United States
          Environmental Protection
          Agency
             Office of
             Emergency and
             Remedial Response
EPA/ROOR03-86/02S
September 1966
SEPA
Superfund
Record of Decision:
          Bruin Lagoon, PA
               (Second Remedial Action)

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TECHNICAL REPORT DATA
(Please read Inunctions on the rtvene be fort completing)
EPA/ROD/RO 3-86/025

4. TITLE AND SUBTITLE
SLPERFUND RECORD OF DECISION
Bruin Lagoon, PA
Second Remedial Action
7. AUTHORIS)
9. PERFORMING ORGANIZATION NAME AND ADDRESS

12. SPONSORING AGENCY NAME AND ADO
L.S. Environmental Protectic
401 M Street, S.W.
Washington, D.C. 20460

RESS
>n Agency

5. REPORT DATE
Sept»ml?ftr 29. 1986
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Rpport-
14. SPONSORING AGENCY CODE
800/00
IS. SUPPLEMENTARY NOTES
16. ABSTRACT
Bruin Lagoon is located about 45 miles north of Pittsburgh in Bruin Borough, Butler
County, PA. The site occupies over four acres and is located along the western t*mk of
the South Branch of Bear Creek, approximately seven miles upstream of the creek's
confluence with the Allegheny River. The site is also partially situated in the
100 -year flood plain of the creek. The commercial and main residential areas of Bruin
Borough are located less than five blocks from the site and over 30 residences lie
within 500 feet of Bruin Lagoon. Beginning in the 1930s, Bruin Oil Company, located on
property adjacent to the site, used the lagoon for disposal of wastes resulting from the
production of white oil (mineral oil). Disposal operations continued for more than 40
years. In 1968 a breach in the lagoon dike caused an acidic sludge spill into the South
Branch of Bear Creek which killed 4 million fish in the Allegheny River. An RI/FS
report, begun in July 1981, resulted in a remedial action between August 1983 and May
1984. The first remedial action included: removal of liquid floating on top of the
open lagoon and offsite disposal; lagoon and dike stabilization; removal of scrap tanks
and equipment; installation of a multi-layer impermeable cap; and construction of a
channel to prevent ground water from entering the site. In May 1984 a previously
unidentified sludge layer, releasing toxic gases, was penetrated during remedial
construction. EPA declared an emergency situation, stopped all remedial activities, anc
(See Attached Sheet)
17.
a. DESCRIPTORS
KEY WORDS AND DOCUMENT ANALYSIS
b.lOENTIFIERS/OPEN ENDED TERMS
Record of Decision
Bruin Lagoon, PA
Second Remedial Action
Contaminated Media: gw, sw, sediments
Key contaminants: organics, heavy metals,
oils, sludge, inorganics, acids
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (Tliit Report!
None
20. SECURITY CLASS (Tint page)
None

c. COSATI Field/Croup

34
22. PftlCE
EPA Fo»m 2220-1 (R«». 4-77)    Previous COITION i* OSIOLKTK

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EPA/ROD/RO3-86/025
Bruin Lagoon, PA
Second Remedial Action

16.  ABSTRACT (continued)
initiated an immediate emergency action.  These actions were terminated in
September 1984 after the site was stabilized and secured.   EPA,  upon
completion of the emergency work, determined the need for  a reevaluation of
the site.  The primary contaminants of concern include:  toxic gases,  heavy
metals, oils, inorganics, and acidic sludge.
   The selected remedial action includes:   onsite
stabilization/neutralization of sludge and perched liquid  zone;  in-situ
treatment of bedrock underneath the former lagoon area; completion of  dike
reinforcement; capping the former lagoon area with a multi-layer  cap;
monitoring and maintenance of the site, cap and ground water.  The  estimated
capital cost is $2,695,000 with annual O&M of $16,000.

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                            RECORD OF DECISION

                      REMEDIAL ALTERNATIVE SELECTION

              BRUIN LAGOON SITE, BRUIN BOROUGH, PENNSYLVANIA


DOCUMENTS REVIEWED

      I am basing my decision principally on the following documents des-
cribing the analysis of cost-effectiveness and feasibility of remedial
alternatives for the Bruin Lagoon Site.

     - Draft Remedial Investigation/Feasibility Study Report, for the
       Bruin Lagoon Site, Bruin Borough, Pennsylvania, Roy F. Weston
       Inc., June, 1986.

     - Preferred Remedial Alternative for the Bruin Lagoon Site, EPA
       and PADER Fact Sheet, August 21, 1986-.

     - Staff summaries and recommendations.

DESCRIPTION OF SELECTED REMEDY

     - On-Site stabilization/neutralization of sludge and perched liquid
       zone.

     - In-situ treatment of bedrock underneath former lagoon area.

     - Completion of dike reinforcement.

     - Capping the former lagoon area with multi-layer cap.

     - Monitoring and maintenance of the site cap and groundwater.

DECLARATIONS

     Consistent with the Comprehensive Environmental Response, Compensation
and Liability Act of 1980 (CERCLA) and the National Contingency Plan (40 CFR
Part 300), I have determined that onsite neutralization/stabilization of
sludges and perched liquids; bedrock neutralization, and placement of a multi-
layer cap over the former lagoon area is a eost-effective remedy which effec-
tively mitigates and minimizes damage and provides adequate protection of pub-
lic health, welfare, and the environment.  The remedial action will be designed
to minimize the risk of potential evacuation and temporary inconveniences to
the local environment during the .< ludge neutralization/stabilization and bed-
rock neutralization efforts.

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                                   -2-
     The State of Pennsylvania has been  consulted  and  agrees  with the  approved
remedy.  Following the stabilization of  the  sludge and  capping  of the  area,
operation and maintenance activities will be required  to  ensure the  continued
effectiveness and level of protection of the remedy.   These activities will  be
considered part of the approved action and eligible  for Trust Fund monies  for
a period of one year.
         Date/
     James M. Saify
Regional Adminifstrator

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                                   -J-
SITE DESCRIPTION AND SUMMARY OF REMEDIAL ALTERNATIVE SELECTION FOR THE BRDIN
LAGOON SITE

Site Location and Description

     Bruin Lagoon is located about 45 miles north of Pittsburgh in Bruin Borough,
Butler County, Pennsylvania.  The site occupies over four acres and is located
along the western bank of the South Branch of Bear Creek, approximately seven
miles upstream of the creek's confluence with the Allegheny River.  A spur of
the Baltimore and Ohio Railroad runs along the eastern bank of the stream.
The site is also partially situated in the 100-year floodplain of the South
Branch of Bear Creek.

     Private homes and State Route 268 border the site on the west.  The
commercial and main residential areas of Bruin Borough are located less than
five blocks from the site and over 30 residences lie within 500 feet of Bruin
Lagoon.  An abandoned refinery, which was the source of the wastes desposited
in the lagoon, is located adjacent to the site'on the south.  Two ponds and a
small stream, which discharge into the South Branch of Bear Creek, lie along
the former refinery property boundary bordering the- Bruin Lagoon Site.

     The site presently consists of an earthen diked lagoon which has been
covered, to varying degrees, by a stabilized sludge/soil mixture.  Unstabliized
sludge/tar is contained beneath much of the cover and numerous areas of up-
welling of the black sludge tar material are evident.  The sludge tar is a
result of white oil manufacturing (mineral oil) and contains sulfuric acid,
heavy metals, and other materials.  The lagoon area of the site is generally
level 'and unvegetated.

     The entire site is enclosed by a security fence.  A dike extends along
the north and east sides of the site and separates the lagoon from the South
Branch of Bear Creek.  It is approximately 25 feet high and is composed of
sandy clay and shale.  Riprap, gabion cages, and concrete barriers have been
placed along portions of the dike to protect it from flood erosion.
                                                                    *'-~
Site History

     Operations at Bruin Lagoon began in the 1930s when the Bruin Oil Company,
located on adjacent property, used the lagoon for disposal of wastes resulting
from the production of white oil (mineral oil).  Disposal operations continued
for a period of over 40 years.  Materials deposited in the lagoon included:

     0 Bottom residues from crude oil storage tanks.

     0 Spent bauxite, none powder, and charcoal filtering agents

 : '•'• •.  ° Non-specification oils

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Rgur» t    Site Location Map

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Note Mo»lut*MiMifcl*tMlu»
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                                   -'-*-
    . ° Spent Alkali

     0 Boiler house coal and ashes

     0 Lime

     0 Coal fines

     In 1968, Bruin Lagoon received national attention when approximately
3,000 gallons of acidic sludge spilled into the South Branch of Bear Creek
through a breach in the dike.  An estimated four million fish in the Alleg-
heny River were killed as a result of the discharge and evidence of the spill
was observed over 100 miles downstream from the site.  Many downstream
communities had to temporarily shut down their water supply systems.

     In July 1981, EPA begaa a remedial investigation to determine the type
and extent of contamination at the site, and conducted a feasibility study to
identify alternatives for remedial action.  The feasibility study, completed
in February 1982 called for: removing the liquid floating on top of the open
lagoon and disposing of it offsite, stabilizing the lagoons and dikes,
removal of scrap tanks and equipment, building a channel to prevent
groundwater from entering the site, and covering the site with an impermeable
multilayer cap.

     In September 1982, EPA signed a Superfund State Contract with Pennsylvania
for implementation of the action.  The work was managed by the U. S. Army Corps
of Engineers.  The site cleanup work began in August 1983 and proceeded until
May 1984.

     In May 1984, toxic gases containing high concentrations of carbon dioxide,
sulfuric acid mist, and hydrogen sulfide were released from the lagoon when a
previously unidentified sludge layer was penetrated during remedial construction.

     EPA declared an emergency situation at the site and stopped all remedial
activities in order to initiate an immediate emergency action at the Bruin
Lagoon Site.  Emergency actions were terminated in September 1984 after the
site was stabilized and secured by backfilling the lagoon and installation
of gas recovery wells.

     Upon completion of the emergency work, EPA determined that a second
remedial investigation and feasibility study was warranted to reevaluate
the site.                                  •

Present Site Status
     EPA Region  III completed the second Remedial Investigation/Feasibility
Study (RI/FS) on Bruin Lagoon in July 1986.  Data collected in the RI and in
the previous studies of  the site were used to describe the nature and extent
of contamination.

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                                   -5-
     The following points summarize the findings of the RI regarding geology,
hydrogeology,  and concentrations of contaminants detected in the air, soils,
bedrock, surfacewater,  groundwater, and subsurface gases.

Major Findings of the RI:

     ° There are elevated concentrations of heavy metals in 'the majority of
       soil/sludge samples that were analyzed.  A few organic compounds were
       identified at concentrations less than 1 part per million.

     0 There are appoxiraately 17,500 cubic yards of unstabilized sludge.

     0 There is a hot spot in the unstabilized portion at the lagoon that
       contains potentially hazardous gases.  This is located in the area
       where the crust  was encountered.  The gases include sulfur dioxide,
       hydrogen sulfide, carbon dioxide, and methane.

     0 The bedrock underlying the site has been contaminated by the lagoon.

     0 The shallow water in the perched liquid zone of the lagoon is re-
       charged predominantly by onsite precipitation and infiltration.

     0 The South Branch of Bear Creek is contaminated upstream of the site
       and, on a day-to-day basis, its water quality is highly variable.

     0 The groundwater  underlying the site exhibits localized inorganic
       contamination.

     0 Groundwater flowing underneath the site runs towards the South Branch
       of Bear Creek.

     0 Regional ground  water quality is generally poor.

     0 Residential wells, upgradient of the site, do not appear to have been
       impacted by the  site.


Geology                                       .

     The Bruin Lagoon Site is located in tRe Appalachian Plateau Province.
The bedrock strata are  bedded horizontal to subhorizontal and are sedimentary
in origin.  The Pennsylvania Age Allegheny Group comprises most of the rock
formations in the Bruin area.  This group consists of cyclic sequences of sand-
stone, shale,  limestone, clay and coal beds.  The bedrock encountered immedia-
tely underneath the site consists of a gray sandstone.

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                                   -6-
     The Bruin area was extensively mined for coal.  However, there are no
active surface or underground mines within one mile of the site.  An abandoned
underground coal mine is located approximately 0.5 mile northeast of the site.

Hydrogeology

     Two groundwater systems were identified during the RI: a bedrock groundwater
system located in the fractured sandstone and a perched liquid zone located within
the soil fill and sludges at the lagoon site.

     The bedrock water table aquifer at the site flows in a general northeasterly
direction and discharges into the South Branch of Bear Creek.

     Th.e groundwater is recharged by infiltration of precipitation upslope
as well as direct vertical infiltration on the site itself.

     The perched liquid zone is composed of water; viscous petroleum products
such as oils, waxes, and emulsions; and acidic wastes.  The zone has a radial
flow eventually discharging into the South Branch via leachate seeps in the
dike or vertically migrating into the bedrock aquifer Recharge of the perched
liquid zone is due to infiltration of precipitation.

Air Monitoring

     Low levels of organic vapors, sulfur dioxide or hydrogen sulfide were
released into the ambient breathing zone when the subsurface of the site was
disturbed by drilling operations.  However, concentrations of these gases
were nondetectable at the site perimeter.

Soils

     Soil sampling at this site includes samples taken in the stabilized and
unstabilized sludge.  The following conclusions are presented:

     0 The pH of the stabilized sludge is typically greater than 10,' while
       the pH of the unstabilized sludge is generally less than 4.  The
       lowest pH values are usually found in the area of the former open
       lagoon at depths greater than 15 feet where acidic unstabilized
       sludges are still present.
                                           •
     0 The indicator parameters of TOG and oil and grease are several
       orders of magnitude higher for stabilized and unstabilized sludges
       as compared to the apparent background levels as measured in native
       soil samples.

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                                                                                       Clean Soil Fill
                                                                                                I ULU halt: Stifcpb 4)

                                                                                                 Appioxmalely
                                                                                                   I.MSFettl
Oiieclion
                                                                                                -*•  EMI
                                                                                                                              o* H«UI,I,« ol P.,ch.U Zont
                                                                                                                and Retiinck Aqmtot

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                                   -7-
     0 An area of low pH sludge appears to be located In the former closed
       lagoon area at the southeast corner of the site.

     0 Shallow soils at the site perimeter show slight contamination as
       evidenced by TOC and oil and grease levels greater than background
       concentrations.

Bedrock

     The primary conclusions from the investigation of the bedrock are as
follows:

     0 The top of the bedrock, under portions of the former open and closed
       lagoons, is impregnated with acidic sludge material.  Black and gray
       staining typically extends 5 to 12 feet into the bedrock, while contami-
       nation of fractures may extend 10 to 35 feet into the rock.  Also,
       contaminated rock and fractures are located completely or partially
       within the zone of saturation of the bedrock aquifer.

     0 The primary effects of the site on the bedrock appear to be the move-
       ment of waste acids vertically into the bedrock under the former lagoon
       areas.  The pH data indicate that acidic conditions extend deeper into
       the bedrock than the visually observed staining.  These conditions pro-
       bably exceed depths of 20 to 30 feet into the bedrock at various loca-
       tions.  Acidic influences gradually decrease as depth into the bedrock
       increases.

     0 Site data suggests that unstabilized sludge is not migrating beneath
       the dike on the eastern boundary of the lagoon site.

Subsurface Gases

     0 Hazardous subsurface gases are still present under the site.  Sulfur
       dioxide was determined to be the gas of primary concern.  It was measured
       in 6 of the 23 shallow wells, while hydrogen sulfide and sulfuric acid
       mist were detected in most of the wells.

     0 The wells where hazardous subsurface gases were found are clustered in
       the east-central portion of the site, in an area corresponding to the
       southern part of the 1981 open lagoon.  Previous investigations have
       measured hazardous subsurface gases in this same "hot spot" zone.

     0 The locations where hazardous subsurface gases were found, generally
       correspond to the locations where crust has been encountered in the
       subsurface.  Gas generation appears to occur under the crust, and
       the crust appears to effectively trap and contain the gases.

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tOW 4
                                                                   11 WO,
                                                                                                                                            Monitor Wall 

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                                   -8-
     9 The potential for  the  release.of hazardous gases to the atmos-
       phere exists during  the implementation of remedial alternatives
       involving excavation or disturbance of the crust layer.  The
       greatest potential for such a release would occur during activi-
       ties conducted in  the  "hot spot" zone in the east-central portion
       of the site.

Surface Water

     Visual observations  and  analytical data confirm that the water quality
of the South Branch of Bear Creek upstream of the Bruin Lagoon site is generally
poor and highly variable.

     The chemical data indicates that the site may have a slight impact on the
water quality of the South  Branch.  Concentrations of phenol, sulfate, and
some metals were at measured  somewhat higher levels below the site than upstream
of the site.

Groundwater

A.   Perched Liquid Zone

     0 The perched liquid zone is a heterogeneous mixture composed of stratified
       layers of water, acid  wastes, and petroleum-based products.  The acidic
       and petroleum wastes were primarily contained in wells located within the
       unstabilized sludge  of the former open lagoon.

     9 'The materials in the perched liquid zone generally had low pH's and po-
       tential Impacts are  likely to result from the acidic nature of the liquids.

     9 Liquids having pH values less than 1.0, and specific conductivity values
       greater than 50,000  umhos/cm, were found in the same wells where hazardous
       subsurface gases were  detected and crust was. encountered.  These results
       indicate that concentrated acids are present under the crust and are
       directly related to  the production of hazardous subsurface gases'*.

     9 Samples having pH values greater than 11 consisted primarily of water
       and were collected from wells located in the southern part of the site.
       This is where lime and stabilized sludge were stockpiled during the
       remedial construction  work.
                                              /
     0 The perched liquid zone within some areas of the former open lagoon
       is comprised solely  of oil.

Bedrock Aquifer .

  -  : Based on a review of the analytical results for indicator parameters,
organics, and inorganics  from bedrock well samples collected during the
remedial investigation, the following conclusions regarding the groundwater
in the bedrock aquifer are  made:

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                                   -9-
     ° The- background quality of groundwater In the areas of the Bruin Lagoon
       site is poor.  This is evidenced especially by the high iron, manganese,
       sulfate, and pH values which exceeded secondary drinking water standards
       in background wells.  The poor quality of the groundwater is related to
       Che local mining and oil. industry.

     0 The site has impacted the groundwater in the bedrock aquifer.  Three
       types of contaminant effects were observed:

       - An acidic impact characterized by low pH values and high sulfate
         levels.

       - An organic impact characterized by elevated concentrations of TOC,
         oil and grease, TOX, and volatile organics.

       - An inorganic impact characterized by elevated levels of specific
         conductivity and metals.

       0 The impacted groundwater in the bedrock aquifer extends from the wes-
         tern perimetar of the site to the immediate downg^adient area along Bear
         Creek where it discharges into the stream.

         Acetone, benzene, toluene, and xylenes were the organic compounds
         detected most frequently and at the highest concentrations in the
         groundwater.

Health Evaluation

     In its present condition, the Bruin Lagoon Site represents a potential threat
to public health, welfare, and the environment.  If the site groundwater were in-
gested it could pose a risk to human health.  The unsolidified sludge at the site
poses a threat to both humans and wildlife that might come into dermal contact
with it or ingest it. .  Intermittent ponded water af the site a-lso poses a threat
to humans and wildlife since the caustic material could cause tissue damage.
Furthermore, if th-.j site were disturbed by digging or drilling of a well, there
is the potential for the release of hazardous gases at toxic levels.

Alternatives Evaluation

     This section will briefly define the remedial action objectives; the
screening methods to determine appropriate remedial technologies; and the
specific alternatives considered.  The Feasibility Study and Appendix con-
tains a more in-depth analysis of these discussions.

     0  Remedial Action Objectives;

        - Contain, reduce, and/or eliminate site contaminants identified as
          representing possible sources of exposure to human and other poten-
          tial receptors.

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                       PO-'tMTIAL EXPOSURE PATHWAYS ASSOCIATED WITH THE BRUIN LAGOON SITE
           Receiving        Release                Exposed             Potential      Complete Pathway
            Medium       Mechanism             Population         Exposure Route    Current  Future


$          Air           Gases emitted  from    Downwind recep-    Inhalation,  uptake   No      Yes
j£                        sludge  and soil        tors:  humans and
•T>                                               plants
•«j
           Soil          Unsolidified sludge    Humans or wild-    Dermal contact,      Yes     Yes
                                                life on-site       ingestion

           Groundwater   Leaching of ions       Humans drinking    Ingestion            No      Yes
                         from soil  and          groundwater
                         bedrock by acids

           Bear Creek    Discharge  of           Aquatic life in    Contact,  ingestion   No      Yes
                         groundwater, surface   Bear Creek
                         water runoff

           Intermittent  Dissolution of acids   Humans or animals   Dermal contact,      Yes     Yes
           Standing                             coming into        ingest ion
           Mater                             *  contact with water

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       - Reduce or eliminate exposure of site contaminants to potential
         receptors by controlling potential contaminant pathways.

       - Ensure technical feasibility, protection to public health and the
         environment, and cost-effectiveness of the remedial actions.

     The list of technologies to be considered for Bruin Lagoon was developed
by reviewing the sources and pathways of contaminants and their potential re-
ceptors and then identifying corresponding potential response actions.  For
each potential response action various technologies were identified.  See
table 9-3 for a summary of the response actions and technologies.

     0 Factors Used for Screening and Remedial Technologies

       - Technical Criteria

         0 applicability to site conditions (geology, topography, etc).

         0 applicability to waste characteristics

         0 performance and reliability

         0 implementability (construction, operation, and maintenance)

       - Environmental and Public Health Criteria

         0 screened for effectiveness of remediation and efficiency in re-
           ducing present and future contaminant exposure

         0 short term and long term risks

       - Institutional Criteria (Compliance with other environmental laws)

         0 TSCA

         0 RCRA

         0 CWA

         0 NPDES

         ' etc.

       - Cost Criteria

         0 increased cost offering no greater reliability

         0 increased cost offering no greater environmental or public health
           benefit

     For a detailed analysis of technologies screened out see Section 10 of
the RI/FS.

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                                   -11-
Alternatives Considered in Detail

     Seven alternatives incorporating the technologies considered in
detail were evaluated for remedial action.  These seven alternatives
were:

     1.  No action with monitoring

     2.  Sludge and liquid zone stabilization, soil capping, and monitoring

     3.  Sludge and liquid zone stabilization, in situ bedrock treatment,
         RCRA capping and monitoring.

     4.  Removal, stabilization, -.id off site disposal of stabilized and
         unstabilized sludge, perched liquid zone, and contaminated soils
         with monitoring.

     5.  Removal, stabilization, and offsite disposal of unstabilized sludge,
         perched liquid zone, RCRA capping and monitoring.

     6.  Onsite incineration of sludge, perched liquid zone, contaminated
         soils, and monitoring.

     7.  Offsite incineration of sludge, perched liquid zone and contami-
         nated soils with monitoring.

     The onsite and offsite incineration alternatives were not evaluated in the
feasibility study but were evaluated separately in Appendix Q of the RI/FS.

     Alternative No. 1 - No Action with Monitoring

     This alternative was prepared for comparative purposes.  The monitoring of
groundwater would function as a detection system to warn of-increasing contaminant
concentrations in the groundwater from the site.  This alternative is not appro-
priate because:

     - Without additional remedial actions localized groundwater contamination
       and subsequent contamination migration to Bear Creek will continue.

     - Toxic gas can accumulate under the sludge posing a potential health and
       environmental hazard if the sludge is disturbed.

     - Acidic and caustic puddles on the surface of the lagoon pose a threat to
       public health and are an environmental hazard.

     - This alternative does not meet the goals of CERCLA and would not comply
       with other environmental regulations.

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                                   -12-
     Alternative 2 - Stabilization of Sludge and Liquid Zone with Soil Capping,
     Dike Reinforcement, and Post Closure MoniCoring

     - In this alternative, the unstabilized sludge would be mixed with a soil
bulking agent and lime to immobilize the inorganic contaminants and allow the
sludge to support a cap.  During the excavation, gas monitoring with provisions
for gas venting and treating would be necessary.  A soil cap would be placed
over the former lagoon to reduce infiltration.  Dike stabilization would be
completed to withstand the maximum probable flood.  Post closure monitoring
consists of cap maintenance and long term ground water monitoring.

     The advantages of this alternative include:

     - Stabilization of sludge and perched liquid zone will reduce
       contaminant migration to ground water and will support a cap.

     - The soil cap will reduce infiltration and, therefore, reduce
       contamination migration to the ground water and surface water.

     - Direct contact threats are removed.

     - The dike improvements will ensure stability under worse case
       flood conditions.

     The disadvantages associated with this alternative are:

     - The sludge impregnated bedrock is not addressed.

     - Short term risks due to excavation and stabilization process.

     Alternative 3 - Stabilization of Sludge and Liquid Zone with Multi-
     layer cap, Dike Reinforcement, Shallow Bedrock Treatment, and Post
     Closure Monitoring.

     This alternative is similar to Alternative 2 except for the addition
of shallow bedrock treatment with a lime slurry and the placement of a
multilayer cap instead of the soil cap for alternative 2.

     The advantages of this alternative include:

     - The mobility and toxicity of inorgarfic constituents in the waste is
       reduced.

     - Stabilization of sludg.e and perched liquid zone will reduce con-
       taminant migration to ground water and will support a cap.

     - The multilayer cap will significantly reduce infiltration through
       the stabilized sludge and contaminated soils and thus reduce impact
       on surface water.

     - Dike improvements will ensure stability under worse case flood
       conditions.

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                                   -13-
     •- Treatment of bedrock will address contamination of groundwater
       from sludge impregnated bedrock.

     The disadvantage of this alternative is:

     - Short term risks due to excavation and stabilization process.

     Alternative 4 - Complete Removal and Off-site Disposal of all
     Stabilized and Unstabilized Sludge, Perched Liquids, and Con-
     taminated Soil with shallow Bedrock Treatment, Dike Reinforce-
     ment, and post closure monitoring.

     This alternative offers complete removal of the contaminated sludges,
liquids and soil from the site.  Monitoring for gases with provisions for
venting and gas treatment will be done during the excavation.  The material
would be transported to an approved RCRA disposal facility.  The dike would
be reinforced and post closure monitoring would be conducted.

     The advantages of this alternative are:

     - All contaminants are removed from the site.

     The disadvantages of this alternative are:

     - High project cost.

     - Limited space at RCRA facilities.

     - Short term risks due to excavation and transportation of material
       offsite.

     - Transfer of contaminants to a RCRA facility will transfer a risk
       of future contaminant release to the accepting RCRA facility.

     Alternative 5 - Complete Removal Offsite of Unstabilized Sludge and
     Perched liquid with Shallow Bedrock Treatment, Dike Reinforcement,
     Placement of a Multi-layer cap, and Post Closure Monitoring.

          This alternative is similar to alternative 4 except that contami-
     nated soils and previously stabilized sludge would remain onsite under-
     neath a multilayer cap.

          The advantages and disadvantages are the same as in alternatives
     3 and 4.

     Alternative 6 - Gnsite Incineration of sludge, perched liquid zone,
     and contaminated soils with onsite or offsite ash disposal, dike
     reinforcement and post closure monitoring.

          In this alternative the sludges, perched liquids and contami-
     nated soils would be incinerated in an onsite mobile incinerator.
     Costs for the process differ depending on whether the sludge must
     be stabilized or just neutralized before incineration and also
     whether the ash would remain onsite or taken offsite to an
     approved RCRA facility.

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                                   -14-
     The advantages of this alternative are:

     - Neutralization and incineration of the sludge will reduce contami-
       nant migration to the groundwater..
     - This alternative offers a slightly higher level of environmental
       effectiveness and reduction of the public health risk as alterna-
       tive 3.

     The disadvantages of this alternative are:

     - short terra risks due to excavation of the waste
     - high project cost
     - long time frame for implementation (approximately 3 1/2 - 4 years)
     - limited space onsite for incinerator operation
     - public acceptability

     Alternative 7 - Offsite Incineration of Sludge, Perched Liquid Zone,
     and Contaminated Soils with Dike Reinforcement and Post Closure
     Monitoring

          This Alternative calls for the containerization of sludges, perched
     liquids and contaminated soils and shipment to an approved RCRA offsite
     incinerator.  The ash generated at the incinerator would be managed by
     the commercial facility.

     The advantages of this alternative are the same as alternative 4 and
     6.  The disadvantages are:

     - short terra risks due to excavation and transportation of the waste
     - high project cost
     - long time frame for implementation (estimated at 6 to 7 years)
     - limited number of commercial facilities available

Costs

     Costs for the seven alternatives can be seen in table 2.  Values for
capital costs, annual operation and maintenance costs, present worth and
total present worth are given.

RECOMMENDED ALTERNATIVE

     Section 300.68(j) of the National Contingency Plan (NCP) states that the
appropriate extent of remedy shall be determined by the lead agency's selection
of the remedial alternative which the agency determines is cost effective (i.e.,
the lowest cost alternative that is technologically feasible and reliable) and
which effectively mitigates and minimizes damage to and provides adequate pro-
tection of public health, welfare and the environment*  In selecting a remedial
alternative EPA considers all environmental laws that are applicable or rele-
vant and appropriate.  Based on our evaluation of the proposed alternatives,
the public comments and the information received from the Pennsylvania Depart-

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                                                 ALTERNATIVES COST ANALYSIS SUMMAR
I
m
Alternative

1.  No Action/Monitoring

2.  Onsite Stabilization,
    Soil Cap

3.  Onsite Stabilization,
    Multl Layer Cap

4.  Offsite Disposal,
    All

5.  Offsite Disposal,
    Part

6.  Onsite Incineration

      a. Neutralized Sludge, Ash Remains

      b. Stabilized Sludge, Ash Remains

      c. Neutralized Sludge, Ash Offsite

      d. Stabilized Sludge, Ash Offsite

7.  Offsite Incineration

      a. New Jersey Facility      ,

      b. Illinois Facility
Capital Cost
$ 15,000
2,155,0001
2,695,000
36,581,000
16,029,000
20,981,000
24,230,000
28,983,000
33,754,000
202,117,000
99,837,000
Annual Cost
§23,000
16,000
16,000
9,000
, 16 ,000
9,000
9,000
9,000
9,000
9,000
9,000
Present Worth*
§216,000
150,000
150,000
85,000
150,000
85,000
85,000
85 ,000
85,000
85,000
85,000
Total Cost
§ 231,000
2,305,000
2,845,000
36,666,000
16,179,000
21,066,000
24,315,000
29,068,000
: 33,839,000
202,202,000
99.922,000
         *  1986 Dollars, assuming 30 years of use, and a 110 percent
            average rate of return on private investment

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                                   -15-
ment of Environmental Resources, implementation of Alternative 3, Onsite stabili-
zation of the sludge with a multilayer cap is the recommended alternative.
This includes:

     - Onsite stabilization/neutralization of remaining unstabilized sludge and
       perched liquid zone

     - gas monitoring during site activities
     - gas venting/collecting/treating if necessary

     - Geotextile silt fences to control offsite soil transport

     - In situ shallow ground water/bedrock neutralization

     - Completion of dike embankment reinforcement

     - Capping lagoon area with a multilayered cap which complies with
       RCRA standards

     - Grading and vegetating the cap and the surrounding area to
       promote runoff

     - Construction of a surface water diversion which will direct
       both run-on and runoff away from the site

     - Post closure monitoring.

Operationand Maintenance

     Operation and Maintenance will consist of maintaining the effectiveness
of the RCRA cap, and the periodic monitoring of gases underneath the cap
and monitoring of ground water monitoring wells.  Long term monitoring of
the ground water is necessary to ensure that the remedial action has been
effective in reducing the impact of the site on the ground water.  State
responsibility for O&M would begin one year after the Remedial Construction
is completed.

Consistency with Other Environmental Laws

     The site will be closed in accordance with the relevant and appropriate
landfill closure requirements of 40 CFR § 264.310.

     The multilayered surface cap will be designed and constructed in accordance
with the requirements of § 264.310(a).  The State will perform O&M required by
§264.310(b)(l) as necessary on the cover.  The State will also maintain
and operate the ground water monitoring system required by § 264.310(b)(4).
A run-on and run-off control system will be installed by EPA and maintained
by the State consistent with the requirements of §264.310(b)(5).  Because
there will not be any leachate detection or leachate collector systems
in place which would require maintenance, the requirements of § 264.310(b)(3)
and (4) are not relevant and appropriate.

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                                     -16-
  Schedule

  Approve Remedial Action (ROD)                       September 1986
* Start Design                                        November 1986
  Finish Design                                       June 1987
  Start Construction                                  September 1987
  Complete Construction                               August 1988

* Contingent on CERCLA reauthorization

  Evaluation of Alternatives Not Selected

       A.  Alternative 1, no action with monitoring.  This alternative would do
  nothing to mitigate the potential threats posed by the site, and would not
  comply with the relevant and appropriate requirements.  Because this alternative
  does not effectively minimize or mitigate the threats posed by this site, it
  was not selected.

         Alternative 2, sludge stabilization, soil capping, dike reinforcement
  and post closure monitoring.  This alternative was not selected because the soil
  cap would not comply with the RCRA closure requirements and would not effectively
  reduce rainfall infiltration in comparision to the recommended alternative.
  This alternative also would not mitigate the threats posed by the contaminated
  bedrock.

       Alternatives 4 and 5, offsite land disposal options would only move the
  wastes to another facility.  Because Alternative 3 will effectively stabilize
  the waste and significantly reduce the mobility and toxicity of the wastes,
  the offsite landfilling of unstabilized sludge will not be more effective
  than the recommended alternative.  Also, Alternatives 4 and 5"are substantially
  more costly than Alternative 3. Because these two alternatives are not .as
  cost-effective and permanent as Alternative 3, they were rejected.

       Alternatives 6 and 7, onsite and offsite incineration, were not selected
  because they are not as cost-effective as the selected alternative.  Incineration
  will only destroy the organic compounds of the sludge and will not affect
  the metals, so proper handling of the residua> metal containing ash would be
  required.  Onsite incineration will take at least 3 to 4 years to complete
  and offsite will take at least 7 years, if there is sufficient capacity.
  This is much longer than the one year anticipated for the selected alternative.
  Onsite incineration will also cause concern in the community because of the
  potential for air emissions during combustion.  Additionally, the costs are
 :aa order of magnitude greater than the selected alternative and incineration
  does not provide substantially greater benefits.

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                      FINAL RESPONSIVENESS SUMMARY

                             BRUIN LAGOON  SITE

                      BRUIN  BOROUGH, PENNSYLVANIA
    From August 8, 1986 through August 29, 1986, the U.S.  Environmental
Protection Agency (EPA) held a public comment period on the draft remedial
investigation and feasibility study (RI/FS) report for the Bruin Lagoon site
located in Bruin Borough, Butler County, Pennsylvania.  The purpose of this
document is-to summarize comments on the RI/FS report expressed by residents,
local officials, and other interested parties during the'public comment period
and to provide EPA responses to those comments.

    This responsiveness summary is divided into the following sections-.

         Section I      Overview of Technical Activities.   This
                        section provides a brief site history and
                        discusses EPA-'s preferred alternative for
                        remedial action.

         Section II     Background on Community Involvement and
                        Concerns.  Tnis section provides a brief
                        history of community interest and concerns
                        raised during remedial planning activities
                        at the Bruin Lagoon site.

         Section III    Summary of Major Comments and EPA
                        Responses.  All comments are categorized by
                        relevant topics.  EPA responses to thess
                        comments are also provided.

         Section IV     Unanswered Concerns.   This section
                        describes remaining community concerns thae* •«•
                        EPA and the Pennsylvania Department of
                        Environmental Resources (PADER) should be
                        aware of and attempt to address during the
                        remedial design and remedial action at the
                        Bruin Lagoon site.
                                            *
In addition to tha sections above, Attachment A, included as part of this
responsiveness summary, identifies community relations activities conducted by
EPA during remedial response activities at the Bruin Lagoon site.
-.1-:, OVERVIEW OF TECHNICAL ACTIVITIES

    The Bruin Lagoon site is located in Bruin Borough, Pennsylvania,
approximately forty-five miles north of Pittsburgh.  The site covers over four
acres and consists of an unlined, earthen-diked, and covered lagoon.
Operations began at Bruin Lagoon in the 1930s and continued for over 40

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                                   -2-


years.  The site was used as a disposal area for wastes generated by a
petroleum refine.ry located adjacent to the southern side of the site.  Both
Bruin Lagoon and the refinery are owned by the AH&RS Coal Company, which is
currently involved in bankruptcy proceedings.

    Contractors to EPA began the RI/FS a^ Bruin Lagoon in June 1981.
Following release of the- RI/FS report in January 1982, EPA and PADER decided
to implement a waste containment alternative at Bruin Lagoon.   This
alternative was selected to stabilize the sludge in the lagoon, reinforce the
dike, remove debris from the site area, and cover the lagoon with' a
multi-layer cap.  Design of the selected remedial action began in September
1982 and remedial construction began in September 1983.

    Construction activities continued at the site until May 4, 1984 when a
previously unidentified crust layer was broken resulting in a release of gas
and mist.  Following the gaseous release, contractors collected samples of gas
and liquid beneath the crust layer.  Analytic results showed that the 333
contained high concentrations of carbon dioxide, hydrogen sulfide, and
sulfuric acid mist.  Based on these findings, EPA suspended the cleanup
activity and began an immediate removal action to prevent further release of
the toxic gas.  In addition, EPA's emergency contractor covered the open
lagoon with stabilized sludge, installed gas monitoring wells, and collected
sludge and soil samples for further analysis.  Emergency work at the site was
completed in September 1984.

    In January 1985,  EPA announced that a second RI/FS would be conducted at
Bruin Lagoon to reevaluate the nature and extent of contamination at the
site.  Field activities associated with the second RI/FS began in June and
continued through October 1985.

    On July 24, 1986, EPA released the draft RI/FS report to the public.  In
the report, seven alternatives to clean up hazardous waste contamination at
the Bruin Lagoon site were discussed.   After careful review and consideration
of those alternatives, EPA and PADER selected Opttion 3 as the preferred
alternative for implementation at Bruin Lagoon..  Specifically this option
calls for:

         •    On-site stabilization/neutralization of remaining
              sludge and perched liquid zone.  Gas monitoring and
              venting or treating would be conducted during
              excavation activities.
                                           f
         •    Shallow bedrock neutralization using a lime slurry
              injection.

         •    Installation of a multi-layer cap over the former
              lagoon.

         •    Complete dike embankment reinforcement/stabilization.

         •    Post-closure monitoring and maintenance, including
              periodic sampling of monitoring wells up-gradient and
              down-gradient of the site.

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                                   -3-


II.   BACKGROUND ON  COMMUNITY  INVOLVEMENT AND  CONCERNS

    Although residents  living near Bruin Lagoou have  been aware of the site's
existence since disposal of petroleum refining wastes began in the 1930s,
vocal community concern about Bruin Lagoon dates back to  1981 when the site
was proposed for inclusion on the. Superfund Interim Priorities List.   The
interest and involvement of residents and Borough officials has focused
primarily on EPA field activities at the site and has increased whenever
additional field activities have been proposed and conducted at the site.
Major concerns expressed since 1981 during the remedial planning activities at
the Bruin Lagoon sice are described briefly below.
            "•^.^
         Use of" Super-fund monies to clean up the Bruin  Lagoon
         site.  Many residents and local officials believed  chat
         Bruin Lagoon is not hazardous to the health  of local
         residents and that Federal funds should not  be used co
         clean up the site.  Local officials emphasized that the
         community needs money for sewers and a public water supply
         rather than for the cleanup of hazardous wastes  in the
         lagoon.

         Health effects.  Seve-ral families who lived near the
         site were concerned about the release of toxic gas from the
         lagoon during the 1984 remedial construction activities.

         Impact from drilling activity on existing  residential
         wells.   Local  officials  and  residents worried that
         drilling activity might contaminate a drinking water supply
         aquifer or  residential wells located near the site.

         Property  values.  Residents  living near  Bruin Lagoon
         feared that the second.RI/FS would depress residential
         property values in the area.

         Economic  development.   Local officials and  residents
         expressed fear that remedial activities at the site would* '-
         contribute  to increasing economic depression and
         unemployment in northern Butler County.


ML   SUMMARY OF MAJOR COMMENTS AND EPA RESPONSES
                                           »
    EPA held a public comment period on the Bruin Lagoon  draft RI/FS report
from August 3, 1986  to August 29, 1986.  A public meeting was held at the
Bruin Borough Fire Hall on August 21, 1986 at 7:00 pra. Those attending the
meeting included . epresentatives from EPA, the Pennsylvania House of
Representatives, a  local Congressional office, area press, and approximately
30 community members.  During the meeting, EPA staff gave an overview of the
Superfund program and discussed the history of the site,  the scope and
findings of the RI/FS,  the proposed remedial alternatives, and EPA's preferred
remedial alternative.  Following this presentation, EPA opened the floor to
all those present.   Questions, comments, and concerns received during the
meeting are summarized below and are categorized by relevant topics.  Each

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                                    •4-
 comment  is  followed  by  EPA's  response.   Oral  comments  received during  the
 p-iblic meeting were  the only  comments  received throughout  the  public comment
 period.

     Project Cost

     Question:  A  resident  asked  how much money EPA  has  spent to date on  che
     Bruin Lagoon  site.

     Response:  EPA stated  that approximately  $3 to  $5  million  has  been spent
     to date on the Bruin Lagoon  site.  These  costs  include initial  site
     sampling and  contractor studies; che RI/FS;  the RI/FS  report;  initiation
     of construction  activities;  an emergency  removal;  a second RI/FS;  and  a
     second RI/FS  report.

     Site Contamination

     Question;  Several  residents  asked about  gas  that  was  released from  the
     site prior to the 1984 emergency action.   Specifically, the residents
     asked what the gas  was composed of,  what  effect it  could have,  and whether
     or not the gas was  considered dangerous.

     Response:  EPA said analytic  results showed that the gas contained
     hydrogen sulfide, sulfur  dioxide,  and methane.   High concentrations  of
     these compounds  could  potentially  be lethal.  However,  the concentrations
     of these compounds  found  leaving the site were  not  chat high.

     Question:  A  resident  asked why EPA  was concerned  with protecting  ground
   'water from further  contamination.

     Response: . EPA responded  that sampling has shown that  the  site  is  not
     affecting residential  wells.  If drilling were  to  take place on site or
     just below the site, however, the water produced from  the  well  could pose
     a health risk.

     Preferred Remedial  Alternative                                * '~

     Question:  A  resident  asked  if EPA's preferred  alternative was  the same
     as the remedy selected from the initial RI/FS report in"1982.

     Response;  EPA stated  that the stabilization  technique is  the  same in
     both the preferred  remedial alternative*outlined in the July 1986  RI/FS
     report and the initial remedy selected for the  Bruin Lagoon site by  EPA in
     1982.  Since  the initial  RI/FS was completed, however,  additional  studies
     have provided EPA with more detailed information about site
     characteristics  that will ultimately make the remedy more  effective.   For
     example, because more  is  known about the  gases  discovered  on site, EPA
•':    will be able  to  monitor them  more  efficiently.   Also,  as a result  of
     recent subsurface investigations,  the bedrock will  be  treated  with a lime
     slurry.

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                                    -3-
     Quescion:   Several residents asked questions  about the cap recommended
     for the site including what it  will be constructed of, where it  will  be
     placed, and how it will work.

     Response:   EPA replied that capping techniques  are designed to reduce the
     infiltration of precipitation through^waste materials  and the subsequent
     potential  for contaminants  to leach through those same materials.   The
     reduction  of infiltration can ba  achieved through capping with impervious
     materials  or surface-sealing techniques.   The cap recommended as part of
     Option 3 would be placed over the entire  site area and would be  composed
     of a multi-layered cover system.   The  actual  composition  of that cap  will
     be decided during the remedial  design  phase of  this project.

     Question:   A resident asked if  a  total clean  up will be done of  the
     contamination found at the  Bruin  Lagoon site.

     Response:   EPA stated that  in order to remove 100% of  the contamir^.Cion
     found on site, excavation and off-site disposal of some contaminated
     materials  would be necessary.   Although Option  3 does  not include
     .excavation and off-site disposal  as part  of the remedy, EPA believes
     Option 3 will meet the Superfund  goals of minimizing present and future
     migration  of hazardous substances and  protecting human health and the
     environment, while complying with all  applicable and relevant Federal
     public health and environmental standards, guidances,  and advisories.

     Question:   A resident asked if, as part of the  remedial action,  lime  were
     used to neutralize the bedrock, whether che lime would react with the
     sulfuric acid present on site to  create more  gases.

     Response:   EPA stated that  while  it is possible for a  chemical reaction
     to occur when neutralizing 'contaminants,  the  gases potentially generated
     from such  a reaction would not  be the  same as the gases that were released
     from the site in 1984.  Nonetheless, EPA  added, it will be important  for
     field staff to proceed carefully  during the construction  of the  remedial
     action.
                                                                  * '•»

 IV.  UNANSWERED  CONCERNS

     Although EPA' representatives responded to many questions  and concerns
 during the public meeting on the RI/FS report, the  following  issues  remain
 unanswered:                                '  .

     Odor

     Question:   Many residents described to EPA an odor they claim  is
     emanating  from the vicinity of the site.   These residents said that the
•-'•"'  odor is sometimes strong enough to wake them  up at night, and has caused
     headaches  and feelings of nausea.  In  addition, residents reported that-
     the odor is worse some times than at others,  is smelled only within Bruin
     Borough, and had been present for approximately six weeks prior-to the
     public meeting.  These residents  asked EPA what the odor  is and  where it
     is coming from.

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                               •6-
Response:  EPA replied that site sampling had been completed in February
1986 and, at that time, EPA Was unaware of any odor coming from the site.

Question:  A resident asked that EPA investigate the odor and find out
where -it is coming from.

Response;  EPA responded that the Agency does not have the authority to
conduct an investigation.  State and local laws govern the regulation of
nuisance odors.

Question:  A resident asked if the odors could be generated by tanks
located on the refinery property adjacent to Bruin Lagoon.

Response:  EPA stated that a site investigation has been conducted at the
abandoned refinery next to the Bruin Lagoon site.  Whether odors could be
emanating from the refinery or not will have to be investigated.  EPA will
refer residents.'  concerns to PADER.

Question;  A resident asked how EPA could determine whether or not the
remedial action is effective if EPA does not investigate odors coming from
the site.

Response;  EPA replied that they do not believe odors are coming from the
site.  However, if Option 3 is selected as the remedial action, on-site
stabilization may address the odor problem.  EPA reminded residents that
the Agency does not have the authority to investigate nuisance odors, but
added they would relay all the community's questions and concerns co PADER.

Superfund reauthorization

Question:  A resident asked what will happen to the Bruin Lagoon site if
Superfund is not reauthorized.

Response:  EPA responded that Bruin Lagoon will remain ,in its present
state until Federal funds become available.  EPA said, however, that, if
necessary, emergency activity would be funded.                * ~

Question:  Several residents asked if Bruin Lagoon is currently
stabilized, when it will become unstabilized, and what kind of monitoring
would take place at the site in the period before Superfund is
reauthorized.
                                       »
Response;  EPA reported that the site is stabilized for the short term,
but not for the long term.  In addition, EPA responded that it is
difficult to determine when the site will become unstabilized.  EPA said
that any monitoring done prior to reauthorization will have to be
negotiated with PADER.

Question;  A resident asked if the erosion occurring under the fence
located around the site will be addressed even if Superfund is not
reauthorized.

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                                -7-
S^^^l^^^/^ ™« b. needed co address soi


that if Superfund is noc ^authorized, ano her nublv"'  "" alSO added

in Bruin Borough so that residents are ^are of'any chan^"8 WiU '? he
or developments.                                  y c»ange in site plans

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                                ATTACHMENT A

                  COMMUNITY RELATIONS ACTIVITIES  CONDUCTED

                          AT  THE BRUIN  LAGOON SITE
    The following list includes  community  relations activities conducted to
date by EPA at the Bruin Lagoon  site.
       DATE
              ACTIVITY
    August 1Q36
    August 1986
    August 1986
    March 1986

    May 1985


    September 1982

    July 1982


    February 1982



    June 1981
Held a three-week public comment period to
allow interested citizens the. opportunity to
comment on the draft RI/FS report.

Prepared and released a fact sheet  that
outlined EPA's preferred remedial
alternative.

Conducted a public meeting to announce the
selection of a preferred remedial
alternative and received comments from the
public.

Revised the community relations plan.

Conducted a public meeting to discuss  the
work plan for the second RI/FS.

Prepared the community relations plan.

Conducted a public meeting to announce the
selection of a remedial alternative.

Held a public meeting to present the
proposed alternatives for the remedial
action.
         f
Held a public meeting to discuss the
proposed RI/FS.

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PENNSYLVANIA
                                   COMMONWEALTH  OF PENNSYLVANIA
                                DEPARTMENT OF ENVIRONMENTAL RESOURCES
                                             Post Office Sox 2063
                                          Harrisburg, Pennsylvania 17120

                                              September 19, 1986
                                                                             717-787-9871
Bureau of Waste Management
   Mr. Thomas Voltaggio'
   Chief, Superfund Branch
   U. S. Environmental Protection Agency
   Region III
   8*1 Chestnut Building
   9th and Chestnut Streets
   Philadelphia, PA  19107

   Dear Mr. Voltaggio:

              The draft Record of Decision for the selection of the alternative for the remediation
   of the  Bruin Lagoon site has been reviewed by DER staff members. The only revision of the ROD
   that would be necessary  is the Operation and Maintenance (Page 16).  The State responsibility for
   O&M would begin one year after the Remedial Construction is completed.

              We concur with your assessment of the proposed alternatives and with the selection <
   the final remediation measures. The selected remedial alternative is stabilization of sludge and
   liquid zone with a multilayer cap, dike reinforcement, shallow bedrock treatment, and post-
   closure monitoring. We  can then ensure that, the selected remedial alternative will adequately
   protect the public health and the environment of the Commonwealth.

              If you have any questions concerning this matter, do not hesitate to contact Donald
   Becker or Randy Roush at 717-783-7816.

                                                  Sincerely,
                                                  James P. Snyder, Assistant Director

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