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REVISED TECHNICAL MEMORANDUM

Preliminary Remediation Goals (PRGs)and Applicable or Relevant and

Appropriate Requirements (ARARs)

Waukegan Manufactured Gas and Coke Plant Site

September 4, 1992

Prepared forNorth Shore Gas Company

Prepared by Barr Engineering Co.

TECHNICAL MEMORANDUM

PRELIMINARY REMEDIATION GOALS (PRGs) AND

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)

TABLS OF CONTENTS

Pace

1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2.0 PRELIMINARY REMEDIATION OBJECTIVES . . . . . . . . . . . . . . . . . 12.1 Conceptual Site Model . . . . . . . . . . . . . . . . . . . . . 3

2.1.1 Sources . . . . . . . . . . . . . . . . . . . . . . . . 32.1.2 Key Contaminants . . . . . . . . . . . . . . . . . . . . 42.1.3 Contaminant Migration . . . . . . . . . . . . . . . . . 62.1.4 Land Use Factors and Potentially Exposed Populations . . 72.1.5 Potential Exposure Pathways . . . . . . . . . . . . . . 9

2.2 Preliminary Identification of Remediation Objectives . . . . . 102.2.1 general Remedial Action Objectives . . . . . . . . . . . 102.2.2 Site-Specific Remedial Action Objectives . . . . . . . . 12

3.0 POTENTIAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS ... 133.1 ADDli|<7*hle Requirements . . . . . . . . . . . . . . . . . . . . 133.2 Relevant and Appropriate Requirements . . . . . . . . . . . . . 143.3 Application of ARARs . . . . . . . . . . . . . . . . . . . . . 143.4 Other Criteria or Guidelines to be Considered . . . . . . . . . 153.5 Classification of ARARs . . . . . . . . . . . . . . . . . . . . 15

3.5.1 Chemical-Specific ARARs . . . . . . . . . . . . . . . . 163.5.1.1 Soil . . . . . . . . . . . . . . . . . . . . . 163.5.1.2 Sediment . . . . . . . . . . . . . . . . . . . 173.5.1.3 Groundwater Quality Standards . . . . . . . . . 173.5.1.4 Surface Water Quality Standards . . . . . . . . 19

3.5.2 Location-Specific ARARs . . . . . . . . . . . . . . . . 203.5.3 Potential Action-Specific ARARs . . . . . . . . . . . . 20

4.0 PRELIMINARY REMEDIATION GOALS . . . . . . . . . . . . . . . . . . . 214.1 Soil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 224.2 Groundwater . . . . . . . . . . . . . . . . . . . . . . . . . . 24

REFERENCES

TECHNICAL MEMORANDUM

PRELIMINARY REMEDIATION GOALS (PRGs) AND

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)

1.0 INTRODUCTION

This technical memorandum discusses preliminary remediation objectives for

the Waukegan Manufactured Gas and Coke Plant (WCP) site, identifies potentialARARs, and discusses PRGs for addressing contamination at the site. Thepreliminary identification of ARARs and the development of PRGs is based on thecurrent understanding of site conditions (summarized below) and the preliminaryidentification of remedial alternatives presented in the July 1991 Work Plan.

The ARAR and risk assessment issues summarized in this technical memorandumare submitted for United States Environmental Protection Agency (U.S. EPA)review and approval. This technical memorandum has been revised from the July1991 draft version based on U.S. EPA comments and the results of the Phase Iinvestigation (Barr, 1992). U.S. EPA comments on this revised document will beconsidered before the Phase II investigation begins. This process has beendesigned to provide a basis for interaction between: (1) the remedialinvestigation data collection activities directed by North Shore Gas Company andGeneral Motors; and (2) the risk assessment activities directed by the U.S. EPA.

2.0 PRELIMINARY REMEDIATION OBJECTIVES

As defined in the National Contingency Plan (NCP), remediation objectivesare established to provide a general description of what the remedial action isintended to accomplish. The remedial objectives are based on the understandingof site conditions and risks derived from the remedial investigation and thebaseline risk assessment. At this stage in the RI/FS process, the remedialobjectives presented are preliminary.

Remedial action objectives include general and site-specific objectives.General remedial action objectives are defined by the National Contingency Plan(NCP) and CERCLA (as amended by SARA) and are applicable to all Superfund sites.

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These objectives relate to the statutory requirements for development of the

remedy. Site-specific remedial objectives relate to specific contaminatedmedia, potential exposure routes, and exposure parameters. They are intendedto identify target remediation areas and remediation goals. Remedial action

objectives are presented in Section 2.2. Preliminary remediation objectives arediscussed below to: (1) establish a framework for beginning consideration ofpotential remedial actions designed to meet remediation goals; and (2) providethe U.S. EPA and IEPA with information about the conceptual model used todevelop the approach to site investigation.

SARA requires that remedial actions must comply with ARARs under federaland state environmental laws or facility siting laws or must provide grounds for

seeking a waiver of the requirement. In addition to ARARs, remedial actions mayconsider, as appropriate, other advisories, criteria, or guidelines. PotentialARARs are presented in Section 3.5.

Remediation goals are medium-specific or operable unit specific chemicalconcentrations that are protective of human health and the environment and serveas goals for the remedial action. Preliminary remediation goals are an earlyscreening tool and are developed early in the RI/FS process based on ARARs andother information such as concentrations associated with a cancer risk level.PRGs are revised as information on the site is developed. The NCP (U.S. EPA

1990) and EPA guidance (U.S. EPA 1991b) indicate that PRGs are to be modified

based on the results of the baseline risk assessment.

The preliminary remediation objectives developed in this section are usedin conjunction with potential ARARs (Section 3) to establish PRGs (Section 4).Early consideration of these issues will help coordinate completion of theinteractive investigation/risk assessment activities.

As the site investigation proceeds, information about the nature and extentof potential contamination will be used to quantify associated potential risksto human health and the environment. The quantified risks will be consideredin the feasibility study for developing site-specific goals for the remedialmeasures being evaluated. The following discussions are based on the current


understanding of site conditions and will be re-evaluated as the investigation

progresses.

2.1 Conceptual Site Model

The following conceptual model of site conditions has been developed toprovide a rational framework for establishing preliminary remediation objectivesfor the WCP site.

2.1.1 Sources

As described in the July 1991 Work Plan, two potential sources ofcontamination have been identified at the WCP site. The first is a formerrailroad tie and wood treating plant located on the west side of the site. Thesecond is the manufactured gas/coke plant formerly present on the easternportion of the site.

Creosote was used as wood preservative at the former railroad tie and woodtreating plant. Waste disposal and other operating practices at the formerplant are not clear. Drippings from treated ties, spillage during processing,leaks and spillage from creosote storage or transfer areas, and disposal ofprocess wastes are potential sources of contamination. The presence of oil inthe soil and moderate to heavy oil sheens were observed on soil samples from thevicinity of the former wood treating plant (Barr, 1992) . There are no currentlyvisible structures associated with this operation on-site.

The operating practices of manufactured gas/coking facilities includedcollection and sale of by-products such as tar and ammonia. Gas was purifiedon-site using a Thylox process. The disposition of Thylox and othermanufactured gas/coking wastes is not known. MGP/coking residuals may includetars, tarry and/or oily soils, purifier residuals, and groundwater containingassociated chemical constituents. The presence of tar and oil in the soil andmoderate to heavy oil sheens were observed on soil samples collected from areasin the vicinity of the former MGP/coking facilities in the Phase Iinvestigation; moderate oil sheens were also observed on samples from an areain the northeast portion of the site (Barr, 1992). With the exception of a


building being used by OMC and a few at-grade structures or foundations, noabove-ground structures from the manufactured gas/coking facility remain at the

site.

2.1.2 Key Contaminants

Waste types that may have resulted in chemical constituents identified in

the Phase I RI include creosote, coal tar, and Thylox wastes. These wastes maycontain hundreds of different individual compounds. Based on toxicities andregulatory standards, four categories of key constituents have been identifiedas being most significant for the investigation and remediation of the WCP site.These categories are described below:

• Polycyclic Aromatic Hydrocarbons (PAHs) — PAHs are organic compoundsthat are primary components of both creosote and coal tar. Thesecompounds contain two or more benzene ring structures. IndividualPAHs vary in toxicity, and seven PAH compounds have been identifiedby the U.S. EPA as probable human carcinogens.

• Phenolic Compounds — Phenolic compounds are organic compoundsassociated with creosote and coal tar. Phenols are comprised of a

single benzene ring structure with one or more attached hydroxyl

groups. Phenolic compounds as a class are generally less toxic thanPAHs, and have not been identified as known or suspected humancarcinogens by the U.S. EPA.

• Volatile Organic Compounds — Volatile organic compounds associatedwith creosote and/or coal tar wastes include the following aromatic

compounds: benzene, ethylbenzene, toluene, and xylenes (BETX),These aromatic compounds are comprised of a single benzene ring withor without attached methyl groups. Benzene is classified as a knownhuman carcinogen by the U.S. EPA. The other three have not beenidentified as known or suspected human carcinogens by the U.S. EPA.

• Metals and Inorganics — The most significant of the metals andinorganic compounds likely to be associated with manufactured


gas/coking processes are arsenic and cyanide compounds(thiocyanates). These constituents may be associated with wastesfrom the Thylox gas purification process formerly used at the WCPsite. The toxicities of these constituents vary depending upon theparticular chemical form that may be present at the site.

Data collected during Phase I of the remedial investigation (Barr, 1992)have been reviewed to assess specific chemical constituents associated with theabove categories and to identify possible additional chemicals of concern. Thereview was also used to determine if all the chemicals listed in the July 1991draft discussion of PRGs are, in fact, likely to be addressed duringremediation. Based on this review, potential ARAR identification led to thedevelopment of preliminary remediation goals for the following chemicals:

• Benzene• Ethylbenzene• Toluene• Xylenes• Carcinogenic PAHs (see Table I)• Noncarcinogenic PAHs (see Table 1)• Phenols• Arsenic

• Cyanide

• Cadmium• Selenium

• Mercury

Specific preliminary remediation goals were developed for certain specificPAHs, but not for noncarcinogenic PAHs as a group. Nevertheless, the suite of

noncarcinogenic PAHs in Table 1 is carried through in subsequent chemicalspecific evaluations because of their association with creosote and MGP/cokingtars.

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2.1.3 Contaminant Migration

Potential contaminant migration pathways at the WCP site will depend on thelocations of the waste and contaminated media. Shallow groundwater at the siteis believed to move through the sand unit and discharge to surface waters.Phase I groundwater elevation data indicate the discharge is predominantly toWaukegan Harbor. Deeper groundwater reportedly shows upward gradients, basedon regional information, and is isolated from shallow groundwater by thepresence of a till unit extending from depths of approximately 25 to 30 feet

below the ground surface to depths of approximately 65 to 110 feet below theground surface.

The potential contaminant migration mechanisms for the site include:

• Movement of tars downward to the sand/till contact and subsequenthorizontal movement controlled primarily by the slope of the till;

• Leaching by infiltrating water of contaminants from source materialsabove the water table and leachate migration to the groundwater;

• Leaching by groundwater of contaminants from tars and tar-saturatedsoil present below the water table;

• Movement of dissolved phase constituents with groundwater anddischarge to surface waters;

• Release of fugitive dust to ambient air through wind-driven andmechanical erosion (including disturbance/development) ifcontaminants are present in surface soil; and

• Volatilization and upward diffusion of constituents from theunsaturated zone to the ambient air.

The movement of specific constituents will be a function of their physicaland chemical properties. Of the identified key contaminants, the volatileorganics, phenolics, and lower molecular weight PAHs (e.g., naphthalene and


acenaphthene) are most mobile in a soil-groundwater matrix and may be released

to groundwater. The volatile organics and lower molecular weight PAHs are mostmobile in a soil-air matrix and may be capable of volatilization and diffusionto the ambient air. The higher molecular weight PAHs and metals are more likelyto remain bound to a soil matrix and have limited mobility.

2.1.4 Land Use Factors and Potentially Exposed Populations

Consideration of current and potential land use at the WCP site will affectthe potential for and degree of exposure to contaminants contained in variousmedia. As stated in the NCP (page 8710), "the likelihood of [an] exposureactively occurring should be considered when deciding the appropriate level ofremediation." The following discussion of existing land use factors andcontrols provides a basis for evaluating the potential for various exposures to

occur.

Land use in the area surrounding the WCP site is predominantly industrial,recreational, and commercial. Land use at the WCP site is commercial marine,industrial, and vacant land; recent uses include special event parking, boatstorage, and miscellaneous storage. The City of Waukegan Zoning Ordinance(1987) identifies the southern portion of the site as being zoned for industrialuse (General Industrial District 12, "relatively remote from residential andbusiness development") and the northern portion of the site as being zoned forcommercial development to support marine recreational use (Marine-CommercialRecreational District M-CR, "for commercial marina and lake-orientedactivities"). Residential development is not a permitted land use for thesezoning classifications.

The 1987 Comprehensive Land Use Plan for the City of Waukegan states thatthe City's goals and policies are for future industrial use of the site. Ifresidences are to be developed along the harbor, the 1987 Comprehensive Planindicates that it would likely occur in an area designated as "Harbor MixedUse", located approximately 1 mile south-southwest of the site. A boat launchfacility, formerly under consideration by the Waukegan Port District (nowcanceled), is a type of use appropriate to the site zoning and the site

designation in the comprehensive plan. The commercial marine facility is


expected to expand their operation around Slip No. 4. There are currently no

other active plans for development of the site.

Current uses of Waukegan Harbor can be expected to continue in the future.

The harbor serves as a freight harbor for ships unloading gypsum and cement.At the north end of the harbor is a boat storage/servicing facility forrecreational boats. The harbor serves as access to this facility. Otherwise,little recreational boating takes place in the harbor. Fishing in the harborwould take place along the breakwater that forms the south boundary of the

harbor or from boats.

Possible future expansion of marinas south of Waukegan Harbor, noted in theCity's Comprehensive Land Use Plan, may change the volume and/or pattern of useof the newly-constructed slip and boat storage/servicing facility in the

northwestern portion of the WCP site. However, space limitations of the newslip will provide an upper bound on potential boat traffic volumes. The newslip is designed for use as a commercial facility. Future uses of the harboralso include the PCB hazardous waste impoundment under construction at theformer Slip No. 3.

Current recreational use of nearby areas of the Lake Michigan can beexpected to continue in the future. The public beach on Lake Michigan to the

east, separated from the site by Pershing Road, is a swimming and recreationalarea. Lake Michigan is also used for boating and fishing.

In addition to potentially affecting the land uses described above,chemical constituents originating from the WCP site may affect aquatic organismspresent in Waukegan Harbor and Lake Michigan. These organisms include fish,bottom-dwelling organisms (benthic macroinvertebrates), and plankton (CH2M Hill,1983) . Because continued use of the harbor for boating and industrial purposeswill require periodic dredging of accumulated sediments, it is unlikely that acontinuous community of benthic macroinvertebrates will be established in theharbor.

Chemical constituents in wastes and soils at the WCP site may affectgroundwater quality. The use of groundwater for drinking water supplies in the


Waukegan area is restricted by the 1987 Waukegan Zoning Ordinance. This

ordinance indicates that individual wells are not permitted in the 12 and M-CRDistricts encompassing the site (Article 11.3-4). In addition, any newsubdivisions in the City would be required to tie in to the existing city watersupply system (Article 11.3-2). The water intake for the City of Haukegansystem is located in Lake Michigan more than 6,000 feet east-southeast of the

site.

2.1.5 Potential Exposure Pathways

The land use factors and conceptual model of site conditions describedabove indicate that risks from contamination that may be identified at the siteare likely to be associated with the following potential exposure pathways:

• Exposure of recreational users of the harbor (i.e., boaters andfishermen) and lake (i.e., boaters, fishermen, and swimmers) to

compounds released to the surface water from groundwater discharge;

• Exposure of aquatic organisms in the harbor and lake to compoundsreleased to the surface water from groundwater discharge;

• Exposure of people consuming fish from the harbor and lake if thefish accumulated compounds that had been released to the surfacewater;

• Direct contact of site visitors with waste residuals present insurface soils;

• Direct contact of terrestrial biota with waste residuals present insurface soils;

• Inhalation by site visitors of contaminated dust or volatilecompounds released to the ambient air; and

• Exposure of utility workers to contaminated soils by direct contactor inhalation during excavation.

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Ingestion of groundwater is not considered a likely exposure pathway

because existing institutional controls (i.e., the Waukegan Zoning Ordinance)do not permit individual water supply wells on or near the site and would alsorequire any new developments to tie in to the city water supply system.

The potential exposure of benthic organisms in Waukegan Harbor to

contaminants migrating off-site is not considered a major exposure pathway. Thedredging of harbor sediments as part of the OHC cleanup, along with continuedperiodic dredging necessary for harbor maintenance, would prevent theestablishment of a permanent community of benthic macroinvertebrates.

Potential exposures of site visitors to contaminants present in soil andgroundwater would reasonably be expected to occur under land use scenariosinvolving continued industrial/marine recreation uses, as prescribed by existinginstitutional controls (i.e., the Waukegan Zoning Ordinance). Even ifresidential use of the site is considered as a possible scenario for riskassessment purposes, potential exposures would be limited by: (1) the need toimport topsoil for growing grass or shrubs in the site's sandy soils, therebyproviding a 4- to 12-inch cover that would limit potential direct contact withcontaminated surface soils; and (2) the shallow water table at the site, whichwould preclude the construction of basements for on-site residences — theresulting construction methods (likely involving construction on concrete slabs)may mitigate the potential for exposures from volatilization of chemicals intoresidences.

2.2 Preliminary Identification of Remediation Objectives

2.2.1 General Remedial Action Objectives

General remedial action objectives are defined by CERCLA (as amended bySARA) and the National Contingency Plan (NCP) and are applicable to allSuperfund sites. Under CERCLA (as amended by SARA), the statutory scope ofremedial actions at all CERCLA sites includes the following general objectives:

• Remedial actions "shall attain a degree of cleanup of hazardoussubstances, pollutants, and contaminants released into the


environment and of control of further releases, at a minimum, which

assures protection of human health and the environment" (Section

• Preference should be given to selection of remedial actions "in whichtreatment that permanently and significantly reduces the volume,toxicity, or mobility of the hazardous substances, pollutants, andcontaminants is a principal element" (Section 121(b)). Anexplanation must be published if a permanent solution using treatmentor recovery technologies is not selected.

• The selected remedy must comply with or attain the level of "anystandard, requirement, criteria, or limitation under any federalenvironmental law or any promulgated standard, requirement, orlimitation under a state environmental or facility siting law that ismore stringent than any federal standard, requirement, criteria, orlimitation" (Section 121(d) (2) (A) ) .

The NCP (40 CFR 430[f][lJ) lists the following general objectives forselection of a remedy:

• "Each remedial action selected shall be protective of human healthand the environment" (40 CFR 430[f ] [1] [A] ) .

• "On-site remedial actions selected . . . must attain those ARARs thatare identified at the time of the ROD signature or provide groundsfor invoking a waiver" (40 CFR 430[f ] [1] [B] ) .

• "Each remedial action selected shall be cost-effective provided thatit first satisfies the threshold criteria" (i.e., protect iveness andattainment of ARARs) (40 CFR 430[f ] [ 1 ] [D] ) .

• "Each remedial action shall utilize permanent solutions andalternative treatment technologies or resource recovery technologiesto the maximum extent practicable" (40 CFR 430[f][l](G]).


2.2.2 Site-Specific Remedial Action Objectives

The conceptual site model described above has been used to developpreliminary remediation objectives for the WCP site. The specific objectivesare designed to attain the overall project objective of eliminating ormitigating risks to the public health and environment resulting from on-sitecontamination and potential off-site contaminant migration. The preliminaryremediation objectives are:

1. To eliminate or mitigate risks associated with exposures tocontaminants present in near-surface soils. For soils between zeroand two feet below the ground surface, these exposures are expectedto include inhalation of contaminated dust, inhalation of volatilizedcompounds, direct exposure to contaminated soils, or ingestion ofcontaminated soils. Reasonable land use scenarios for evaluatingthese risks involve industrial and marine commercial recreationalland uses. For soils deeper than two feet below the ground surfaceand above the water table, exposures may include inhalation or directcontact under construction or excavation scenarios.

2. To eliminate or mitigate risks resulting from direct contact with oringestion of surface waters affected by the discharge of contaminatedgroundwater from the WCP site, or ingestion of fish affected by suchsurface waters. These risks may be associated primarily with themore mobile of the identified key contaminants (i.e., BETX and two-and three-ring PAHs) that will be more likely to migrate off-site.Reasonable exposure scenarios for evaluating these risks involveboating and fishing in Waukegan Harbor and swimming, boating andfishing in Lake Michigan.

3. To eliminate or mitigate the effects of discharge of contaminatedgroundwater from the WCP site on water quality at the water intakefor the City of Waukegan system. The intake is located in LakeMichigan more than 6,000 feet east-southeast of the site.


4. To eliminate or mitigate risks to the environment resulting fromchemical constituents present at or originating from the site. Theprimary objective will be to protect the aquatic environment inrelevant areas of Lake Michigan in accordance with applicable waterquality standards. Risks to this environment may be associated withgroundwater discharge from the site to Waukegan Harbor and subsequent

chemical constituent migration to the lake.

As the RI/FS proceeds, more specific remediation goals will be establishedfor the objectives identified above. For the first objective, the goals willinvolve soil quality criteria for near-surface soils, established to provide thenecessary degree of remediation. For the second and third objectives, goals mayinvolve both groundwater quality and soil quality criteria established to resultin acceptable water quality in the relevant surface waters. At this early stageof the RI/FS process, the preliminary remediation goals are dependent to a largedegree on readily available information such as chemical-specific ARARs and onpreliminarily identified potential exposure scenarios. The PRGs are thereforedeveloped in Section 4 based on the above objectives and the discussion ofpotential ARARs in Section 3.

3.0 POTENTIAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

SARA as implemented by the NCP (40 CFR 430[e][9][iii][A]) requires thatremedial actions must comply with applicable or relevant and appropriaterequirements (ARARs) under federal environmental laws and state environmental

,laws or facility siting laws or provide grounds for seeking a waiver of therequirement. In addition to ARARs, remedial actions may consider, asappropriate, other advisories, criteria, or guidelines.

3.1 Applicable Requirements

The NCP defines applicable requirements as "those cleanup standards,standards of control, and other substantive requirements, criteria, orlimitations promulgated under federal environmental or state environmentalfacility siting laws that specifically address a hazardous substance, pollutant,contaminant, remedial action, location, or other circumstance found at a CERCLA


site. Only those state standards that are identified by a state in a timelymanner and that are more stringent than federal requirements may be applicable"

(40 CFR 300.5).

For a requirement to be applicable, the remedial action or thecircumstances at the site must satisfy all of the jurisdictional prerequisitesof that requirement. For example, the minimum technology requirements forlandfills under RCRA would be applicable only if a new hazardous waste landfill(or an expansion of an existing landfill) were to be built on a CERCLA site.

3.2 Relevant and Appropriate Requirements

The NCP defines relevant and appropriate requirements as "those cleanupstandards, standards of control, and other substantive requirements, criteria,or limitations promulgated under federal environmental or state environmentalor facility siting laws that, while not "applicable" to a hazardous substance,pollutant, contaminant, remedial action, location, or other circumstance at aCERCLA site, address problems or situations sufficiently similar to thoseencountered at the CERCLA site that their use is well suited to the particularsite. Only those state standards that are identified in a timely manner and aremore stringent than federal requirements may be relevant and appropriate (40 CFR300.5). For example, while RCRA regulations are not applicable to closing in

place hazardous waste that was disposed of before 1980, RCRA regulations forclosure with hazardous waste in place may be deemed relevant and appropriate.

In some circumstances, a requirement may be relevant to the particular

site-specific situation but will not be appropriate because of differences inthe purpose of the requirement, the duration of the regulated activity, or thephysical size or characteristic of the situation it is intended to address.

3.3 Application of ARARs

A requirement that is judged to be relevant and appropriate must becomplied with to the same degree as if it were applicable. Relevant andappropriate requirements that are more stringent than applicable requirementstake precedence. More discretion can be applied in the determination of


relevant and appropriate requirements than in the determination of applicablerequirements. It is possible for only a part of a requirement to be applicable

or relevant and appropriate.

Requirements -that must be complied with may be substantive or

administrative. On-site CERCLA response actions often must comply with the

substantive requirements but not with administrative requirements. Substantive

requirements are those that pertain directly to actions or conditions in theenvironment. Administrative requirements are the mechanisms that facilitate the

implementation of the substantive requirements of a statute or regulation. Ingeneral, administrative requirements prescribe methods and procedures, such asfees, permitting, inspection, and reporting requirements by which substantiverequirements are made effective for purposes of a particular environmental orpublic health program. In other words, on-site CERCLA response actions must

meet the intent of the law but need not conform with all the applicableadministrative rules. This distinction applies only to on-site actions;

off-site response actions are subject to the full requirements of all applicablestandards or regulations, including administrative requirements such as permits.

3.4 Other Criteria or Guidelines to be Considered

In addition to the legally binding requirements established as ARARs, manyfederal and state programs have developed criteria, advisories, guidelines, or

proposed standards that may provide useful information or recommend proceduresif no ARARs address a particular situation or if existing ARARs do not provide

,protection. In such situations, these "to be considered" (TBCs) criteria orguidelines may be used to set remediation goals.

3.5 Classification of ARARs

Three classifications of requirements are defined in the ARAR determinationprocess, chemical-specific, location-specific, and action-specific ARARs. Theyare defined as:

• Chemical-specific ARARs are usually health- or risk-based numericalvalues or methodologies used to determine acceptable concentrations


of chemicals that may be found in or discharged to the environment,

e.g., MCLs that establish acceptable concentrations of impurities indrinking water. Potential chemical-specific ARARs are defined in

Table 2 and associated numerical values are listed in Tables 3 and 4.

• Location-specific ARARs restrict actions or contaminant concentrationin certain environmentally sensitive areas. Examples of areasregulated under various federal laws include floodplains, wetlands,and locations where endangered species or historically significant

cultural resources are present. Potential location-specific ARARsare listed in Table 5.

• Action-specific ARARs are usually technology or activity-basedrequirements or limitations on actions or conditions includingspecific substances. They establish performance, design, or othersimilar action-specific controls or regulations on actions, e.g.,RCRA incinerator regulations. Potential federal action-specificARARs are listed in Table 6. Potential state action-specific ARARsare listed in Table 7. The evaluation of action-specific ARARsrelative to each developed remedial action will be presented in theRI/FS Report.

3.5.1 Chemical-Specific ARARs

Chemical-specific ARARs include those laws and requirements that regulatethe release to the environment of specific substances having certain chemicalor physical characteristics or materials containing specified chemicalcompounds. They are important in determining the extent of soil, sediment, andgroundwater remediation as well as determining the residual concentrationsallowable after treatment.

3.5.1.1 Soil

Chemical-specific ARARs are not available for soil for the chemicals ofconcern identified for the site. Risk-based target concentrations can bedeveloped for soil for specific exposure scenarios. These values would be TBCs.

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Risk-based target concentrations are presented in Section 4.2 as part of the

discussion of Preliminary Remediation Goals (PRGs).

3.5.1.2 Sediment

Chemical-specific ARAKs are not available for sediment for the chemicalsof concern identified for the site. U.S. EPA Region V has developed guidelinesfor the evaluation of Great Lakes harbor sediments (U.S. EPA, 1977). Theseguidelines are a general classification of sediments into categories (e.g.,nonpolluted, moderately polluted, etc.) and were developed for disposal ofdredged materials. These guidelines are not adequately related to the impactof the sediment on the lakes and therefore are not applicable as ARARs or TBCs.

U.S. EPA is currently developing sediment quality criteria for nonionicorganic chemicals based on an equilibrium partitioning approach. A technicalapproach has been proposed (U.S. EPA 1991) but has not been finalized. Thesecriteria, once finalized, could be TBCs for sediment.

3.5.1.3 Groundwater Quality Standards

The selection of ARARs for groundwater at the site depends on theidentification of the appropriate groundwater use category. This has not yetbeen determined.

EPA's Groundwater Protection Strategy establishes different degrees of

protection for groundwater based on vulnerability, use, and value (U.S. EPA,1986). The NCP states that EPA expects to return usable groundwater to theirbeneficial uses wherever practicable, within a timeframe that is reasonablegiven the particular circumstances of the site (40 CFR 300.430(a)(1)(iii)(F)).

Maximum contaminant level goals (MCLGs) are established under the SafeDrinking Water Act (SDWA). MCLGs that are set at levels above zero arepotential ARARs for groundwaters that are current or potential sources ofdrinking water. Where the MCLG has been set at zero or the MCLGs are notrelevant or appropriate to the circumstances of the site (as outlined in 40 CFR


300.400{g)(2), the maximum contaminant level (MCL) is the potential ARAR. MCLs

and MCLGs are summarized in Table 3.

The Illinois Pollution Control Board (IPCB) has promulgated groundwaterquality standards for four groundwater classes (IPCB, 1991):

• Class I: Potable Resource Groundwater• Class II: General Resource Groundwater• Class III: Special Resource Groundwater• Class IV: Other Groundwater

Class IV groundwater would include any and all groundwater located withina lateral distance of 25 feet or a vertical distance of 15 feet from any primaryor secondary source at the HCP site. The remedial investigation has not yetdefined the vertical extent of contamination at the site. This class ofgroundwater would apply to the wood treating area, the MGP/coking area, thenortheast pond area, and potentially other zones at the site as well, on thebasis of classifying these areas as primary or secondary sources. Groundwaterin areas of former coal storage and handling may be Class IV groundwater under35 ILL. Admin. Code 620.240(f) and (g). The Class IV standards are equal to theexisting concentrations of constituents in the groundwater. No standards forClass IV are listed in Table 3, as the existing concentrations are still beingdefined by the remedial investigation.

Class II Groundwater would include all groundwater outside the Class IVzone, but less than 10 feet below the ground surface. Class II standards arelisted in Table 3.

Class I groundwater may apply to groundwater that is outside the Class IV

zone and is greater than 10 feet below the ground surface. This designation isfor groundwater-bearing formations that can be developed for potable watersupply. Water in the unconsolidated sand 10 feet or more below the groundsurface appears to meet the criteria for Class I groundwater for portions of theWCP site that are outside Class II and Class IV zones. The Class I standardsare listed in Table 3.


The groundwater rules permit a groundwater management zone (620.250) forgroundwater being managed to mitigate impairment caused by the release of

contaminants from a site. Alternative groundwater standards are applied togroundwater management zones. During the corrective action, the groundwater isexempt from the Clas-s I through IV standards. After remediation, concentrationsmay exceed the groundwater standards if, to the extent practicable, the

exceedence has been minimized and beneficial use has been returned and anythreat to public health or the environment has been minimized.

Groundwater may also be reclassified by petition to the IPCB. Thereclassification procedure is outlined in 35 ILL. Adm. Code 620.260.

Lifetime health advisories (HAs) are issued by U.S. EPA's Office of Water.These are TBCs for groundwater subject to potable water use. Lifetime HAs aredeveloped only for noncarcinogenic health effects.

Risk-based target concentrations can be developed for potable use ofgroundwater for specific groundwater uses and exposure scenarios. These valuesare TBCs. The risk-based target concentrations are described in Section 4.2 aspart of the discussion of PRGs.

3.5.1.4 Surface Water Quality Standards

Chemical-specific ARARs for the protection of human health and aquatic life

from exposure to contaminants in Lake Michigan are important at the WCP site

.because: (1) the lake may be affected by chemical constituents in groundwaterdischarge from the site; and (2) several possible remedial alternatives couldinclude discharge of treated water to the lake.

Federal water quality criteria (FWQC) established under Section 303 or 304of the Clean Water Act (CWA) for priority pollutant may be relevant andappropriate, depending on the circumstances of the site (40 CFR310.430(e)(2)(i)(E). FWQC for human health are promulgated for exposures thatinclude drinking water and consuming fish and consuming fish only. These FWQCare listed in Table 4. FWQC for aquatic life protection are also promulgatedand are listed in Table 4.


At the time of the development of the FWQC for aquatic life protection,sufficient data were not available to derive aquatic life criteria for all of

the priority pollutants. The lowest report effects levels (LRELs) available inthe scientific literature for these chemicals were published in lieu ofcriteria. The LREL-would be TBCs and are summarized in Table 4.

There are some situations where FWQC will not be both relevant andappropriate in light of other potential ARARs. Whether a FWQC is relevant andappropriate depends on the availability of standards, such as an MCL or statewater quality standard specific for the constituent and use.

Illinois Water Quality Standards (IWQS) are promulgated as part of theIllinois Water Pollution Control Rules (35 111. Adra. Code Subtitle C, Part 302).Lake Michigan waters are subject to standards under Subpart E (Lake MichiganWater Quality Standards). Lake Michigan water quality standards apply inaddition to either (depending on water use) the general use (Subpart B) or thepublic and food processing water supply standards (Subpart C). The IWQS arepresented in Table 4.

3.5.2 Location-Specific ARARs

Location-specific ARARs are those requirements that relate to the

geographical position of the site. The location-specific requirements currentlyidentified as potential ARARs for CERCLA remedial actions are listed in Table 5.There are no applicable location-specific ARARs for the WCP site.

3.5.3 Potential Action-Specific ARARs

Action-specific ARARs are requirements that define acceptable treatment anddisposal procedures for hazardous substances. Potentially applicable ARARs arelisted in Tables 6 and 7.


4.0 PRELIMINARY REMEDIATION GOALS

Remediation goals consist of medium-specific or operable unit-specificchemical concentrations that are protective of human health and the environmentand serve as goals for the remedial action (U.S. EPA, 1990). The goalspresented below are preliminary and serve to focus the development of remedialalternatives. These PRGs will be modified in the risk assessment to reflect

additional site-specific information gathered in the remedial investigationprocess. The remediation goals in the risk assessment and subsequent evaluationprocesses will be developed consistent with the presence of an adjacent andoverlapping PCB site and the risk levels embodied in the PCB remedy selection.Final selection of remedial goals for the WCP site must await the final remedyselection process and balancing of criteria in the record of decision process.

Chemical-specific PRGs are concentration goals for individual chemicals atCERCLA sites. There are two general sources of chemical-specific PRGs:

• Concentrations based on ARARs (ARAR-based PRGs)

• Concentrations based on risk assessment (risk-based PRGs)

Where chemical specific ARARs clearly exist for a chemical of concern, theARAR is the basis of the PRG. Where chemical specific ARARs are not availablerisk-based PRGs may be developed. The procedure for developing risk-based PRGsis presented in Risk Assessment Guidance for Super fund: Volume I - Human HealthEvaluation Manual - Part B, Development of Risk-based Preliminary Remediation

Goals (RAGS-Part B) (U.S. EPA 1991b).

Preliminary remediation goals were selected by identifying: (1) thechemicals and media of concern, as outlined in the description of the siteconceptual model (Section 2); (2) chemical-specific ARARs, if available, as

described in Section 3; and (3) other criteria to be considered (TBCs), if ARARsare not available.


4.1

The current conceptual model of the site indicates that soil will be alikely media of concern at the WCP site. The ultimate remediation goals forsoils are likely to be based on: {1) potential exposures to contaminantspresent in near-surface soils via the exposure routes described in Section 2.2;and (2) potential exposures to contaminants present in subsurface soils byleaching of soil contaminants to groundwater and subsequent migration to surface

waters.

The selection of exposures relevant to near-surface soil is guided by landuse factors and potential exposure pathways as outlined in Sections 2.1.4 and

2.1.5, respectively. Future land uses can reasonably be expected to becontinued industrial and commercial marine recreational uses (i.e., boat storageand servicing), consistent with City Zoning Ordinances.

There are no ARARs for soil and consequently the PRGs are risk-based. TheRAGS-Part B outlines approaches to soil PRGs based on residential and industrialland uses. The industrial land use scenario is most consistent with the futureland use at the site.

An industrial/marine commercial soil ingestion exposure pathway forms thebasis of the near-surface soil PRGs. It is the most likely exposure pathway fora future industrial/commercial use of the site. A method for calculatingchemical-based PRGs, including default occupational soil ingestion exposure

assumptions is provided in RAGS-Part B.

The default exposure assumptions may not be entirely applicable to futureindustrial/commercial uses of the site. For example, exposure to surface soilmay be limited by the weather (e.g., snow cover, frozen ground in the winter)and the limited boating season. The RAGS-Part B guidance does not account forthis and assumes exposure five days/week. In order to reflect these sitespecific weather concerns, the exposure frequency has been adjusted to eliminatecold weather months (i.e., the number of days exposed reflects days above 32°F)and precipitation events. Other aspects of the exposure scenario outlined in


RAGS-Part B also may not be appropriate to describe a site use where there is

limited exposure to soils, such as an office park or marina.

The target risk levels used suggested by EPA guidance (U.S. EPA 1991b)

correspond to the following:

• For carcinogenic effects, a concentration that corresponds to a 10"'incremental risk of an individual developing cancer over a lifetimeas a result of exposure to the potential carcinogen from allsignificant exposure pathways for a given medium.

• For noncarcinoqenic effects. a concentration that corresponds to ahazard index of one, which is the level of exposure to a chemicalfrom all significant exposure pathways for a given medium below whichit is unlikely for even a sensitive population to experience adversehealth effects.

The 10"' risk corresponds to the "point of departure" indicated in the NCPas a starting point for analysis of remedial alternatives. It reflects EPA'spreference for managing risks at the more protective end of the risk range,other things being equal. Use of "point of departure" target risks does notreflect, however, a presumption that the final remedial action should attainsuch goals (U.S. EPA 1991b) . U.S. EPA uses a risk range from 10'4 to 10"' to

describe protectiveness. A risk of 10~4 may be an appropriate target risk whenthe potential for exposure is limited, such as in the described industrial/.commercial exposure scenarios. PRGs for carcinogens were estimated for the 10"'point of departure risk, as well as for the 10"* risk level, to reflect a rangeof potential remedial goals.

The risk-based PRGs for near-surface soils are summarized in Table 8. Thecomputed PRG concentrations for individual carcinogenic PAHs at the 10'4 risklevel range from 253 mg/kg to 25,300 mg/kg. At the 10'* risk level, thecomputed PRG concentrations for individual PAHs range from 2.5 to 253 mg/kg.

It is anticipated that a concentration goal will be developed later in the RI/FSprocess for total carcinogenic PAHs based on several factors, including: 1)additional soil quality data to be collected during Phase II of the RI; 2) the


results of the risk assessment's refined evaluation of exposure scenarios andassociated risks; and 3) consideration of carcinogenic potency differences amongthe individual carcinogenic PAHs. Preliminary evaluations of total carcinogenicPAH concentrations that corrrespond to the PRGs in Table 8 fall between 253 and25,300 rag/kg for the 10'4 risk level and between 2.5 and 253 mg/kg for the 10''risk level.

Remediation goals for subsurface soils cannot be determined for chemicalsthat may leach to groundwater until site-specific data regarding soil quality,contaminant partitioning to groundwater, groundwater flow characteristics, andmixing with surface waters are more completely evaluated. However, theselection of remediation goals for subsurface soils will necessarily depend oncorresponding remediation goals for groundwater and surface waters. Preliminarynumerical remediation goals for surface waters are represented by the ARARs

presented in Table 4.

4.2 Groundwater

The groundwater PRGs will reflect the potential groundwater use. Thepotable use of groundwater appears unlikely. It is more likely that remediationgoals for groundwater will be established to protect surface water quality tothe degree necessary to protect uses of Lake Michigan. Contaminant fate andtransport assessments, along with surface water quality data, will be used toevaluate the impacts on surface water quality of site contaminants dischargedin the groundwater.

The surface water ARARs listed in Table 4 will most likely form the basisfor calculation of groundwater PRGs. If an ARAR-based PRG is not available orappropriate, a risk-based PRG may serve as the basis for calculation of agroundwater PRG. Remediation goals for groundwater will also be sufficient toprotect water quality at the City of Waukegan water supply intake. ARARs forwater quality at the water supply intake are the IWQSs, MCLs, and MCLGs forcommunity water supplies (Tables 3 and 4).


REFERENCES

Barr Engineering Co., 1992. Remedial Investigation/Feasibility Study Phase ITechnical Memorandum, Waukegan Manufactured Gas and Coke Plant Site. July1992.

U.S. EPA 1991. Proposed Technical Basis for Establishing Sediment QualityCriteria for Nonionic Organic Chemicals Using Equilibrium Partitioning.Office of Water, Health and Ecological Criteria Division. August 1991.

U.S. EPA 1977. "Guidelines for the Pollutional Classification of Great LakesHarbor Sediments". U.S. EPA Region V. April 1977.


TABLE 1

POLYCYCLIC AROMATIC HYDROCARBON (PAH)COMPOUNDS OF CONCERN

Carcinogenic PAHs* Non-Carcinoaenic PAHs

Benzo(a)Anthracene AcenaphtheneBenzo(b)Fluoranthene AcenaphthyleneBenzo(k)Fluoranthene AnthraceneDibenzo(ah)Anthracene Benzo(ghi)PeryleneIndeno (1,2,3-cd)Pyrene DibenzofuranChrysene fluoranthene

Fluorene2-MethyInaphthaleneNaphthalenePhenanthrenePyrene

*Listed as potential or suspected carcinogens, U.S. EPA.

13\49\003\RIFSTAB.TAB\MST

TABLE 2

POTENTIAL CHEMICAL-SPECIFIC ARARsWCP SITE

REGULATION

Groundwater

Safe Drinking Water Act (SDUA) -Maximum Contaminant Levels (MCLs)40 CFR 141.61 (organic chemicals)40 CFR 141.62 (inorganic chemicals)

SDUA - Max i nun Contaminant Level Goals(HCLGs)40 CFR 141.50 (organic chemicals)40 CFR 141.51 (inorganic chemicals)

SOUA - Secondary MCLs (SMCLs)40 CFR 143

Office of Drinking Water. DrinkingMater health advisories.

Illinois Water Quality Standards(IUQS) 35 III. Ackn. Code 620

IWQS Class I: Potable ResourceGroundwater(Section 620.210; 620.410)

IWQS Class II: General ResourceGroundwater(Section 620.220; 620.420)

REQUIREMENT POTENTIAL ARAR STATUS ANALYSIS

CERCLA 121 (d) states that a remedialaction will attain a level under theSDWA. MCLs are enforceable maximumpermissible level of a contaminantwhich is delivered to any user of apublic water system.

CERCLA 121(d)(2)(A) states that aremedial action attain MCLGs whererelevant and appropriate. MCLGs arenon- enforceable health goals under theSDWA.

Non-enforceable limits intended asguidelines for use by states inregulating water supplies

Guidance levels for drinking waterissued by Office of Drinking Water

Groundwater must meet the standardsappropriate to the groundwater's classas specified in Subpart D/Section620.401-440.

Standards for potential potable watersupply.

Applicable to groundwater compatiblewith agricultural, industrial,recreational, or beneficial uses andnot in Classes I, III, or IV.

Potentially relevant and appropriate.


To be considered.

To be considered.


Potential ARAR.

Potential ARAR.

MCLs are relevant and appropriate forpotential drinking water sources byEPA policy (see'NCP). Aquifer statusto be determined. Alternativeconcentration limits (ACL) approachoutlined in NCP may be used if MCLsare not appropriate for the site.

MCLGs equal to zero are notappropriate for cleanup of groundwateror surface water at CERCLA sites byEPA policy (see NCP). Non-zero MCLGsmay be relevant and appropriate.

SMCLs may be considered if drinkingwater use of aquifer is consideredfeasible.

May be applicable for chemicalswithout MCLs if groundwater is to meetdrinking water quality.

May be applicable depending ongroundwater use designation.

Not applicable to groundwater where10 feet or less from ground surface.Could be applicable if groundwaterwere designated for potable water use.

May be applicable if groundwater isnot designated for potable use.


TABLE 2 (Continued)POTENTIAL CHEMICAL-SPECIFIC ARARs

WCP SITE

| REGULATION

Class III: Special ResourceGroundwater(Section 620.230; 620.430)

Class IV: Other Groundwater(Section 620.240; 620.440)

Alternative Groundwater QualityStandards - Groundwater QualityRestoration Standards(Section 620.450(a))

REQUIREMENT

Applicable to groundwater determinedby Pollution Control Board asdemonstrably unique and suitable formore stringent standard than otherwiseapplicable, vital for sensitiveecosystem; discharge to dedicatednature preserve.

Other groundwater includes:groundwater which underlies potentialprimary or secondary source,groundwater underlying various coalmining and processing areas, andgroundwater within previously minedareas.

Applies to groundwater within agroundwater management zone. Mayallow concentrations higher thandesignated use after remediation.

Surface Water

Illinois Water Quality StandardsIllinois Administrative Code,Title 35, Subtitle C. Chapter 1,Part 302

General Use - Subpart BSections 302.201-212

Public and food processingwater supply - Subpart C;Sections 302.301-305

Section 11 of Environmental ProtectionAct - regulation to restore, maintain,and enhance purity of the water of thestate.

Waters of state for which there is nospecific designation

acute standards apply withinmixing zonechronic apply after mixing zone

Applies to waters of state designatedfor waters drawn for treatment anddistribution as a potable supply orfood processing at the point ofwithdrawal.

POTENTIAL ARAR STATUS

Not a potential ARAR.

Potential ARAR.

Potential ARAR.

Potential ARAR.

Potential ARAR.

Potential ARAR.

ANALYSIS

Not appropriate. Groundwater is notdemonstrably unique nor does itdischarge to dedicated naturepreserve.

May be applicable. Groundwaterunderlies a source area, and siteoperations included coal processing.

May apply if IEPA concurrence isobtained.

See specific category.

Applies to Lake Michigan, cumulativewith Subpart E standards.

Applies to Lake Michigan at point ofwater withdrawal, cumulative withSubpart E requirements.


TABLE 2 (Continued)POTENTIAL CHEMICAL-SPECIFIC ARARs

WCP SITE

REGULATION

Secondary Contact andIndigenous Aquatic LifeStandards. Subpart D -Sections 302.401-410.

Subpart E: Lake Michigan WaterQuality Standards. Section302.501-509

Federal Water Quality Criteria (FWOC)established under Section 303 and 304of Clean Water Act

REQUIREMENT

Applicable to waters designated in 35III. Adm. Code 303.204 and 303.441.

Applicable to waters of Lake Michigan.

Protection of human health fromconsumption of fish and water;consumption of fish.

Protection of aquatic life.

POTENTIAL ARAR STATUS

Not potential ARAR.

Potential ARAR.

Potential ARAR.

Potential ARAR.

ANALYSIS

Does not apply to Lake Michigan.

Subpart E is applicable to LakeMichigan - cumulative with Subpart s Bor C.

Relevant but not appropriate. Dependson use of surface water andavailability of other ARARs. Statewater standards available.

May be applicable to Lake Michigan butstate water quality standards mayoverride.


TABLE 3

POTENTIAL CHEMICAL-SPECIFIC ARARs AND TO BE CONSIDERED CRITERIAGROUNDWATER - DRINKING WATER USE

WCP SITE(Concentrations in

Chemical

Benzene

Ethylbenzene

Toluene

Xylenes (total)

BETX

Phenol

Phenols

Acenaphthene

Acenaphthylene

Anthracene

Benzo(a)anthracene

Benzo(a)pyrene

Benzo(b)f luoranthene

Benzo(g,h, i )perylene

Benzo( k ) f I uoranthene

Chrysene

D i benzoC a , h ) anth rancene

F I uoranthene

Fluorene

indeno(1,2,3-cd)pyrene

Potential ARARS

MCLs1

5

700

1000

10000

0.2

MCLGs*

0

700

1000

10000

0

IGUSk

Class I

5

700

1000

10000

11705

100

Class 11

25

1000

2500

10000

13525

100

To Be Considered

HealthAdvisories0

700

1000

10000

4000

Risk -Based PRGsd

Toxicity*

1600

970

2200

2200

HOOO

1500

1500

1061

0.35

0.15

0.015

0.15

0.15

1.5

0.015

0.15


TABLE 3 (Continued)

POTENTIAL CHEMICAL-SPECIFIC ARARs AND TO BE CONSIDERED CRITERIAGROUNDHATER - DRINKING WATER USE

WCP SITE(Concentrations in

Chemical

2-Hethylnaphthalene

Naphthalene

Phenanthrene

Pyrene

Cadmium

Selenium

Cyanide

Arsenic

Potential ARARS

MCLs'

5

50

200

50

MCLGs*

5

50

200

IGUS*

Class I

5

50

200

50

Class II

50

50

600

200

To Be Considered

HealthAdvisories0

20

5

200

Risk-Based PRGsd

Toxicity*.

150

1100

18

180

730

11

1081

0.049

HCLs - Maximum Contaminant LevelMCLG - Maximum Contaminant Level Goal

IGWS - Illinois Groundwater StandardsClass I Section 620.410 - Potable Resource UatersClass II Section 620.420 - General Resource Grounduater

Lifetime Health Advisories issued by U.S. EPA Office of Water (U.S. EPA 1992).

Risk-based PRGs assumed exposure 350 days/year, 30 years; Mater ingest ion of 2 liters/day; body weight of 70 kg; inhalation of volatile compounds relevant to indoorair from drinking water with an inhalation rate of 15 ing/day.

PRGs for non-carcinogens - assumes a hazard quotient of 1 for non-carcinogenic health effects.

PRG for carcinogens set a 1 in 1.000,000 individual excess lifetime cancer risk level, based on the exposure assumptions in footnote d.


TABLE 4

POTENTIAL CHEMICAL-SPECIFIC ARARsSURFACE WATER

WCP SITE(Concentrations in pg/L)

Chemical

Ammonia as N

Anmonia, unionized

Arsenic (III)

Cadmium

Cyanide

Selenium

Potential ARARs

FUQC Aquatic Life*

Acute

360

6.9"

22

20

Chronic

190

6.7*

5.2

5

Illinois Water Quality Standard*1

Subpart B General Use0

AS

360

67.1"

22

CS

190

1.7»

5.2

Standard

15,000

0.04

1,000

Subpart CPublic/Food*

50

10

10

Subpart DSecondaryContact

2,500/4,000

1,000

150

100

1,000

Subpart ELake

Michigan

20

TBCs

Lowest Reported EffectsLevel9

Acute

i

i

Chronic

i

i

Benzene

Ethylbenzene

Toluene

Xylene

Phenols

Phenol

Acenaphthene

Acenaphthylene

Anthracene

Benzo [a] anthracene

Benzo [b] fluoranthene

Benzo Cg, h , i ] pery lene

100 1

5,300

3,200

17,500

300

10,200

1,700

2,560


TABLE 4 (Continued)

POTENTIAL CHEMICAL-SPECIFIC ARARsSURFACE WATER

WCP SITE(Concentrations in fjg/L)

Chemical

Benzo [k] f luoranthene

Chrysene

0 i benzo la, h] anthrancene

F luoranthene

Fluorene

Indeno[1,2,3-cd]pyrene

2-Methylnaphthalene

Naphthalene

Phenanthrene

Pyrene

Potential ARARs

FUQC Aquatic Life1

Acute Chronic

Illinois Water Quality Standard6

Subpart B General Usec

AS CS StandardSubpart c

Public/Food*

Subpart DSecondaryContact

Subpart ELake ,

Michigan1

TBCs

Lowest Reported EffectsLevel'

Acute

3.980

2.300

Chronic

620

Federal Ambient Water Quality Criteria for aquatic life protection.Illinois Water Quality Standards - 35 III. Adm. Code Subtitle C, Chapter 1, Part 302.General use standards include acute standards (AS), chronic standards (CS). and other standards to be met in waters of the state for which there is no specificdesignation.For public and food processing water supply standards. Cumulative with general use standards. To be met at point at which water is withdrawn.Standards for secondary contact and indigenous aquatic life standards. Met for designated water only.Lake Michigan standards. They are cumulative with Subpart B and C standards.To-be-considered. Lowest reported effects level (LREL) reported in ambient water quality criteria (U.S. EPA 1980).Based on hardness. Hardness assumed to be 165 mg/L based on Waukegan Harbor RAP (IEPA 1992).Based on pH and temperature. See U.S. EPA 1986.


TABLE 5

POTENTIAL LOCATION-SPECIFIC ARARBWCP SITE

Loot ion-Specific Concern

Wetland

Require

Wilderness area

UUdlife refuge

Area affecting stream orriver

Within area affectingnational uild f scenic( orrecreational river

Within coastal zone

Within designated coastalbarrier

Action to prohibit dischargeof dredged or f i l l Mterialinto wetlanch without permit

Action to avoid adverseeffects, minimize potentialharm, and preserve andenhance wetlands, to theextent possible

Area Bust be administered insuch Manner as will leave itunimpaired as wilderness andto preserve its wilderness

Only actions allowed underthe provisions of 16 useSection 668 dd(c) nay beundertaken in areas that arepart of the NationalW i l d l i f e Refuge System

Action to protect fish orwildlife

Avoid taking or assisting inaction that w i l l have directadverse effect on scenicriver

Conduct activities in nannerconsistent with approvedState management programs

Prohibits any new Federalexpenditure within theCoastal Barrier ResourceSystem

Prerequisite

wetlands as defined in U.S.Army Corps of Engineersregulations

Action involving construc-tion of facilities ormanagement of property inwetlands, as defined by 40CFR Part 6, Appendix A,section 4 (j>

F e d e r a 1 1 y - o w n e d areadesignated as wilderness

Area designated as part ofNational W i l d l i f e RefugeSystem

Diversion, channeling orother activity that modifiesa stream or river andaffects fish or wildlife

Activities that affect ormay affect any of the riversspecified in section 1276(a)

Activities affecting thecoastal zone including landstherein and thereunder andadjacent shorelands

Activity within the CoastalBarrier Resource System

Citation

Clean Water Act section 404;40 CFR Parts 230, 33 CFRParts 320-330

Executive Order 11990,Protection of Wetlands, 40CFR Part 6, Appendix A

Wilderness Act (16 USC 1131et sea.): 50 CFR 35.1 el

16 USC 668dd et jest; 50 CFRPart 27

F i s h a n d W i l d l i f eCoordination Act (16 USC 661Si sag.): 40 CFR 6.302

Wild and Scenic Rivers Act(16 USC 1271 tl sea.): 40CFR 6.302(e)

Coastal Zone Management Act(16 USC Section 1451 fjsea.)

Coastal Barrier ResourcesAct (16 USC 3501 et sea.)

Potential ARARDetermination Analysis

Not ARAR No designated wetland on thesite.

No designated wetland on theNot ARAR slt«.

Not ARAR Site not designated as afederal wilderness area.

Not ARAR Site not designated as 9National Wildlife Refuge.

Not ARAR No stream m o d i f i c a t i o nanticipated.

Not ARAR No national wild or scenicrivers are located on s i t e orw i l l be Impacted by s i t eremediation.

Not ARAR Site is not in a coastal area.

Not ARAR No dredge and f i l l a c t i v i t i e splanned.

Within 61 meters (200 feet)of a fault displaced inHolocene time

New treatment, storage ordisposal of hazardous wasteprohibited

RCRA hazardous waste,treatment, storage ordisposal

40 CFR 264.18(8) Not ARAR There is no evidenrr ofpotentially act ive I.TIwithin 61 meters of sif


TABLE 5 (Continued)POTENTIAL LOCATION-SPECIFIC ARAR 8

WCP SITE

Location-Specific Conctrn

Uithfn 100-year floodplain

Within floodplain

Within salt dome formation,underground nine, or cave

Within area where action maycause irreparable harm,loss, or destruction ofsignificant artifacts

Historic project owned orcontrolled by Federal agency

Critical habitat upon whichendangered species orthreatened species depends

Requirement

Facility must be designed,constructed, operated, and•aintained to avoid Hashout

Action to avoid adverseeffects, minimize potentialhana, restore and preservenatural and beneficialvalues

P l a c e m e n t of non-containerized or bulk liquidhazardous waste prohibited

Action to recoverpreserve artifacts

and

Action to preserve historicproperties; planning ofaction to minimize ham toNational Historic Landmrks

A c t i o n to conserveendangered species ort h r e a t e n e d species.Including consultation withthe Department of Interior

Prerequisite

RCRA hazardous waste,treatment, storage, ordisposal

Action that Hill occur in afloodplain, i.e., lowlands,and relatively flat areasadjoining inland and coastalwaters and other flood proneareas

RCRA hazardousplacement

uaste.

Alteration of terrain thatthreatens significantscientific, prehistorical,h i s t o r i c a l , o rarchaeological data

Property included in oreligible for the NationalRegister of Historic Places

Determination of presence ofendangered or threatenedspecies

Citation

40 CFR 264.18(b>

Executive Order 11988,Protection of floodplain*(40 CFR 6, Appendix A); Fishand Wildlife CoordinationAct (16 USC 661 £J seo.I: 40CFR 6.302

40 CFR 264.18(c)

N a t i o n a l H i s t o r i c a lPreservation Act (16 USCSection 469); 36 CFR Part 65

N a t i o n a l H i s t o r i cPreservation Act, Section106 (16 USC 470 fl »eq.): 36CFR Part 800

Endangered Species Act of1973 (16 USC 1S31 si »ea.):50 CFR Part 200, SO CFR Part402 Fish and WildlifeCoordination Act (16 USC 661II sea.): 33 CFR Parts 320-330

Potential ARARDetermination Analysis

Not ARAR Site not within 100-yearfloodplain

Not ARAR Site actions not withinfloodplain

Not ARAR Site does not contain saltdome, mines, or caves

Not ARAR There are no knownarchaeological or historicalartifacts on the site

Not ARAR Site not on the NationalRegister of Historic Places

Unlikely ARAR No endangered species areknown to exist at the site.No evidence of unique habitatis present.


TABLE 6

POTENTIAL FEDERAL ACTION-SPECIFIC ARARsWCP SITE

Federal Regulations Requirement

CLEAN AIR ACT

Section 101(40 CFR 52)

Section 109(40 CFR 50)

National Emission Standards forHazardous Pollutants

Development and implementationof regional air pollutioncontrol programs. Section 101as implemented by 40 CFR 52,d e l e g a t e s p r i m a r yresponsibility for regional airquality management to thestates.

National Ambient Air QualityStandards.

• Pre-construction review fornew sources

Major source permit, PSDpermit, nonattainmentpermit, visibility permit.

Requires limiting ambienthydrogen sulfide emissions toless than 0.1 ppm. Theregulation also includesemission standards for mercury,vinyl chloride, benzene,beryllium, inorganic arsenic,and radio nuclide.

Potential ARAR Status

Potentially applicable

Analysis

Not applicablePotentially relevant andappropriate

Not applicable. Potentiallyrelevant but not appropriate


Regulation promulgated underthe Clean Air Act may apply topossible actions at the sitethat generate air emissions.Air stripping may ,be subject.See State air regulations.

Remedial action could result innew sources of air emissions.Purpose of this review is toobtain construction permit.Permits exempted for on- siteCERCLA actions, however, thisreview would meet requirementto f u l f i l l substantiverequirements and condition ofpermitting process.

Emissions from site activitiesnot anticipated to qualify asmajor source, therefore, exemptfrom substantive requirementsof reviews and permits.

Emissions from airmust meet standards.

stripper


TABLE 6 (Continued)


Federal Regulations Requi rement Potential ARAR Status Analysis

CLEAN WATER ACT

National Pollutant DischargeElimination System (NPDES)40 CFR 122, 125

Regulate the discharge of Materinto surface water bodies. TheState of Illinois has authorityto administer NPDES inIllinois. Refer to StateARARs.

Potentially applicable The remedial action may includethe discharge of treated oruntreated groundwater to LakeMichigan. Substantiverequirements wi l l .have to bemet, although administrativerequirements (a permit) may notbe required because action ison-site.

E f f l u e n t G u i d e l i n e s ,Pretreatment Standards40 CFR 403

Ocean Discharge40 CFR 277

Dredge and F i l l Requirement40 CFR 230

S e c t i o n e s t a b l i s h e spretreatment standards for thecontrol of pollutants dischargeto POTUs. The POTU should haveeither an EPA-approved programor sufficient mechanism to meetthe requirements of thenational program in acceptingCERCLA Haste.


NPDES permit requireddischarge to marine water.

to

Regulates the discharge ofdredged or fill material intothe water of the U.S.

Not applicableNot relevant


Discharge to POTW possiblealterative. It is considereda n o f f - s i t e a c t i o n .Pretreatment regulations areapplicable.

Not relevant to situation.

No dredging or f i l l i n ganticipated.

SAFE DRINKING WATER ACT

Underground Injection ControlProgram40 CFR 144

Controls the undergroundinjection of wastes and treatedwastewater.

P o r t i o n s p o t e n t i a l l yapplicable; Nay be relevant andappropriate

Not relevant to situationunless underground injection isconsidered as part of in situgroundwater remediation.

RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)

Criteria for Classification ofSolid Waste Disposal Facilitiesand Practices 40 CFR 257

Identifies which solid wastedisposal facilities andpractices have adverse effectson health and environment.

Not applicable. Potentiallyrelevant and appropriate

Disposal at site occurred priorto October 15. 1979. May beapplicable to long-termcontainment of contaminatedsoils on site.


TABLE 6 (Continued)


Federal Regulations Reoui rement Potential ARAR Status Analysis

Hazardous Waste ManagementSystem 40 CFR 260

Classification of Coke and By-Product Coal Tar FR Vol. 56,No. 35, February 21. 1991.

Boiler and Industrial FurnaceRules FR Vol. 56, No. 35,February 21, 1991

Definition and identificationof hazardous waste40 CFR 261

Standards for Generators40 CFR 262

Standards for Transport40 CFR 263

Management of generation,treatment storage, disposal,and transport of hazardouswaste. State of Illinoisadministers RCRA in Illinois.Refer to State ARARs.

Reel ass ificat ion of tardecanter sludges (K087) asproducts when used as waste-derived fuels.

Regulates air emissions fromthe burning of hazardous wastesin boilers and individualfurnaces.

Identifies those wastes subjectto regulation

Establishes regulation coveringactivities of generators ofhazardous wastes - requirementsinclude ID number, recordkeeping, and use of uniformnational manifest.

The transport of hazardouswaste is subject torequirements including DSTregulations, manifesting,record keeping, and dischargecleanup

Coal tar/coke plant wastes:May be applicable

May be relevant and appropriate

Treatment residues:May be applicable

May be relevant and appropriate

May be relevant andappropriate.

Potentially applicable; may berelevant and appropriate.

Applicable



Wastes were placed on-siteprior to 1980, therefore, RCRAis not applicable to on-siteactions. Coal tar wastes arenot listed wastes, therefore,RCRA may not be applicable toon-site or off-site actionsconstituting treatment ordisposal. Coal tars aresimilar to K060 and K087 listedwaste (coke plant by-products),therefore, RCRA as a whole maybe relevant and appropriate foron-site actions.

Coal tars may be similar toK087 listed wastes.

Potentially applicable fora l t e r n a t i v e s i n v o l v i n gincineration of wastes, if RCRAhazardous.

Potentially applicable totreatment residues or wastestaken off-site, if RCRAhazardous.

Applicable to off-site actionsif waste or treatment residuesare RCRA hazardous.

Applicable to off-site actionif wastes or treatment residuesare RCRA hazardous.

REGULATIONS FOR OWNERS ANDOPERATIONS OF PERMITTED


TABLE 6 (Continued)


Federal Regulations Requirement Potential ARAR Status Analysis

REGULATIONS FOR OWNERS ANDOPERATIONS OF PERMITTEDHAZARDOUS WASTE FACILITIES

Subpart G - Closure40 CFR 264.111

264.117C

Subpart I - Storage Container40 CFR 264.171-178

Subpart J - Tank Storage40 CFR 264.191-198

Subpart KImpoundments40 CFR 264.221-228

Surface

Subpart L - Waste Piles40 CFR 264.251-258

Subpart M - Land Treatment40 CFR 264.271-283

Subpart N - Landfills40 CFR 264.301-314(Neu Landfills)

Concern s i t e closurerequirements, i n c l u d i n goperation and maintenance, sitemonitoring, record keeping, andsite use.

Requirement concern permits on-site storage of hazardouswastes or temporary storagephases during cleanup actions.

Requirements for maintenance ofs t o r a g e c o n t a i n e r s ,compatibility with waste,inspection, storage area,location and closure.

Requirements apply to tankstorage of hazardous materials.

Requirements for hazardouswaste containment using new orexisting surface impoundments.

Requirements for hazardouswaste kept in piles.

Requirements pertain to landtreatment of hazardous wastes

Requirement for design,operation, and maintenance of anew hazardous waste landfill.Includes minimum technologyrequirements under HSWA.

Not applicablePotentially relevantappropriate


and

and


and

Not applicableNot relevant and appropriate




Some actions consider leavingwastes in place. If RCRA isdeemed relevant and,appropriatein general to these wastes,then closure requirements mayalso be relevant andappropriate.

Hay be relevant and appropriateto storage of wastes prior tooff-site shipment if RCRA isdetermined relevant andappropriate for wastes.

Tank storage is notanticipated; treatment in tanksmay be considered.

No surface impoundments areanticipated.

Temporary waste piles notsubject to RCRA; may berelevant and appropriate forlong-term storage piles.

Applicable if land treatment isused and wastes or treatmentresidues are RCRA hazardous.

Creation of a new landfill isnot an action considered.Actions anticipated do notconstitute placement.

13\49\Q03\RIFSTAB.TAB\MST

TABLE 6 (Continued)


Federal Regulations Requirement Potential ARAR Status Analysis

Closure40 CFR 261.310

Subpart 0 - Incinerators40 CFR 264-340-351

MiscellaneousSubpart XTreatment40 CFR 264. Subpart X

Land Disposal Restrictions40 CFR 268, Subpart C and

Subpart D

Requirement for closure oflandfill with waste in place.Includes requirement forcapping, monitoring.

Requirements forwaste incinerators

hazardous

Standards for performance ofmiscellaneous treatment units.Miscellaneous treatment unitsmay include temporary wasteholding units or effluentpretreatment units.

The land disposal restrictionsand treatment requirements formaterials subject torestrictions on land disposal.


and

Not applicableNot relevant and appropriate



Wastes may be left in place.If RCRA is deemed relevant andappropriate for the waste,closure requirements may bedeemed relevant andappropriate.

On-site incinerator isconsidered for this site.

not

Subpart X may apply to use ofon-site physical, chemical, orb i o l o g i c a l t r e a t m e n ttechnologies if RCRA isdetermined to be relevant andappropriate overall.

On-site land disposal (i.e.,new placement) not anticipated,therefore, land ban would notbe triggered.

TOXIC SUBSTANCES CONTROL ACT (TSCA) PCBs40 CFR 761

Requirement for disposal ofPCBs.

Likely not relevant to site PCBs not identified as keychemical at the site. AdjacentOMC site contains PCBs.

GREAT LAKES WATER QUALITY AGREEMENT OF 1978(Amended by Protocol)

Establishes levels ofprotectiveness for Great Lakeswater quality in executiveagreement with Canada.

Not applicableNot appropriate

GLWQA notU.S. Law.

enforceable under


TABLE 7

POTENTIAL ILLINOIS ACTION-SPECIFIC ARARsWCP SITE

Illinois Regulations

AIR QUALITY

III. Adm. Code, Title 35Subtitle B, Part 201

Requirement

Rules governing requirementsfor air quality includingemissions from new sources

Potential ARAR Status

Applicable

Analysis

Remedial action could result innew sources of air emissions.The substantive portion ofthese regulations may beapplicable.

WASTEUATER TREATMENT AND DISPOSAL

IAC Title 35Subtitle CChapter 1

IAC Title 35Subtitle Chapter 1Part 310

LEAKING UNDERGROUND STORAGE TANKS

IEPA Leaching UndergroundStorage Tank M a n u a l ,IEPA/LPC/91-203 (Referencing 35IAC 731)

Water quality standards.D e s i g n a t e s s t r e a mclassifications, monitoringand reporting requirements,POTU Regulations, NPDES Permits

Effluent and pretreatmentstandards. Prohibitsdischarges without an NPDESpermit. Sets effluentl i m i t a t i o n s , r e p ortingrequirements, pretreatmentrules.

Generic cleanup objectives forsoil and groundwater for siteswith releases of light, middleand heavy end petroleumproducts from undergroundstorage tanks.

Applicable

Potentially applicable.

Not Applicable

Remedial actions may dischargeto Lake Michigan. Protectionof designated use may be anapplicable requirement.

Remedial action may dischargeto Lake Michigan or POTU. Thesubstantive portion of theseregulations may be applicable.

No underground storage tanksreported or identified at site.

HAZARDOUS WASTE

IAC Title 35Subtitle GChapter 1Subchapter A

General hazardous waste rules:scope of title; definitions;forms; rules of practice.III. RCRA rules.

Applicable Applicable to treatment ofresidues or wastes taken off-site.


TABLE 7 (Continued)

•POTENTIAL ILLINOIS ACTION-SPECIFIC ARARsWCP SITE

Illinois Regulations Requirement Potential ARAR Status Analysis

Subchapter BParts 702 et. eg.

Permitting Portions p o t e n t i a l l yapplicable. Potentiallyrelevant and appropriate.

Some actions may result in off-site treatment. Others mayresult in leaving Haste inplace.

Subchapter CParts 720-729

Subchapter D

Hazardous waste rules. Wastemanagement system; standardsfor generators, transporters,and owners and operators oftreatment, storage, anddisposal facilities;notification requirements.

Underground Injection Controland Underground Storage

Portions p o t e n t i a l l yapplicable. Potentiallyrelevant and appropriate.

P o r t i o n sapplicable,relevant.

p o t e n t i a l IyPotentially

Some actions may result in off-site treatment. Others mayresult in leaving uaste inplace.

Some actions could involveinjection; actions do notanticipate underground storage.


TABLE 8

PRELIMINARY REMEDIATION COALS

NEAR - SURFACE SOILS

SITE: Waukegan Manufactured Gas and Coke Plant SiteRISK-SPECIFIC TARGET CONCENTRATIONRISK EVALUATED: EXCESS LIFETIME CANCER RISK/NONCANCER RISKEXPOSURE MEDIA: SOILROUTE OF EXPOSURE: INGESTION

Chemical

AnenicCadmiumCyanideSeleniumEthylbenzeneTolueneXylcneAcenaphtheneAnthnceneFluoreneFluortntheneNaphthalenePyrenePhenolBenzeneBenzo[a]anlhraceneBenzo[a]pyreneBenzo[b]fluonntheneBenzopc]fluonuitheneChryseneDibenzo{a4i]anthnmceneIndeno{l>2>3-cd]pyiene

Weight of Slope FactorEvidence (mg/kg-day}-!

A 1.750E+OO

A 0.029B2 038B2 S.8B2 0.58B2 0.58B2 0.058B2 5.8B2 058

Source

mis

mismismismismismismismis

RfDmgAg-day

0.00030.0005

0.020.005

0.10.2

20.060.3

0.040.04

0.0040.030.6

CucmogcnCone.

Source mg&g

IRISIRISIRISIRISIRISIRISIRISIRISmismismismismismis

838.6

50603.02530.22S3.0

2530.22530.2

25301.5253.0

2530.2

Tox.Cone.ing/kg

1.6E+03Z6E403l.OE+05Z6E+045.2E+051.0E+O6l.OE+073.1E+051.6E+06Z1E+O5Z1E+05Z1E+O41.6E+053.1E+06

EXPOSURE ASSUMPTIONS

Target RiskIR-Ingestion rateBW-Body weightEF-Exposure frequencyCC-Oimate correctionED-Expocure durationAT-Averaging time-cancerAT-Averaging time-noncancerCF-Convenrion factor

UniU Data

IE-045070

2500.39

257025

IE-06

unitiesmg/day

kgdayi/yr

*vry*yr

kg/tag

mput* input

inputmputinputmputinputcalc

fixed

TABLE 8 (continued)

PRELIMINARY REMEDIATION COALS

NEAR - SURFACE SOILS

SITE: Waukegan Manufactured Gu and Coke Plant SiteRISK-SPECIFIC TARGET CONCENTRATIONRISK EVALUATED: EXCESS LIFETIME CANCER RISK/NONCANCER RISKEXPOSURE MEDIA: SOILROUTE OF EXPOSURE: INGESTION

Chemical

ArsenicCadmiumCyanideSeleniumEthylbenzeneTolueneXylencAcenaphtheneAnthraceneFluoreneFluonntheneNaphthalenePyrenePhenolBenzeneBenzo[a]anthraceneBenzo[a]pyRneBenzo[b]fluonnthcoeBenzo[k]fluonntheneChryteneDibenzo[a,h]anihnnceneIndeno( 1 ,2.3-cd]pyrene

Weight ofEvidence

A

AB2B2B2B2B2B2B2

Slope Factor(mg/kg-<Uy)-l

1.750E+00

0.0290.585.8

0.58038

0.0585.8

0.58

Source

mis

misnusIRISIRISIRISIRISIRISmis

RfDmgfltg-day

0.00030.0005

0.02aoos

ai0.2

20.06as

0.040.04

0.0040.030.6

CarcinogenCone.

Source 3)8̂ 8

IRISmismismismismismismisDOSmismismismismis

8.4

506.025.3Z5

25.325.3

253.0Z5

25.3

To*.Cone.mg/kg

1.6E-K)32.6E+03l.OE+052.6E-KM5.2E+05l.OE+061.0E4073.1E+051.6&462.1E+05Z1E+05Z1E-KMl.fiE-Ktf3.1E+06

EXPOSURE ASSUMPTIONS Uniu Data

Target Riskm-Ingestion rateBW-Body weightEF-Exposure frequencyCC-Qimate correctionED-Exposure durationAT-Avenging time-cancerAT-Avenging time-nonctncerCF-Convenion factor

IE-065070

2500.39

257025

IE-06

unitleumg/day

kgdays/yr

%yryryr

kg/mg

mput.input

inputinputmputinputinputcalc

fixed

revised technical memorandum · gas/coking processes are arsenic and cyanide compounds...

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