UNITED STATES ENVIRONMENTAL PROTECTION … · Chain from Hazardous Substances or Pollutants or...

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6 1445 ROSS AVENUE, SUITE 1200 DALLAS, TX 75202·2733 AUG 27 2008 MEMORANDUM SUBJECT: FROM: TO: THRU: Request for a Removal Action at Delfasco Forge Site, Grand Prairie, Dallas County, Texas Gregory E. Fife, Senior On-Scene Coordinator d Removal Site Section (6SF-PR) 'n- Samuel Coleman, P.E., Director Superfund Division (6SF) R. Broyles, Associate Director Q Prevention and Response Branch (6SF-# 1. PURPOSE This memorandum documents the verbal approval and requests approval for a Removal Action pursuant to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended, 42 U.S.C. §§ 9601 at the Delfasco Forge Site located in Grand Prairie, Dallas County, Texas. The proposed action includes the installation of exhaust fan systems on houses impacted by soil vapor intrusion. Verbal approval was provided by the Acting Superfund Division Director, Pam Phillips on August 5, 2008. That verbal approval was for the installation of exhaust fan systems on two homes within the Site. This action meets the criteria for initiating a removal action under the National Contingency Plan (NCP), 40 CFR § 300.415. This action is expected to require less than twelve months and $2 million to complete. II. SITE CONDITIONS AND BACKGROUND Cerclis # TXD988034328 Category of Removal: Time Critical Site ill # A6H5 Latitude 32°45'00" N Longitude 99°57'47" W \ \\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\ \\\\ 858156 Internet Address (URL). http:/twww.epa.gov RecyciedIRecyclabl8 • Printed wnh Vegetable on Based Inks on Recycled Paper (Minimum 25% Postconsumer) 000198

Transcript of UNITED STATES ENVIRONMENTAL PROTECTION … · Chain from Hazardous Substances or Pollutants or...

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 6

1445 ROSS AVENUE, SUITE 1200DALLAS, TX 75202·2733

AUG 27 2008MEMORANDUM

SUBJECT:

FROM:

TO:

THRU:

Request for a Removal Action at Delfasco Forge Site, Grand Prairie, DallasCounty, Texas

Gregory E. Fife, Senior On-Scene CoordinatordRemoval Site Section (6SF-PR) 'n-Samuel Coleman, P.E., DirectorSuperfund Division (6SF)

~bert R. Broyles, Associate Director Q~~Prevention and Response Branch (6SF-#

1. PURPOSE

This memorandum documents the verbal approval and requests approval for a RemovalAction pursuant to the Comprehensive Environmental Response, Compensation and LiabilityAct (CERCLA), as amended, 42 U.S.C. §§ 9601 et~, at the Delfasco Forge Site located inGrand Prairie, Dallas County, Texas. The proposed action includes the installation of exhaustfan systems on houses impacted by soil vapor intrusion. Verbal approval was provided by theActing Superfund Division Director, Pam Phillips on August 5, 2008. That verbal approval wasfor the installation of exhaust fan systems on two homes within the Site.

This action meets the criteria for initiating a removal action under the NationalContingency Plan (NCP), 40 CFR § 300.415. This action is expected to require less than twelvemonths and $2 million to complete.

II. SITE CONDITIONS AND BACKGROUND

Cerclis # TXD988034328Category ofRemoval: Time CriticalSite ill # A6H5Latitude 32°45'00" NLongitude 99°57'47" W

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A. Site Description

I. Removal Site Evaluation

The Delfasco Forge Site is the location of a former forge and foundry facility. DelfascoForge Division operated at this site from 1981 to 1997. Delfasco performed steel and ironforging, metal fabrication and machining operations. Delfasco used trichloroethylene (TCE) as adegreaser in their operations. Investigations conducted from 2003 to 2005 indicated that arelease of TCE had occurred and the TCE had reached groundwater. The contamination plumein the ground water extends under 65 acres of a residential neighborhood adjacent to the Site.

2. Physical Location

The Delfasco Forge facility is located at 114 NE 28th Street in Grand Prairie. The facilityis approximately 1.1 acres. The Site including the residential neighborhood is bounded by NE28th Street to the west, Bowles Street to the north, Hensley Drive to the east, and E Main Street tothe South. The actual perimeter of the Site is subject to change as the groundwater plume and thesoil vapor plume are better defined.

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3. Site Characteristics

Approximately five-hundred homes and business are situated within the Site perimeter.The Site perimeter is based roughly on the groundwater plume that was defined by Delfasco'scontractor Ensafe during the recent investigation. TCE vapors from the contaminatedgroundwater ·are migrating through the soil and into the homes and businesses. An investigationconducted by EPA revealed elevated TCE in homes. The concentration ofTCE in some of thehomes exceeded the action level for TCE vapors in residences. Only 18 of the potential 500properties were sampled. Additional vapor plume definition and in home sampling will occurconculTentIy with this action.

fl~~~r~~::jFigure 2. Groundwater Plume

4. Releases. or threatened release into the environment of a hazardous substance,pollutant or contaminant

TCE has been found in the groundwater under the homes and the source has beenidentified as the former Delfasco Forge facility. TCE is a hazardous constituent under 40 C.F.R.Part 261. TCE is a characteristic hazardous waste at concentrations at or above 0.5 milligramsper liter (hazardous waste code D040) and a potentially ignitable hazardous waste (hazardouswaste code D001). TCE is also a listed hazardous waste when used in degreasing (hazardouswaste code FOOl). (See Attachment 2, Material Safety Data Sheet for TCE and Attachment 3,Agency for Toxic Substances and Disease Registry (ATSDR) ToxFAQ). Therefore, TCE is ahazardous substance as defined in Section 101(14) ofCERCLA, 42 U.S.c. §9601, and 40 C.F.R.§302.4.

S. NPL Status

The Site is not on the NPL. CUlTently, information is being gathered for the HazardRanking System for potential inclusion on the NPL.

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6. Maps, Pictures and other graphic representations

Attachment 1 Enforcement Addendum (Enforcement ConfidentialitylFOIA Exempt)·Attachment 2 Material Safety Data Sheet for TCE

. Attachment 3 Agency for Toxic Substances and Disease Registry (ATSDR) ToxFAQ for TCE

B. Other Actions to Date

1. Previous actions

The Site was a participant in the State of Texas Voluntary Cleanup Program (VCP).That participation was to address the groundwater plume.

2. Current actions

Additional sampling and investigation is being conducted to define the extent of the soilvapor plume. Additional sampling of indoor air will be conducted to identify additional homesaffected by the vapor intrusion. The concentration ofTCE in homes is dependent on seasonalweather. The homes are closed up in colder weather and the concentration ofTCE is expected tobe higher in the winter. Therefore, additional indoor samples will be taken in winter.

C. State and Local Authorities' Roles

1. State and local actions to date

The State has worked with Delfasco under their VCP.

2. Potential for continued State/Local response

The Texas Commission of Environmental Quality (TCEQ) has indicated that they do nothave the funding for this response.

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT,AND STATUTORY AND REGULATORY AUTHORITIES

A. Threats to Public Health or Welfare

The current conditions at the Site meet the following factors which indicate that the Siteis a threat to the public health, welfare and the environment and a removal action is appropriateunder Section 300.415(b)(2) of the National Contingency Plan. Any or all of these factors maybe present at the Site yet anyone of these factors may determine the appropriateness of a removalaction.

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1. Actual or Potential Exposure to Nearby Human Populations, Animals, or the FoodChain from Hazardous Substances or Pollutants or Contaminants NCP Section300.4I5(b)(2)(i)

TCE has been found in concentrations above the action level in several homes within theSite. Acute and chronic inhalation exposure to trichloroethylene can affect the human centralnervous system, with symptoms such as dizziness, headaches, confusion, euphoria, facialnumbness, and weakness. Liver, kidney, immunological, endocrine, and reproductive!developmental effects have also been reported in humans. A recent analysis of availableepidemiological studies reports trichloroethylene exposure to be associated with several types ofcancers in humans, especially kidney, liver, cervix, and lymphatic system. Animal studies havereported increases in lung, liver, kidney, and testicular tumors and lymphoma.

2. Actual or Potential Contamination of Drinking Water Supplies or SensitiveEcosystems. NCP Section 300.4I5(b)(2)(ii)

Investigations under the TCEQ's VCP found TCE concentrations in the groundwaterabove the residential protective concentration limit (PCL) set by TCEQ of 5 micrograms per liter.The EPA Maximum Contaminant Level (MCL) for TCE is 5.0 parts per billion (ppb) in drinkingwater wells.

3. High Levels of Hazardous Substances or Pollutants or Contaminants in SoilsLargely At or Near the Surface that May Migrate. NCP Section 300.4I5(b)(2)(iv)

TCE is migrating from the groundwater plume through the soils and into the homes. Thegroundwater in that area varies from 18 to 32 feet below grade level. TCE is coming off asvapors out of the groundwater and migrating through the ground and into homes. TCE isabsorbed readily after inhalation and ingestion, and to a lesser extent, through the skin. TCE cancross th~ placenta and has been detected in breast milk. The odor recognition of TCE is orders ofmagnitude above the action level and does not provide an adequate indication of hazardousconditions.

4. The Availability of other Appropriate Federal or State Response Mechanisms toRespond to the Release. NCP Section 300.4I5(b)(2)(vii)

Delfasco has declined offers from EPA's Resource Conservation and Recovery (RCRA)program to enter into an Administrative Order on Consent to take the necessary actions at theSite. Delfasco indicated that they could not comply with a RCRA Unilateral AdministrativeOrder that ordered Delfasco to do the necessary work. EPA's RCRA program then referred theSite to the Superfund Division. Delfasco has filed for bankruptcy protection and the Departmentof Justice is pursuing EPA's claim in that action.

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IV. ENDANGERMENT DETERMINATION

Actual or threatened releases ofhazardous substances, pollutants or contaminants fromthis Site, if not addressed by implementing the response action selected in this ActionMemorandum, may present an imminent and substantial endangerment to the public health,welfare, or the environment.

v. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed actions

1. Proposed Action Description

The proposed removal action involves the installation of exhaust fan systems on homesaffected by the soil vapor plume above the action level. The type and location of the systems isdependent on the construction type of the building. Most of the homes are pier and beamconstruction with crawl spaces under the living areas. The system for pier and beam will bedesigned to evacuate the air in the crawl space and therefore not allowing the build up ofTCEand further migration into the homes. Homes sitting on slabs will require a subsurfacemitigation fan system incorporating laterals and sumps. Solar powered fan systems will beutilized when appropriate to reduce the burden on the home owner and reduce the energyconsumption.

2. Contribution to remedial performance

The proposed action is consistent with any remedial action that may take place on theSite. The proposed action interrupts the vector from the contaminated water and soil to theresidents in the homes. This action will not interfere with any remedial actions.

3. Description of alternative technologies

The alternatives to the exhaust fan system have a long completion time. Any action toremove or reduce the plume such as vapor extraction, or natural attenuation will take years tocomplete and does not mitigate the migration into the homes.

4. Applicable or relevant and appropriate requirements (ARAR)

This removal action will be conducted to eliminate the actual or potential exposure tohazardous substance, pollutant or contaminant to the environment, pursuant to CERCLA, 42V.S.c. § 9601 et seq., and in a manner consistent with the National Contingency Plan (NCP), 40CFR Part 300, as required at 33 U.S.c. § 1321 (c)(2) and 42 U.S.c. §9605. Pursuant to 40 CFRPart 300.4150), fund-financed removal actions under CERCLA § 104 and removal actions

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pursuant to CERCLA § 106 shall, to the extent practicable considering the exigencies of thesituation, attain the applicable or relevant and appropriate requirements under Federalenvironmentallaw.· .

5. Project Schedule

The installation of each exhaust fan system on !l pier and beam house can be completed inone to two days after taking delivery of the system. The installation of each system on a slabfoundation house can be completed in 7 to 10 days. The initiation of the installation is subject toaccess agreements and resident's schedules. The initial deployment will begin immediately. Ifadditional homes are identified that need to be addressed, the installation will begin inappropriate timeframe to be protective of the residents and maintain cost effectiveness of theresponse.

B. Estimated Costs

Extramural Costs

Cleanup Contractor.. $200,000START : $40,000Total Extramural : $240,000

Site Contingency : : $10,000

TOTAL CEILING $250,000

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYEDOR NOT TAKEN

If this action is not taken at the Site, residents of the homes will continue to be exposed toconcentrations ofTCE above the action level. They will be subject to a higher risk of cancer andother the health affects previously cited. The migration from the groundwater plume is expectedto continue for up to 30 years.

VII. OUTSTANDING POLICY ISSUES

There are no outstanding policy issues associated with this site.

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VIII. ENFORCEMENT

For administrative purposes, infonnation concerning confidential enforcement strategyfor this Site is contained in the Enforcement Attachment #1. The total cost for this removalaction based on full-cost accounting practices that will be eligible for cost recovery are estimatedto be $419,678.

(Direct Cost) + (Other Indirect Costs) + 52.61 %(Direct + Indirect Costs) =Estimated EPA Cost

$250,000 + $25,000 + 0.5261($200,000+ $25,000) = $419,678

Direct costs include direct extramural costs and direct intramural costs. Indirect costs arecalculated based on an estimated indirect cost rated expressed as a percentage of site-specificdirect costs, consistent with the full cost accounting methodology effective October 2,2002. Theestimates do not include pre-judgment interest, do not take into account other enforcement costs,including Department of Justice costs, and may be adjusted during the course of a removalaction. The estimates are for illustrative purposes only, and their use is not intended to create anyrights for responsible parties. Neither the lack of a total cost estimate nor the deviation of actualtotal costs from this estimate will affect the United States' right to cost recover.

IX. RECOMMENDATION

This decision document represents the selected removal action for the Delfasco ForgeSite, Grand Prairie, Dallas County, Texas, developed in accordance with CERCLA as amended,and not inconsistent with the NCP. This decision is based on the administrative record for theSite.

Conditions at the Site meet the criteria as defined by 40 CFR Section 300.415(b)(2) of theNCP for a removal, and I recommend your approval of the proposed removal action. The totalproject ceiling will be $250,000.

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ATTACHMENT 1

ENFORCEMENT ATTACHMENT TO THE ACTION MEMORANDUMFOR the "Delfasco Forge" SITE," IS

ENFORCEMENT SENSITIVE

Note: This document has been withheld asEnforcement Confidential and is located inSeparate "CONFIDENTIALITY FILING" atU.S. EPA, Region 6

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ATTACHMENT 2

Material Safety Data Sheetfor TeE

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TRICHLOROETHYLENE

MSDS Number: T4940' • • • • Effective Dnte: 11106107' •••• Supercedes: 08101105

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!MSDS IMaterialSaferyOataSheer 7

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TRICHLOROETHYLENE

1. Product Identification

S~n<>n~ms: Trid\\oroelhene; TeE', acetylene trichloride; Ethit\yl trichlorideCAS No.: 79-01-6Molecular Weight: 131.39Chemical Formula: C2HCI3Product Code"J.T. Baker: 5376,9.154,9458,9464.9473.vfallillckrodt: 8600. 8633

2. Composition/lnformation on Ingredients

[ngred~ent

Trlchloroethylene

3. Hazards Identification

Emergency Overview

CAS No

79-01- 6

Percent

100l

HnZOlrdOU5

Yes

WARNING! HARMFUL IF SWALLOWED OR II\; HALED. AFFECTS HEART, CENTRAL NERVOUS SYSTEM, LIVER AND KIDNF:YS. CAUSESSEVERE SKIN IItRITATION. CAUSES IRRITATION TO EYF:S AND RF;SPIRATORY TRACT. SUSPECT CANCER HAZARD. MAY CAUSF.CANCER. Risk o( cancer depcnds on level .nd duration of ..posure.

SAF-T_DATA(tm) Rating. (Provided hcre for your eonvcnience)

Health Rating: 2 - iVloderate (Poi.on)Flammability Rating: I - SlightReactivity Rating: I . SlightContacl Rating: 3 - SevereLab Protective Eqnip: GOGGLES & SHIELD; LAB COAT & APRON; VENT HOOD; PROPER GLOVESSlorage Color Cod': Blue (Health)

Potential Heallb Effects

Inhalation:Vapors call irritate the. respiratory tract. Causes depression of the central nervous system with symptoms of visual disturbances and mental c.onfusion.incoordination. headache, nausea, euphoria, and dizziness. Inhalation of high concentrations could cause unconsciousness, heart effects. liver effects, kidneyeffects, and death. .Ingestion:Cases irritation to llastrointestinaJ tracL May also cause effects similar to inhalation. May cause coughing, abdominal pain, diarrhea, dizzine.s. pulmonary edema,unconsciousness. ~idney failure can result in severe cases. Estimated fatal dose is 3·5 mll1<g.Skin Contact:Cause irritation, redness and pain. C.n cause blistering. Continued skin contact has a defatting action and can produce rough, dry. red skin resulting in secondaryin~tioo. .Eye Contact:Vapors may cause severe irritation with rednes< and pain. Splashes may cause eye damage.Chronic Exposure:Chronic exposures may cause liver, kidney, central nervous system, and peripberal nervous system effects. Workers chronically «posed m.y exhibit centralnervous system del"ession, intolerance to alcohol, and increased cardiac output. This malerial is linked (0 mutagenic efTeclS ill humans. This material is also asuspect carcinogen.Aggrav~tionof p(e-uisting Conditions:

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TRICHLOROETHYLENE Page 2 of 5

Persons with pre-existing skin disorders. cardiovascular disorders. impaired liver or kidney or respiratory function, or central or peripheral nervoLlS systemdisorders may be more susceptible to the effects of the substance.

4. First Aid Measures

Inhalation:Removc 10 fresh air. Ifnot breathing, give artificial respiration. Ifbreatlting is difficult, give oxygen. Call a physician.

Ingestion:Induce vomiting immediately as direc.ted by medical personnel. Never give anything by mouth to an unconscious pcrson. Call a physician.Skin Contact: .Immediately flush skin with plenty of soap and waler for at Ieasl 15 minules while removiug contaminated c10thiug and shoes. Get medical attention. Washelothing before reuse. Thoroughly clean slloes before reuse.Eyeeon,,,t:Immediately flush eyes with plenty of water for at least 15 minutes, lifting Iowcr and npper eyclids occasionally. Gel medical attention immediately.

Note to Physician:Do not administer adrenaline Or epin~phrine to a victim ofchlorinated solvent poisoning.

------_..-_.__ ._.. -.'....---_.__•._-_._----

5. Fire Fighting Measures

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Fire:Autoib'Ttition temperature: 420C (78SF)Flammable limits in air % by volume:lcl: 8; uel: 12.5EXlllosion:A strong ib'llirion souTce, t. g., a welding torch, ,an produce ib'llition. Scaled containers may ruphlJe when heated.Fire Extinguishing Media:Usc water spray 10 kecp fire exposcd containcrs cool. IfsnbsUlnce does ignite. nse C02, dry chemical or foam.Special Information:In the event of a fire, "ear full protective clothing and NIOSH"ppTO\"ed self-contained breathing apparotus with full facepiece operated in lhe pressure demandor other positive pressurc mode. Combustion by·products include phosgene and hydrogen chloride gases. Structural firefighters' clothing provides only limitedprotection to the combustion product~ of this material.

6. Accidental Release Measures

Ventilate area of leak or spill. Remove all sources of ib'Ttition. Wear appropriate personal protective cqnipment as specified in Section 8. Isolate hazard arca. Keepnnnecessary and unprotectcd personnel from entering. Con lain and recover liquid when possible. Use non·sparki"g 10015 a"d cqu;pmcJIf, Collect liquid in anappropriate container or absorb w1th tin inert material (e. g., vemticulite) dry sand, earth). and place in a chemical waste container. Do not use combustiblematerials, such as saw dust. Do nol flush 10 sewer! US Regnlations (CERCLA) require reporting spills and releases to soil, water and air in excess of reportablequantilies. The loll free number for the US Coast Guard National Respouse Center is (800) 424,8802.

7. Handling and Storage

Keep in a tightly closed container, swrcd in a cool. dry, ventilated area. Protect against physical damage. Isolate from any source of heat or ignition. Isolate fromincompatible subslJlnces. Conlainers of this material may be hazardous when cmpty since they rctaiu product residues (vapors, liqnid); obselVe all warnings andprecautions listed for the product.

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8. Exposure Controls/Personal Protection

Airborne Exposure Limits:Trichloroethylene:·OSHA Permissible Exposure Limit (PEL):100 pplll (TWA), 200 ppm (Ceiling),300 ppm/5min/2hr (Max)

·ACGIH Threshold Limit Value (TLV):10 ppm (TWA) 25 ppm (STEL); A2 Suspected Humau Carcinogcn.Veltlilation System:A syslem oflocal ~nd/orgeneral exh~ust is recommended to keep employee exposures below the Airbome Exposure Limits. Local exbaus' ventilation isgenerally preferred because it can cOlltrol the emissions of the contaminant al its source, preventing dispersion ofil into the general work area. Please refer to theACGIH document, IndllslriaJ VenliMlion, A Manual ofRecommended Prrrcl;ces, most recent edition, for details.Personal Respirators (NIOSH Approved):If lhe exposure limit is exceeded and engineering controls are not feasible, wear a supplied air, full-facepiece respirator, airlined hood, or full·facepiece self·contained breathing apparatus. Breal}ling air quality must meet lhe requirements of the OSHA respiratory protection slJlndard (29CFR1910.134). This substancehas poor wanting jlfopenies. Where respiralors are required, you mUSI have a written program covering the basic requirements in UIC OSHA respirator standard.These include training, fit testing, medical approval, cleaning, maintenance, cartridge change schedules, etc. See 29CFR 1910.134 for details.

Skin Protection:Wear impeIVious proteclive clothing. including boots, gloves, lab coat, apron or coveralls, as appropriate, 10 prevent skin contaCt. Neoprene is a recommendedmaterial for personal proteclive equil'men!.Eye Protection:Use chemical safety goggles and/or a full face shield where splashing is possible. Maiutain eye wash fountain and quick.dIench facilities in work area.

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TRICHLOROETHYLENE'

9. Physical and Chemical Properties

Appearance'Clear, colorless liquid.Odor:Chlorofoml-like odor.Solubility:Practically insoluble in water. Readily miscible in organic solvents.Specific Gravity:1.47@ZOC/4CpH:No illfonnation found.% Volatiles by volume@2IC(701'):100Boiling Point:87C (1891')Melting Point:-73C (-991')Vapor Density (Air=l):4.5Vapor Pressure (mm Hg)'57.8 @ ZOC (681')Evaporation Rate (BuAe=I):No infomlation found.

10. Stability and Reactivity

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Stabilitv;Stable .;nder ordinary conditions of nse and storage. \ViII sJowly decompose to hydrochloric acid when exposed to light and moislure.Hazardous Decomposition Products:May produce carbon monoxide, carbon dioxide, hydrogen chloride and phosgene when heated to decomposition.Haz..dous Polymerization:Will not occur.Incompatibilities:Strong caustics and alkalis. strong oxidizers, chemically aclive metals. such as barium, lithium, sodium. magnesium, titanlum and beryllium. liquid oxygell.Conditions 10 Avoid:Heat, name. ignition SOurces. light, moisture. incompatibles

11. Toxicological Information

Toxicological Data:Trichloroethylene: Oral rat LD50: 5650 mgtkg; investigated as a tumorigen, mutagen, reproductive effector.Reproductive Todcit,·:This material has been linked to mutagenic effects in humans.

--_. -- -- \Cancer L.lstS\-- -- - -- - - _.•. _. -- -- --- --- -- --- -- - - - - - -_. - - -- -- - _.• -- --_. -NTP C'arclI''l.ogen - --

Ingredlent Known Anticlpated IARC Category

Tn.chlOroE!thylt:me (79·Ql-li)

12. Ecological Information

NO Yes 2...

Environmental Fate:\\'hcll released ll1to the soil, this maLerial may leach into gToundwater. When released into the soil, this material is expected to quickly evaporate. When releasedto water. this material is expected to quickly evaporate. This material has an experimentally-detennined bioeoncentration factor (BCF) of less than 100. Thismaterial is not expected to significantly bioaccllmulale. When released inlO the air, this material may bc moderately deb'faded by reaction with photochemicallyproduced hydroxyl radicals. When released into the air, this material is expected to have a half-life between I and 10 days.Environmental Toxicity:The LCSOI96-hollr values for fish are between 10 and 100 mgt\. This material is expected <0 be slightly toxic to aquatic life.

13. Disposal Considerations

Whatever cannot be saved for recovery or recycling should be haudled as hazardous waste and sene eo a RCRA approved incinerator or disposed in a RCRAapproved waste facility_ Processing, use or contamination of this product may change the waste management options. State and local disposal regulations maydiffer from federal disposal regulations. Dispose ofcontainer and unused contents in accordance with federal. state aud local requirements.

14. Transport Information

Domestic (Land. D.O.T.)

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TRICHLOROETHYLEN E

Proper Shipping Name: TRICHLOROETHYLENEHazard Class: 6.1UN/NA: UNI710Packing Group: IIIInformation reported for product/size: 4L

International (Water. J.M.O.)

Proper Shipping Name: TRICHLOROETHYLENEHazard Class: 6.1UNINA: UNI710Packing Group: IIIInformation reported for product/size: 4L

15. Regulatory Information

--------\Chem~cal Inventory Status - Part 1\--------------------------------­Ingredlent TSCA EC Japan AustralIa

Page 4 of 5

Trichloroethylene 179-01-6) Yes Yes Yes Yes

--------\Chemical Inventory Status - Port 2\-----------------------------------Canada~-

IngredIent Korea DSL NDSL Phll.

Trichloroethylene 179-01-6. Yes Yes °NO YeS

--------\Federal. Sta.te &. !.nternatl0nal Rcgulatlons . Part 1\·········_-_····-SAPA 302· ·_··_·SAPA 313-··_·-

IngredIent P.Q TPQ Llst Cheml.cal Catg.

TrichloToethylene (79-01- 6) NO No YeS NO

--·-----\Fecteral., State & International P.egulations

IngredIent CERCLA

Part 2\-----------------P.CPA- -T$CA-261.33 aid)

Trichloroethylene (79- 01 -6) lQO 1]228 NO

Cheml.cal Weapons Convent.lon:. NC TSCA 12 (b): No CUTA: NOSARA 311/312: Acute: Yes Chronic: Yes Fire: No Pressure: NoReactIvity: No (Pure / LiqUidl

WARNING:TI US PRODUCT CON TAINS A CHEM ICAL(S) KNOWN TO THE STATE OF CALIFORNIA TO CA USE CANCER.

Australian f1"chem Code: None allocated.I'oison Schedule: S6WHMIS:This MSDS has bee" prepared according to the hazard criteria of the Controlled Products Regulations (CPR) and the MSDS contains all of the infonnationreqnired by the CPR.

16. Other Information

NFPA Ratings: Health: 2 Flammability: I Reactivity: 0Label Hazard Warning:WARNING! HARMFUL IF SWALLOWED OR INHALED. AFFECTS HEART, CENTRAL NERVOUS SYSTEM, LIVER AND KJDNEYS. CAUSE~SEVERE SKIN IRRITATION. CAUSES IRRITATION TO EYES AND RESPIRATORY TRACT. SUSPECT CANCER HAZARD. MAY CAUSE CANCER.Risk of cancer depends on level and duratlon ofexposure.Label PTecautions:Do not get in eyes. on skin, or on clothing.Do not breathe vapor.Keep container closed.Use only with adequate ventilation.Wash thoroughly after handling.Keep away from heat and flame.Label First Aid:If swallowed. induce vomiting immediately as directed by medical personnel. Never give anything by mouth to an unconscious person. If inhared. remove tofresh air. II not breathing, give artificial respiration. Ifbreathing is difficul~ give oxygen. In case ofeonlact, immediately flush eyes or skin with plenty of waterfor at least IS minutes. Remove contaminated clothing and shoes. Wash clothing before reuse. In all cases call a physician. Note to physician: Do not administeradrenaline or epinephrine to a victim of chlorinated solvent poisoning.Product Use:Laboratory Reagent.Revision Information:MSDS Section(s) changed since last revision ofdocnment include: 8.Disclaimer:................* *****" .**.* *.".**.~ ~*III.**"* **ljr; ••••••••••~ **•••••MalJinekrodt Baker, Inc. provides lhe information contained herein In good faith but makes no representation as to its comprehensiveness or accuracy.This document i. intended only as a gnide to the appropriate precautionary handling ofrhe material by.a properly trained person using this product.Individuals receiviug the information must ..ercise their independent judgment in determining irs appropriateness for a partiCUlar purpose.MALLINCKRODT.BAKER, INC. MAKES NO REPRESENTATIONS OR WARRANTIES, EITHER EXPRESS OR IMPLIED, INCLUDINGWITHOUT LIMITATION ANY WARRANTIES OF MERCHANTABILITY, FITNESS FORA PARTlCUl.AR PURPOSE WITH RESPECT 1'0

http://www.jtbaker.com/msds/englishhtml/t4940.htm 8/7/2008.

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TRICHLOROETHYLENE Page 5 of 5

THE II"FORMATION SET FORTH HEREIN OR THE PRODUCT TO WHICH THE INFORMATION REFERS. ACCORDINGLY,MALLINCKRODT BAKER, INC. WILL NOT BE RESPONSIBLE FOR DAMAGES RESULTING FROM USE OF OR RELIANCE UPON TH ISINFORMATION....... ** *** *"'''',,** ''' ••***** "'* "'''' '''''' .Prepared b)': Environmenmt Health & SafetyPhone Number: (314) 654·1600 (U.S.A.)

http://www.jtbaker.com/msds/englishhtmllt4940.htm 8/7/2008

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ATTACHMENT 3

ATSDR forToxFAQ for TeE

Request for Removal Action at Delfasco Forge Site

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ATSDRAGENCY FOR TOXIC SUBSTANCES

AND DISEASE REGISTRY

TRICHLOROETHYLENECAS # 79-01-6

I Division of Toxicology ToxFAQSDI -- - - ------------------J-uly 2003-

This fact sheet answers the most frequently asked health questions (FAQs) about trichloroethylene.For more information, call the ATSDR Information Center at 1-888-422-8737. This fact sheet is one ina series of summaries about hazardous substances and their health effects. This information isimportant because this substance may harm you. The effects of exposure to any hazardous substancedepend on the dose, the duration,. how you are exposed, personal traits and habits, and whether otherchemicals are present.

HIGHLIGHTS: Trichloroethylene is a colorless liquid which is used as a solventfor cleaning metal parts. Drinking or breathing high levels of trichloroethylenemay cause nervous system effects, liver and lung damage, abnormal heartbeat,coma, and possibly death. Trichloroethylene has been found in at least 852 ofthe 1,430 National Priorities List sites identified by the Environmental ProtectionAgency (EPA).

What is trichloroethylene?Trichloroethylene (TCE) is a nonflammable,

colorless liquid with a somewhat sweet odor and a sweet,burning taste. It is used mainly as a solvent to removegrease from metal parts, but it is also an ingredient inadhesives, paint removers, typewriter correction fluids, andspot removers.

Trichloroethylene is not thought to occur naturallyin the environmcnt. Howevcr, it has been found inunderground water sources and many surface waters as arcsult of thc manufacture, use, and disposal of the chemical.

.What happens to trichloroethylene when it entersthe environment?1;J Trichloroethylene dissolves a little in water, but it can

remain in ground water for a long time.

Cl Trichloroethylene quickly evaporates from surface water,

so it is commonly found .as a vapor in the air.

el Trichloroethylene evaporates less easily from the soil than

from surface water. It may stick to particles and remain for a

long timc.

el Trichloroethylene may stick to particles in water, which

will cause it to eventually settle to the bottom sediment.

I;J Trichloroethylene does not build up significantly in

plants and animals.

How might I be exposed to trichloroethylene?CI Breathing air in and around thc homc which has been

contaminated with trichloroethylcnc vapors from shower

water or household products such as spot removcrs and

typcwritcr corrcction fluid.

Cl Drinking, swimming, or showering in water that has bcen

contaminated with trichloroethylene.

Cl Contact with soil contaminated with trichloroethylene,

such as near a hazardous waste site .

Q Contact with the skin or breathing contaminated air while

manufacturing trichloroethylene or using it at work to wash

paint or grease from skin or equipment.

How can trichloroethylene affect my health?Breathing small amounts may cause headaches, lung

irritation, dizziness, poor coordination, and difficultyconcentrating.

Breathing large amounts of trichloroethylene maycause impaired heart function, unconsciousness, and death.Breathing it for long periods may cause nerve, kidney, andliver damage. .

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Page 2TRICHLOROETHYLENEI

CAS # 79-01-6

Drinking large amounts of trichloroethylene maycause nausea, liver damage, unconsciousness, impaired heartfunction, or death.

Drinking small amounts of trichloroethylene for longperiods may cause liver and kidney damage, impaired immunesystem function, and impaired fetal development in pregnantwomen, although the extent of some of these effects is notyet clear.

Skin contact with trichloroethylene for short periodsmay cause skin rashes.

How likely is trichloroethylene to cause cancer?Some studies with mice and rats have suggested that

.high levels of trichloroethylene may causc livcr, kidney, or lungcancer. Some studies of people exposed over long periods tohigh levels oflrichloroethylene in drinking water or in workplaceair have found evidence of increased cancer. Although, there aresome concerns about the studies of people who were exposedto trichloroethylene, some of the effects found in people weresimilar to effects in animals.

In its 9th Report on Carcinogens, the NationalToxicology Program (NTP) determined that trichloroethylene is"reasonably anticipated to be a human carcinogen." TheInternational Agency for Research on Cancer (fARC) hasdetermined that trichloroethylene is "probably carcinogenic to

humans."

Is there a medical test to show whether I've beenexposed to trichloroethylene?

If you have recently been exposed totrichloroethylene, it can be detected in your breath, blood, orurine. The brcath test, if it is performed soon after exposure,can tell if you have been exposed to even a small amount oftrichloroethylene.

Exposure to larger amourits is assessed by blood

and urine tests, which can detect trichloroethylene and manyof its breakdown products for up to a week after exposure.'However, exposure to other similar chemicals can producethe same breakdown products, so their detection is notabsolute proof of exposure to trichloroethylene. This testisn't available at most doctors' offices, but can be done atspecial laboratories that have the right equipment.

Has the federal government maderecommendations to protect human health?

The EPA has set a maximum contaminant level fortrichloroethylene in drinking water at 0.005 milligrams per liter(0.005 mg/L) or 5 parts of TCE per billion parts water. .

The EPA has also developed regulations for thehandling and disposal of trichloroethylene.

The Occupational Safety and Health Administration(OSHA) has set an exposure limit of 100 parts oftrichloroethylene per million parts of air (100 ppm) for an 8­hour workday, 40-hour workweek..

GlossaryCarcinogenicity: The ability of a substance to cause cancer.CAS: Chemical Abstracts Service.Evaporate: To change into a vapor or gas.Milligram (mg): One thousandth of a gram.Nonflammable: Will not burn.ppm: Parts per million.Sediment: Mud and debris that have settled to the bottom ofa body of water.Solvent: A chemical that dissolves other substances.

ReferencesThis ToxFAQs information is taken from the 1997

Toxicological Profile for Trichloroethylene (update) producedby the Agency for Toxic Substances and Disease Registry,Public Health Service, U.S. Department of Health and'HumanServices, Public Health Service in Atlanta, GA.

Where can I get more information? For more information, contact the Agency for Toxic Substan~esand Disease

Registry, Division of Toxicology, 1600 Clifton Road NE, Mailstop F-32, Atlanta, GA 30333. Phone: 1-888-422-8737,FAX: 770-488-4178. ToxFAQsTM Internet address is http;llwww.atsdr.cdc.gov/toxfaq.html. ATSDR can tell you where tofind occupational and environmental health clinics. Their specialists can recognize, evaluate, and treat illnesses resultingfrom exposure to hazardous substances. You can also contact your community or state health or environmental qualitydepartment if you have any more questions or concerns.

000215

MEMORANDUM AUG 27 2008SUBJECT: Request for a Removal Action at Delfasco Forge Site, Grand Prairie, Dallas

County, Texas

FROM: Gregory E. Fife, Senior On-Scene CoordinatorRemoval Site Section (6SF-PR)

TO: Samuel Coleman, P.E., DirectorSuperfund Division (6SF)

THRU: Robert R. Broyles, Associate DirectorPrevention and Response Branch (6SF-P)

1. PURPOSE

This memorandum documents the verbal approval and requests approval for a RemovalAction pursuant to the Comprehensive Environmental Response, Compensation and LiabilityAct (CERCLA), as amended, 42 U.S.c. §§ 9601 et seq., at the Delfasco Forge Site located inGrand Prairie, Dallas County, Texas. The proposed action includes the installation of exhaustfan systems on houses impacted by soil vapor intrusion. Verbal approval was provided by theActing Superfund Division Director, Pam Phillips on August 5, 2008. That verbal approval wasfor the installation of exhaust fan systems on two homes within the Site.

This action meets the criteria for initiating a removal action under the NationalContingency Plan (NCP), 40 CFR § 300.415. This action is expected to require less than twelvemonths and $2 million to complete.

II. SITE CONDITIONS AND BACKGROUND

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000216