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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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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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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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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° 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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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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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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•- 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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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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