site investigation/characterization and gather information about the area on and around the property. ☐ Optional: Begin using the completeness list (see LRP webpage) to help verify that all requirements have been met. ☐ Optional: Determine if the property/site is affected by regulated substances not from the property to determine if the background standard may be appropriate. Contact DEP Regional Office for information. 261-0300-101 / January 19, 2019 / Page II-49 ☐ Submit an NIR for the SHS. Also, provide notice to the municipality, publish a notice in a local newspaper, and obtain reasonable proof of submittal for inclusion with the final report. Procedures for submittal of notifications are contained in Section II.A.3 of this manual. ☐ Continue with the site characterization and required activities, including vapor intrusion evaluation (see Section IV of this manual), needed to complete the final report. ☐ Remediate the site to the SHS. ☐ Demonstrate attainment of the SHS. Methods for demonstrating attainment are described in 25 Pa. Code § 250.707(b) and in Section III.B of this manual. ☐ Calculate the mass of contaminants remediated using the procedure in Section III.D of this manual. ☐ Complete the Final Report Summary electronically in accordance with the instructions on the LRP webpage. ☐ Prepare and submit final report, along with the optional completeness list (if used), to the Department. Reporting requirements are established by 25 Pa. Code § 250.312 and are described in Section II.B.2(f) of this manual. ☐ A postremediation care program must be implemented and documented in the final report including the information required by § 250.204(g) of the regulations if: (1) engineering controls are needed to attain or maintain the SHS; (2 institutional controls are needed to maintain the standard; (3) the fate and transport analysis indicates that the remediation standard, including the solubility limitation, may be exceeded at the POC in the future; (4) the remediation relies on natural attenuation; (5) a postremedy use is relied upon but is not implemented to eliminate complete exposure pathways to ecological receptors; or, (6) mitigative measures are used. ☐ Submit an environmental covenant, if applicable, to the Department. ☐ Receive approval of the final report from the Department, if the final report documents that the person has demonstrated compliance with the substantive and procedural requirements of the SHS (which automatically confers the Act 2 liability protection as set forth in Chapter 5 of Act 2). ☐ Except for the special case of a nonuse aquifer standard (See Section II.B.4(c), when the SHS can be maintained without engineering controls operating, document this to the Department and receive approval to terminate the postremediation care program. 261-0300-101 / January 19, 2019 / Page II-50 c) Selection of MSCs The appropriate MSC for each regulated substance present at a site is determined for each environmental medium, particularly groundwater and soil. The decision tree in Figure II-11 illustrates the thought process that goes into the selection of the appropriate MSCs for groundwater and soil. If values for the compounds on a given site cannot be found in Tables 1 through 4, please check Table 6: Threshold of Regulation Compounds. The values shown in the MSC tables are generally rounded to two significant figures. Due to rounding the numeric values for placement in the tables, the remediator is also permitted to round the concentrations reported by the laboratory to two significant figures for comparison to the MSC values. For example: The chosen MSC value for a certain compound is 2.6 µg/L. If the laboratory reports a result of 2.629 µg/L, the remediator is permitted to round the laboratory’s reported value to 2.6 µg/L and thus is able to attain the standard. However, if the laboratory’s reported concentration is 2.678 µg/L, rounding to two significant figures results in a concentration of 2.7 µg/L and thus exceeds the MSC and is not able to attain the standard. i) Determining Groundwater MSCs MSCs for regulated substances in groundwater are found in Appendix A to Chapter 250, Table 1 for organic substances, and Table 2 for inorganic substances. To use the tables, the remediator needs to know the use status of the aquifer under the site, the naturally occurring level of Total Dissolved Solids (TDS) in the aquifer, and the land use of the site. ii) Determining Soil MSCs In determining the applicable soil standard, the remediator must compare the appropriate soil-to-groundwater numeric value to the direct contact numeric value for the corresponding depth interval within 15 feet from the ground surface. The lower of these two values is the applicable MSC for soil. If either the soil buffer distance (described in 25 Pa. Code § 250.308(b) and (c)) or the equivalency demonstration (described in 25 Pa. Code § 250.308(d)) is met, the soil-to-groundwater numeric value will be deemed to be satisfied, and the soil MSC will be the direct contact numeric value. The soil-to-groundwater numeric value is the MSC for soil at depths below 15 feet, unless either the soil buffer distance or the equivalency demonstration is met. These values are determined in the following manner: 261-0300-101 / January 19, 2019 / Page II-51 Figure II-11: Decision Tree for Selecting Statewide Health Standard MSCs for Groundwater and Soil 261-0300-101 / January 19, 2019 / Page II-52 (a) Choosing the Soil-To-Groundwater Numeric Value The remediator should begin by determining the appropriate soil- to-groundwater numeric value from Part B of Table 3 for organics or Table 4 for inorganics. The numbers in the table include both the value which is 100 times the appropriate groundwater MSC and the number resulting from application of the soil-to- groundwater equation in the regulations (the “generic value”). The remediator must determine the use status of the aquifer underlying the site, its naturally occurring TDS level, and the land use characteristics of the site. The numeric value may then be selected from the appropriate column on the table and compared to the value for the Synthetic Precipitation Leaching Procedure (SPLP), if appropriate. Since the remediator has the choice of which soil- to-groundwater numeric value to use, the remediator may choose the highest of these three values (i.e., 100x GW MSC, the generic value, or the SPLP result) as the soil-to-groundwater numeric value. The remediator must keep in mind that for periodically saturated soils, the generic value to use in this selection process is one-tenth the value listed in the table (see § 250.308(a)(2)(ii) and (a)(4)(ii) of the regulations). The intent of the one-tenth of the generic numeric value provision in the soil-to-groundwater numeric value calculation is to account for the dilution in contaminant concentrations that occurs in soils that are periodically saturated which does not occur in unsaturated soil. For permanently saturated soils, contamination becomes a groundwater contamination issue as the soil is in constant contact with the groundwater rather than being only periodically saturated. The value for the SPLP is the concentration of a regulated substance in soil at the site that does not produce a leachate in which the concentration of the regulated substance exceeds the groundwater MSC. Values for the SPLP could not be published in the tables of MSCs in the regulations because this test must be conducted on the actual site soil. The following procedure should be used to determine the alternative soil-to-groundwater value based upon the SPLP: • During characterization, the remediator should obtain a minimum of ten samples from within the impacted soil area. The four samples with the highest total concentration of the regulated substance should be submitted for SPLP analysis. Samples obtained will be representative of the soil type and horizon impacted by the release of the regulated substance. • Determine the lowest total concentration (TC) that generates a failing (leachate concentration greater than the 261-0300-101 / January 19, 2019 / Page II-53 groundwater MSC) SPLP result. The alternative soil-to- groundwater standard will be the next lowest TC. • If all samples have a passing (leachate concentration less than the groundwater MSC) SPLP result, the alternative soil-to-groundwater standard will be the TC corresponding to the highest SPLP result. The remediator has the option of obtaining additional samples. • If all samples have a nondetect SPLP result, the alternative soil-to-groundwater standard will be the TC corresponding to the highest concentration of each contaminant. The remediator has the option of obtaining additional samples. • If none of the samples generates a passing SPLP, the remediator can obtain additional samples and perform concurrent TC/SPLP analyses to satisfy the above requirements for establishing an alternative soil-to- groundwater standard. (b) Considering Direct Contact Value in Relation to the Soil-to- Groundwater Value and Soil Depth The number selected according to the process outlined in Section II.B.3.b.i of this TGM for the soil-to-groundwater pathway numeric value must then be compared to the appropriate residential or nonresidential, surface or subsurface, direct contact numeric value from Part A of Table 3 or Table 4. The lower of the two numbers is the appropriate MSC for the regulated substance. If the soil buffer distance requirements are met or the equivalency demonstration has been made, then the soil-to-groundwater numeric value is deemed to be satisfied and the MSC is the appropriate direct contact numeric value for the regulated substance. The soil buffer approach incorporates fate and transport considerations; therefore, meeting the soil buffer requirements will not require any additional fate and transport analysis. (c) Selecting Applicable MSCs – Example The process for selecting the appropriate MSCs for a site is illustrated in Figure II-12. This figure represents the cross section of a nonresidential site with soil contaminated with a petroleum product. The aquifer does not qualify as a nonuse aquifer. The remediator is interested in determining and applying the soil MSCs under the SHS. This example shows the process applied to one of the regulated substances: cumene. 261-0300-101 / January 19, 2019 / Page II-54 Figure II-12: Application of the MSC Selection Process 261-0300-101 / January 19, 2019 / Page II-55 Details of the site determined during the site characterization are as follows (see also Figure II-12). • Soil characterized as contaminated with regulated substances from the petroleum product, including cumene (concentration values > PQL, see Section III.G), is shown and extends to a depth of 20 feet. For this example, the remediator characterized the soil to the level of the PQL, but could have selected any concentration level between the SHS and the PQL, with the appropriate justification. • Soil contaminated at levels greater than the applicable SHS is shown as a subset of the contaminated area and extends to a depth of 18 feet. • Samples collected and analyzed according to the methodology in Section II.B.2(c)(ii)(a) established an alternative soil-to-groundwater value of 20 mg/kg. • SPLP testing of site soil was established at 400 mg/kg. • Shale bedrock is present at varying depths between 30 and 35 feet. • The groundwater level is approximately 35 feet, but fluctuates (annual high and low) between 28 to 40 feet and the natural total dissolved solids level in the groundwater is 80 mg/L. • The vertical distance from the bottom of the contaminated area to groundwater is h = 15 feet. Scenario #1 - the above conditions apply, and in addition, the results of sample analysis of the groundwater show no values greater than 3,500 g/L. Scenario #2 - the above conditions apply, and in addition, free floating product (approximately 1 inch) is found on top of the groundwater level, and the concentration of cumene below the groundwater level is 5,000 g/L. 261-0300-101 / January 19, 2019 / Page II-56 The remediator takes the following steps to determine appropriate MSCs for cumene at this site. Groundwater MSC: 1) For Scenario #1 AND Scenario #2: As a first step, turn to LRP regulations, Chapter 250, Appendix A, Table 1 - Medium-Specific Concentrations (MSCs) for Organic Substances in groundwater. The remediator looks for the row for cumene, under the headings “Used Aquifers,” “TDS2500 mg/L,” “NR” (for Nonresidential). The groundwater MSC is 3,500 g/L. Under Scenario #1, the remediator concludes that there is no aquifer area which exceeds the groundwater MSC (3,500 g/L) and, therefore, no attainment demonstration is needed. Under Scenario #2, the remediator concludes that the aquifer area exceeds the groundwater MSC (3,500 g/L) and, therefore, attainment demonstration is needed. Soil MSC: 2) The remediator turns to Chapter 250, Appendix A, Table 3 – Medium-Specific Concentrations (MSCs) for Organic Substances in Soil, Part B, Soil to Groundwater Numeric Values. The remediator looks for the row for cumene, under the Headings “Used Aquifers,” “TDS 2500 mg/L,” “Nonresidential.” The two values listed are: • 100x GW MSC – 350 mg/kg • Generic Value - 2,500 mg/kg The remediator then looks over to the last column on the right for the soil buffer distance – 15 feet. 3) The remediator assesses the use of numeric soil-to- groundwater values. Three options exist under the regulations (§ 250.308). • 100x GW MSC – 350 mg/kg • Generic Value – 2,500 mg/kg • SPLP value – 400 mg/kg (from analysis of site soil—see site characterization. 261-0300-101 / January 19, 2019 / Page II-57 Among the three acceptable values, the generic value of 2,500 mg/kg is the highest. The remediator considers using this option, but first wants to see if the site could qualify for the remaining two options for satisfying the soil-to- groundwater numeric value, the soil buffer and groundwater equivalency options. 4) In examining the soil buffer option, the remediator checks to see if the site meets the three regulatory conditions under 25 Pa. Code § 250.308(b), which states: (b) The soil-to-groundwater pathway soil buffer is the entire area between the bottom of the area of contamination and the groundwater or bedrock and shall meet the following criteria: (1) The soil depths established in Appendix A, Tables 3B and 4B for each regulated substance. (2) The concentration of the regulated substance cannot exceed the limit related to the PQL or background throughout the soil buffer. (3) No karst carbonate formation underlies or is within 100 feet of the perimeter of the contaminated soil area. Karst carbonate formations are limestone or carbonate formations where the formations are greater than 5 feet thick and present at the topmost geologic unit. Areas mapped by the Pennsylvania Geologic Survey as underlain by carbonate formations are considered karst areas unless geologic studies demonstrate the absence of the formations underlying or within 100 feet of the perimeter of the contaminated soil area. Scenario #1 - The remediator concludes that the site meets the conditions for use of the soil buffer alternative to satisfy the soil-to-groundwater numeric value and, therefore, only the direct contact numeric value applies and becomes the soil MSC for cumene. Alternatively, the remediator could have considered use of the groundwater equivalency option [§ 250.308(d)], but this includes the condition that he/she monitor the groundwater for 8 quarters prior to submitting the final report. The remediator instead chooses the soil buffer option above. 261-0300-101 / January 19, 2019 / Page II-58 Scenario #2 - The remediator concludes the site DOES NOT meet the conditions for use of the soil buffer alternative because h=0 since soil contamination extends to the water level and, therefore, there is no depth of clean soil between the bottom of contamination and the groundwater level. The remediator then checks to see if the site meets the requirements for use of the groundwater equivalency option. (25 Pa. Code § 250.308(d) and Section II.B.6(d) of the Technical Manual). The site does NOT qualify because groundwater is contaminated above SHS and background. Therefore, the remediator should consider BOTH the soil- to-groundwater numeric value and the direct contact (DC) value. Chapter 250, Appendix A, Table 3A—Medium-Specific Concentrations (MSCs) for Organic Regulated Substances in Soil, Direct Contact Numeric Values states that the nonresidential numeric value for cumene is: 10,000 mg/kg applied to the 0’-2’ zone in soil 10,000 mg/kg applied to the 2’-15’ zone in soil. The remediator chooses the soil-to-groundwater numeric value based on the generic value of 2,500 mg/kg, which applies to the zone(s) of the soil contaminated above this value: Zone 1—0-18’ (see Figure II-12) Zone 2 – the “smear zone” in the soil column created by groundwater level movement – 28’--40.’ Note that this zone also is considered saturated soil under Chapter 250. Next, the remediator checks to see where each numeric value is applied: DC value Soil-to-GW value Resulting Soil MSC Zone 0’-2’ 10,000 mg/kg 2,500 mg/kg 2,500 mg/kg Zone 2’-15’ 10,000 mg/kg 2,500 mg/kg 2,500 mg/kg Zone 15’-18’ NA 2,500 mg/kg 2,500 mg/kg 261-0300-101 / January 19, 2019 / Page II-59 Zone 28’ to 40’ NA 400 mg/kg 400 mg/kg Zone 28’ to 40’ is periodically saturated soil. The selection of the applicable soil MSC for this zone must consider the requirement that the published generic value be divided by 10. Therefore, the remediator may choose from the following values: 100x GW MSC 350 mg/kg Generic Value 250 mg/kg (0.1 x published value) SPLP Value 400 mg/kg Therefore, the remediator chooses the SPLP result as the applicable soil MSC. For both scenarios, analysis of any attainment samples (determined under Section II.B.2(f)(vii) of this manual) would be compared to the appropriate numeric value for the zone in which the sample was taken, and the attainment test (e.g., 75%/10x) would be applied to the sample set as a whole (e.g., the percentage of samples which exceeded the appropriate numeric value must be 25% and no sample may exceed the appropriate numeric value by more than 10 times [10x]). d) Nonuse Aquifer Determinations i) General Section 250.303 of the regulations provides for options for requesting a nonuse aquifer determination. Anytime a person is proposing an area for nonuse aquifer determination, they must meet the notification requirements of 25 Pa. Code § 250.5, which are described in Section II.A.3, relating to public notice. • A remediator may request from the Department approval to use alternative MSCs in groundwater at the POC when the aquifer under a site is not used or planned to be used for drinking water or agricultural purposes. This determination is to be requested by the remediator, and the Department’s concurrence must be obtained in writing before the remediation may begin. The notice requirements under the nonuse aquifer request are made separate from those under the NIR. Note that an NIR must be submitted with, or prior to, the nonuse aquifer determination request. Although not required, the Department suggests that this request be submitted in conjunction with an NIR. 261-0300-101 / January 19, 2019 / Page II-60 Attachment 49 Regulatory Analysis Form INDEPENDENT REGULA TORY (Completed by Promulgating Agency) (AllComments submitted on this regulation willappear on IRRC’swebsite) (1) Agency — Environmental Protection m (2) Agency Number: Identification Number: 7-486 C IRRC Number: 3057 ,. (3) PA Code Cite: , )%J 25 Pa. Code, Chapter 250 (4) Short Title: Administration of the Land Recycling Program (5) Agency Contacts (List Telephone Number and Email Address): Primary Contact: Laura Edinger, 783-8727, [email protected] Secondary Contact: Patrick McDonnell, 783-8727, [email protected] (6)Type of Rulemaking (check applicable box): LIProposed Regulation [1 Emergency Certification Regulation; Final Regulation [] Certification by the Governor [1 Final Omitted Regulation [1 Certification by the Attorney General (7) Briefly explain the regulation in clear and nontechnical language. (100 words or less) The Department of Environmental Protection (DEP)’s Land Recycling Program implements standards for the cleanup of soil and groundwater contamination from releases of various toxic and carcinogenic chemicals. The amendments to the Land Recycling Program regulations will update one of the three cleanup standards for many regulated substances, specifically the Statewide health cleanup standards, correct errors and omissions, and to clarify certain established program policies. Existing regulation requires that every three years DEP evaluate its standards to consider new scientific information and propose changes as necessary to the medium-specific concentrations (MSCs) that are a part of the Statewide health standards. (8) State the statutory authority for the regulation. Include specific statutory citation. This rulemaking is being made under the authority of Sections 104(a) and 303(a) of the Land Recycling and Remediation Standards Act (the Land Recycling Act or Act 2) (35 P. S. § 6026.104(a) and 6026.303(a)), and Section 1920-A of The Administrative Code of 1929 (71 P.S. §510-20). Section 104(a) of the Land Recycling Act authorizes the Environmental Quality Board (EQB) to adopt Statewide health standards, appropriate mathematically valid statistical tests to define compliance with the Land Recycling Act and other regulations that may be needed to implement the provisions of the Land Recycling Act. Section 303(a) of the Land Recycling Act authorizes the EQB to promulgate Statewide health standards for regulated substances for each environmental medium and methods used to calculate the standards. Section 1920-A authorizes the EQB to formulate, adopt and promulgate rules and regulations that are necessary for the proper work of DEP. (9)Is the regulation mandated by any federal or state law or court order, or federal regulation? Are there any relevant state or federal court decisions? If yes, cite the specific law, case or regulation as well as, any deadlines for action. Section 303(a) of the Land Recycling Act (35 P.S. §6026.303(a)) states: “The Environmental Quality Board shall promulgate Statewide health standards for regulated substances for each environmental medium.” 25 Pa. Code §250.11 requires DEP to regularly review new scientific information that relates to the basis of the MSCs and to propose appropriate regulations to the EQB whenever necessary, but not later than 36 months from the effective date of the most recently promulgated regulations. (10) State why the regulation is needed. Explain the compelling public interest that justifies the regulation. Describe who will benefit from the regulation. Quantify the benefits as completely as possible and approximate the number of people who will benefit. The elimination of public health and environmental hazards on existing commercial and industrial land across the Commonwealth is vital to its use and reuse as commercial and industrial employment, housing, recreation and open-space areas. The reuse of industrial land is an important component of a sound land-use policy that will help prevent the needless development of prime farmland, open-space areas and natural areas and reduce public costs for installing new water, sewer and highway infrastructure. The Administration of the Land Recycling Program regulations provide standards used during the cleanup of contaminated sites in Pennsylvania. These standards apply to all releases of regulated substances that are addressed under the Land Recycling Act, the Hazardous Sites Cleanup Act (35 P.S. 6020.101 et seq.), the Solid Waste Management Act (35 P.S. § 6018.101 et seq.), the Storage Tank and Spill Prevention Act (35 P.S. § 6021.101 et seq.), and the Clean Streams Law (35 P.S. §691.1 et seq.). Releases of regulated substances not only pose a threat to the environment, but also could affect the health and welfare of the general public if they are inhaled or ingested. With new research being conducted every day, it is necessary that the residents of Pennsylvania be adequately protected with site cleanup requirements based on the most up-to-date information. Chemical substances that can have toxic, carcinogenic, or esthetic effects as defined under Act 2 and the regulations promulgated thereunder are widespread in use, and potential contamination of soil and groundwater from accidental spills and unlawful disposal can impact almost any citizen of the Commonwealth. Examples of substances that contain toxic, carcinogenic, or esthetic properties include gasoline and petroleum products, solvents, elements used in the manufacture of metals and alloys, pesticides, herbicides, and some dielectric fluids previously contained in transformers and capacitors. The Land Recycling Act requires the EQB to establish by regulation a uniform Statewide health standard that can be used to eliminate any substantial present or probable future risk to human health, welfare, and the environment. The original standards were promulgated in 1997 and codified in Chapter 250. Section 104(a) of the Land Recycling Act explicitly recognizes that these standards would need to be updated over time as better science became available and as the need for clarification or enhancement of the program became apparent. Updating the standards serves the public, as DEP is able to use the 2 most up-to-date health and scientific information to establish the cleanup standard for exposure to substances that cause cancer or have other toxic effects on human health or welfare. The Statewide health standard is expressed as a list of MSCs, which apply to either soil or groundwater contamination and to residential and non-residential exposure scenarios as authorized under the Land Recycling Act. The changes in the MSCs in these amendments to Chapter 250 serve both the public and the regulated community as they provide clear information on what is required at contaminated sites. Having access to that information allows the public to know the acceptable level of contamination at a site based on the intended use of the property, and it provides remediators with a uniform endpoint to the remediation process. Because each site and situation is unique, it is necessary to provide different MSCs for: 1) specific constituents in groundwater at points of compliance, 2) specific constituents in soil, where there may be direct contact through ingestion or inhalation, and 3) specific constituents in soil that may leech into groundwater. Each of these MSCs is based on the physical, toxicological, and esthetic properties of a specific regulated substance, which are based on scientific sources of information. (11) Are there any provisions that are more stringent than federal standards? If yes, identify the specific provisions and the compelling Pennsylvania interest that demands stronger regulations. No provisions are more stringent than federal cleanup standards. (12) How does this regulation compare with those of the other states? How will this affect Pennsylvania’s ability to compete with other states? The Chapter 250 regulations provide a uniform Statewide health standard that is not available in many other states. These states and the federal government require a site-specific risk analysis at every site to establish a numeric value that is used to determine the completion of soil and groundwater cleanup. The Land Recycling Act provides for a generic Statewide health standard that can be used as an efficient way to clean up sites, particularly where small spills and releases contaminate soil. However, the ability to conduct a risk analysis to establish a cleanup value on an individual-site basis is also available through the site-specific cleanup standard under Land Recycling Act, providing an additional option. The regulations promote and facilitate the remediation and redevelopment of idle and underutilized commercial and industrial sites while protecting the public health, welfare, and the environment. These updates to Chapter 250 will not affect Pennsylvania’s ability to compete with other states. (13) Will the regulation affect any other regulations of the promulgating agency or other state agencies? If yes, explain and provide specific citations. No. (14) Describe the communications with and solicitation of input from the public, any advisory council/group, small businesses and groups representing small businesses in the development and drafting of the regulation. List the specific persons and/or groups who were involved. (“Small Business” is defined in Section 3 of the Regulatory Review Act, Act 76 of 2012.) Members of the Cleanup Standards Scientific Advisory Board (CSSAB) typically have a background in engineering, biology, hydrogeology, statistics, medicine, chemistry, toxicology, or other related scientific disciplines or experience. Some members of the CSSAB represent small businesses and other members work as environment consultants and attorneys and represent small business clients. The CSSAB reviewed the proposed rulemaking in May and October 2013 and reviewed the draft final rulemaking in December 2014. The draft final rulemaking was supported unanimously at the 3 CSSAB meeting held on December 17, 2014. The CSSAB supported all aspects of the proposal except that it questioned the groundwater MSC for Methyl Tertiary Butyl Ether (MTBE) which is based on a U.S. Environmental Protection Agency (EPA) published drinking water advisory. The Storage Tank Advisory Committee (STAC) also reviewed the proposed rulemaking in June and December 2013 and reviewed the draft final rulemaking in March 2015. Members of STAC represent local government, Associated Petroleum Industries of Permsylvania, the Pennsylvania Petroleum Association, the Petroleum Retailers and Auto Repair Association, the Pennsylvania Chemical Industry Council, Tank Installers of Pennsylvania, the Pennsylvania Environmental Council, a registered professional engineer, a hydrogeologist, and other members of the public. STAC is authorized by the Pennsylvania Tank Act to provide advice to DEP in regulations related to the Storage Tank and Spill Prevention Act. STAC supported the draft final rulemaking, except it questioned the groundwater MSC for MTBE, noting the same issue as the CSSAB. IRRC requested that the advisory committees’ concerns related to the MSCs for MTBE be addressed in the Preamble and the Regulatory Analysis Form of the final regulation. IRRC requested an explanation of how the MTBE standards meet the criteria established in Act 2 and how the MTBE standards adequately protect the public health, safety and welfare. It also requested an explanation of the statutory authority for a non-health-based method tbr calculating the MTBE MSCs be provided in the final regulation. In the original Chapter 250 regulations published in the Pennsylvania Bulletin on August 16, 1997, the Board promulgated a groundwater MSC for MTBE of 20 jig/L based on a draft lifetime HAL published by EPA. In subsequent publications of the federal drinking water standards, EPA listed MTBE under a separate table titled “Drinking Water Advisories” with an advisory level of 20 ig!L—the one at which water would either have an odor or taste. The Board decided not to propose a change in the MSC for MTBE because drinking water advisory level reflects no change in the degree of protectiveness from the original draft HAL. EPA continues to indicate it is further evaluating MTBE for a MCL determination. The Land Recycling Act requires federally or state promulgated groundwater MCLs to be the groundwater MSC. (35 P.S. §6026.30 1(c)). Currently six regulated substances have groundwater MSCs that are federally promulgated MCLs that are solely based on secondary effects (aesthetic thresholds, e.g. taste and odor). Since the Land Recycling Act requires the use of MCLs when available, the Act therefore allows for groundwater MSCs to be based on drinking water standards that are not health based, but are aesthetic based. Therefore, the Land Recycling Act provides for groundwater MSCs that are based on taste and odor in addition to being health based. The Department has determined that taste and odor are esthetic values that are important to human welfare. (15) Identify the types and number of persons, businesses, small businesses (as defined in Section 3 of the Regulatory Review Act, Act 76 of 2012) and organizations which will be affected by the regulation. How are they affected? These technical amendments to the Land Recycling regulations can affect property owners of contaminated sites, operators of commercial and industrial facilities where hazardous substances are spilled onto soil or are released into groundwater, and purchasers of historically contaminated brownfield sites that are intended for redevelopment. It can also affect members of the public and the business community that may be threatened with exposure to releases and spills. The types of businesses affected could include gasoline service stations, fuel distribution facilities, commercial facilities that use toxic or carcinogenic chemicals, commercial or industrial manufacturing operations, and redevelopers of brownfield sites. There are about 12,000 facilities in the Commonwealth that contain regulated underground and above ground storage tanks, including gasoline 4 stations and fuel distribution and storage facilities. Some of these facilities would include small gasoline station owners. Small businesses would also make up some of the commercial facilities that use toxic or carcinogenic substances. Because of the broad potential reach of this regulation, it is difficult for DEP to identify further specifics on the types and numbers of small businesses that would potentially be affected if they contaminate a property by releasing a regulated substance. The amendments to the Chapter 250 regulations are not expected to increase costs or provide any significant savings for the regulated community. MSCs have been promulgated for about 390 regulated substances. Under this amendment, the numeric values in the MSC tables changed for about 190 of the substances for groundwater and 270 of the substances for soil. About 10% of the values are being lowered, indicating a more stringent cleanup is required at a site. About 90% of the values are increasing, which may indicate a less stringent cleanup at a site. Values for many commonly encountered regulated substances, including those found in gasoline and in solvents, are either not changing or are slightly increasing. The cost impact on a given site remediation would depend on the specific regulated substances being remediated and the specific soil and groundwater conditions at the site. For example, a site with a tight clay soil profile may not allow contaminants to spread horizontally or vertically. Therefore, the amount of soil to be excavated in this situation will not significantly change to meet a lower or higher MSC value. However, it is important to note that the site remediator always has the option of using a site- specific cleanup standard. Most small businesses that DEP can identify as possibly being affected by this regulation are owners of small gasoline stations. These amendments are unlikely to affect these businesses because the majority of the MSC values, including petroleum compounds, are increasing and therefore becoming less stringent. In addition, many of these businesses are required to participate in the Underground Storage Tank Indemnification Fund, which provides insurance coverage for the costs to clean up releases from their tanks, regardless of the MSC value used at the site. Overall, no type of person or business is expected to be adversely affected by the updates to Chapter 250. Accordingly, the Department believes that there will be little, if any, adverse impact to small businesses. (16) List the persons, groups or entities, including small businesses that will be required to comply with the regulation. Approximate the number that will be required to comply. These technical amendments to the Land Recycling regulations will affect owners, operators and purchasers of properties and facilities who volunteer or are required to perform remediation of contaminated sites pursuant to Chapter 250 standards. The types of businesses that may need to comply with the regulations include gasoline service stations, fuel distribution facilities, commercial facilities that use toxic or carcinogenic chemicals, manufacturing operations, and redevelopers. There are about 12,000 facilities in the Commonwealth that contain regulated underground and aboveground storage tanks, including gasoline stations and fuel distribution and storage facilities. Some of these facilities would include small gasoline station owners. Small businesses would also make up some of the commercial facilities that use toxic or carcinogenic substances. Not all of these facilities have releases or accidental spills that result in a cleanup obligation. The number of remediation actions completed can vary from year to year. The number of voluntary remediation actions completed each year is usually in the range of 200 - 400. The number of required remediations (mostly regulated storage tank sites) completed each year is usually in the range of 400- 600. 5 These amendments will affect all types of responsible parties, including individual homeowners and small businesses, implementing a rernediation under Chapter 250. No type of person or business is expected to be adversely affected by these updates to Chapter 250. Please also see the response to item (15) above. (17) Identify the financial, economic and social impact of the regulation on individuals, small businesses, businesses and labor communities and other public and private organizations. Evaluate the benefits expected as a result of the regulation. The amendments to the Statewide health MSCs reflect some of the latest toxicological data on human health effects when exposed to hazardous and toxic chemicals. This assures potentially affected citizens of the Commonwealth and persons interested in buying and redeveloping contaminated sites that the MSCs are protective of human health and welfare. The amendments to the Chapter 250 regulations are not expected to increase costs or provide any significant savings for the regulated community. Under these amendments, the numeric values in the MSC tables changed for about 190 of the substances for groundwater and 270 of the substances for soil. About 10% of the values are being lowered, indicating a more stringent cleanup is required at a site. About 90% of the values are increasing, which may indicate a less stringent cleanup at a site. However, values for many commonly encountered regulated substances, including those found in gasoline and in solvents, are either not changing or are slightly increasing. Persons conducting remediation under the Land Recycling Act can choose from three different cleanup standards: background, Statewide health or site-specific. Updating Statewide health standard MSCs will not limit cleanup options available to remediators under other cleanup standards. The Department believes that there will be little if any adverse impact to small businesses. (18) Explain how the benefits of the regulation outweigh any cost and adverse effects. The amendments to the Statewide health MSCs reflect the latest toxicological data on human health effects when exposed to hazardous and toxic chemicals. This assures potentially affected citizens of the Commonwealth and persons interested in buying and redeveloping contaminated sites that the MSCs are protective of human health and welfare. The Department believes that there will be little if any adverse effects from this regulation. Please also see the response to item (15) above. (19) Provide a specific estimate of the costs and/or savings to the regulated community associated with compliance, including any legal, accounting or consulting procedures which may be required. Explain how the dollar estimates were derived. The amendments to the Chapter 250 regulations are not expected to increase costs or provide any significant savings for the regulated community. Please also see the response to item (15) above. 6 (20) Provide a specific estimate of the costs and/or savings to the local governments associated with compliance, including any legal, accounting or consulting procedures which may be required. Explain how the dollar estimates were derived. The amendments are not expected to increase or decrease costs or savings for local governments. In some cases local governments are remediators; however, as with all other types of remediators, the regulation is not expected to increase or decrease costs. Please also see the response to item (15) above. (21) Provide a specific estimate of the costs and/or savings to the state government associated with the implementation of the regulation, including any legal, accounting, or consulting procedures which may be required. Explain how the dollar estimates were derived. The amendments are not expected to impact costs or savings for state government agencies. In some cases state government agencies are remediators; however, as with all other types of remediators, the regulation is not expected to increase costs or result in significant savings. Please also see the response to item (15) above. (22) For each of the groups and entities identified in items (19)-(2 1) above, submit a statement of legal, accounting or consulting procedures and additional reporting, recordkeeping or other paperwork, including copies of forms or reports, which will be required for implementation of the regulation and an explanation of measures which have been taken to minimize these requirements. The amendments to Chapter 250 will not require any additional recordkeeping or paperwork. (23) In the table below, provide an estimate of the fiscal savings and costs associated with implementation and compliance for the regulated community, local government, and state government for the current year and five subsequent years. This amendment is not expected to impact costs or savings Current FY FY +1 FY +2 FY +3 FY +4 FY +5 Year Year Year Year Year Year SAVINGS: $ $ $ $ $ $ Regulated Community $0 $0 $0 $0 $0 $0 Local Government $0 $0 $0 $0 $0 $0 State Government $0 $0 $0 $0 $0 $0 Total Savings $0 $0 $0 $0 $0 $0 COSTS: $0 $0 $0 $0 $0 $0 Regulated Community $0 $0 $0 $0 $0 $0 Local Government $0 $0 $0 $0 $0 $0 State Government $0 $0 $0 $0 $0 $0 Total Costs $0 $0 $0 $0 $0 $0 7 REVENUE LOSSES: $0 $0 $0 $0 $0 $0 Regulated Community $0 $0 $0 $0 $0 $0 Local Government $0 $0 $0 $0 $0 $0 State Government $0 $0 $0 $0 $0 $0 Total Revenue Losses SO $0 $0 SO $0 j_$0 (23a) Provide the past three year expenditure history for programs affected by the regulation. Program FY 3 FY 2 FY I Current FY 2012-13 2013-14 2014-15 2015-16 Environmental Protection $74,547,000 $75,184,000 $84,438,000 $87,172,000 Operations Environmental Program $24,965,000 $25,733,000 $28,517,000 S28,277,000 Management Industrial Land Recycling Fund $189,000 $66,000 $212,000 $300,000 Hazardous Site $23,000,000 $21,708,000 $18,546,000 $27,000,000 Cleanup Fund Storage Tank $5,842,000 $6,526,000 $6,883,000 $7,161,000 (24) For any regulation that may have an adverse impact on small businesses (as defined in Section 3 of the Regulatory Review Act, Act 76 of 2012), provide an economic impact statement that includes the following: (a) An identification and estimate of the number of small businesses subject to the regulation. Please see the response to item (15) above. The types of businesses affected could include gasoline service stations, fuel distribution facilities, commercial facilities that use toxic or carcinogenic chemicals, manufacturing and industrial operations, and redevelopers. There are about 12,000 facilities in the Commonwealth that contain regulated underground and aboveground storage tanks, including gasoline stations and fuel distribution and storage facilities. Some of these facilities would include small gasoline station owners. Small businesses would also make up some of the commercial facilities that use toxic or carcinogenic substances. Due to the broad potential reach of this regulation, it is difficult for DEP to identify further specifics on the type and number of small businesses that would potentially be affected if they contaminate a property by releasing a regulated substance. (b) The projected reporting, recordkeeping and other administrative costs required for compliance with the proposed regulation, including the type of professional skills necessary for preparation of the report or record. The amendments to the Chapter 250 regulations do not add any new procedures, recordkeeping or compliance efforts. 8 (c) A statement of probable effect on impacted small businesses. - - -- The amendments to the Chapter 250 regulations are not expected to increase costs or provide any significant savings for small businesses. MSCs have been promulgated for 390 regulated substances. Under this amendment, the numeric values in the MSC tables changed for about 190 of the substances for groundwater and 270 of the substances for soil. About 10% of the values are being lowered, indicating a more stringent cleanup is required at a site. About 90% of the values are increasing, which may indicate a less stringent cleanup at a site. However, values for many commonly encountered regulated substances, including those found in gasoline and in solvents, are either not changing or are slightly increasing. The cost impact on a given site remediation would depend on the specific regulated substances being remediated and the specific soil and groundwater conditions at the site. For example, a site with a tight clay soil profile may not allow contaminants to spread horizontally or vertically. Therefore, the amount of soil to be excavated in this situation will not significantly change to meet a lower or a higher MSC value. Most small businesses DEP can readily identify that are impacted by these revisions will be owners of small gasoline stations. The amendments are unlikely to negatively affect these businesses because the majority of the MSC values, including petroleum compounds, are increasing and therefore becoming less stringent. In addition, many of these businesses are required to participate in the Underground Storage Tank Indemnification Fund, which provides insurance coverage for the costs to clean up releases from the storage tanks, regardless of the MSC value used at a site. Small businesses that handle hazardous substances can use pollution prevention techniques available through various assistance programs to prevent spills that would result in contamination of soil and groundwater. In addition, background and site-specific cleanup standards are available and not affected by the updates to the Statewide health MSCs. Small businesses may be eligible for brownfield financial assistance programs when they are not responsible for the soil and groundwater contamination. (d) A description of any less intrusive or less costly alternative methods of achieving the purpose of the proposed regulation. The Department believes that there will be little, if any, adverse effects from this regulation. The Department is unaware of any less intrusive or less costly alternative methods of achieving the purpose of the regulation, which is to update various MSCs based on current scientific information. Background and site-specific cleanup standards are available and not affected by the updates to the Statewide health MSCs. (25) List any special provisions which have been developed to meet the particular needs of affected groups or persons including, but not limited to, minorities, the elderly, small businesses, and farmers. The amendments to Chapter 250 do not include special provisions developed to meet the needs of any groups listed because they are not expected to adversely affect any listed group. Please see the responses to items (15), (17) and (24) above. 9 (26) Include a description of any alternative regulatory provisions which have been considered and rejected and a statement that the least burdensome acceptable alternative has been selected. The Land Recycling Act and the Chapter 250 regulations require the periodic update of the Statewide health standard. Background and site-specific cleanup standards are available and are not affected by these updates to the Statewide health MSCs. (27) Tnconducting a regulatory flexibility analysis, explain whether regulatory methods were considered that will minimize any adverse impact on small businesses (as defined in Section 3 of the Regulatory Review Act, Act 76 of 2012), including: a) The establishment of less stringent compliance or reporting requirements for small businesses; b) The establishment of less stringent schedules or deadlines for compliance or reporting requirements for small businesses; c) The consolidation or simplification of compliance or reporting requirements for small businesses; d) The establishment of performing standards for small businesses to replace design or operational standards required in the regulation; and e) The exemption of small businesses from all or any part of the requirements contained in the regulation. The amendments are not expected to have any adverse impact on small businesses; therefore, no regulatory methods were considered to minimize any adverse impact on small businesses. Background and site-specific cleanup standards are available and are not affected by the updates to the Statewide health MSCs. (28) If data is the basis for this regulation, please provide a description of the data; explain in detail how the data was obtained, and how it meets the acceptability standard for empirical, replicable and testable data that is supported by documentation, statistics, reports, studies or research. Please submit data or supporting materials with the regulatory package. If the material exceeds 50 pages, please provide it in a searchable electronic format or provide a list of citations and internet links that, where possible, can be accessed in a searchable format in lieu of the actual material. If other data was considered but not used, please explain why that data was determined not to be acceptable. Section 303 of the Land Recycling Act (35 P. S. § 6026.303) and the 25 Pa. Code 250.11 require the periodic update of the Statewide health standard which are based on nationally recognized, peer- reviewed toxicological data, including cancer slope and unit risk factors, reference dose values, and reference concentrations published under the Integrated Risk Information System (IRIS), the National Center for Environniental Assessment, Provisional Peer-Reviewed Toxicity Values (PPRTV), the Health Effects Assessment Summary Tables, Agency for Toxic Substances and Disease Registry (ATSDR) Toxicological Profiles, and California EPA Cancer Potency Factors and Chronic Reference Exposure Levels. This information is extensively published by the United States Environmental Protection Agency (www.epa.gov) and the United States Centers for Disease Control (www.cdc.gov) and is used by all state environmental and health departments in the country for conducting risk assessments for potential exposure to contaminants in soil and groundwater. 10 (29) Include a schedule for review of the regulation including: A. The date by which the agency must receive public comments: June 17, 2014 B. The date or dates on which public meetings or hearings will be held: N/A C. The expected date of promulgation of the proposed regulation as a final-form regulation: Quarter 2, 2016 D. The expected effective date of the final-form regulation: Quarter 2, 2016 E. The date by which compliance with the final-form regulation will be required: Quarter 2, 2016 F. The date by which required permits, licenses or other approvals must be obtained: N/A (30) Describe the plan developed for evaluating the continuing effectiveness of the regulations afier its implementation. DEP evaluates the effectiveness of the Land Recycling Program and the Chapter 250 regulations on an ongoing basis. The efforts include ongoing tracking of remediation actions completed under the program and preparation of an annual program report. When these amendments become effective, DEP will be required to review the MSCs and update them, if necessary, within three years. 11 Attachment 50 Attachment 51 ÿ ÿÿ ÿ ÿ ÿÿ! " #ÿ$ ! ÿ%ÿ&! #ÿ' (ÿ)ÿ0 1 ' @UaBÿUB @ABCDEBFÿHIAPÿQÿRSSDTUAVISFÿWBTX YI`Ua`ÿbBUcIESUVd eDUBÿVDÿfDBBITV 234555( 1 (6 7"!"889 98 ÿ ÿÿ ÿ ÿ ÿÿ! " #ÿ$ ! ÿ%ÿ&! #ÿ' (ÿ)ÿ0 1 ' @ABCÿAC 234555( 1 (6 7"!"889 8 ÿ ÿÿ ÿ ÿ ÿÿ! " #ÿ$ ! ÿ%ÿ&! #ÿ' (ÿ)ÿ0 1 ' TBUCÿBC @ABCÿEAÿFBGHÿIPQQÿRSAIBQG 234555( 1 (6 7"!"889 8 ÿ ÿÿ ÿ ÿ ÿÿ! " #ÿ$ ! ÿ%ÿ&! #ÿ' (ÿ)ÿ0 1 ' @`aHÿ`H @AAÿCDEAFGÿHIPAQÿRSTTUUVÿRSXYUTTS 234555( 1 (6 7"!"889 8 ÿ ÿÿ ÿ ÿ ÿÿ! " #ÿ$ ! ÿ%ÿ&! #ÿ' (ÿ)ÿ0 1 ' @QWXÿQX @AAÿCDDÿEFGHIAI PQARÿSHFTQDAÿUCVWAI 234555( 1 (6 7"!"889 88 Attachment 52 Table of Contents 1. Introduction ...... 1 1.1 Facility Description ...... 1 1.2 Facility Operational History and Current Use ...... 1 1.3 Regulatory History/Overview ...... 3 1.4 Selection of Constituents of Concern ...... 5 1.5 Selection of Applicable Standards and Screening Levels ...... 6 1.5.1 Soil ...... 6 1.5.2 Groundwater ...... 7 1.5.3 Potential Vapor Intrusion into Indoor Air ...... 7 2. Environmental Setting ...... 7 2.1 Hydrology and Topography...... 8 2.1.1 Historical Topography and Natural Depositional Environments ...... 8 2.1.2 Post-Industrialization ...... 9 2.2 Regional Geology and Hydrogeologic Conditions ...... 9 2.2.1 Coastal Plain Deposits ...... 9 2.2.1.1 Anthropogenic Fill ...... 9 2.2.1.2 Quaternary Deposits ...... 10 2.2.1.2.1 Recent (Holocene) Alluvium ...... 10 2.2.1.2.2 Pleistocene Alluvium ("Trenton Gravel") ...... 11 2.2.1.3 Cretaceous Deposits ...... 12 2.2.1.3.1 Upper Clay Unit ...... 13 2.2.1.3.2 Upper Sand Unit ...... 13 2.2.1.3.3 Middle Clay Unit...... 13 2.2.1.3.4 Middle Sand Unit ...... 14 2.2.1.3.5 Lower Clay Unit ...... 14 2.2.1.3.6 Lower Sand Unit ...... 15 2.2.2 Bedrock ...... 16 3. Soil Investigation ...... 16 3.1 Summary of Previous Soil Analytical Results ...... 17 3.2 Historic Product Handling/Storage Areas ...... 18 3.3 Open Storage Tank Incidents ...... 18 3.3.1 GP T81 (Former PADEP Tank 121A, Incident 45692) ...... 19 3.3.2 GP 676 (Former Tank GPU 676, PADEP Tank 130A, Incident 4844) ...... 19 3.3.3 GP 797 (Former PADEP Tank 097A, Incident 29122) ...... 19 3.4 Historic Releases ...... 20 3.4.1 ‘Area West of’ GP 676, or ‘2000 Surface Release’ ...... 20 3.4.2 1733 Unit ...... 21 3.4.3 Transfer Line Located Northeast of No. 4 Boiler House...... 21 3.4.4 1332 Line ...... 21 3.4.5 Main Office ...... 21 GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page i Table of Contents 3.5 Delineation of Direct Contact MSC/SSS Exceedances ...... 22 3.6 Site Characterization in the 0-2 ft. bgs interval, 2-15 ft bgs Interval and Beneath LNAPL22 4. Groundwater Investigation ...... 23 4.1 Historic Groundwater Investigations ...... 23 4.2 Well Installation Activities...... 23 4.3 Groundwater Sampling Events ...... 24 4.4 Well Gauging Activities ...... 25 5. Site-Specific Hydrogeologic Conditions ...... 25 5.1 Geologic Formations and Units Observed ...... 26 5.1.1 Anthropogenic Fill ...... 26 5.1.2 Recent (Holocene) Alluvium ...... 26 5.1.3 Trenton "Gravel" ...... 26 5.1.4 Upper Clay Unit/Upper Sand Unit/Middle Clay/Middle Sand/Lower Clay ...... 26 5.1.5 Lower Sand Unit ...... 27 5.1.6 Crystalline Bedrock ...... 27 5.2 Aquifer Hydraulic Properties ...... 27 5.2.1 Methodology for Evaluation of Hydraulic Data ...... 27 5.2.2 Unconfined (Water-Table) Aquifer ...... 27 5.2.2.1 Hydraulic Heads and Groundwater Flow ...... 28 5.2.3 Semi-confined (Lower) Aquifer ...... 28 6. LNAPL Investigation ...... 29 6.1 LNAPL Characterization Sampling ...... 29 6.2 LNAPL Distribution ...... 30 7. Vapor Investigation ...... 30 7.1 Indoor Air Sampling ...... 30 7.2 Air Sampling over LNAPL Plumes ...... 32 8. Quality Assurance/Quality Control ...... 32 8.1 Equipment Decontamination ...... 33 8.2 Equipment Calibration ...... 33 8.3 Sample Preservation ...... 33 8.4 Documentation ...... 33 9. Conceptual Site Model ...... 33 9.1 Description and Site Use ...... 33 9.2 Geology and Hydrogeology ...... 34 9.2.1 Geologic Framework ...... 34 9.2.2 Unconfined (Water-Table) Aquifer ...... 34 9.2.3 Lower Aquifer (Semi-Confined) ...... 35 GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page ii Table of Contents 9.3 Compounds of Concerns ...... 35 9.3.1 Soil ...... 35 9.3.2 Groundwater ...... 35 9.3.3 Indoor/Ambient Air ...... 36 9.4 LNAPL Distribution and Mobility ...... 36 9.5 Qualitative Fate and Transport of Selected Compounds ...... 36 9.6 Potential Migration Pathways and Site Receptors ...... 37 10. Qualitative Fate and Transport Assessment ...... 37 10.1 Geologic Framework ...... 38 10.2 Hydrogeology ...... 38 10.2.1 Unconfined (Water-Table) Aquifer ...... 38 10.2.2 Lower Aquifer (Semi-Confined) ...... 38 10.3 Hydrogeology and Topography ...... 39 10.4 Anthropogenic Features...... 39 10.4.1 Historic Fill ...... 39 10.4.2 Former Remediation Systems ...... 40 10.5 Groundwater Constituents of Concern ...... 40 10.5.1 Unconfined (Water Table) Aquifer ...... 40 10.5.2 Lower Aquifer ...... 40 10.6 Potential Onsite and Offsite Receptors ...... 40 10.7 Plans for Quantitative Fate and Transport Analysis ...... 41 11. Ecological Assessment ...... 41 12. Community Relations Activities ...... 42 13. Conclusions and Recommendations ...... 42 13.1 Soil ...... 42 13.2 Groundwater ...... 43 13.2.1 Unconfined (Water-Table) Aquifer ...... 43 13.2.2 Lower Aquifer ...... 43 13.3 Vapor Intrusion ...... 43 13.4 LNAPL ...... 43 14. References ...... 43 GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page iii 1. Introduction This Remedial Investigation (RI) Report (RIR) has been prepared for Area of Interest (AOI) 6, also known as Girard Point Chemicals Processing Area, at the Philadelphia Energy Solutions Refining and Marketing LLC (PES) Philadelphia Refining Complex (facility). Sunoco Inc. (R&M) (Sunoco) transferred the facility to PES on September 8, 2012. Sunoco retained the remediation liability prior to this date. The remediation liability was transferred to Philadelphia Refinery Operations, a series of Evergreen Resources Group, LLC (Evergreen) on December 30, 2013. The remediation program is currently being performed under a Buyer Seller Agreement signed by Sunoco, PES, and the Pennsylvania Department of Environmental Protection (PADEP) in September 2012. Site remediation at the facility is ongoing as part of previously-established programs and the 2012 Buyer Seller Agreement. The facility has operated, and is planning to continue operating, as an oil refinery, marketing terminal, and petrochemical complex. 1.1 Facility Description The facility is located along the banks of the Schuylkill River in the City of Philadelphia, Philadelphia County, Pennsylvania. Portions of the facility occupy both the eastern and western Schuylkill River banks. The facility, which is located on industrial property, covers approximately 1,300 acres of land with access restricted by fencing and security measures. The area surrounding the property is characterized by a mixture of residential, commercial, and industrial properties. Current operations at the facility consist of the production of basic petrochemicals for the chemical industry. AOI 6, also known as the Girard Point Chemicals Processing Area, encompasses approximately 100 acres and is located on the east side of the Schuylkill River. AOI 6 is a wedge-shaped property bordered by Lanier Avenue/AOI 3 to the east, Penrose Avenue (Route 291)/Platt Memorial Bridge/AOI 5 to the south and Pennypacker Avenue/AOI 7 to the north (Figures 1 and 2). The entire western boundary of AOI 6 along the Schuylkill River is bound by a sheet pile wall. The extent of the sheet pile wall (“bulkhead”) is shown on Figure 2. 1.2 Facility Operational History and Current Use The facility has a long history of petroleum transportation, storage, and processing. The oldest portion of the facility started petroleum related activities in the 1860s, when the Atlantic Refining Company was established as an oil distribution center. In the 1900s, crude oil processing began and full-scale gasoline production was initiated during World War II. In addition to refining crude oil, various chemicals, such as acids and ammonia, were also produced at the facility for a time. The facility has operated continuously as a refining, product distribution, and storage facility. Use of the facility has remained similar following the transfer of ownership to PES. Historically, AOI 6 consisted of numerous above ground storage tanks (ASTs) containing benzene, toluene, naphtha and other fuel stocks. A sulfuric acid plant was located along the northern boundary of the AOI. A gasoline treating unit, two reformer units, a BDDA (soap) unit, and a thermal hydro-dealkylation unit were also located in this area. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 1 Currently, AOI 6 consists of Udex and cumene units, reformer with associated naphtha hydrotreater, diesel hydrotreater, tankage, boiler house and associated feed water treatment, maintenance buildings, lay-down yards, control rooms, office buildings, the # 2 oil-water separator, remote Laboratory and new Scale House. On October 13, 2017, an updated building survey for AOI 6 was completed. During this survey 16 structures were identified as routinely occupied or potentially occupied. These buildings included: Building 6636, 24 Gate Building 295, Lab/Bottle Washing Building 163, Girard Point Training Building 651, Girard Point Main Office Building 650, Capital Projects Tank Group Trailers, Control Room 739, Trade Shops 178, Carpenter Shop 726, North Tank Field Blockhouse 475, WTP Control Room 745, Control Room 6627, Control Room south of Boiler House #3, Former Locker House associated with former Boiler House #2, and Office near Separator. The characteristics of several of these buildings, refinery lab/bottle washing, Capital project tank group trailers, control room south of Boiler House #3 and former Locker House near former Boiler House #2/Process Building were such that vapor intrusion is not considered a complete pathway as is further discussed in Section 7.1. The building-specific conditions are as follows: • Refinery Lab/Bottle Washing Building 163 – broken windows visible throughout that allows outdoor air flow • Capital Projects Tank Group Trailers – elevated trailers with perforated soffit-style skirt that allows outdoor air flow • Control Room south of Boiler House #3 – elevated without a skirt • Former Locker House near former Boiler House #2/Process Building – locked and inaccessible, not occupied • Office near Separator – blast resistant building sitting on ground and fork truck holes at the surface (to facilitate relocation) • Paint Shop Building 701 – accessible but unoccupied • Insulation Building 265 – unoccupied building used for storage There are two leaded tank bottom SWMUs (SWMU Nos. 92 and 95) located in AOI 6 (Figure 2) that were addressed in several previous Resource Conservation and Recovery Act (RCRA) investigations as part of the United States Environmental Protection Agency (USEPA) Corrective Action process and during the Act 2 site characterization activities. The 27 Pump House Total Fluids Recovery System was installed in November 2001, the system included 12 total fluid recovery wells in the vicinity of the former 27 Pump House. The 27 Pump House Total Fluids Recovery system was turned off September 20, 2010 due to absence of recoverable LNAPL. Passive remediation began on October 10, 2010 with the installation of absorbent socks in wells B-124, B-132, B-137, B-139, B-142, B-143, and B-147. Based on limited recoverable LNAPL in the proximal wells, passive remediation was discontinued on January 26, 2015. Groundwater gauging of select monitoring wells in AOI 6 occurs on an annual basis during the second quarter of each year by Stantec Consulting Corporation (Stantec). Annual gauging activities and results are reported to the PADEP and EPA in Quarterly Reports prepared by Evergreen. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 2 1.3 Regulatory History/Overview Sunoco and the PADEP entered into a Consent Order & Agreement (CO&A) in December 2003 with respect to the facility. Sunoco's Phase I Remedial Plan (Phase I Plan), dated November 2003, was included as an attachment to the CO&A. In accordance with the CO&A and Phase I Plan, a Current Conditions Report and Comprehensive Remedial Plan (CCR) was prepared by Sunoco in June 2004. The Phase I Plan and the CCR divided the facility into 11 AOIs, and presented a prioritization of the AOIs based on specific risk factors. The CCR also presented the Phase II remedial approach and schedule to characterize each of the 11 AOIs, and to conduct Phase I and II corrective action activities in accordance with the 2003 CO&A and the Phase I Plan. Since 2003, Sunoco has performed site characterization activities at all 11 AOIs in accordance with the 2003 CO&A. Sunoco has prepared and submitted a corresponding Site Characterization Report (SCR) for each AOI in accordance with the Revised Phase II Corrective Action Activities schedule that was included in the CCR. In October 2006, Sunoco submitted a notice of intent to remediate (NIR) to the PADEP for the facility, entering the facility into the Act 2 program. This NIR was later updated and submitted to the PADEP in November 2014 in order to revise the ownership identity to PES and the remediator identity to Evergreen. In November 2011, the facility was formally entered into the PA One Cleanup Program with the USEPA Region III and PADEP. In November 2011, Sunoco submitted a revised Work Plan for Sitewide Approach under the One Cleanup Program (Work Plan for Sitewide Approach). As previously discussed, characterization and remediation work at the facility is currently being performed under the September 2012 Buyer Seller Agreement signed by Sunoco, PES, and the PADEP. The following provides a timeline of major events and submissions for the facility and AOI 6: 2004 • The PADEP and USEPA signed an agreement entitled "One Cleanup Program Memorandum of Agreement (MOA or One-Cleanup Program)," which clarifies how sites remediated under Pennsylvania's Voluntary Cleanup Program may satisfy RCRA corrective action requirements through characterization and attainment of remediation standards established under the Pennsylvania Land Recycling and Environmental Remediation Standards Act (Act 2). • Langan prepared the CCR for the Philadelphia Refinery and the Sunoco Logistics Belmont Terminal. 2005 • PADEP, USEPA, and Sunoco agreed that the One Cleanup Program would benefit the project by merging the remediation obligations under the various programs into one streamlined approach which would be conducted under the existing 2003 CO&A. 2006 • Sunoco submitted an NIR to the PADEP for the Philadelphia Refinery thereby entering the facility into the Act 2 program. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 3 • A Site Characterization Work Plan (Work Plan) for AOI 6 was submitted in February 2006 to the PADEP and the Environmental Protection Agency (EPA). This Work Plan summarized proposed activities to be completed to characterize AOI 6 in accordance with the objectives of the 2004 CCR. • The Work Plan was implemented between March and June 2006 and the results were summarized in the Site Characterization Report that was submitted to PADEP and EPA in September 2006. 2011 • On November 8, 2011, the USEPA provided an acknowledgment letter to Sunoco formally accepting the Sunoco Facility into the One Cleanup Program. • Sunoco submitted the Work Plan for Site Wide Approach to document the site-wide remedial approach extending beyond the requirements of the 2003 CO&A. The PADEP and USEPA reviewed and provided input to this report. Sunoco submitted a letter of commitment stating the facility would be remediated according to the Work Plan for Site Wide Approach. 2012 • Sunoco transferred the facility to PES. • Sunoco, PES, and PADEP signed the Buyer-Seller Agreement that established the environmental remediation and management obligations of Sunoco and PES following the sale of the facility. 2013 • The legacy remediation liability for environmental impacts existing prior to the conveyance of the facility to PES was transferred from Sunoco to Evergreen. • Sunoco prepared and submitted a SCR/RIR in September 2013 to formerly satisfy the requirements Act 2. This SCR/RIR describe site characterization work included in the 2006 AOI 6 SCR, as well site characterization work completed in 2012 to supplement the 2006 work. • The PADEP provided Evergreen comments on the 2013 SCR/RIR. 2014 • Evergreen submitted an updated NIR to the PADEP for the facility. 2015 • Langan, on behalf of Evergreen, submitted a Human Health Risk Assessment (HHRA) Report to establish a site-specific standard (SSS) for lead in soil at the facility, the Sunoco Logistics Belmont Terminal, and the Sunoco Partners Marcus Hook Industrial Complex (Langan, 2015). • The HHRA was approved by the PADEP in a letter dated May 6, 2015 establishing a SSS of 2,240 milligrams per kilogram (mg/kg) for lead in soil. On February 19, 2016 the PADEP, Evergreen, Aquaterra and GHD met to discuss the Work Plan. The PADEP provided comments to the Work Plan via email on February 25, 2016. In accordance with the Work Plan for Site Wide Approach, Evergreen is submitting this RIR for AOI 6 to formally GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 4 satisfy the requirements of Act 2 as specified in 25 PA Code §250.408. This RIR describes site characterization work conducted following the last submittal (2013 SCR/RIR). Activities that have been performed in order to complete characterization as required by an RIR under Act 2 include: • Additional characterization of surface soil (0 to 2 feet below ground surface [ft. bgs] interval) and subsurface soil (2 to 15 ft. bgs) including targeted soil investigations in potential contaminant source areas, such as historic product handling and storage locations, open storage tank incident areas, and known product releases. • Horizontal and vertical delineation of impacts in soils. • Additional soil sampling in areas with light non-aqueous phase liquid (LNAPL). • Additional groundwater sampling from monitoring wells not containing light non-aqueous phase liquid LNAPL. • Collection of groundwater samples beneath LNAPL samples. • Delineation of LNAPL. • Evaluation of LNAPL mobility. • Investigation of the potential vapor intrusion to indoor air pathway at occupied buildings. • Collection of air samples above LNAPL plumes. • Qualitative evaluation of contaminant fate and transport. As discussed with the PADEP, Stantec, and Evergreen during a meeting conducted in September 2015, Evergreen is in the process of developing a site-wide MODFLOW model to perform quantitative fate and transport modeling. Evergreen also intends to submit a site-wide human health risk assessment report. Following the approval of these site-wide reports and other RIRs, Evergreen intends to submit a site-wide Cleanup Plan, pursuant to 25 PA Code §250.410, which will present remedies chosen to allow attainment of the selected remediation standards in soil and groundwater. In accordance with Act 2, the required public and municipal notices for this report have been prepared and issued. Appendix A includes a copy of the original facility NIR, the updated facility NIR, as well as the report notices and their proof of receipt/publication. 1.4 Selection of Constituents of Concern A list of the constituents of concern (COCs) in soil and groundwater for AOI 6 is included as Table 1. This list is an updated listing of the compounds identified in the Work Plan as the COCs for the facility under Pennsylvania One Cleanup Program and will be referred to as the petroleum short list. This list includes all current constituents from the Pennsylvania Corrective Action Process (CAP) Regulation Amendments effective December 1, 2001; provided in Chapter VI, Section E of PADEP's Closure Requirements for Underground Storage Tank Systems, with the exception of the waste oil parameters. In May 2009, two additional COCs, 1,2,4- trimethylbenzene (1,2,4-TMB) and 1,3,5-trimethylbenzene (1,3,5-TMB), were added to the list of COCs based on the PADEP's revisions to the petroleum short list of compounds and at the request of the PADEP. The COC listing for groundwater was also revised in 2012 to follow the soil COC listing. The additional GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 5 compounds added to the groundwater COC list included anthracene, benzo(a)anthracene, benzo(g,h,i)perylene, benzo(a)pyrene, and benzo(b)fluoranthene. No additional compounds were added to Evergreen short list during the 2016 sampling events, but pH was added to the analyses for samples collected in the vicinity of a former tank (Tank 81). 1.5 Selection of Applicable Standards and Screening Levels The media of concern for AOI 6 include soil and groundwater. The potential vapor intrusion into indoor air exposure pathway was also evaluated through the collection of the indoor air samples. The approach for attaining Act 2 remediation standards for the media of concern is described below by media. As the current and anticipated future use of the facility is industrial, standards for non-residential properties were selected for comparison. 1.5.1 Soil All soil results were screened using a multi-step process, as described in this section. Soil results were first screened against the PADEP non-residential, used aquifer (total dissolved solids [TDS] <2,500 micrograms per liter [µg/L]) medium specific concentrations (MSCs) developed by the PADEP to implement the Statewide Health Standard (SHS). The following process was used to select the soil SHS for each COC: • The highest value of either 100 times the groundwater MSC or the generic value MSC was selected to represent the soil to groundwater numeric value. • The selected used aquifer, non-residential soil to groundwater (NRSGW) numeric value was then compared with the non-residential direct contact value (NRDC) (0 to 2 feet or 2 to 15 ft. bgs, as applicable). • The more stringent of the soil to groundwater value and the direct contact value was selected as the soil MSC, otherwise referred to as the SHS, for initial comparison of soil sample results. The SHS value is usually driven by the soil-to-groundwater MSC, and the soil-to-groundwater pathway will be addressed in the groundwater investigation presented in this report. In order to further evaluate the risk posed by the concentrations of COCs which were detected above their respective SHS, the next step is to compare all of the soil analytical results to the non-residential direct contact MSCs. Soil sample locations that will require further pathway evaluation or require a remedial measure in order to attain a standard under Act 2 were identified through comparison to the non-residential direct contact MSCs. An exception to this soil screening process exists for lead. On February 24, 2015, Evergreen submitted a Human Health Risk Assessment Report to PADEP which presented the development of a risk-based site-specific standard (SSS) for lead in soil. In a letter dated May 6, 2015, PADEP approved the report, and a non-residential direct contact site-specific numerical standard for lead of 2,240 mg/kg was established. This SSS is used in place of the default 0 to 2 ft. bgs direct contact standard for lead. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 6 1.5.2 Groundwater Groundwater sample analytical results were screened against the PADEP MSCs for non-residential properties overlying used aquifers with TDS less than or equal to 2,500 µg/L (SHS). Where constituent concentrations are above the SHS, Evergreen evaluated application of the site-specific remediation standard using the pathway elimination option. 1.5.3 Potential Vapor Intrusion into Indoor Air Indoor and ambient air sample results collected in AOI 6 were screened against the USEPA Region 3 Regional Screening Levels (RSLs) for Industrial Air Target Risk (TR)=1E-6, Target Hazard Quotient (HQ)=0.1 (updated November 2015); the PADEP Indoor Air Statewide Health Standard Vapor Intrusion Screening Values, Non-Residential (November 2016); and the Occupational Safety and Health Association (OSHA) Permissible Exposure Limits (PELs). The National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limits (RELs) and the American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLVs) were used for compounds without established OSHA PELs. In accordance with the PADEP Vapor Guidance, since indoor air is the only potential exposure pathway, the results were also screened against the USEPA Region 3 Regional Screening Levels (RSLs) for Industrial Air based on the lower of the Target Risk (TR)=1E-5 and HQ = 0.1 and the PADEP SHS Indoor Air values divided by a factor of 10. These values were used as the threshold to indicate whether additional controls will be necessary to address vapor intrusion. Any such controls will be presented in the Cleanup Plan. 2. Environmental Setting This section summarizes the geologic framework and general hydrogeologic properties of sedimentary deposits and bedrock underlying the south Philadelphia area, with emphasis near the facility. A brief discussion of historical and present-day topography and hydrology is also included. This section provides a regional context from which sedimentary deposits observed beneath AOI 6 are classified and characterized for the purposes of this RIR. Much of the information presented in this section was summarized during conceptualization of a site geologic model that is being used in the development of a numerical groundwater flow model by Stantec as presented in the AOI 1 RIR (Stantec, 2016). In general, the groundwater resources and stratigraphic framework of the facility area have been well-documented through a variety of data sources, including previous groundwater resource investigations dating back to the early 1900s, state and federal geologic mapping projects, groundwater modeling studies, and consultant site characterization and remedial investigation reports. Those data sources are summarized herein. In large part, available well and test boring logs from previous on-site and local subsurface investigations were the most valuable resource in evaluating the local subsurface stratigraphy. As such, subsurface information from approximately 750 well and test boring logs was considered in the evaluation of regional conditions. A database of stratigraphic "picks" on interpreted vertical lithologic unit boundaries (and, where possible, geologic formations) was also developed and includes all identified records of boreholes completed to bedrock at and near the facility. The purpose of the "picks" database was to archive interpretation of GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 7 individual borehole lithologies to bedrock, so that stratigraphic profiles could be developed for this RIR and the Schreffler lithologic model (Schreffler, 2001) could be refined and updated for site-specific use at the facility (Stantec, 2016). One stratigraphic profile was developed for use in this RIR and is presented herein to support evaluation of the lithologic character, geographic extent, and thickness of each geologic unit identified. A structure contour map of the bedrock surface was also developed and used to support the discussion presented below. 2.1 Hydrology and Topography The facility occupies a large area adjacent to the Schuylkill River near its confluence with the Delaware River. This region has a long history of human influence and disturbance, dating back to the early 17th Century when European settlers first arrived. The following sections present a brief discussion of the significant land surface morphologic changes that are apparent when comparing modern environments and topography to that shown on historical maps. 2.1.1 Historical Topography and Natural Depositional Environments The City of Philadelphia Archives and several online archival resources have catalogued and provide free access to copies of many historical maps of Philadelphia. Based on a review of many of those maps, much of the land area occupied by the present-day Philadelphia Refinery was formerly tidal marsh and lowlands that once fringed the Schuylkill River. Figure 3 presents a geo-referenced United States Geological Survey (USGS) topographic map from 1898 (20-foot contour interval). The map indicates that several small tributary streams, digitized on-screen and shown as blue lines, formerly dissected that marshland and presumably would have exchanged water with the tidal Schuylkill River on a semi-diurnal basis. Several islands were also present throughout the lowlands, most notably League Island, which are interpreted as erosional remnants of uplands that formed sometime after deposition of the Trenton "gravel" sediments (discussed in detail below). At that time, relatively higher topography was apparent north and west of the Schuylkill River, near Gibson's Point. South and east of that general area, the Schuylkill River coursed through a distinctive meander around Point Breeze, and appeared to have formed an erosive cut bank along present-day AOI 2 where higher elevations were present (and favoring point bar deposition north of AOI 10). A southwest/northeast trending ridge of higher elevation was also present south of Point Breeze near AOI 4 (see 20-foot contour on Figure 3), and between those two areas of higher elevation a stream was mapped to have been present. That stream appears to have originated in southern AOI 1 and flowed southwest through AOIs 3 and 7, towards its confluence with the Schuylkill River. Numerous other small streams and ditches draining the lowlands surrounding Hollander Creek were also noted. Additional historic maps indicate that by 1900, an earthen dike had been constructed along the banks of the lower Schuylkill River, and sluices were present at each stream/ditch confluence. Other maps show wooden pilings in places along the Schuylkill River. In general, the construction of containment dikes, sluices, and shoreline hardening would have altered the natural tidal exchange between the Schuylkill River and these historic creeks, thereby limiting the natural accretion of sediment in the marshes that once fringed the river. Moreover, the modifications indicated on these maps would have altered the pre-existing tidal regime and dynamic equilibrium of the Schuylkill River. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 8 2.1.2 Post-Industrialization Figure 3 indicates that by 1898, storage of petroleum near Point Breeze and Gibson Point had already begun. According to archived records, much of the remaining tidal marsh and lowland environments nearby were reclaimed and routinely dewatered for farming practices around this same time period (mostly on the west side of the Schuylkill River). Industrialization warranted further land filling activity and shoreline hardening, including bulk-heading and filling of the tributary streams that modified and generally raised the antecedent topography into its present-day configuration. Farms were displaced in favor of industrial and commercial land uses. Although some clusters of residential property and open space exist or have existed near the facility, most land in south Philadelphia is presently and has been used for industrial and commercial purposes for over 100 years (IST, 1998). Light Detection and Ranging (LiDAR) data obtained from the USGS (USGS, 2010) and topographic contours published in 2007 by the City of Philadelphia indicate that present-day topography is relatively flat in the study area, and land surface elevations generally range from a few feet below sea-level near Mingo Creek to approximately 30 feet above sea level near the eastern boundary of the Philadelphia Refinery in AOIs 1 and 8 (referenced to the North American Vertical Datum of 1988 [NAVD 88]) (Figure 4). Although subtle, the high-resolution LiDAR model displays topographically low areas that based on location, likely correlate to the locations of former stream valleys (e.g., Franklin Delano Roosevelt Park). In addition to raising the land surface, much of the filled areas were either paved and/or rendered relatively impervious (Figure 5), which decreased rates of recharge to the water table and necessitated the construction of numerous sewers to convey stormwater runoff (and also sewage) to the Schuylkill and Delaware Rivers. 2.2 Regional Geology and Hydrogeologic Conditions The facility occurs within the up-dip limits of the Atlantic Coastal Plain, generally within 2 miles of the "Fall Line," where crystalline bedrock of the Appalachian foothills intersects the ground surface (outcrops) (Figure 6). The Atlantic Coastal Plain is a physiographic province that is defined as having relatively flat topography and as being underlain by a characteristic wedge of unconsolidated sediments that thicken in a southeasterly direction, away from sediment source areas in the Appalachian Mountains. These sediments were deposited atop a sloping bedrock surface in complex fluvial, estuarine, and marginal marine environments along the passive Atlantic margin. Overall, subsidence of the Piedmont land surface in conjunction with cyclical sea-level fluctuations have been the primary controlling mechanisms driving periods of deposition, non-deposition and erosion in the Atlantic Coastal Plain (Trapp, 1992). In general, the resulting sedimentary record in the vicinity of the Philadelphia Refinery is complex, largely incomplete, and under-represented by only Cretaceous and Quaternary deposits, separated by a regional disconformity (Stantec, 2012). A summary of those deposits is presented below. 2.2.1 Coastal Plain Deposits 2.2.1.1 Anthropogenic Fill For reasons discussed, much of the facility and surrounding area is underlain by historical fill material, which was placed for the purpose of reclaiming lowlands along the banks of the tidal GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 9 Delaware and Schuylkill Rivers during industrialization. These fill materials are heterogeneous in nature and have been described on borehole logs by others as a mixture of compacted soil and anthropogenic debris, including sand, clay, silt, gravel, cinders, concrete, asphalt, crushed stone, ash, glass, brick fragments, and wood. Apparent fill thickness ranges from a veneer where antecedent topography was highest to greater than 50 feet where it was used as railroad ballast just east of the Philadelphia Refinery. Within the locations of former stream valleys and marshes (Figure 3), the historical fill material is generally 20 feet or greater in thickness. The fill materials may contain isolated lenses of groundwater (perched groundwater) where coarse or granular materials are separated from the underlying water table by low permeability sediments. The fill may also be saturated and/or in hydraulic connection with the water table along the axes of former stream channels, where the water-table appears to intersect the fill, or where the fill was placed on marshland. However, at most locations across the Philadelphia Refinery, the fill layer occurs above the regional water-table under average head conditions. 2.2.1.2 Quaternary Deposits Quaternary sedimentary deposits are present beneath the Philadelphia Refinery and are generally representative of geologically-recent cycles of deposition and erosion that occurred within the last 200,000 years. These cycles of sedimentation were the result of a series of glacial and interglacial periods, namely the Illinoian and Wisconsin glaciations, separated by an intervening interglacial period and followed by the present interglacial period through the Holocene (Sevon et al., 1999). Depositional environments through this Period were primarily controlled by sea-level and the successive down-cutting and infilling of ancestral river valleys, primarily that of the Schuylkill and Delaware Rivers (Owens and Minard, 1979). Details of the Quaternary deposits present at the Philadelphia Refinery are described below. 2.2.1.2.1 Recent (Holocene) Alluvium Predominantly gray, muddy deposits with occasional sandy, gravelly, and organic-rich lenses comprise the most-recent alluvium present at the Philadelphia Refinery. These sediments were deposited in dynamic floodplain, channel, and marsh environments through the Holocene. As noted, the upper surface of alluvium, in most places covered by fill, defines the antecedent topography that pre-dated development of the Philadelphia Refinery area. This geologic unit is generally present below an elevation of approximately 20 feet NAVD 88. The alluvium ranges in thickness from a few feet at higher elevations, away from the present Schuylkill and Delaware River estuaries, to approximately 15 feet within the former floodplains of buried tributary streams. However, adjacent to and fringing these major river estuaries, apparent marsh deposits accreted in freshwater environments to as much as 60 feet thick (to elevations as low as approximately -60 feet NAVD 88) as sea-level transgressed and flooded the incised river valleys through the Holocene. Figure 3 provides some estimation of how extensive the tidal marshes once were prior to development, generally along the Schuylkill River south of and surrounding Point Breeze. A stratigraphic profile location map is presented on Figure 7. Stratigraphic profile E-E' supports this interpretation and distribution of the most recent alluvial deposits across the Philadelphia Refinery (Figure 8). Similar to the fill described above, most recent alluvium at the facility has limited water-bearing capacity due to its fine-grained texture. However, heterogeneities within the alluvium may allow for GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 10 the presence of localized seasonal perched groundwater resulting from the percolation of recharge water. Within former marsh areas along the Schuylkill and Delaware River estuaries, the regional water-table occurs within the Holocene alluvium. At locations distal to the rivers and where the Schuylkill River appears to have eroded older alluvial deposits (e.g., along the western periphery of AOI 2), the Holocene alluvium occurs above the regional water-table and is unsaturated. 2.2.1.2.2 Pleistocene Alluvium ("Trenton Gravel") Geologically-recent glacial outwash deposits, commonly referred to informally as the Trenton "gravel", have long been recognized in the vicinity of southeastern Pennsylvania along the Delaware River valley. Sevon and Braun (2000) provide a comprehensive map of glacial deposits in Pennsylvania, including the presence of sand and gravel outwash, interpreted as stratified drift, along the present Delaware River. Owens and Minard (1979) published a comprehensive summary of previous research into these deposits and subdivided the "Trenton gravel" into two distinct deposits (the Spring Lake and Van Sciver Lake beds) based on topographical position and lithology at those type sections. Low et al. (2002) indicate that in most places the Trenton gravel rests directly atop Cretaceous sediments and is overlain by younger alluvium of Holocene age near the Schuylkill River. Based on literature review presented in the AOI 1 RIR (Stantec, 2016), the Trenton gravel was interpreted as a heterogeneous, stratified alluvial deposit of primarily sand and gravel, with occasional beds of clay and silt (the Van Sciver Lake beds), that resulted from glacial outwash through the Delaware River valley sometime after the Illinoian glacier receded. At the Philadelphia Refinery, the Trenton gravel is commonly described on boring logs as a brown, reddish-brown or, where stained, black, fine to coarse sand with lenses of gravel. The gravel fraction is often multicolored and comprised of a mixture of sub-angular to sub-rounded, sedimentary and metamorphic rocks derived from the Appalachian Piedmont. The Trenton gravel generally ranges in thickness from a few feet up to approximately 30 feet near the Philadelphia Refinery. It appears to be laterally continuous and its thickness depends on the antecedent Cretaceous topography that it filled and on the degree of erosion from above (Stantec, 2016). Along the Schuylkill River at the George C. Platt and Penrose Avenue bridges, and in places beneath the Delaware River, Greenman et al. (1961) mapped the Trenton gravel to be present beneath thick sections of Holocene alluvium to elevations near -60 feet NAVD 88, and those interpretations are shown on Figure 8. The regional water-table at the Philadelphia Refinery most often occurs within the Trenton gravel, and, as a result of its stratigraphic position, this geologic unit forms the bulk of the unconfined aquifer (along with localized areas of saturated alluvium and fill). Published well records indicate that the Trenton gravel can be a prolific aquifer (Paulachok, 1991). Nevertheless, due to lateral changes in Trenton gravel thickness and to its heterogeneous character, hydraulic properties and groundwater yields can vary widely. Stantec reviewed published data and available on-site aquifer testing data regarding the hydraulic properties of the Trenton gravel and presented those data in the AOI 1 RIR (Stantec, 2016) which are included on Figures 9 and 10 in this report. A nearly 7-day groundwater extraction test was conducted at recovery well RW-2 at the Philadelphia Refinery (IST, 1998). During testing, RW-2 was pumped at a constant rate of 225 gallons per minute (gpm). Distance-drawdown data analyzed along transects of observation GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 11 wells suggested that the area of influence extended approximately 1,680 feet from the pumping well under relatively isotropic conditions. The hydraulic conductivity (k) was estimated to be greater than 400 feet per day (ft/d). More recently, a 24-hour pumping test was conducted at the former DSCP property at monitoring well DSCP-MW-65, a well that appears to be screened across the Trenton gravel and underlying sandy Cretaceous deposits (ARCADIS, 2013). Analysis of that data provided in the referenced report supports comparable aquifer properties at that site. However, it is noted that during the test, the Trenton gravel was dewatered and individual aquifer k values could not be calculated/resolved. Other, in-situ, single well instantaneous displacement tests and short-duration pumping tests for remedial system design suggest a much lower k for the Trenton gravel, on average, but test results vary widely, from less than 1 ft/d to over 600 ft/d. The observed wide range in k values over relatively short distances is consistent with this geologic unit's lithologic heterogeneity. 2.2.1.3 Cretaceous Deposits Many studies of the Atlantic Coastal Plain near the Philadelphia Refinery have identified the presence of Cretaceous age sediments in the subsurface. These are the oldest sedimentary deposits in the area and are configured in a southeasterly-thickening wedge, overlain by the much younger Quaternary deposits described above and underlain by Piedmont crystalline bedrock. Greenman et al. (1961) detailed the age, character, configuration, and hydraulic properties of these deposits in southeastern Pennsylvania. At the time of that publication, the Cretaceous deposits were assigned primarily to the Raritan Formation and noted to represent three distinct, fining-upward cycles of non-marine sedimentation. Similarities to lithologic sequences identified on borehole logs were correlated to previously-identified strata at their type locality in New Jersey, where the deposits are much thicker and more easily distinguished. Other similar, near time-equivalent geologic formations of Cretaceous age were elsewhere identified in Maryland and Delaware (Jordan, 1962), and more recently authors began wholly referring to the Cretaceous deposits in south Philadelphia as the Potomac-Raritan-Magothy (PRM) aquifer system. In south Philadelphia, the PRM aquifer system is subdivided into six geologic units in order of increasing age: • The upper clay unit • Upper sand unit • Middle clay unit • Middle sand unit • Lower clay unit • Lower sand unit (Schreffler, 2001) Near the Philadelphia Refinery, it is generally true that these units thin, intercalate, and exhibit gradual facies changes that make separation of individual units difficult. Total thickness of PRM deposits at the facility ranges from 0 feet, where Quaternary deposits are present atop bedrock, to more than 100 feet within paleochannels incised into bedrock. A structure contour map of the top of the bedrock surface is included on Figure 11. Details of the individual units based on boring log GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 12 records and published descriptions as presented in the AOI 1 RIR (Stantec, 20016) are presented below. 2.2.1.3.1 Upper Clay Unit The upper clay unit is a variegated clay/silt that is sometimes discernible from older clay units of the PRM where sandy and gravelly. In general, it is thin when compared to the other PRM clay units in south Philadelphia, and in places distal to the Delaware River the upper clay may be entirely absent (Greenman et al., 1961). On the basis of geophysical log signature, others have mapped the upper clay to be at least 0.5 feet thick and up to 30 feet thick at the Philadelphia Refinery, exhibiting its greatest thickness in northern portions of the study area while pinching out to the south (IST, 1998). At the Philadelphia Refinery, Stantec assigned the upper clay to first occurrences of light brown, tan, mauve, yellow, gray, and less-commonly, red sandy, silty clay beneath the Quaternary alluvium. However, overall stratigraphic correlation of the PRM across the facility supports the upper clay unit pinching out or being truncated by younger deposits throughout most of the AOIs (Figure 8). The upper clay unit by nature acts as a confining or leaky confining bed. Where present, it creates hydraulic separation between the upper sand unit and water-table aquifer. 2.2.1.3.2 Upper Sand Unit The upper sand unit is a varicolored but predominantly brown to gray sand with varying amounts of gravel, clay, and silt (Greenman et al., 1961). Nearer the Philadelphia Refinery, it has been described as mostly silty and/or clayey fine to medium sand (IST, 1998). Where the upper clay is absent, the upper sand occurs directly beneath, and is typically discernable, from the coarser and more heterogeneous Trenton gravel above. Stantec used color and lithologic changes, in addition to subtle changes in drilling conditions including Standard Penetration Test (SPT) blow counts, to make "picks" on upper sand occurrences (Stantec, 2016) to create the current geologic interpretation for the facility. In general, the upper sand appears restricted to northern portions of the refinery (AOIs 1, 2, 4, and 8) where it subcrops the Trenton gravel. The upper sand unit, where present, rarely exceeds 10 to 20 feet in total thickness. The upper sand unit is an excellent aquifer where its thickness and extent are sufficient (Greenman et al., 1961). Aquifer testing of the upper sand unit in New Jersey has indicated that the aquifer has similar hydraulic properties to the middle and lower sand units where discrete (Navoy and Carleton, 1995). At the Philadelphia Refinery, Stantec did not identify any existing testing data for wells discretely screened across the upper sand unit from which to infer sole hydraulic properties (Stantec, 2016). The upper sand generally occurs in pockets beneath the Philadelphia Refinery and comprises a portion of the unconfined aquifer. Most wells that fully penetrate the unconfined aquifer in northern areas of the refinery may intersect and be influenced by the hydraulic properties of the upper sand. 2.2.1.3.3 Middle Clay Unit Whereas other clay units of the PRM are described as being sandy and gravelly in places, the middle clay unit is generally regarded as being a laterally extensive and uniformly massive confining GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 13 bed of thick, red and white clay with very little sand (Greenman et al., 1961). Near the Philadelphia Refinery, others have found the middle clay to be nearly continuous in the subsurface (IST, 1998). Thicknesses of the middle clay unit generally range from approximately 20 feet, near the Belmont Terminal area, to just over 1 foot in southeastern AOI 1. While the middle clay appears to be everywhere present, at least on the eastern side of the Schuylkill River, its characteristically muddy texture can vary and become finely-laminated/bedded and intercalated with muddy sand. West of the Schuylkill River and particularly under areas north of Point Breeze, the middle clay unit (in addition to most if not all of the PRM) appears to have been incised and completely removed by erosion. Downgradient, nearer AOI 9 and the George C. Platt Bridge, some pockets or thin lenses of middle and/or lower clay may be present under a thick section of Quaternary alluvium. At other locations beneath the Philadelphia Refinery, the middle and lower clay units appear to be in direct contact with each other, where the middle sand is absent (Stantec, 2016). The middle clay unit, in places resting directly on and combining with the lower clay unit, acts as a significant confining bed at the Philadelphia Refinery. In a regional context, it creates hydraulic separation between the unconfined aquifer and deeper, confined to semi-confined aquifer(s) of the middle and/or lower sand units. 2.2.1.3.4 Middle Sand Unit The middle sand unit is a light-colored, stratified, fine to coarse sand with occasional gravel and clay that was generally deposited in lenticular masses along the axes of troughs carved into the lower clay unit (Greenman et al., 1961). As such, it is by nature discontinuous in the subsurface. Stantec has mapped the presence of middle sand at the Philadelphia Refinery based on stratigraphic position and where present, is commonly described on boring logs as brown or orange sand and gravel. In some areas where the lower clay was entirely removed, it may be indistinguishable from and rest unconformably atop the lower sand unit. At those locations, Stantec used subtle changes in sample descriptions, including color and/or texture, of the sequences of sand below the middle clay to infer the contact between those units. The middle sand unit, where discernable from the lower sand, has been observed at thicknesses up to approximately 15 feet beneath the Philadelphia Refinery and is generally thickest in lenticular or tabular bodies. Much like the other sand units of the PRM, the middle sand unit can be a prolific aquifer where it is laterally continuous and of sufficient thickness. Aquifer testing of the middle sand in New Jersey has indicated that the aquifer has similar hydraulic properties to the lower sand unit (Navoy and Carleton, 1995). At the Philadelphia Refinery, Stantec did not identify any wells discretely screened across the middle sand unit from which to infer sole hydraulic properties (Stantec, 2016). Most deep refinery wells are screened in the lower sand, or potentially across the lower and middle sand units, where hydraulically connected. 2.2.1.3.5 Lower Clay Unit Published descriptions of the lower clay unit indicate that it appears very similar to, and is sometimes inseparable from, the middle clay unit where the middle sand is absent. The lower clay is generally tough, red clay but is known from drilling records to contain softer zones of gray clay stratified with fine sand. The lower clay tends to exhibit its greatest thickness along the lateral margins of paleochannels in underlying bedrock, and can be thin to absent along the axes of GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 14 paleochannels where eroded prior to deposition of the middle sand unit (Greenman et al., 1961). Of the PRM clay units, Stantec has interpreted the lower clay unit to be the least significant at the Philadelphia Refinery in terms of both its lateral extent and vertical thickness. (Stantec, 2016) This is based on stratigraphic correlation and likely the result of erosion prior to deposition of the middle sand. Generally gray and red, commonly sandy clay and muddy sand zones were assigned to the lower clay if observed below and distinguishable from the middle clay. Where present, the lower clay was observed at thicknesses ranging from less than 1 foot to no greater than 10 feet. The lower clay appears to thicken and become more continuous to the south and east of the Philadelphia Refinery. Where physically connected, the lower and middle clay units combine to form a significant confining bed at the Philadelphia Refinery. In a regional context, they create hydraulic separation between the unconfined aquifer and deeper, confined to semi-confined aquifer of the lower sand unit. The lower clay can also create localized areas of hydraulic separation between the lower and middle sands, where discretely present. 2.2.1.3.6 Lower Sand Unit The lower sand unit is a varicolored but predominantly white to yellow sand with gravel, usually fining upward to a cap of fine to medium sand with occasional yellow and gray clay lenses. As further described below, the lower sand unit is the oldest of the PRM deposits and rests unconformably atop bedrock. The lower sand is generally thickest (up to 87 feet thick) along the axial troughs of paleochannels carved into bedrock by discharge through former positions of the Schuylkill and Delaware Rivers (Greenman et al., 1961). At the Philadelphia Refinery, the lower sand unit is present as a nearly continuous deposit, with the exception of some areas west of the Schuylkill River where it appears that the river entirely removed the PRM. Where present, the lower sand unit is observed to range in thickness from approximately 20 feet to a maximum of just over 50 feet, where it fills a bedrock paleochannel beneath a portion of AOI 1. Philadelphia Refinery borehole logs indicate that the lower sand unit is commonly yellow, white, and pale gray in color and predominantly medium to coarse sand with gravel, or gravel with sand. The lower sand's gravelly texture beneath the refinery has been well documented on drilling logs. Of the PRM aquifer system, it can be argued that the lower sand unit was historically the most important groundwater resource in south Philadelphia. Figure 10 summarizes hydraulic information available for the lower sand unit, based on published aquifer testing results. Proximal to the Philadelphia Refinery at the Philadelphia Naval Shipyard (PNSY), a wealth of historical testing data is available for the lower sand unit and indicates an average k value of approximately 134 ft/d. Across the Delaware River in New Jersey, k values seem to be slightly higher. At the Philadelphia Refinery, there are several wells that appear to be discretely screened within the lower sand unit. However, Stantec did not identify any aquifer testing data derived from testing of onsite lower sand wells (Stantec, 2016). It is noted that Stantec recently installed two new AOI 4 monitoring wells screened within the lower sand unit aquifer. Those wells will be utilized for the collection of slug test data and for two short-duration, constant-rate pumping tests to estimate lower sand hydraulic properties at the Philadelphia Refinery. The data from this testing will be submitted in future Act 2 submittals. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 15 2.2.2 Bedrock Bedrock beneath the Coastal Plain near south Philadelphia has been inferred from surface outcroppings above the "Fall Line," and has been described in the subsurface where penetrated by past drilling activities. Bosbyshell (2008) has mapped schist of the Wissahickon Formation to occur in Philadelphia along the "Fall Line" (Figure 6). Relatively small bodies of granitic gneiss, resulting from igneous intrusions into the country rock during metamorphism, can also be present. Most boring log records of deep holes drilled at the Philadelphia Refinery indicate that schist is present beneath the Coastal Plain, in agreement with published maps. Available data pertaining to the bedrock surface beneath the Philadelphia Refinery suggests that the surface generally dips to the southeast but contains local complexity. Greenman et al. (1961) recognized the presence of four paleochannels incised into bedrock and attributed those features to previous positions of the Schuylkill River. Two of those channels, referred to as the Schuylkill River and League Island Troughs by those authors, occur beneath parts of the Philadelphia Refinery and influence the total thickness of the Coastal Plain sedimentary sequence above them (Figure 11). Through boring log review, Stantec has identified additional detail in the bedrock surface beneath the Philadelphia Refinery, including a small bedrock paleochannel beneath the southern portion of AOI 1 that appears to be an extension of the League Island Trough, and a few localized bedrock surface highs (pinnacles) (Stantec, 2016). In general, bedrock can store and transmit groundwater primarily through secondary porosity structures (e.g., fractures, joints). Bosbyshell (2008) indicates that the Wissahickon Formation can yield up to 20 gpm to wells in the mapped area above the "Fall Line." Balmer and Davis (1996) indicate that in Delaware County, Pennsylvania, the Wissahickon Formation is the most productive of the consolidated rock aquifers present in that county and can yield anywhere from 0 gpm to 300 gpm to wells (data from 127 wells). However, the wells included in their report were generally located above the "Fall Line" and were not screened below significant accumulations of Coastal Plain sediments. In general, when compared to the permeability and thickness of the Coastal Plain deposits, the water-bearing properties of the Wissahickon Formation beneath the Philadelphia Refinery are considered de minimis. 3. Soil Investigation The following sections summarize the soil investigation activities performed as part of the remedial investigation activities in AOI 6. The site characterization activities conducted for the RIR in 2016/2017 were completed by Stantec, GHD and Aquaterra, on behalf of Evergreen. The goal of the 2016/2017 activities was to characterize soil in potential source areas, such as historic product handling and storage locations, open storage tank incident areas, and known product releases. Investigations before 2016-2017 are summarized in Section 3.1. All characterization fieldwork was performed in accordance with Evergreen's Quality Assurance/Quality Control Plan and Field Procedures Manual (Appendix B). Soil borings were advanced using a variety of methods including hand auger, backhoe, split spoons in conjunction with hollow stem augers, and split spoons driven using direct push methods. The general strategy for the investigation was to characterize soil in the 0 to 2 ft. bgs and greater than 2 ft. bgs intervals GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 16 (unsaturated soil). Generally, subsurface soil samples were collected at the depth exhibiting the highest photoionization detector (PID) response and/or above the water table. Delineation was performed to the highest of the Act 2 non-residential SHS, the non-residential direct contact MSC, and the numeric SSS (for lead). Soil samples from BH-16-014 through BH-16-16 and from well installations B-172 through 175 were initially sampled for volatile organic analyses (VOCs) and then were re-sampled for semi-VOCs (SVOCs). The soil sample from BH-16-041 was only analyzed for pH in accordance with Table 2. Table 2 summarizes the soil boring rational and soil boring logs are included in Appendix C. All soil analytical results are summarized in Tables 3a and 3b, which compares the results to the 1) non-residential SHS (as previously defined in this report, the more stringent of the soil to groundwater MSC and the direct contact MSC), 2) the non-residential direct contact MSC, and 3) the numeric SSS (for lead) (Soil Screening Levels). Samples were analyzed for the COCs on Table 1. Analysis of soil samples was conducted by Lancaster Laboratories. All laboratory analytical reports from this investigation work are included in Appendix D. 3.1 Summary of Previous Soil Analytical Results Soil data collected during previous soil investigations are summarized in Tables 4a and 4b and the locations are shown on Figures 12a and 12b. The soil data summarized on Tables 4a and 4b were collected from 2002 to 2016 during RCRA, Act 2 and Tank investigation activities. The majority of the previous data collection activities were completed in support of the 2006 SCR/RIR and the 2013 SCR/RIR. A total of 57 soil borings and 20 monitoring wells were installed during the 2006 and 2013 site characterization activities. Information from these investigations is presented in the 2006 SCR (Langan, 2006) and the 2013 SCR/RIR (Langan, 2013). Soil sampling was completed from 20 borings within SWMU 92 and from six borings in SWMU 95 between 2006 and 2012. No leaded tank bottom materials were observed in SWMU 92 (Storage Tank Areas: Buried Lead Sludge Area 6). Therefore, Sunoco requested a Final Agency Determination for SWMU 92 in AOI 6 from USEPA in 2013. Potential leaded tank bottom materials were observed in four soil samples from SWMU 95 (Storage Tank Areas: Buried Lead Sludge Area 9). The lead results were below the SSS for all samples and the TCLP results collected for three samples were below the USEPA maximum concentration of lead for toxicity concentration of 5 mg/L. Therefore, Sunoco requested a Final Agency Determination for SWMU 95 in AOI 6 from USEPA in 2013. A SWMU closure request letter will also accompany the copy of this report to the USEPA. A total of 31 soil borings with soil sampling were advanced outside of the SWMU areas. Soil sampling also occurred during the installation of 14 monitoring wells in 2006 and six monitoring wells in 2012. The soil borings locations are shown on Figures 12a and 12b, as historic soil borings, the soil data from these investigations is summarized in Tables 4a and 4b. The 2006 and 2013 SCR/RIRs are included in Appendix J. AOI 6 includes ASTs and many soil samples have been collected for tank characterization and closure under 25 PA Code Chapter 245, in addition to the sampling completed as part of the Act 2/One Cleanup Plan activities. Although the rationale and results of all of these soil sampling projects are not discussed in detail in this RIR, as they have been submitted to PADEP under 25 PA GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 17 Code Chapter 245 reporting, they are relevant to the characterization of AOI 6 under Act 2. The analytical results for these tank-related assessments are included in Tables 4a and 4b, and the soil sample locations are shown on Figure 2 as historic sample locations. The investigation of select tank incidents was performed as part of the field effort for this RIR, and those results are discussed in the following sections. 3.2 Historic Product Handling/Storage Areas In order to investigate areas of historic product handling and storage, soil borings were advanced within the area of former Tank 237, former Tank 238 and Tank 251 during the 2016 site characterization activities. These borings included boring BH-16-039 in the vicinity of Tank 237 and BH-16-010 and SB-16-011 in the vicinity of Tank 238. None of the soil results from these borings exceeded the SHS. 3.3 Open Storage Tank Incidents Evergreen intends to address all open AOI 6 storage tank incidents for which it is responsible through the 25 PA Code Chapter 245 CAP Program under separate cover. In 2014, the PADEP provided Evergreen with a list of the open Evergreen tank incidents in the PADEP database for AOI 6. One of the tank releases, PADEP Release Incident Number 37546 for Tank 250, was originally listed as on open incident by the PADEP in their 2014 summary of open incidents but was changed to closed in accordance with Mr. David Brown's Technical Review Memo dated August 29, 2017 which is included in Appendix E. PADEP release incident 46762 was assigned to a tank containing Nalco which is a filming agent (cyclohexylamine) used as an additive for boiler feedwater. Discussions with Sunoco personnel confirmed that this material was held in small temporary plastic tanks and therefore their location can not be shown on the figures. Cyclohexylamine is very biodegradable (Handbook of Environmental Fate and Exposure Data for Organic Chemicals, 1990) and is not expected to have lasted in the environment. Based on these conditions, no impacts are expected for the incident and therefore no further investigation was completed for incident 46762.The remaining open tank incidents are summarized in Table 5. Soil characterization activities were conducted to further investigate the open storage tank incidents within AOI 6. For borings associated with storage tank incidents that involve releases within tank berms, soil analytical results are presented in this RIR for informational purposes only, as they relate to overall AOI 6 soil characterization. These data will be used in separately prepared SCRs for the identified open storage tank incidents, which will be submitted under separate cover to the PADEP in order to satisfy the requirements of 25 PA Code Chapter 245. The following summarizes the incidents that the PADEP provided to Evergreen, available information for these tanks, completed investigation activities during the 2016 site characterization activities and whether this tank will have a separate SCRs submitted to fulfill the requirements of 25 PA Code Chapter 245. This section also includes groundwater data from the 2016 site characterization activities, if applicable to the discussion of the Tank Incident. The groundwater results are further discussed in Section 4. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 18 3.3.1 GP T81 (Former PADEP Tank 121A, Incident 45692) On September 11, 1993, a split in a line caused the release of approximately 100 gallons of liquid caustic onto the ground. The release was reported to PADEP on September 12, 1993 and Incident No. 45692 was assigned by the PADEP. A confirmation letter was sent to PADEP on October 4, 1993. The letter stated the liquid caustic was vacuumed up and the contaminated soil was removed for treatment. During the 2016 site characterization activities, three borings, BH-16-040, BH-16-041, BH-16-043 were completed in the vicinity of Tank 81. Sampling during the AOI 6 RI was conducted to characterize this release incident by analyzing for pH. The results indicate a pH range of 7.86 to 9.15 standard units (s.u.). The calculated median is 8.12. A SHS does not exist for pH. The pH results indicate the soil is slightly alkaline; however, these levels do not create hazardous condition. The pH results in groundwater in B-39 during the groundwater sampling in 2016 ranged from 7.3 to 7.5. Although not related to the release, samples from BH-16-040, BH-16-041, and BH-16-043 had exceedances of the SHS for benzene, naphthalene, 1,2,4 TMB, none of these sample results exceeded the NRDC. The soil samples in BH-16-041 collected from 0.75 to 1.25 feet exceeded the SSS for lead, but it was vertically delineated by the soil sample collected from BH-16-041 from 1.75 to 2.25 feet. This SSS exceedance was horizontally delineated by four additional borings which were completed in 2017, BH-17-003 to 005 and BH-17-009. 3.3.2 GP 676 (Former Tank GPU 676, PADEP Tank 130A, Incident 4844) Tank 676 was used to store No. 6 fuel oil. On July 19, 1998, 60 barrels of No. 6 fuel oil were released into the tank dike. Sunoco immediately took corrective action and recovered 59.5 barrels of fuel from the tank dike area. Sunoco notified the PADEP of the incident on July 20, 1998 and submitted a Notification of Reportable Release on August 10, 1998. Incident No. 4844 was assigned to this release by the PADEP. Boring BH-12-104, completed during the 2012 site characterization activities, is located in the area of former Tank 676 and had no exceedances of the SHS. During the 2016 site characterization activities, one boring BH-16-006 was completed in the tank dike of former Tank 676 and none of the soil samples collected from this boring exceeded the SHS. Stantec conducted closure sampling within the tank berm of Tank 676 for PES in December 2016. Nine samples were collected as part of this investigation, GP676-1 though GP676-9. No obvious contamination was observed during the soil sampling. None of the samples had exceedances of the SHS. Groundwater well B-95, located in area of Tank 676, had one slight exceedance of the SHS for an estimated concentration of benzo(a)pyrene. Stantec’s AST Closure Report Form for Tank 676, dated December 16, 2016 is included in Appendix J. 3.3.3 GP 797 (Former PADEP Tank 097A, Incident 29122) GP 797 was an above ground storage tank (AST) which contained process water that contained light-end hydrocarbons (e.g., benzene and cumene) that was closed-in-place. The in-place closure of tank GP 797 was completed on April 30, 2002, by Sunoco. As part of the closure activities, four hand augers borings (HA-1, HA-2, HA-3, and HA-4) were completed and shallow soil samples were collected at each location, with two samples collected at HA-3. Benzene was detected at GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 19 concentrations above the NRDC in two samples. The SHS was exceeded for benzene, ethyl benzene and toluene. Based on these results Sunoco notified the PADEP of a release on June 10, 2002. PADEP issued a Notice of Violation (NOV) dated July 29, 2002 and Incident No. 29122 was assigned. In the NOV, PADEP requested a characterization of the extent of soil contamination and impact submitted in an SCR. Sunoco submitted a closure assessment report to the PADEP for AST 797 dated July 10, 2002. Sunoco subsequently submitted a SCR for AST 797 to the PADEP dated December 12, 2002, to further characterize the release from this tank. The SCR documented the collection of three soil samples from three locations, MW-1, MW-2, and MW-3 completed outside of the containment dike. Benzene (in MW-1, MW-2, and MW-3) and toluene (in MW-3) exceeded the SHS during this sampling. Benzene also exceeded the NRDC in the soil sample collected from MW-3. Wells MW-1 through MW-3 were renamed B-149 through B-150 respectively. During the 2012 site characterization activities, five additional soil borings with the collection of six soil samples were completed to further characterize Tank 797. Four of the borings were installed in the locations of HA-1 through HA-4 to characterize soil greater than two feet below grade. Benzene and toluene exceeded the NRDC in four of the five soil samples. The surface soil sample from boring BH-12-125 had no exceedances of the SHS. PADEP requested delineation to the northwest, north, and northeast of tank GP 797 in SCR comments dated November 22, 2013. Nine soil borings (BH-16-030 through BH-16-038) were completed during the 2016 site characterization activities to delineate conditions near the tank area within the limits of the tank berm. These samples had exceedances of the SHS for benzene, isopropyl benzene and toluene. In addition, the sample from BH-16-037 also exceeded the NRDC for benzene. Groundwater from well B-155 located downgradient of tank 797 had exceedances of the groundwater SHS for benzene and benzo(a)pyrene during the 2016 site characterization activities as summarized in Table 7a. 3.4 Historic Releases The following section discusses known historic releases that were investigated as part of the AOI 6 characterization activities. As part of the remedial investigation under Act 2, historic releases that may have created sources for COCs in soil were identified based on the available information. In order to identify areas that would require further investigation, a review of internal facility files was completed by Evergreen. PADEP also reviewed its records and provided information on historic incidents. Specific release locations were determined based on document descriptions and interviews with refinery personnel. Based on information obtained, targeted soil investigations were performed as described in the following subsections. This section also includes groundwater data from the 2016 site characterization activities, if applicable. The groundwater results are also further discussed in Section 4. 3.4.1 ‘Area West of’ GP 676, or ‘2000 Surface Release’ On September 29, 2000, approximately 15,000 gallons of No. 6 fuel oil from No. 3 Boiler House was released from a product line outside of the tank berm for Tank 676. Approximately 7,500 gallons of product was recovered by vacuum trucks, a boom was set up due to the proximity to the bulkhead GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 20 and the contaminated soil was excavated and sent for off-site disposal. Since the release occurred outside of a tank dike, this is considered a historic release even though the PADEP assigned incident number 6133 to this event. During the 2016 site characterization activities, five borings (BH-16-002 through BH-16-006) were completed to characterize conditions between the outside of the dike for Tank 676 and the bulkhead to characterize this area. None of the soil samples collected from BH-16-002 to BH-16-006 exceeded the SHS or the SSS for lead. Groundwater downgradient of these borings in monitoring wells B-170, B-153, B-168, and B-169 had no exceedances of the SHS with the exception of lead in B-169. 3.4.2 1733 Unit Approximately 840 gallons of benzene were released at the 1733 unit (Bell Hood CUE 4B) on November 27, 1995 based on a review of Sunoco's records. Three borings were completed in this area during the 2016 site characterization activities (BH-16-007 through BH-16-009). None of the soil results from these borings exceeded the SHS. 3.4.3 Transfer Line Located Northeast of No. 4 Boiler House Approximately 1,300 gallons of No. 2 fuel oil were released from a transfer line located north east of the No. 4 Boiler House and east of Tank 238 on September 3, 1993. Two borings were completed during the 2016 site characterization activities (BH-2016 -16-012 through BH-2016-16-013). None of the soil results from these borings exceeded the SHS. 3.4.4 1332 Line Approximately 4,400 gallons of naphtha were released from the 8-inch line outside of the tank dike for GP-251 that lead to unit 1332 on February 2, 1994. Chevron personnel applied foam and then completed vacuum removal of the release. Three borings were completed in this area during the 2016 site characterization activities (BH-16-17, BH-16-018 and BH-16-023). None of the soil results from these borings exceeded the SHS. An additional three borings (BH-16-14 to BH-16-16) were completed inside the dike of Tank 251 during the 2016 field activities based on comments from former Sunoco employees. None of the soil results from these borings exceeded the SHS. 3.4.5 Main Office Approximately 4,000 gallons of jet fuel were released from an underground line near the main office in September 1992. Three borings were completed during the 2016 site characterization activities (BH-16-019 to BH-16-022). None of the soil results from these borings exceeded the SHS, with exception of BH-16-019 which exceeded the SSS for lead. The lead detection in BH-16-019 was delineated by BH-17-001 and BH-17-002. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 21 3.5 Delineation of Direct Contact MSC/SSS Exceedances In order to complete horizontal and vertical characterization in soil, areas exhibiting exceedances of the non-residential direct contact MSC (and the SSS for lead) were delineated. These areas and associated investigations are described below: • A historic soil sample (BH-30-09) from 0 to 2 ft. bgs had a lead detection above the SSS for lead and historic soil sample (BH-29-06) from 0 to 2 ft. bgs had a lead detection above the numeric SSS for lead and a BaP detection above the NRDC. Soil samples collected from B0152, BH-12-108, BH-32-09, BH-27-09, BH-28-09, BH-29-09, BH-31-09, and BH-27-06 delineate these NRDC. • Historic soil samples GP-797-HA-1, GP-797-B-150, and GP-797-HA-3 in the GP-797 area from 0 to 2 ft. bgs had an exceedance of the NRDC for benzene. The soil samples from BH-16-029, BH-12-122, BH-12-119, B-149, BH-16-033, BH-16-32, BH-16-031, GP-797-HA-4, and BH-12-130 delineated these NRDC exceedances for benzene. • Historic sample BH-12-128 had an exceedance of the NRDC for benzene. The soil samples from BH-16-032, BH-12-125, BH-16-031, and BH-16-033 delineated the NRDC for benzene. • Historic soil samples BH-12-149, BH-12-129, BH-12-128, and BH-12-124 in the GP-797 area from >2 ft. bgs had an exceedance of the NRDC for benzene. The soil samples from BH-16-032, BH-16-033, BH-12-129, BH-16-036, BH-16-035, and BH-16-008 generally delineate this exceedance for benzene. • Soil sample BH-16-037 from 0 to 2 ft. bgs exceeded the NRDC for benzene during the 2016 site characterization activities. This sample was delineated by BH-16-025, BH-16-026, BH-16-036, BH-16-038, and by BH-12-149. • Soil sample BH-16-019 from 0 to 2 ft. bgs exceeded the SSS for lead during the 2016 site characterization activities. This sample was delineated by BH-16-021, BH-16-020, BH-17-002, and BH-17-001. • Soil samples BH-16-041 and BH-17-004 from 0 to 2 ft. bgs exceeded the SSS for lead during the 2016/2017 site characterization activities. These samples were delineated by BH-17-003, BH-17-009, BH-17-005, BH-16-043, and BH-16-040. • Soil samples BH-16-025 and BH-16-037 from greater than 2 ft. bgs exceeded the NRDC for benzene during the 2016 site characterization activities. These sample were delineated by BH-16-036, BH-16-034, BH-16-030, and BH-16-008. Additional sampling may be completed for BH-16-025 during risk assessment or remedial design activities. 3.6 Site Characterization in the 0-2 ft. bgs interval, 2-15 ft bgs Interval and Beneath LNAPL In response to PADEP comments to previous site characterization activities and the February 19, 2016 meeting, additional soil sampling was completed to complete characterization in the 0-2 ft. bgs GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 22 interval, 2-15 ft. bgs. interval and beneath LNAPL. These results associated with the 2016/2017 site characterization activities are described below: • As shown on Figure 12a, the following surface samples (0-2 ft. bgs) exceeded the NRDC (or numeric SSS for lead): BH-16-019 (lead), BH-16-041 (lead), BH-16-037 (benzene), BH-17-004 (lead) and BH-16-019 (lead) during the 2016/2017 site characterization activities. • As summarized in Table 3a, Surface samples (0-2 ft. bgs) exceeded the soil to groundwater MSCs for benzene (BH-16-026, BH-16-029, BH-16-030, BH-16-031, BH-16-034, BH-16-036, BH-16-037, BH-16-038, BH-16-040, BH-16-043, and B-175), ethylbenzene (BH-16-037), isopropylbenzene (BH-16-037), toluene (BH-16-037) and lead (BH-16-003, BH-13-004, BH-16- 007, BH-16-010, BH-16-011, BH-16-15, BH-17-003, BH-17-005) during the 2016/2017 site characterization activities. • As shown on Figure 12b, the following subsurface samples (>2 ft. bgs) exceeded the NRDC for benzene: BH-16-025 and BH-16-037 during the 2016/2017 site characterization activities. • As summarized in Table 3b subsurface samples (>2 ft. bgs) exceeded the soil to groundwater MSCs for benzene (BH-16-027, BH-16-029, BH-16-030, BH-16-031, BH-16-032, BH-16-034, BH-16-036, and BH-16-043), 1,2,4-trimethylbenzene (BH-16-025), isopropylbenzene (BH-16-037), naphthalene (BH-16-040) and toluene (BH-16-025 and BH-16-037) during the 2016/2017 site characterization activities. • Soil samples from BH-17-003 and BH-16-040 were selected to be collected in the vicinity of well B-39 which has identified LNAPL to address the PADEP request for soil samples in LNAPL areas. None of the results from BH-17-003 exceeded the SHS. The soil results from BH-16-040 had an exceedance of the SHS for benzene, but none of the results exceeded the NRDC. In addition, soils from historical sampling events collected in LNAPL areas from 0-2 ft collected from BH-21-06, B-161, B-148, B-149, B-150, B-175 and BH-25-06 had no exceedances for the SHS with the exception of benzene (B-148, B-149, B-150, B-175 and BH-25-06) and toluene (B-150). The soil sample collected from 2-15 feet from B-175 did not exceed the SHS. 4. Groundwater Investigation 4.1 Historic Groundwater Investigations Available well construction details are summarized in Table 6. Previous consulting reports in Appendix L describe the various historic groundwater sampling events that have been conducted within AOI 6. All of the available analytical data for wells located in AOI 6 from 2013 to present are presented in Table 8 and all available historic groundwater data are presented in Appendix K. 4.2 Well Installation Activities This section describes well installation activities that were performed as part of the 2016 remedial investigation. Activities are discussed by purpose in order to clarify characterization goals. All fieldwork was performed in accordance with Evergreen Field Procedures (Appendix B). Monitoring well locations are shown on Figure 2. Well logs, including both lithologic information and well construction details, are included in Appendix C. Well construction details are also summarized in GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 23 Table 6. The following sections discuss the well installation strategy/rationale; however, a summary is also available in Table 2. In order to better delineate LNAPL and dissolved benzene plumes interior to AOI 6, additional water-table monitoring wells B-172 through B-175 (WP9-1 replacement) were installed during the 2016 remedial investigation activities. An additional location, B-171 was attempted; however, the well was not installed due to the presence of a concrete floor in this area. Several attempts were made to install B-171, but the concrete flooring was encountered at each location. Prior to the installation of the monitoring wells, well locations were cleared for subsurface utilities to 8 ft. bgs using a vacuum truck. Monitoring well installation activities were performed using hollow stem auger methods by US Environmental of Mullica, New Jersey under the oversight of GHD in April 2016. During borehole advancement, surface and subsurface soil samples were collected for laboratory analysis of the COCs in Table 1. Continuous soil sampling using a split spoon sampler was performed. A GHD geologist screened soil with a PID and logged sample lithologies. LNAPL was not observed in B-172, B-173, B-174, or B-175. 4.3 Groundwater Sampling Events A comprehensive characterization groundwater sampling event, consisting of 37 monitoring wells was conducted in May 2016. A second, more focused groundwater sampling event was conducted in August 2016 for B-39, B-43, B-116, B-117, B-125, B-126, B-132, B-133, B-145, B-150, B-158, B-164, B-169, U-4, URS-1, URS-2, URS-3, URS-4, URS-5, and the newly installed wells (B-172 to B-175). All fieldwork was performed in accordance with Evergreen Field Procedures (Appendix B). Monitoring well locations are shown on Figure 2. All samples were analyzed for the COCs (Table 1) by Lancaster Laboratories, located in Lancaster, Pennsylvania. Analytical results for groundwater samples collected in 2016 and all historic results for AOI 6, are summarized in Tables 7a and b and in Appendix K, respectively. Concentrations of the following COCs were detected above the non-residential MSC during the 2016 groundwater sampling events: benzene, isopropyl benzene, 1,2-dibromoethane (EDB), toluene, 1,2,4-TMB, benzo(a)anthracene, benzo(a)pyrene, benzo(g,h,i)pyrene , benzo(b)fluoranthene, chrysene, naphthalene, and lead. The following observations can be made concerning the groundwater exceedances: • The benzo(a)pyrene groundwater MSC exceedances in B-162 and B-117 are delineated by B-116 and B-115. • As shown on Figure 19, there are several wells with exceedances of the groundwater MSC for benzene. As shown on Figure 19, these wells are delineated in the downgradient direction with the exception of benzene in URS-5, which intermittently has detections of LNAPL, and is located adjacent to the bulkhead. • One additional well with a benzene exceedance of the MSCs is B-152. This well is delineated by wells B-43 and B-168. • Wells B-145, U-4, B-175, B-125, URS-3, B-173, and B-126 had SHS exceedances of benzene, SVOCs or lead which were delineated by B-174, URS-1, URS-4, and B-164. • Wells B-156 and B-172 had SHS exceedances of benzene and SVOCs generally delineated by B-170. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 24 • Groundwater samples from B-39, B-132, B-134, B-144, and B-150 were collected beneath LNAPL. As shown on Figure 19 and in Tables 7a and 7b, all of these samples had at least one detection above the groundwater MSCs as discussed below: – B-39 had low level exceedances of the MSCs for ethyl dibromide, benzo(a)pyrene, benzo(b)fluoranthene, benzo(b)fluoranthene, benzo(g, h, i)perylene, chrysene and lead. – B-132 had low level exceedances of the MSCs for benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, chrysene which is delineated by URS-5 except for benzo(a)pyrene. – B-134 had low level exceedances of the MSCs of benzo(a)pyrene which is delineated by B-126 and URS-5. – B-144 had low level exceedances of 1,2,4-trimethylbenzene, benzene, benzo(a)anthracene, benzo(b)fluoranthene, benzo(g,h,i)perylene and chrysene which is delineated by B-126. – B-150 had elevated exceedances of the MSCs 1,2,4-trimethylbenzene, benzene, isopropyl benzene, and toluene and low levels of benzo(a)pyrene which is delineated by B-156 with the exception of benzo(a)pyrene which is delineated by URS-5. • The remaining wells with groundwater MSC exceedances, B-43 and B-169, are located in close proximity to the bulkhead and will be evaluated through the site-wide fate and transport report. • None of the monitoring wells screened in the lower aquifer had exceedances of the non-residential groundwater MSCs, as presented on Figure 20. 4.4 Well Gauging Activities Stantec presently conducts annual groundwater and LNAPL gauging of all existing wells at the Philadelphia Refinery. The site-wide annual well gauging event, which is typically conducted during the second quarter of each year, is used to identify the presence of LNAPL and determine groundwater flow patterns. Liquid level measurements, groundwater contour figures, and product thickness figures are submitted to PADEP with the Philadelphia Refinery Remediation Program Groundwater Remediation Status Reports during the first half of each year. Groundwater elevation contours from the May 2016 annual gauging event is included on Figure 13. In addition to the annual events, the wells included in the September 2016 groundwater gauging event were gauged are shown on Figure 14. 5. Site-Specific Hydrogeologic Conditions In Section 2 above, details regarding the methodology and interpretation of regional geologic conditions were presented. The purpose of this discussion of site-specific conditions is to refine the regional hydrogeologic framework to summarize conditions observed beneath AOI 6, with an emphasis on groundwater occurrence, groundwater flow, and hydraulic head potentials. It is understood that although this RIR is designed to address subsurface conditions beneath AOI 6, PADEP has previously requested that investigations of individual AOIs look beyond the boundary of the AOI being investigated. As such, GHD has utilized well gauging from AOIs 5, 6, and 7. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 25 Groundwater contouring and evaluation of head conditions in the study area are included on Figures 13 and 14. 5.1 Geologic Formations and Units Observed On the basis of available lithologic data from boring logs, the principle of stratigraphic position, results of past investigations, review of historical maps, attempted correlation of observed lithologies across the study area to a published geologic framework (e.g., Quaternary deposits and the PRM aquifer system) documented in the AOI 1 RIR (Stantec, 2016), GHD has interpreted the following stratigraphy in the subsurface beneath AOI 6. A generalized stratigraphic column is included as Table 10 and the cross section through the facility, including AOI 6, is shown on Figure 8. 5.1.1 Anthropogenic Fill Apparent fill is present everywhere beneath the existing land surface in AOI 6 and has been identified averaging approximately 10 feet. Stratigraphic Profile E-E' (Figure 8) presents the interpreted fill thickness in AOI 6. 5.1.2 Recent (Holocene) Alluvium Recent alluvial deposits that post-date the Trenton gravel are present beneath filled areas within AOI 6. In general, recent alluvium defines the antecedent topography that preceded industrialization at the Philadelphia Refinery. In large part, recent alluvium within the facility is fine-grained, brown to brownish gray silt/clay with occasional lenses of sand and gravel that commonly grades with depth to include some sand. In places, decomposing organic material has also been indicated. The thickness of the recent alluvium within AOI 6 has been observed to range from approximately 20 to 35 feet. The recent alluvium is the most significant units to occur beneath AOI 6, as shown on Figure 8. 5.1.3 Trenton "Gravel" The Trenton "gravel" does not occur uniformly throughout AOI 6. The Trenton "gravel" ranges in thickness from approximately 10 feet to pinching out along the eastern boundary of AOI 6. Its predominant lithology appears to be silty, clayey, poorly-sorted sand with gravel, but includes secondary sandy gravel and clay/silt lithologies in lenses. As described site-wide, the Trenton gravel is a heterogeneous unit that is reflective of its depositional environment. 5.1.4 Upper Clay Unit/Upper Sand Unit/Middle Clay/Middle Sand/Lower Clay The PRM upper clay/upper sand/middle clay/middle sand and lower clay units are not interpreted to be present beneath AOI 6. It appears that these units were truncated by erosion prior to or contemporaneous with deposition of the Trenton "gravel". The Trenton "gravel" or alluvium (where the Trenton "gravel" is absent) rests unconformably above the Lower Sand unit as shown on Figure 8. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 26 5.1.5 Lower Sand Unit In general, the lower sand coarsens with depth, from a dense fine to medium pale gray, pale yellow and white quartz sand to white and varicolored sandy gravel and gravelly sand. An area of sandy gravel has been mapped beneath AOI 6 in the Lower Sand Unit. The thickness of the lower sand in AOI 6 is approximately 20 feet. 5.1.6 Crystalline Bedrock Bedrock where encountered, has been described as moderately to highly-weathered mica schist. As shown on Figure 6, bedrock elevations beneath AOI 6 range from a maximum of approximately -60 feet NAVD 88, near the AOI 7/AOI 3 boundary, to a minimum of approximately -80 feet NAVD 88 in the northwest portion of AOI 6. 5.2 Aquifer Hydraulic Properties Two aquifers have been identified beneath AOI 6. In general, these are the water-table (unconfined) and lower (semi-confined) aquifers. Stantec identified and evaluated properties of those aquifers at the facility through review of approximately 300 well records as documented in the AOI 1 RIR (Stantec, 2016). Records reviewed included well gauging data and where available, lithologic logs, physical properties, and well/aquifer testing data. Hydrostratigraphic units were assigned by Stantec to wells where possible using the stratigraphic profiles and nearby and deep boreholes as control points. Overall, approximately 90 percent of existing monitoring wells used at the facility are screened across the unconfined aquifer and are designed to intersect the water table. Of the remaining 10 percent screened in the lower aquifer, approximately 9 percent partially penetrate the lower sand and 1 percent are screened in either the middle sand, or across the middle clay. It is noted that intervening PRM upper sand and middle sand aquifers do not appear to be present beneath AOI 6. It is also noted that hydraulic head potentials between the unconfined and lower aquifers are downward across AOI 6. These site-specific hydrogeologic conditions are discussed further below and are supported by Figures 13 and 15 which show groundwater elevation contours for both aquifers for 2016. 5.2.1 Methodology for Evaluation of Hydraulic Data For the purposes of evaluating hydraulic head, flow direction(s) and magnitudes of groundwater flow for the aquifers identified in this RIR, GHD reviewed 2015 and 2016 water levels from annual, site-wide gauging data within the facility. For wells gauged by GHD, depth-to-water measurements were collected with an optical interface probe and reported to the nearest hundredth of a foot. Water-table elevations were calculated using surveyed well top-of-casing elevations and, where necessary due to LNAPL accumulations, corrected using LNAPL density data from the nearest available LNAPL sample data (see Table 9) for density assignments and for gauging data) 5.2.2 Unconfined (Water-Table) Aquifer Beneath AOI 6, the unconfined aquifer is primarily composed of saturated portions of the fill and alluvium and the Trenton "gravel." On average, the saturated thickness of the unconfined aquifer beneath AOI 6 is approximately 20 to 30 feet. As a part of the AOI 1 RIR, Stantec (Stantec, 2016) GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 27 mined existing data and has identified estimations of horizontal hydraulic conductivity (kh) for the unconfined aquifer from 15 in-situ aquifer (slug) tests and two, short-duration pumping tests (see Figure 9). None of these tests were identified in AOI 6. From those tests, estimated values of unconfined aquifer kh vary two orders of magnitude across the facility. The wide range of estimated values of kh is reflective of the heterogeneous nature of the Trenton gravel. Anomalously low values of kh may also be the result of poor well-aquifer hydraulic communication related to inadequate well development, or fouling of the well screen. Stantec is presently evaluating potential values of reported unconfined aquifer kh as a part of site-wide numerical model calibration and sensitivity analysis. 5.2.2.1 Hydraulic Heads and Groundwater Flow As shown on Figure 14, water-table mounds are apparent in AOI 6. These mounds are found immediately adjacent to the bulkhead and one is in the southeastern portion of the site. The mounding along the bulkhead is due to the lower hydraulic conductivity of the bulkhead as compared to site soils. There are also two areas of groundwater depression in the eastern and central portion of AOI 6. Review of historic groundwater contours show that these contours are consistent with previous groundwater contours. Evaluation of groundwater mounding/depression is an important component of understanding horizontal hydraulic gradients since they strongly influence contaminant fate and transport in an analytical or numerical model. Groundwater flows to the south west towards the river. The gradient towards the southwest is 0.0019 ft/ft. This pattern is consistent with the historical contours and supports that flow in AOI 6 is towards the river. 5.2.3 Semi-confined (Lower) Aquifer Groundwater flow within the lower aquifer beneath AOI 6 has been contoured utilizing data from AOI 5, 6, and 7 wells, and the resultant potentiometric surfaces are shown on Figure 15 for synoptic well gauging events conducted in May 2016. The groundwater flow direction is to the southwest under a hydraulic gradient of approximately 0.002 ft/ft. GHD evaluated the vertical hydraulic head gradients for May and August 2016 between the unconfined and lower aquifer throughout AOI 6. There is a downward gradient between the unconfined and lower aquifers. These gradients are consistent with previous data collected in AOI 6 (2013 RIR). Beneath the study area, the lower aquifer is primarily composed of saturated portions of the lower sand unit. On average, the saturated thickness of the lower aquifer beneath AOI 6 is approximately 25 feet. There is no available aquifer testing data for the lower aquifer at the facility. Evergreen is planning on conducting slug and hydraulic tests on the lower aquifer in AOI 4 in support off the facility wide fate and transport modeling. At the time of this RIR however, the best available kh data for the lower aquifer is estimated from historical testing performed at the Philadelphia Naval Shipyard and has been summarized on Figure 10. From those tests, values of lower sand kh are estimated to vary from approximately 123 ft/d to 151 ft/d. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 28 6. LNAPL Investigation 6.1 LNAPL Characterization Sampling Various petroleum products have been stored and distributed within AOI 6. Historic testing has been completed to characterize the LNAPL at the Site. The results of the tests are summarized in Appendix F and are discussed below. Stantec has gone back through the historic LNAPL sampling and has reclassified some of the LNAPL types as summarized in Table 11, these re-classifications are also included below. 2004 In 2004, LNAPL samples from wells B-129, B-130, B-144, B-39, B-43, and WP 9-2 were collected and submitted to Torkelson Geochemistry, Inc. (Torkelson) for analysis. Torkelson completed gas chromatograph analysis of the samples. LNAPL characterization data included product type, density, proportions of product, weathering, and similarities to other samples. • Well B-129 is located near the eastern border of AOI 6. Torkelson characterized the sample from B-129 as being severe-extremely weathered middle distillate with heavier material and gasoline (Langan, 2004). • Well B-130 is located near the western border of AOI 6 along the bulkhead. Torkelson characterized the sample from B-130 as being severely-extremely weathered middle distillate and residual oil (Langan, 2004). • Well B-144 is located near 2nd Street. Torkelson characterized the sample from B-144 as being severely weathered gasoline and residual oil (Langan, 2004). • Well B-39 is located in the southwestern corner of AOI 6. Torkelson characterized the sample from B-39 as being severely weathered middle distillate and gasoline (Langan, 2004). • Well B-43 is located along the bulkhead in the northwestern area of AOI 6. Torkelson characterized the sample from B-43 as being extremely weathered middle distillate (Langan, 2004). • WP 9-2 is located along 2nd street in the southwestern corner of AOI 6. Torkelson characterized the sample from WP 9-2 as being severely weathered aviation gasoline and middle distillate (Langan, 2004). 2006 In 2006, LNAPL samples from wells B-47 and B-150 were collected and submitted to Torkelson Geochemistry, Inc. (Torkelson) for analysis. LNAPL characterization data included product type, density, proportions of product, weathering, and similarities to other samples. • Well B-47 is located near the center of AOI 6. Torkelson characterized the sample from B-47 as being extremely weathered residual oil with a trace of unknown aromatics (Langan, 2006). • Well B-150 is located west central of AOI 6. Torkelson characterized the sample from B-150 as being unknown aromatics with unknown weathering (Langan, 2006). GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 29 2013 • During the January 2013 groundwater sampling event, 19 monitoring wells had measureable (>0.01 feet) LNAPL. 6.2 LNAPL Distribution Numerous monitoring wells across AOI 6 have been gauged for LNAPL over the course of implementing the investigation and remediation programs. Stantec completed LNAPL and groundwater elevation gauging events in May 2016. During this event, 76 wells were gauged in the unconfined and semi-confined zones. LNAPL was detected in 21 wells with a maximum thickness of 4.27 feet at well B-116 during the May 2016 gauging. Figure 16 presents the May 2 2016 apparent LNAPL thicknesses from a limited groundwater gauging event and Figure 17 presents the LNAPL thickness from the May 11 2017 annual gauging. A shown on Figure 16, during the May 2016 event there was three main areas with LNAPL detections: • LNAPL in wells B161, B-124, B-175 delineated by B-173 and B-125. • LNAPL in wells B-143, B-142, Sump-1, B-138 and B-147 delineated by B-126, B-138, B-141, B-134 and B-133. • LNAPL in wells B-150, B-149 and B-148 delineated by B-155, B-156, B-163and B-154. LNAPL was also detected in isolated wells B-130, URS-3, B-152, RW-9, U-3, and B-129 delineated by adjacent wells. Based on evaluation of multiple lines of evidence, as presented in Appendix F (LNAPL Evaluation), LNAPL is largely present as hydraulically immobile and unrecoverable residual that is stable in overall extent. The fact that the 27 Pump House Total Fluids Recovery System has been off since September 20, 2010 and passive remediation was discontinued on January 26, 2015, with no perceived rebound in LNAPL thicknesses, also lends support to this assertion. 7. Vapor Investigation The vapor intrusion pathway in AOI 6 was evaluated for potential receptors of vapors originating from subsurface soil or groundwater, in accordance with the PADEP, Land Recycling Program; Technical Guidance Manual for Vapor Intrusion into Buildings from Groundwater and Soil under Act 2, January 2017 (VI Guidance). 7.1 Indoor Air Sampling Evergreen and PES identified structures that could be occupied in AOI 6 during the initial building survey and the October 2017 building survey review, as shown in Table 12 and on Figure 18. During this survey 16 structures were identified as routinely occupied or potentially occupied. These buildings included: Building 6636, 24 Gate Building 295, Lab/Bottle Washing Building 163, Girard Point Training Building 651, Girard Point Main Office Building 650, Capital Projects Tank Group GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 30 Trailers, Control Room 739, Trade Shops 178, Carpenter Shop 726, North Tank Field Blockhouse 475, WTP Control Room 745, Control Room 6627, Control Room south of Boiler House #3, Former Locker House associated with former Boiler House #2, and Office near Separator. The characteristics of several of these buildings were such that vapor intrusion is not considered a complete pathway. The building-specific conditions are as follows: • Refinery Lab/Bottle Washing Building 163 – broken windows visible throughout that allows outdoor air flow • Capital Projects Tank Group Trailers – elevated trailers with perforated soffit-style skirt that allows outdoor air flow • Control Room south of Boiler House #3 – elevated without a skirt • Former Locker House near former Boiler House #2/Process Building – locked and inaccessible, not occupied • Office near Separator – blast resistant building sitting on ground and fork truck holes at the surface (to facilitate relocation) • Paint Shop Building 701 – accessible but unoccupied • Insulation Building 265 – unoccupied building used for storage Indoor air and outdoor ambient (background) air samples were collected in March 2016 and March 2017 from the occupied buildings where the vapor intrusion pathway is potentially complete. The numbers of samples collected for each building was based on a combined approach from Appendix Z of the PADEP VI Guidance and professional judgement. The data from these sampling events are summarized in Table 13 and the locations sampled are shown on Figure 18. A building survey and inspection was conducted to identify any potential indoor air sources of volatile organic compounds (VOCs) possibly already present within the building (e.g., smoking, cleaning products, building products, manufacturing chemicals, etc.), the number and frequency of occupants within the various buildings, and potential preferential migration pathways through the building slab (e.g., utility conduits, slab cracking, etc.). At each building GHD completed an Indoor Air Sampling Field Sheet, which is included in Appendix K. Indoor and ambient air samples were collected using 6-liter capacity Summa™ canisters in a suitable location(s) in each building at a representative breathing zone height (i.e., 3 to 5 feet above grade). Canisters were laboratory-certified clean in accordance with Appendix Z of the PADEP draft VI guidance. The canisters were fitted with a laboratory-calibrated critical orifice flow-regulation device sized to limit the indoor air sample collection flow rate to allow for 8-hour sample collection. Canisters maintained a minimum residual negative pressure of approximately 1 to 5 inches of mercury following sample collection. Written documentation of all field activities, conditions, and sampling processes, including names of field personnel, dates and times, etc. were recorded. Documentation included building designation, building use, occupant information, and weather conditions at the time of sampling (temperature, barometric pressure, wind direction and speed, and humidity). GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 31 Outdoor air sampling locations were selected for collection of an ambient air sample in AOI 6. The outdoor locations were set at the same general elevation of the samples in the buildings and were in a position that is generally upwind of the buildings being assessed. Table 13 summarizes the indoor air and outdoor data and compares the detected concentrations to the generic screening criteria. As shown in Table 13, all detected concentrations of constituents in indoor air were below the Pennsylvania generic non-residential SHS for indoor air, except IA-AOI6-6627 (Building 6627 Control Room), which exceeded for benzene. As shown on Table 13, the benzene concentration at this locations also exceeded 1/10th of the SHS. The location of indoor and outdoor air samples is shown on Figure 18. One additional round will be conducted and reported in a future submittal. If concentrations continue to be detected above the indoor air screening level in IA-AOI6-6627 (Building 6627 Control Room) or other locations, then it will be addressed through risk assessment or remedial activities as presented in the site-wide Risk Assessment report or site-wide Cleanup Plan. 7.2 Air Sampling over LNAPL Plumes In March 2016, two air samples (two locations) were collected to evaluate outdoor air quality in locations over NAPL plumes within AOI 6, at the request of the PADEP. The locations of these samples are shown on Figure 18 and the results are summarized in Table 14. These samples were collected from the breathing zone (3 to 5 feet above ground level) using Summa© canisters with laboratory-provided regulators set to collect air over one continuous 8-hour period. The samples were packaged by field personnel and transported by FedEx to Lancaster Laboratories under Chain-of-Custody documentation for analysis of volatile organic compounds (VOCs) on the Act 2/One Cleanup program petroleum short list by EPA Method TO-15. Table 14 summarizes the outdoor air data collected over NAPL plumes and compares the detected concentrations to background concentrations. PADEP operates a network of air toxics monitoring stations that analyze for VOCs. Regional ambient air quality in the Philadelphia area where the refinery is located is best represented by data from the Marcus Hook monitoring station (latitude 39.8178, longitude -75.4142). USEPA's background residential indoor air values are also included in Table 14 to determine whether detected concentrations are within background levels. As shown in Table 14, the results for the ambient air samples collected from over LNAPL in AOI 6 are within the background levels for this area. The location of indoor and outdoor air samples is shown on Figure 18. No additional sampling is proposed for the air quality over the LNAPL areas. 8. Quality Assurance/Quality Control All fieldwork conducted as part of the site characterization activities was performed in accordance with the methods outlined in Appendix B, Evergreen Field Procedures. Methods established by Evergreen to examine data quality are outlined in the Evergreen Data Usability Standard Operating Procedure (SOP). An assessment of analytical data collected as part of this investigation under the SOP is also included in Appendix H in the data usability assessment. The following sections describe specific aspects of quality assurance/quality control procedures that pertain to the activities outlined in this report. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 32 8.1 Equipment Decontamination All sampling equipment was either dedicated or decontaminated in accordance with the field sampling procedures to prevent cross-contamination. Prior to sampling, the equipment was decontaminated with successive rinses of detergent, potable water, and distilled water. 8.2 Equipment Calibration Air quality monitors used for both air monitoring and soil screening were calibrated prior to use. Both a zero calibration and a span calibration using gases of known concentration as recommended by the manufacturer (i.e., 100 parts per million by volume (ppmv) isobutylene for the photoionization sensor) were performed. 8.3 Sample Preservation Samples were placed directly into chemically preserved and/or non-preserved glassware provided by the analytical laboratory, as appropriate. All samples were preserved and shipped at a temperature of approximately 4°Celsius (C) or less by application of ice prior to shipment to the analytical laboratory. This temperature was maintained during shipment by placing ice in zip-top bags above, around, and below the sample containers. 8.4 Documentation Chain-of-custody forms were maintained throughout the sampling program to document sample acquisition, possession, and analysis. Chain-of-custody documentation accompanied all samples from the field to the laboratory. Each sample was assigned a unique identifier that was recorded in the field notes as well as on the chain-of-custody document. 9. Conceptual Site Model GHD's conceptual understanding of the present conditions identified at AOI 6 and nearby proximity is summarized as follows. 9.1 Description and Site Use • The Philadelphia Refinery is located along the banks of the Schuylkill River in the City of Philadelphia, Philadelphia County, Pennsylvania. The facility, which is located on industrial property, covers approximately 1,300 acres of land with access restricted by fencing and security measures. Current operations at the facility consist of the production of fuels and basic petrochemicals for the chemical industry. • The area surrounding the facility is characterized by a mixture of residential, commercial, and industrial properties. • AOI 6, also known as the Girard Point Chemicals Processing Area, encompasses approximately 100 acres and is located on the east side of the Schuylkill River. AOI 6 is a wedge-shaped property bordered by Lanier Avenue/AOI 3 to the east, Penrose Avenue GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 33 (Route 291)/Platt Memorial Bridge/AOI 5 to the south and Pennypacker Avenue/AOI 7 to the north (Figures 1 and 2). • The entire western boundary of AOI 6 along the Schuylkill River is bound by a sheet pile wall. • AOI 6 formerly contained numerous above ground storage tanks (ASTs) containing benzene, toluene, naphtha and other fuel stocks. A sulfuric acid plant was located along the northern boundary of the AOI. A gasoline treating unit, two reformer units, a BDDA (soap) unit, and a thermal hydro-dealkylation unit were also located in this area. • AOI 6 currently consists of Udex and cumene units, reformer and associated naphtha hydrotreater, a diesel hydrotreater, tankage, boiler-houses and associated feed water treatment, maintenance buildings, lay-down yards, office buildings, the # 2 oil-water separator and remote Laboratory. • There are two leaded tank bottom SWMUs (SWMU Nos. 92 and 95) located in AOI 6 that were addressed in several previous RCRA investigations as part of the EPA Corrective Action Process (CAP). 9.2 Geology and Hydrogeology 9.2.1 Geologic Framework • The Philadelphia Refinery occurs within the up-dip limits of the Atlantic Coastal Plain, generally within 2 miles of the "Fall Line". • Beneath AOI 6, the following Coastal Plain deposits may be present, in order of increasing depth/age: apparent fill, Quaternary alluvium [including Holocene and Pleistocene (Trenton "gravel") deposits], and the Cretaceous Potomac-Raritan-Magothy (PRM) aquifer system lower sand unit. • The PRM upper clay, upper sand, middle sand, and lower clay are interpreted to have been cut or laterally "pinch" out in AOI 6. 9.2.2 Unconfined (Water-Table) Aquifer • Beneath AOI 6, the unconfined aquifer is primarily composed of saturated portions of unconsolidated materials primarily in the fill and alluvium, with lesser amount in the discontinuous Trenton "gravel". • On average, the saturated thickness of the unconfined aquifer beneath AOI 6 is approximately 20 to 30 feet. • No aquifer testing was identified in AOI 6. Evergreen is planning additional aquifer testing in AOI 4 as part of the facility wide fate and transport numerical model. • Water-table mounds are apparent in AOI 6. These mounds are found immediately adjacent to the bulkhead portion of the site. The mounding along the bulkhead is due to the lower hydraulic conductivity of the bulkhead as compared to site soils. There is also an area of groundwater depression in the eastern and central portions of AOI 6. Review of historic groundwater contours show that these contours are consistent with previous groundwater contours. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 34 • Groundwater flows to the southwest towards the river. The gradient towards the southwest is 0.002 ft/ft. This pattern is consistent with the historical contours and supports that flow in AOI 6 is towards the river. 9.2.3 Lower Aquifer (Semi-Confined) • Beneath AOI 6, the lower aquifer is primarily composed of saturated portions of the lower sand geologic unit. • On average, the saturated thickness of the lower aquifer beneath AOI 6 is approximately 25 feet. • Groundwater flow within the lower aquifer beneath AOI 6 has been contoured utilizing data from AOI 5, 6, and 7 wells, and the resultant potentiometric surfaces for synoptic well gauging events conducted in May 2016. The groundwater flow direction is to the southwest under a hydraulic gradient of approximately 0.0019 ft/ft. • GHD evaluated the vertical hydraulic head gradients for the 2016 gauging events between the unconfined and lower aquifer throughout AOI 6. There is a downward gradient between the unconfined and lower aquifers. These gradients are consistent with previous data collected in AOI 6 (2010 RIR and 2012 RIR). • There is no available aquifer testing data for the lower aquifer at the facility. Evergreen is planning on conducting slug and hydraulic tests on the lower aquifer in AOI 4 in support off the facility wide fate and transport modeling. At the time of this RIR however, the best available kh data for the lower aquifer is estimated from historical testing performed at the Philadelphia Naval Shipyard From those tests, values of lower sand kh are estimated to vary from approximately 123 ft/d to 151 ft/d. 9.3 Compounds of Concerns 9.3.1 Soil • Soil delineations were performed to the non-residential direct contact MSC for COCs on Table 1 and the numeric SSS (for lead), except along the bulkhead in AOI 6. • Several soil samples collected during the 2016 site characterization activities exceeded the non-residential direct contact MSCs for lead and benzene and one sample for benzo(a)pyrene. 9.3.2 Groundwater • Two rounds of characterization groundwater sampling were completed in 2016 in addition to other sampling in 2006 and 2012 as a part of this RIR and groundwater samples were analyzed for the COCs on Table 1. • Concentrations of the following COCs were detected above the non-residential MSC in the water table aquifer during the 2016 groundwater sampling events: benzene, isopropyl benzene, toluene, 1,2,4-TMB, benzo(a)anthracene, beno(a)pyrene, beno(g,h,i)pyrene , benzo(b)fluoranthene, chrysene, naphthalene, and lead. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 35 • None of the monitoring wells screened in the lower, semi-confined aquifer had exceedances of the non-residential groundwater MSCs. 9.3.3 Indoor/Ambient Air • An indoor and outdoor air sampling events were conducted in March 2016 and March 2017 to represent ambient air and indoor air conditions during two heating seasons when levels of VOCs inside buildings are expected to be higher than during warmer months. • Only one COC, benzene (in 6627 Building Control Room), was detected in an indoor samples above the PADEP VI screening criteria and the USEPA RSLs. 9.4 LNAPL Distribution and Mobility • Numerous monitoring wells across AOI 6 have been gauged for LNAPL over the course of implementing the investigation and remediation programs. Stantec completed LNAPL and groundwater elevation gauging events in May 2016. During this event, 76 wells were gauged in the unconfined and semi-confined zones. LNAPL was detected in 21 wells with a maximum thickness of 4.27 feet at well B-116 during the May 2016 gauging. • Based on evaluation of multiple lines of evidence, as presented in Appendix F (LNAPL Evaluation), LNAPL is largely present as hydraulically immobile and unrecoverable residual that is stable in overall extent. The fact that the 27 Pump House Total Fluids Recovery System has been off since September 20, 2010 and passive remediation was discontinued on January 26, 2015, with no perceived rebound in LNAPL thicknesses, also lends support to this assertion. • A shown on Figure 16, during the May 2016 event there was three main areas with LNAPL detections: – LNAPL in wells B161, B-124, B-175 delineated by B-173 and B-125. – LNAPL in wells B-143, B-142, Sump-1, B-138 and B-147 delineated by B-126, B-138, B-141, B-134 and B-133. – LNAPL in wells B-150, B-149 and B-148 delineated by B-155, B-156, B-163and B-154. LNAPL was also detected in isolated wells B-130, URS-3, B-152, RW-9, U-3, and B-129 delineated by adjacent wells. 9.5 Qualitative Fate and Transport of Selected Compounds • A soil to groundwater model to evaluate the soil to groundwater pathway was not developed for the qualitative fate and transport assessment presented in this RIR. Rather, a qualitative-level assessment of groundwater data was warranted at this stage of the investigation. • Of the COCs identified to be present in groundwater exceeding the non-residential MSC beneath AOI 6, the majority of the exceedances are for benzene as shown on Figure 19 which are associated, generally, with the occurrence of LNAPL which is immobile as discussed in Appendix F. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 36 9.6 Potential Migration Pathways and Site Receptors • AOI 6 encompasses approximately 100 acres and is located on the east side of the Schuylkill River and access is restricted by fencing and security measures. • PES is responsible for overall facility security and oversight of contractor safety, and PES implements PPE and work plan/permitting protocols that mitigate the potential for worker exposure to impacted soil, groundwater, and/or LNAPL through the direct contact pathway. • AOI 6 areas with identified soil exceedances of the direct-contact MSC for BaP and benzene, with the exception of BH-16-025, and SSS for lead have been delineated and remedies will be addressed in future Act 2 submissions, including a Facility-Wide Cleanup Plan. Additional delineation of benzene in BH-16-025 may be completed to support risk assessment or remedial activities. • Concentrations of COCs identified through indoor and ambient air sampling met the PADEP indoor air criteria and the USEPA RSLs 1e-5 or HI of 0.1. • Free-phase and residual LNAPL present beneath portions of AOI 6 appear to be contained within the property boundary and where present, of limited mobility. • COCs are present in unconfined aquifer groundwater at concentrations above their respective SHS within AOI 6 and adjacent to the river. • None of the COCs exceeded the groundwater MSCs in the lower aquifer. • The Schuylkill River is adjacent to, AOI 6 but the bulkhead separates the water table aquifer and the river. The unconfined aquifer is not utilized for municipal or nearby communal, potable water supply in south Philadelphia. Results of the potable well search are presented in Appendix M. 10. Qualitative Fate and Transport Assessment On September 28, 2015, Evergreen's team of consultants met jointly with the PADEP to discuss the groundwater fate and transport modeling approach under Act 2 at the Philadelphia Refining Complex. At that time, it was collaboratively decided that individual AOI RIR submissions would include qualitative assessments of contaminant fate and transport, including an evaluation of plume stability, COC trends, and potential impacts to surface water. Findings and conclusions of the AOI-specific, qualitative assessments of fate and transport will ultimately be used in a calibrated, steady-state MODFLOW model to perform quantitative fate and transport, including predictive simulations that will address cumulative mass loading to potential receptors. The following discussion qualitatively summarizes factors that may influence contaminant fate and transport at AOI of the facility. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 37 10.1 Geologic Framework As discussed in detail in Sections 2 and 5 of this report, the geologic framework present beneath and in close proximity to AOI 1 can be summarized as follows: • The Philadelphia Refinery occurs within the up-dip limits of the Atlantic Coastal Plain, generally within 2 miles of the "Fall Line". • Beneath AOI 6, the following Coastal Plain deposits may be present, in order of increasing depth/age: apparent fill, Quaternary alluvium [including Holocene and Pleistocene (Trenton "gravel") deposits], and the Cretaceous Potomac-Raritan-Magothy (PRM) aquifer system lower sand unit. • The PRM upper clay, upper sand, middle sand, and lower clay are interpreted to have been cut or laterally "pinch" out in AOI 6. 10.2 Hydrogeology As summarized above and discussed in detail in Section 5 of this report, the geologic framework present beneath and in close proximity to AOI 6 supports the following hydrogeologic conditions: • Two aquifers have been identified beneath the Philadelphia Refinery. In general, these are the water-table (unconfined) and a lower aquifer. Their properties are as follows. 10.2.1 Unconfined (Water-Table) Aquifer • Beneath AOI 6, the unconfined aquifer is primarily composed of saturated portions of unconsolidated materials primarily in the fill and alluvium, with lesser amount in the discontinuous Trenton "gravel". • On average, the saturated thickness of the unconfined aquifer beneath AOI 6 is approximately 20 to 30 feet. • No aquifer testing was identified in AOI 6. Evergreen is planning additional aquifer testing in AOI 4 as part of the facility-wide fate and transport numerical model. • Water-table mounds are apparent in AOI 6. These mounds are found immediately adjacent to the bulkhead. Groundwater depressions are found in the eastern and central portion of AOI 6. • Groundwater flows southwest towards the river with a gradient of 0.002 ft/ft. This pattern is consistent with the historical contours and supports that flow in AOI 6 is towards the river. 10.2.2 Lower Aquifer (Semi-Confined) • Beneath AOI 6, the lower aquifer is primarily composed of saturated portions of the lower sand geologic unit. • On average, the saturated thickness of the lower aquifer beneath AOI 6 is approximately 25 feet. • Groundwater flow within the lower aquifer beneath AOI 6 has been contoured utilizing data from AOI 5, 6, and 7 wells, and the resultant potentiometric surfaces are shown on Figure 15 for GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 38 synoptic well gauging events conducted in May 2016. The groundwater flow direction is to the southwest under a hydraulic gradient of approximately 0.002 ft/ft. • GHD evaluated the vertical hydraulic head gradients for May and August 2016 between the unconfined and lower aquifer throughout AOI 6. There is a downward gradient between the unconfined and lower aquifers. These gradients are consistent with previous data collected in AOI 6 (2006 SCR and 2012 RIR). • There is no available aquifer testing data for the lower aquifer at the facility. Evergreen is planning on conducting slug and hydraulic tests on the lower aquifer in AOI 4 in support off the facility wide fate and transport modeling. At the time of this RIR however, the best available kh data for the lower aquifer is estimated from historical testing performed at the Philadelphia Naval Shipyard From those tests, values of lower sand kh are estimated to vary from approximately 123 ft/d to 151 ft/d. 10.3 Hydrogeology and Topography • LiDAR data collected in 2010 indicates that present-day topography is relatively flat within AOI 6 and proximity, where land surface elevations generally range from approximately 60 feet to just over 75 feet NAVD 88. • Within AOI 6, much of the surface area present is impervious or assumed to be of limited permeability. • The Schuylkill River is directly adjacent to AOI 6. • National Weather Service Online Weather Data (NOWData) for Philadelphia, Pennsylvania, indicates that since 1872, mean annual precipitation is approximately 42 inches (ranging from approximately 29 to 64 inches). • Stormwater runoff within AOI 6 is managed by an onsite storm sewer system that is sent to the facility’s Girard Point Wastewater Treatment Plant. • Natural recharge of the unconfined aquifer beneath AOI 6 and proximity is assumed to be spatially variable but limited in overall capacity as a result of: the high percentage of impervious surface coverage present; and, the fine-grained nature and extent of recent alluvial deposits above the water table. 10.4 Anthropogenic Features 10.4.1 Historic Fill Apparent fill is present beneath the existing land surface at most locations in AOI 6 and has been identified to be approximately 10 feet. The fill is generally heterogeneous in nature and is composed of an admixture of sand and gravel, mud, and anthropogenic debris included cinders, ash, bricks, cinder block, and metal. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 39 10.4.2 Former Remediation Systems The 27 Pump House Total Fluids Recovery System was turned off September 20, 2010 due to absence of recoverable product. Passive remediation began on October 10, 2010 with the installation of absorbent socks in wells B-124, B-132, B-137, B-139, B-142, B-143, and B-147. These wells were gauged on a quarterly basis and any detected LNAPL was passively recovered and transferred to the system holding tank. Based on limited recoverable LNAPL in the proximal wells, passive remediation was discontinued on January 26, 2015. A summary of the remediation systems is presented in Appendix G. 10.5 Groundwater Constituents of Concern 10.5.1 Unconfined (Water Table) Aquifer Concentrations of the following COCs were detected above the groundwater MSCs in unconfined aquifer groundwater during the 2016 characterization sampling events; benzene, isopropyl benzene, 1,2-dibromoethane (EDB), toluene, 1,2,4-TMB, benzo(a)anthracene, beno(a)pyrene, beno(g,h,i)pyrene , benzo(b)fluoranthene, chrysene, naphthalene, and lead. These results are consistent with historic sampling for COCs that have been previously analyzed in AOI 6. The areas that are not proposed to be evaluated for remedial action in the Cleanup Plan have very low levels of semi-volatile compounds and are delineated by other monitoring wells or the bulkhead. These compounds will be evaluated by the site-wide Fate and Transport modeling. 10.5.2 Lower Aquifer No concentrations of COCs were detected above the groundwater MSCs in lower aquifer groundwater during 2016 characterization sampling events. This is consistent with the results from previous sampling events. 10.6 Potential Onsite and Offsite Receptors Based on the identified impacts to groundwater at AOI 6, GHD has evaluated the following as potential receptors: • Vapor intrusion effecting potential occupants of buildings in AOI 6 was evaluated. The results did not exceed the PADEP VI screening levels with the exception of one detection of benzene. • The Schuylkill River could receive AOI 6 groundwater discharging to the river. Although the bulkhead will limit migration of the groundwater from AOI 6 to the river. • Potable consumption of impacted groundwater could affect human health. No known potable supply wells exist at or in proximity to AOI 6. Results of the potable well search are presented in Appendix M. • The PRM aquifer system is heavily utilized for water supply in New Jersey. The aquifers of that system, chiefly the lower sand unit, receive recharge via vertical leakage through confining units and direct recharge from younger deposits along their subcrop area in south Philadelphia. None of the COCs were above the groundwater MSCs in the lower Aquifer in AOI 6. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 40 10.7 Plans for Quantitative Fate and Transport Analysis Stantec is presently developing a site-wide groundwater flow model using the USGS MODFLOW2000 computer code and Groundwater Vistas Version 6 software. The MT3DMS contaminant transport module will be utilized to simulate predictive scenarios of the fate and transport of selected COCs in groundwater. The modeling is being performed to meet and demonstrate compliance with the PADEP Site-Specific Standard for remediation of pre-existing contamination under Act 2, Pennsylvania's Land Recycling Program. Under Act 2 and in consideration of the One Cleanup Program, an analysis of the fate and transport of petroleum-related constituents is needed, in general, to assess risk to potential receptors, assess plume stability, and estimate time to project closure. The site-wide flow model will focus on groundwater movement within the Coastal Plain of south Philadelphia, Pennsylvania, near the Philadelphia Refinery. The model domain was adopted from an earlier USGS model developed by Schreffler (2001), later updated by Sloto (2012), and has been updated by Stantec to more-closely simulate site-specific groundwater flow conditions beneath the facility. Updates to the Schreffler (2001) model have included model layer refinement, grid discretization, updates to the model layer hydraulic properties using site-specific testing data, and the inclusion of drains to simulate losses to the sewers and/or localized pumping centers (e.g., Mingo Creek Pump Station). It is anticipated that Stantec will present the site-wide flow model to PADEP for comment prior to utilization of the model in any fate and transport analyses at the refinery in support of a facility-wide Cleanup Plan, or a site-wide RIR to address cumulative loading of COCs to receptors. 11. Ecological Assessment The majority of AOI 6 is covered with soil, gravel, and impervious surfaces. The soil and gravel-covered portions of AOI 6 are not likely to serve as a breeding area, migratory stopover, or primary habitat for wildlife. On September 23, 2016, a survey of endangered, threatened, and special concern wildlife and habitat was conducted by submitting a search request through the Pennsylvania Natural Diversity Inventory (PNDI) Environmental Review Tool. The results of the PNDI search identified no known impacts by the PA Game Commission, the PA Department of Conservation and Natural Resources, and the U.S. Fish and Wildlife Service. The PNDI search identified potential endangered and threatened species impacts that required further review by the PA Fish and Boat Commission. A no effect letter request was submitted to the PFBC on October 22, 2016. A response was received from the PFBC on November 3, 2016 indicating that no impact is anticipated to the species of special concern. Evergreen intends on completing a habitat assessment to document habitat types present and adjoining AOI 6 and the suitability of these habitats to support species of concern based on the results of the PNDI search even though a no effect letter was received from the PFBC. Evergreen will complete these assessments in accordance with PA Chapter 250.311 and the Pennsylvania Technical Guidance Manual (TGM) by a qualified biologist. The results of this assessment will be included in a future submittal. All ecological assessment documentation is included in Appendix I. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 41 12. Community Relations Activities A Community Relation Plan (CRP) that includes public involvement with local residents to inform them of the anticipated investigations and remediation activities was completed as part of the original NIR submittal in 2006. A revised NIR was submitted in 2014. The purpose of the CRP is to provide a mechanism for the community, government officials, and other interested or affected citizens to be informed of on-site activities related to the investigation activities at the Site. This plan incorporates aspects of public involvement under both PADEP's Act 2 program and USEPA's RCRA Corrective Action program. This report and future Act 2 reports will include the appropriate municipal and public notices in accordance with the provisions of Act 2. Notices will be published in the Pennsylvania Bulletin and a summary of the notice will appear in a local newspaper. As part of the CRP, Evergreen has held an initial public meeting in the City of Philadelphia to present the strategy and give status updates of the project at the CRP meeting on an as requested basis. A copy of the original NIR, the 2014 NIR and the Act 2 report notifications for this RIR are included in Appendix A. 13. Conclusions and Recommendations GHD has prepared this RIR for AOI 6 of the Philadelphia Refinery Complex to satisfy the requirements of Act 2, as specified under 25 PA Code §250.408. The documented investigation activities were performed in general accordance with a 2011 revised Work Plan for Site-wide Approach Under the One Cleanup Program, and were conducted in support of Evergreen's commitment to remediate legacy environmental impacts that existed at the facility prior to its conveyance to PES in 2012 (Buyer-Seller Agreement). In support of those stated objectives, this report has described a comprehensive evaluation of available historical data pertaining to AOI 6, and has documented a remedial investigation strategy that included the collection of a significant amount of additional subsurface information in the time since previous AOI 6 Act 2 deliverables were submitted to PADEP (2013 SCR/RIR). Investigations performed as a part of this report also considered and where relevant, sought to address PADEP comments directed towards previous RIR submissions for the facility. The following summarizes the conclusions and recommendations regarding AOI 6. 13.1 Soil Some historical samples had exceedances of the direct-contact MSC for, BaP, lead and benzene. These historical samples have been delineated. Limited soil samples collected in 2016 exceeded the numeric SSS for lead, the NRDC for benzene and BaP. Additional sampling may be completed to support site-wide Risk Assessment or site-wide Cleanup Plan Reports to delineate benzene in the vicinity of AOI 6-16-025. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 42 13.2 Groundwater 13.2.1 Unconfined (Water-Table) Aquifer Benzene, isopropyl benzene, 1,2-dibromoethane (EDB), toluene, 1,2,4-TMB, benzo(a)anthracene, beno(a)pyrene, beno(g,h,i)pyrene , benzo(b)fluoranthene, chrysene, naphthalene, and lead exceeded the current non-residential MSCs in the unconfined aquifer. The concentrations of COCs exceeding the MSCs in the unconfined aquifer have generally been delineated. The following wells have groundwater MSC exceedances but are not explicitly delineated by other wells with concentrations below MSCs: B-39, B-43, B-169, U-4, and URS-5. These wells are located near the bulkhead and do not have any wells that can delineate these concentrations. 13.2.2 Lower Aquifer None of the samples in the lower aquifer exceeded the non-residential MSCs, which is consistent with historic data in AOI 6 therefore no further assessment was completed for the Lower Aquifer in this RIR. As indicated above for the unconfined aquifer, a MODFLOW model will be utilized during quantitative fate and transport analyses to evaluate the Lower Aquifer for the facility. 13.3 Vapor Intrusion Concentrations of COCs in indoor and outdoor ambient air were evaluated in the ten occupied buildings in AOI 6 where the vapor intrusion pathway is potentially complete. There were no exceedances of the PADEP VI criteria except IA-AOI6-6627 (Building 6627 Control Room), which exceeded for benzene. Evergreen is intending to complete an addition round of indoor air sampling within AOI 6. Results of the additional sampling event will be reported to PADEP in a future Act 2 deliverable. Indoor air concentrations in exceedance of the indoor air screening criteria will be addressed in a site-wide risk assessment or remedial activities as presented in the site-wide Risk Assessment report or site-wide Cleanup Plan. 13.4 LNAPL LNAPL within AOI 6 has been delineated, except in areas along the bulkhead where delineation is not possible. The majority of LNAPL sampled was categorized as a light to middle distillates. LNAPL recovery has been suspended due to poor recovery and immobility of the LNAPL. 14. References ARCADIS (2013). Second Quarter 2013 Report for the Former Defense Supply Center Philadelphia Facility, Philadelphia, PA. Balmer, W.T., and Davis, D.K. (1996). Ground-Water Resources of Delaware County, Pennsylvania, Pennsylvania Geological Survey, 4th Series, Water Resources Report 66: 67p. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 43 Bosbyshell, H. (2008). Bedrock Geologic Map of a Portion of the Philadelphia Quadrangle, Montgomery and Philadelphia Counties, Pennsylvania, Pennsylvania Department of Conservation and Natural Resources, Bureau of Topographic and Geologic Survey OFBM 08-05.0. Greenman, D.W., Rima, D.R., Lockwood, W.N., and Meisler, H. (1961). Groundwater Resources of the Coastal Plain Area of Southeastern Pennsylvania, Pennsylvania Geological Survey Bulletin W13. Integrated Science & Technology (IST), Inc. (1998). Non-Aqueous Phase Liquid (NAPL) Source Study at Defense Supply Center Philadelphia, Philadelphia, PA. Langan (2004) Current Conditions Report, Sunoco Philadelphia Refinery, Philadelphia, PA. Langan (2006) Site Characterization Report AOI 6, Sunoco Philadelphia Refinery, Philadelphia, PA. Langan (2013) SCR/RIR, Sunoco Philadelphia Refinery, Philadelphia, PA. Langan (2015) Human Health Risk Assessment Report, PES, Belmont Terminal and MHIC, Philadelphia, PA. Low, D.J., Hippe, D.J., and Yannacci, D. (2002). Geohydrology of Southeastern Pennsylvania, U.S. Geological Survey Water-Resources Investigations Report 00-4166: 347p. Navoy, A.S. and Carleton, G.B. (1995). Ground-Water Flow and Future Conditions in the Potomac-Raritan-Magothy Aquifer System, Camden Area, New Jersey, New Jersey Geological Survey Report 38: 184p. Owens, J.P., and Minard, J.P. (1979). Upper Cenozoic Sediments of the Lower Delaware Valley and Northern Delmarva Peninsula, New Jersey, Pennsylvania, Delaware and Maryland, U.S. Geological Survey Professional Paper 1067-D: 47p. Pennsylvania Department of Environmental Protection, Bureau of Waste Management (2002). Pennsylvania Code, Title 25. Environmental Protection, Chapter 245. Administration of the Storage Tank and Spill Prevention Program. Commonwealth of Pennsylvania, p. 48-66.2. Pennsylvania Department of Environmental Protection, Bureau of Land Recycling and Waste Management (2002). Pennsylvania Code, Title 25. Environmental Protection, Chapter 250. Administration of Land Recycling Program. Commonwealth of Pennsylvania. Pennsylvania Department of Environmental Protection, Land Recycling Program (2013). Statewide Health Standards, Table 1 – Medium Specific Concentrations (MSCs) for Organic Regulated Substances in Groundwater. http://www.portal.state.pa.us/portal/server.pt/community/land_recycling_program/20541/state wide_health_standards/1034862. Pennsylvania Department of Environmental Protection, Land Recycling Program (2013). Statewide Health Standards, Table 2 – Medium Specific Concentrations (MSCs) for Inorganic Regulated Substances in Groundwater. http://www.portal.state.pa.us/portal/server.pt/community/land_recycling_program/20541/state wide_health_standards/1034862. GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 44 Pennsylvania Department of Environmental Protection, Land Recycling Program (2013). Statewide Health Standards, Table 3a – Medium-Specific Concentrations (MSCs) For Organic Regulated Substances In Soil: Direct Contact Numeric Values. http://www.portal.state.pa.us/portal/server.pt/community/land_recycling_program/20541/state wide_health_standards/1034862. Pennsylvania Department of Environmental Protection, Land Recycling Program (2013). Statewide Health Standards, Table 3b – Medium-Specific Concentrations (MSCs) For Organic Regulated Substances In Soil: Soil To Groundwater Numeric Values. http://www.portal.state.pa.us/portal/server.pt/community/land_recycling_program/20541/state wide_health_standards/1034862. Pennsylvania Department of Environmental Protection, Land Recycling Program (2013). Statewide Health Standards, Table 4a – Medium-Specific Concentrations (MSCs) for Inorganic Regulated Substances in Soil: Direct Contact Numeric Values. http://www.portal.state.pa.us/portal/server.pt/community/land_recycling_program/20541/state wide_health_standards/1034862. Pennsylvania Department of Environmental Protection, Land Recycling Program (2013). Statewide Health Standards, Table 4b – Medium-Specific Concentrations (MSCs) for Inorganic Regulated Substances in Soil: Soil to Groundwater Numeric Values. http://www.portal.state.pa.us/portal/server.pt/community/land_recycling_program/20541/state wide_health_standards/1034862. Pennsylvania Department of Environmental Protection (2015). Land Recycling Program Technical Guidance Manual for Vapor Intrusion into Buildings from Soil and Groundwater under Act 2 (Draft). Paulachok, G.N. (1991). Geohydrology and Ground-Water Resources of Philadelphia, Pennsylvania, U.S. Geological Survey Water-Supply Paper 2346: 79p. Schreffler, C.L. (2001). Simulation of Ground-Water Flow in the Potomac-Raritan-Magothy Aquifer System Near the Defense Supply Center Philadelphia, and the Point Breeze Refinery, Southern Philadelphia County, Pennsylvania, U.S. Geological Survey Water-Resources Investigations Report 01-4218: 48p. Sevon, W.D. and Braun, D.D. (2000). Glacial Deposits of Pennsylvania, Pennsylvania Department of Conservation and Natural Resources, Bureau of Topographic and Geologic Survey Map Series No. 59 (2200-MP-DCNR3027). Sevon, W.D., Fleeger, G.M., and Shepps, V.C. (1999). Pennsylvania and the Ice Age (2nd Edition), Pennsylvania Geological Survey, 4th Series, Educational Series 6: 30p. Sunoco (2006). Work Plan for Site Characterization Area of Interest 6, Sunoco Philadelphia Refinery, Philadelphia, PA. Trapp, H. (1992). Hydrogeologic Framework of the Northern Atlantic Coastal Plain in Parts of North Carolina, Virginia, Maryland, Delaware, New Jersey, and New York, Regional Aquifer-System Analysis – Northern Atlantic Coastal Plain, U.S. Geological Survey Professional Paper 1404-G: 59p. USGS (2010). National Elevation Dataset, 1/9 Arc Second Raster Elevation Data, The National Map (download platform). GHD | Remedial Investigation Report, AOI 6 Girard Point Refinery | 11109613 (2) | Page 45 Attachment 53 April 30, 2018 Reference No. 11109613 Mr. David Brown Pennsylvania Department of Environmental Protection Southeast Regional Office 2 East Main Street Norristown, Pennsylvania U.S.A. 19401 Dear Mr. Brown: Re: Responses to Comments – AOI 6 Remedial Investigation Report Dated November 21, 2017 Philadelphia Energy Solutions Refining & Marketing LLC (PES) Philadelphia Refinery Complex 3144 West Passyunk Avenue Philadelphia, PA (PHAOI-6) This letter is being submitted on behalf of Evergreen Resources, LLC to provide responses to comments from the Pennsylvania Department of Environmental Protection (PA DEP) Act 2 Program (Act 2) dated March 1, 2018 regarding the 2017 Remedial Investigation Report (RIR) for Area of Interest (AOI) 6 at the Philadelphia Energy Solutions complex (Site). The original comments provided by PA DEP are reproduced in italicized text below, with Evergreen’s responses following. Soil 1. Benzene direct contact exceedances were present in samples collected from borings BH-16-025 and BH-16-037, in the area north and northeast of Tank 797. These exceedances do not appear to be delineated immediately west of these borings. We recognize that this area is part of an active process unit. Further delineation may be needed to implement a remedy. The benzene direct contact exceedances from boring BH-16-025 and BH-16-037 will be assessed through Risk Assessment activities as presented in the site-wide Risk Assessment Report or the site-wide Cleanup Plan. Additional sampling is anticipated to support either the Risk Assessment or the Cleanup Plan activities. 2. The lead direct contact standard exceedance at BH-17-004 does not appear to be delineated between the bulkhead and the boring location. Further delineation may be needed to implement a remedy. Sample location BH-17-003 is located in the general area between BH-17-004 and the bulkhead and has lead detections at concentrations below the direct contact standard. Additionally, lead in the area between BH-17-004 and the bulkhead will be assessed through Risk Assessment activities as presented in the site-wide Risk Assessment Report or the site-wide Cleanup Plan. Additional sampling is anticipated to support either the Risk Assessment or the Cleanup Plan activities. GHD 455 Phillip Street Waterloo Ontario N2L 3X2 Canada T 519 884 0510 F 519 884 0525 W www.ghd.com 3. An exceedance of the benzo(a)pyrene direct contact MSC was identified in shallow soil (BH-29-06). EPA issued a new IRIS toxicological review of benzo(a)pyrene in Jan 2017. Evergreen might consider calculating a site-specific numerical value for benzo(a)pyrene or performing a risk assessment using the updated toxicological information. Evergreen is planning to submit a site-wide Human Health Risk Assessment for the entire Site. Evergreen will consider including benzo(a)pyrene with the updated toxicological information in the site-wide Risk Assessment. Groundwater & LNAPL 4. LNAPL is not delineated between B-39 and the river. Potential migration of LNAPL to the river should be considered as part of the fate-and-transport and surface water attainment analyses. Since 2007, the appearance of measurable LNAPL in B-39 has been ephemeral, only being noted in two of fourteen well gauging events. Additionally, the LNAPL in this well has been identified as highly weathered/degraded. Considering these points collectively, the LNAPL in the vicinity of B-39 is largely present as old, immobile residual which will be considered during the quantitative fate and transport and surface water attainment analysis. Additional assessment of LNAPL in this area will be conducted and included in a future Act 2 submittal. 5. LNAPL distribution and mobility discussions (Sections 6.2 and 9.4) do not include well B-39 as indicated on Figure 16. LNAPL was present in B-39 in May 2016 as shown on Figure 16. However, LNAPL was not detected in this well in the two more recent gauging events in August 2016 and May 2017. Furthermore, as previously mentioned, the appearance of measurable LNAPL in B-39 has been ephemeral, only being noted in two of fourteen well gauging events since 2007. In other words, measurable LNAPL has not typically/regularly been present in this well with reference to numerous monitoring events in the last 10 years. Additionally, as noted above, the age of the LNAPL, well gauging history, and level of degradation indicate that the LNAPL in the vicinity of B-39 is largely immobile residual. However, since LNAPL has been detected in B-39, it will be considered during the quantitative fate and transport and surface water attainment analysis. Additional assessment of LNAPL in this area will be conducted and included in a future Act 2 submittal. Exposure Pathways 6. We note that there were vapor intrusion screening value exceedances for benzene and naphthalene in some buildings. An inhalation risk assessment should be performed for those receptors in future reporting. The vapor intrusion (VI) screening value exceedances for benzene and naphthalene will be evaluated in the site-wide Risk Assessment Report. 7. Some reporting levels in the indoor air sample analyses exceeded applicable screening values (Table 13). Please refer to DEP’s FAQs on the VI guidance for the application of PQLs to screening. 11109613Brown-1 2 The method TO-15 PQLs were obtained from the laboratory by requesting documentation of the lowest calibration point attained for the time of the sample analysis. This documentation is included in Attachment A to this letter. Table 13, also included in Attachment A, has been revised to present both the sample-specific practical quantitation limits (PQLs), as well as the method detection limits (MDLs). The PQL is used as the reporting limit. The samples with detected concentrations or reporting limits greater than the VI screening levels will be assessed through Risk Assessment activities as presented in the site-wide Risk Assessment Report or the site-wide Cleanup Plan. Additional VI sampling is anticipated to support either the Risk Assessment or the Cleanup Plan activities. 8. Evergreen could consider collecting additional outdoor air samples in the area of benzene soil direct contact MSC exceedances (vicinity of Tank 797). The direct contact MSC for benzene is based on an inhalation exposure pathway. The benzene soil direct contact MSC exceedances (vicinity of Tank 797) will be assessed through Risk Assessment activities as presented in the site-wide Risk Assessment Report. Additional soil and ambient air sampling will be conducted to support the Risk Assessment activities. 9. In the PNDI review, the Pennsylvania Fish and Boat Commission indicated that four threatened/endangered species may be present at AOI 6 (Appendix I). Please identify these species. There is a potentially complete exposure pathway for the species of concern, and the report notes that a habitat assessment will be performed. Evergreen will include the habitat assessment for ecological receptors in a future submittal. Tables, Figures, and Appendices 10. Figure 20 does not show all of the deep wells. The figure should be revised; we recommend that it depict only the deep wells rather than all AOI 6 sample locations. Figure 20 has been revised to present the locations of the deep wells in AOI 6, and is included in Attachment B. 11. The AOI 6 deep wells are not listed in Table 6. Provide a corrected version with the deep well information. Table 6 has been revised to include the deep wells in AOI 6, and is included in Attachment B. 12. According to Appendix F.1, there is a substantial LNAPL thickness in B-129. However, Figures 16, 17, and Figure 16 of Appendix F do not show LNAPL at this well. Provide corrections to these figures. As shown in Appendix F.1, LNAPL was detected in B-129 during the May 11, 2017 groundwater measurement event. LNAPL was not detected during the May 2, 2016 or the May 11, 2016 groundwater measurement events. LNAPL was detected in B-116 during the May 11, 2016 measurement event. B-116 has no history of LNAPL. Depth to water at B-116 is typically approximately 6 feet while the depth to water at B-129 is typically approximately 10 feet. During the May 11, 2016 water level measurements, the depth 11109613Brown-1 3 to water at B-116 was recorded as 9.46 feet and the depth to water at B-129 was recorded as 5.88 feet. Given the proximity of B-116 and B-129, field measurements during May 2016 for these two wells were likely switched. Despite this mix-up in the field, the LNAPL thicknesses in Figure 17 of the RIR and Figure 16 of Appendix F were not revised. Figure 17, of the RIR, was inaccurately dated May 11, 2017 instead of May 11, 2016. The date of Figure 17 and Figure 16 of Appendix F, however, has been revised to May 11, 2016 and is included in Attachment C. The absence of LNAPL in B-116 was confirmed again via gauging on April 24, 2018. 13. Please provide a hardcopy of Appendix F to include in our file. (It can exclude Table 3 and the appendices, and reference the CD-ROM to access them.) Attachment D includes a hardcopy of Appendix F without Table 3 and the appendices. Additional language has been added to reference the CD-ROM for Table 3 and the appendices. Should you require any additional information, please do not hesitate to contact us. Yours truly, GHD Colleen Costello MT/ks/1 cc: Tiffani Doerr – Evergreen Michael Tomka - GHD 11109613Brown-1 4