United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-88/056
September 1988
4>EPA Supe
Dorney Road, PA
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;0~.7.2 1101. -~. _..~
R~~OocUMENTATION~I"l.-REPORT NO.
PAGE EPA/ROD/R03-88/056
, 2.
I 3. Recipient's Accession No.
s.. Report O.te
09/29/88
4. Title .nd Subtitle
SUPERFUND RECORD OF DECISION
Dorney Road LandfilL, PA
First Remedial Action
6.
7. Author(s)
8. Performing Organization Reot. NO.~!
10. Project/Task/Work Unit No. i
9. Performing 0rs.nization N.me and Address
11. ContracHC) or Grant(G) No.
(C)
(G)
--. ----~._----- '--'
J2. Sponsor;n, Org.nization Nam. and Address
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type 0' Report & Period Covered.
Agency
800/000
14.
15. Supplementary Notes
J6.. Abstr.et (Limit: 200 words)
The Dorney Road Landfill site is located in Lehigh county, pennsylvania. The. site is
approximately 27 acres, bounded on the east by Dorney Road, and extends westward such
that the $outhwest corner is in Longswamp TOWnshipr Berks county. Land use in the area
is rural, residential and agricultural. The population within an 0.25 mile radius of
the site is estimated to be approximately 20 people. currently, 1 residence is .located
within 1,000 feet of the site and 3 residences are within 2,000 feet of the site. The
water supply for these nearby homes is ground water from private wells. The majority of
the site is presently owned by R. Emory Mabry. Beginning in 1952, an abandoned iron
mine pit on the site was used as an open dump. From 1966 to 1978, an unpermitted
landfill was operated in the same mine pit. In 1986, EPA conducted a removal action and
regraded the landfill to prevent runoff and erosion of landfill material from migr.ating
to neighboring property. In 1980 and 1982, EPA investigations reve31ed elevated levels
of VOCs, metals and phenols in ground water and leachate samples. This remedial action
will prevent dermal contact and incidental ingestion of landfill soil and solid waste.
It will also minimize the continued leaching of precipitation and onsite ponded waters
through the contaminated landfill. A subsequent remedial action will address the ground
water under the site. The primary contaminants of concern affecting the soil, ground
(See Attached Sheet)
i
I
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I
17Rg~~p"~nt~'lrt~Sc ia$ P~1frlPtors
Dorney Road Landfill, PA
First Remedial Action
contaminated Media: gw, sw, soil
Key Contaminants: metals (arsenic, chromium),
b. Identifiers/Open. Ended Terms toluene, xylenes)
organics (PAHs, phenol), vOcs (benzene,
. .
c. COSATI Field/Group
lL "'"ail.bllity St.tement
19. Security Class (This' Report)
None
21. No. 0' Pages
54
----- --
I
20. Security Clns (This Page)
None
22. Price
(S.. ANSI-Z39.18)
See Instructions on R.v.rse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Oepartm.nt 0' Commerce
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EPA/ROD/R03-88/056
Dorney Road Landfill, PA
First Remedial Action
16.
ABSTRACT (continued)
water and surface water are VOCs including benzene, toluene and xylenes, metals
including arsenic and chromium, and other organics including phenol and PARs.
The selected remedial action for this site includes: offsite disposal of
approximately 700,000 gallons of onsite pond water; construction of a dike and-diversion
ditch system to control runon/runoff; regrading and installation of a multi-layer
landfill cap and a gas collection system; ground water monitoring; and deed and acces~
restrictions. The estimated present worth cost for this remedial action is $14,000,000
with estimated annual O&M costs of $42,000.
"'. ~
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The station of record is the Allentown - Bethlehem - Easton Air-
port, approximately eight miles to the northeast, which has a
historical record length of 50 years. Approximately 60% of the
average annual precipitation of 42.9 inches per year is lost to
evapotranspiration and 40% is available for surface water runoff
and ground water recharge. Prevailing winds are from the west~
northwest.
Site History
The m~jority of the site is currently owned by R. Emory Mabry of
Mertztown, Pennsylvania. A portion of the westernmost protrusion formerly
owned by the Mertz Estate is currently owned "by Robert Tercha. Beginning
in 1952, an abandoned iron mine pit was used as an open dump by Mr. Mabry.
Prior to 1966, Harold E. Oswald began operating a landfill a~ the site in
the same mine pit. In a letter dated January 8, 1970, the Pennsylvania
State Health Center notified Mr. Oswald that the operations of the site
as a landfill constituted a public health threat and required him to
compact the fill and apply cover to the site. A follow-up letter on
March 9, 1970, indicated that Mr. Oswald had' not complied with this
directive.
Mr. Oswald initiated a permit application for'operation
of the landfill, but that permit was never completed by Mr Oswald nor
approved by the Pennsylvania Department of Environmental Resources
(PADER). Although the application was never approved, landfill
operations continued until December 30, 1978. Proper landfill closure
procedures as required by PADER regulations (i.e. grading, reseeding)
were never implemented at the Dorney Road site.
On September 2g, 1979, Mr. Edward Reeser of Whitehall, PA.,
applied for a landfill permit to renew disposal operations at
the site. However, the permit was not granted by PADER.
On May 21, 1980, approximately two years after the landfill
ceased operations, EPA performed a Preliminary Assessment of the
site. Ground water and leachate samples were taken. Organic
contaminants detected in the samples included petroleum hydrocarbons
halogenated hydrocarbons. Inorganic contaminants detected include
arsenic, cadmium, chromium and lead.
On December 8, 1982, PADER representatives coliected water
and ground water samples at the site. High levels of lead and
phenol were detected in the surface water and ground water,
respectively.
As a result of previous' site history and a site inspection
performed during the winter/spring of 1983, the Dorney Road
Landfill was proposed for the ~atiopal Priorities List (NPL)
in September of 1983 and promulgated a year later (September
1984 ) .
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-6-
Since the site was not properly graded or reseeded upon
the completion of landfill operations, no surface drainage control
existed during periods of precipitation. Ponding of rainwater
over the landfill area occurred which resulted in the formation
of gullies due to subsequent erosion. Chronic off-site surface
. drainage to the south of the landfill was observed during rainy
seasons. Corn plants in this area have shown signs of stress
(i.e., yellow, withering).
Responding to a May 1986 removal request by PADER for the
Dorney Road site, the Environmental Response Cleanup Service (ERCS),
an EPA contractor, covered leachate breaks, regraded and seeded the
site, and installed earthen berms to control surface leachate
migration. In addition, obvious areas of access were fenced.
Current Site Status
A Remedial Investigation (RI) was performed at the Dorney
Road Landfill site from the Fall of 1987 through the Spring of
1988. The RI consisted of several activities: surface investi-
gation, geological characteriza~ion and hydrogeological study.
Data from these activities were used as the basis for assessing
the nature and extent of site-reiated contamination and associ-
ated risks to the public health and the environment.
Soils
On-site surficial soil samples were collected at 100-foot
intervals along established survey lines. Off-site surficial
soil samples were collected at 100-foot intervals along a line
50 feet from ,the site boundary on the north, west and south,
and at 200-foot intervals along a line 100 feet from the west
and south edges of the site. One background surface soil sample
was collected approximately 900 feet west of the site. In addition,
five on-site samples were collected at locations identified as
potentially being contaminated. These locations included areas of
broken batteries and leachate seeps. The soil samples collected
were. field screened fo~ the presence of Volatile Organic Compounds
(VOCs) using a photoionization detector. Screened samples were
analyzed for volatile/semi-volatile organic compounds and inorganic
chemical parameters. Contaminants identified in subsurface soils
and their maximum concentrations encountered are listed in Table 1.
Contaminants listed ~re only those whi~h were selected as "indicator
chemicals" in the RI Public Health Evalua~ion. Indicator chemicals
are defined as chemical contaminants which are most likely to pose a
threat to public health or the environment at a given site.
. Selection criteria fo'r the determination of "indicator chemicals" is
presented in the. Public Health Evaluation section of the RI.
Geophysical
- .
The geological characterization involved literature research
as well as field studies. The literature search consisted of
reviewing references and availa~le maps. The field studies
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CORN FIELDS
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SCALE IN FEET
A"M)XIMATE
Figure 2
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I - --~- -
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The "land use of the area surrounding the site is essentially
rural residential and agricultural. The local area is zoned for
agricultural use and the site is completely surrounded by cultivated
farmland. The principal crops are soybean and corn for dairy
and beef cattle "feed.
The population of Lehigh County in 1980 was approximately
272,000, with a population projection of approximately 288,000 by
1990. The population of Upper Macungie Township in Lehigh County
in 1980 was approximately 7,500, with a population projection of
8,800 by 1990. The population within a quarter mile radius of the
site is estimated to be approximately 20 people. At present, only
one residence is located within-1,OOO feet of the site and three
other residences are within 2,000 feet of the site. The water supply
for residents of these nearby homes is ground water from private wells.
The source of drinking water and water used for other beneficial uses
(i.e., agricultural) is dependent upon ground water resources, therefore
ground water in this area is classified as a Class IIA aquifer.
The Dorney Road Site lies within the Great Valley Physiographic
Province area which is located in Lehigh and Berks Counties,
Pennsylvania. Based on available literature, two water supply aquifers
are present in this area. The primary productive zone is a deep
aquifer associated with highly weathered, highly fracturea bedrock.
The second aquifer is the less extensive overburden aquifer which is
associated with the intergranular porosity within the thick residual
soils. Regionally, ground water flows east towards the Little Lehigh
River~ Well records obtained from homeowners during this investi-
gation indicated that the depth of the interval of the aquifer uti-
lized for domestic use var~es between 100 and 200 feet. This is
well within the productive zone of the deep bedrock aquifer.
The surficial geology for the Dorney Road Landfill Site is
comprised primarily of the Washington silt-loam. The Washington
silt-loam is a residual soil which results from the weathering of
the underlying bedrock.
Soil thickness varies greatly across the site. Changes in soil
thickness can be drastic and abrupt. While bedrock is surficially
exposed approximately 200 feet west of the site, during RI drilling
activities, bedrock was encountered at 70 feet. Fractured bedrock
appears to be extensive throughout the study area.
Wildlife on-site and in the surrounding areas is quite varied due
to the rural setting of open land and woodland environments. Ringneck
pheasant, white-tailed deer, cottontail rabbits, ducks, Canada geese,
smaller bird varieties and small rodents are example~:of the most
populous wildlife species observed in the area and on the landfill
site.
Maximum and average precipitation for 'the area is 67.7 inches per
year and 42.9 inches per year, respectively. The period of maximum
monthly precipitation was August, 1955 with 12.10 inches and the period
of minimum monthly precipitation occurred in May of 1964 with 0.09 inches.
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Dorney Road Landfill Superfund Site
Upper Macungie Township, Lehigh County, Pennsylvania
Landfill Waste and Soil Operable Unit
Statement of Purpose
This decision document represents the selected remedial action
for this site developed in accordance with the Comprehensive Environ-
mental Response, Compensation, and Liability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), and to the extent practicable, the National Contingency Plan
(NCP).
Statement of Basis
This decision is based upon the administrative record (index
attached). The attached index identifies the items which comprise
the administrative record upon which the selection of a remedial
action is based.
The Commonwealth of Pennsylvania concurs with the selected remedy.
A copy of the concurrence letter is attached.
Description of the Selected Remedy
This initial operable unit was developed to protect public health
and the environment by preventing dermal contact and incidental
ingestion of landfill soil and solid waste. It will also minimize the
continued leaching of precipitation and on-site ponded waters through
the contaminated landfill media, thereby isolating the source of ground
water contamination. A subsequent operable unit addressing the ground
water under the site is forthcoming.
The selected site remedy is protective of human health and the
environment, will attain the applicable or relevant and appropriate
requirements of other Federal and State environmental laws, and is
cost-effective.
The major components of the selected remedy are as follows:
* Elimination of On-site Ponded Waters.
* Regrading
* Pennsylvania-Type Multi-Layer Cap
* Runon/Runoff Controls
* Runoff Monitoring
* Ground Water Monitoring
* Perimeter Fence
* Deed Notice
~ . - -
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Declaration
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are appli-
cable or relevant and appropriate to the remedial action, and is
cost-effective. This remedy utilizes permanent solutions and
alternative treatment (or resource recovery) technologies to the
maximum extent practicable for this site. Because treatment of
the principal threats of the site was not found to be practicable
or within the limited scope of this action, this remedy does not
satisfy the statutory preference for treatment as a principal
element of the remedy.
Because this remedy will result in hazardous substances re-
maining on-site above health-based levels, a review will be con-
ducted within five years after commencement of remedial action to
ensure that the remedy continues to provide adequate protection of
human health and the environment.
9'-?,-B'6
Date
--~~'
~y L. skowski
- Acting Regional Administrator
Region III
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Site Description and Summary of
Remedial Alternative Selection for the
Dorney Road Landfill Site
- Landfill Waste and Soil Operable Unit-
Introduction
The Superfund investigation of the Dorney Road Landfill, also
known as Oswalds Landfill, focuses on two problem areas: first, dermal
contact and incidental ingestion of landfill soil and solid waste which
contains numerous semi-volatile/volatile organic compounds and inorganic
contaminantsj and second, the ingestion, inhalation and dermal contact
of ground water, which has become contaminated with many of the same
chemical contaminants.
The investigation and the selected remedy for the landfill proper
is the subject that will be discussed herein. This Record of Decision
(ROD) will summarize the results of a Superfund Remedial Investigation/
Feasibility Study (RI/FS) that focused on the contamination at the
Dorney Road Landfill site and will present the chosen remedial action for
the landfill. The remaining problem area (i.e., ground water) is being
studied extensively at this time and will be addressed in a subsequent
FS and Record of Decision (ROD). .
Site Location and Description
The Dorney Road Landfill Site is located along the southwest boundary
of Upper Macungie Township in Lehigh County, ~ennsylvania, approximately
eight miles southwest of Allentown. The site is located on the United
States Geological Survey (USGS) 7.5 minute topographic map, Topton,
Pennsylvania Q.1adrang"1e. The site lies one mile southwest of Breinigsville
and 1.4 miles north-northwest of Mertztown. The site location is shown on
Figure 1. The site is composed of approximately 27 acres which is bounded
to the east by Dorney Road and extends westward such that the southwest
corner of the site is in Longswamp Township, Berks County.
Most of the Dorney Road site consists of an abandoned landfill sur- .
rounded by a soil berm. -Prior to 1966, the site was an open dump with
waste disposed in an abandoned iron mine pit. From 1966 to 1978 an
unpermitted landfill was operated in the same abandoned mine pit. Due to
the nature of wastes present at the Dorney Road Landfill, vegetation is
sparse within several areas of the landfill. Sparse vegetation growth can
also be attributed to a June 1986 EPA Removal Action, when the landfill was
regraded to prevent runoff and erosion of landfill material from migrating
to neighboring agricultural lands. Several ponds remained on site following
the June 1986 EPA surface re~ading effort. Discharge from the southern
most on-site pond is directed to the southeast corner of the site and then
off-site to the south via a rip rap channel. Ground surface elevations range
from approximately 430 feet above mean sea level (MSL) to 470 ft. MSL. The
general layout of the site and surrounding area is shown on Figure 2.
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-7-
Table 1
Surficial Soil Samples
Semi - Volatile Organics
Chemical
phenol
1,4-dichlorobenzene
4-methylphenol
di-n-butylphthalate
bis(2-ethylhexyl)phthalate
dieldrin
PCB (1254)1
PAHs (carcinogenic)2
Chemical
chlorobenzene
benzene
chloroform
ethylbenzene
toluene
4-methyl-2-pentanone
xylenes (total)
tetrachloroethene
Note
Maximum Concentration (ppb)
On-site
410
960 *
3400
2000
20000 *
88
650
6126 *
Volatile Organics
Off-site
BDL
BDL
BDL
BDL
BDL
47
BDL
BDL
Maximum" Conc~ntration (ppb)
On-site
6 *
1 *
72
82
770 *
47 *
190 *
1 *
-r:.;
* - Estimated Value
BDL - Below D~tection Limit
1 - Polychlorinated Biphenyls
2 - Polyaromatic Hydrocarbons
Off-site
8
BDL
4 *
BDL
BDL
BDL
BDL
BDL
Background
Concentration
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
Background
Concentration
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
- "
(Type Bl - probable carcinogenic)
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Table'1 (continued)
Inorganics
Maximum Concentrations (ppm)
Chemical
On-site
arsenic
beryllium
cadmium
copper
lead
mercury
nickel
thallium
chromium
zinc
barium
manganese
16 *
6.3 *
2.1
216
96000
0.23 *
3580 *
3.7
1580 *
472
164 *
2830
NOTE
* - Estimated Value
BDL - Below Detection Limit
-~. :
Off-site
15 *
4.8
2.8
46
248 *
0.15
199 *
2.4 *
109 '*
217
213 *
5070
Background
Concentration (ppm)
2.5
2.1
BDL
15 .'
25
BDL
39 .
0.7
16
117
81 .
2770
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included a seismic refraction survey, horehole geophysical survey,
construction of monitoring wells, and the study of air photos
in the preparation of a fracture trace analysis. The geologic
investigation was performed to gain an understanding of suh-
surface conditions as they may influence contaminant migration.
This was achieved hy ohtaining split-spoon samples of suhsurface
soil at various depths during the installation of on-site and
off-site monitoring wells.
Samples from the horings were analyzed for EPA Target Compound
List (TCL) compounds. Various volatile/semi-volatile organic
compounds and inorganic contaminants were detected on the site and
the immediate vicinity. Contam~nants identified in suhsurface
~oils and their maximum concentrations encountered are listed in
Tahle 2. Again, only those contaminants which were selected as an
, "indicator chemical" are presented.
Ground Water/On-site Ponded Water
The fracture trace analysis of the site and the surrounding
area revealed that the site is intercepted hy several lineaments
~hat strike approximately east/southeast near the southern hound-
ary of the site. The resultant impact on ground water movement
in this, type of geology to some degree is unpredictahle in relation
to'ground water flow patterns.
The hydrogeological study performed during the RI was supple-
mented hy the geologic investigation. The locations of the monitoring
wells were selected based on the results of the geophysical
investigation and the fracture trace analysis. The wells were
placed near the perimeter of the landfill and at upgradient and
downgradient locations in the overhurden and deep aquifers.
, Samples of the ground water were ohtained from these wells on
two separate occasions during the RI (i.e., May 1988 and June 1988),
as well as from residential wells in the area, for analysis of TCL
compounds and other water quality indicators. Samples from the'
on-site ponded waters were also obtained and analyzed for the same
chemical parameters a~d water quality indicators.
Numerous volatile/semi-volatile organic compounds and inorganic
contaminants were detected in ground water ~amples collected from hoth
monitoring and residential wells in and around the Dorney Road
Landfill site. In addition, on-site ponded water samples collected also
detected several volatile organic compounds and inorganic contaminants.
Contaminants identified in the ground water and their maximum
concentrations encountered in monitoring wells are listed in Tahle 3.
Contaminants identified in residential wells and those identified
in on-site ponded water samples are listed in Tahles 4 and 5, respectively.
As in Tahles 1 and 2, on~y those contaminants which were selected as
"indicator chemicals" are presented.
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Table 2
Subsurface Soil Samples
Semi-Volatile Organics
Maximum Concentration (ppb)
On-site
(natural)1
Off-site
(shallow)
Chemical
bis(2-ethylhexyl)phthalate
1,4-dichlorobenzene
di-n-butylphthalate
phenol
4-methylphenol
dieldrin
PARs (carcinogenic)
2400 *
69 *
250 *
170 *
350 *
BDL
124 *
1200
BDL
230 *
BDL
BDL
140 *
84 80 *
Volatile Organics
Maximum Concentration (ppb)
Chemical.
On-si te
(natural) 1
Off-site
(shallow)
benzene
chlorobenzene
chloroform
1,"" -dichloroethane
et. :'lbenzene
te~=achloroethene
trichloroethene
styrene
4-methyl-2-pentanone
xylenes (total)
1,2-dichloroethene (total)
toluene
2 *
2 *
7 *
7 *
96
4 *
2 *
3 *
110
290
5 *
BDL
BDL
- 4 *
4 *
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
33
Note
* - Estimated Value
BDL - Below Detection Limit
1 - Underlying soil layer beneath landfill waste material
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Table 2 (continued)
Inorganics
Maximum Concentration (ppm)
Chemical
On-site
(natural)1
arsenic
beryllium
cadmium
copper
lead
mercury
nickel
thallium
zinc
chromium
barium
6.9
33
4.6
26
200 *
0.16 *
171
3.1
- 466 *
" BDL
BDL
Note
Off-site
(shallow)
23 *
2.6
1.4
-38
446 *
0.19
61
3.2
279
37
101
* - Estimated Value
BDL - Below Detection Limit
1 - Underlying soil layer beneath landfill waste material
- .
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Tahle 3
Monitoring Well Samples
Semi-Volatile Organics
Maximum Concentration (pph)
Chemical
On-site
Off-site
MCL (l )
his(2-ethylhexyl)phthalate.
1,4-dichlorohenzene
diethylphthalate
phenol
4-methylphenol
50
32 *
20
3200 "*
2000 *
33
2 *
BDL
25
23
Volatile Organics
Maximum Concentration (pph)
Chemical
On-site
Off-site
MCL ( 1)
henzene
chlorohenzene
ethylhenzene
toluene
vinyl chloride
styrene
4-methyl-2-pentanone
xylenes (total)
1,2-dichloroethene (total)
1,1-dichloroethane
tetrachloroethene
.l,l,l-trichloroethane
trichloroethene
14
40 *
160
740
25
43 *
490 *
530 *
79 *
BDL
BDL
BDL
BDL
6
BDL
BDL
43
14
BDL
BDL
BDL
180
22
37
2 *
51
5
2
-
2
5
Note
* - Estimated Value
BDL - Below Detection Limit
(1) - MCL -(Maximum Contaminant Level): This is the maximum concentration
allowed under the Safe Drinking Water Act (SDWA).
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Table 3 (continued)
Inorganics (Total)
Maximum Concentration (ppb)
Chemicals
On-site
cadmium
arsenic
chromium
copper
lead
nickel
thallium
19
140
72
218
'11900
3540
18 *
37700
3480
420000
22
0.64
zinc
barium
manganese
beryllium
mercury
Note
MCL (1 )
Off-site
25 *
8.9 *
30 *
127
619 *
800 *
54 *
1470 *
1880 *
29200 *
59 *
2.2
10
50
50
50
1000
2
(1) - MCL (Maximum Contaminant Level): This is the maximum concentration
. allowed under the Safe Drinking Water Act (SDWA).
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~~4....
Table 4
Residential Well Samples
Semi - Volatile Organics
Chemical Maximum Concentration (ppb) MCL (1 )
bis(2-ethylhexyl)phthalate 2
Volatile Organics
Chemical Maximum Concentration (ppb) MCL (1 )
l,l-dichloroethane 2
tetrachloroethene 6
trichloroethene 9 5
1,2-dichloroethene (total) 22
Inorgani~s
Chemical Maximum Concentration (ppb) MCL ( 1)
zinc 448
barium 32 1000
manganese 83
Note
(1) - MCL (Maximum Contaminant Level): This is the maximum concentration
allowed under the Safe Drinking Water Act (SDWA).
-------
-15-
Tahle 5
On-site Ponded Water
Volatile Organics
Chemicals
Maximum
Concentration (pph)
Background
Concentration (pph)
l,l-dichloroethane
ethylhenzene
tol uene
1, 1, I-trichloroethane
9
3 *
8
2 *
BDL
BDL
BDL
BDL
Inorganics
Chemicals
Maximum
Concentration (pph)
Background
Concentration (pph)
arsenic
chromium
lead
zinc
harium
manganese
1.7 *
9.2 *
30
34
580
31000
BDL
5.1 *
BDL
4.9 *
1.8 *
BDL
Note
* - Estimated ,Value
BDL - Below Detection Limit
-------
-16-
Review of the data presented in Tables 1 through 5 de~ects the
movement of some site specific contaminants off-site through an
established contaminant pathway. As can be seen from this data,
site specific contaminants are leaching through the landfill, to
underlying natural soil layer, and then moving off-site by means
ground water aquifer system.
some
the
of the
Risk Assessment
Volatile/semi-volatile organic compounds and inorganic chemical
parameters were detected in the various media at the site. The apparent
source of contamination in the area is the waste buried and dumped on the
soil at the Dorney Road Landfill Site. Although many of these contaminants
have entered the ground water aquifer underlying the site, 'this Risk
Assessment will only address the public health risk associated with dermal
contact and incidental ingestion of landfill soil, solid waste, and on-site
ponded waters. The risk associated with ground water will be addressed in
a future ROD.
A quantitative risk characterization was performed on all of the.
chemicals detected in the various media at the site. A risk level of 10-6
representing an upper bound probability that one excess cancer case in
1,000,000 individuals for a period of 70 years, might result from exposure
to potential carcinogens was used as a benchmark. This would be in addition
to the approximate one chance in four of contracting cancer without any
exposure to this site.
Based on the contaminant concentrations detected at the site and the
many assumptions made throughout the Public Health Evaluation section of
the RI report, the risks posed by the contaminated on-site solids and
ponded waters through dermal contact and incidental ingestion by
teenagers and adults are at or in excess of a 10-6 excess cancer risk
for current use (4x10-6 and 3xlO-S for teenagers and adults). Any
chosen remedy must address reducing this risk.
Alternative Evaluation
Using information collected during the RI, a Feasibility
Study (FS) was developed which describes and evaluates alterna-
tives for remediating the sources of contamination at the Dorney
Road Landfill site. Each alternative developed is designed to reduce
the excess cancer risk associa~ed with the landfill contaminants and
also must satisfy the State requirement for the proper closure of
municipal landfills. Each alternative was evaluated on the basis of
how well it protects public health and the environment, its short-
term and long-term effectiveness, how easy it is to implement, the
extent to which it reduces the mobility, toxicity, or volume of
contamination, its,.cost, and its overall feasibility. In addition,
each alternative was evaluated to determine how well it meets existing
regulatory ~equirements.
In developing cleanup options, numerous source control
and mitigation control technologies were screened to provide
a limited number of technologies applicable for remedial actions
-------
-17-
. at the site. Some of these technologies were removed from further
consideration based on site-specific information and other compar-
ative criteria. These other criteria's include:
* Technical performance/reliability
* Constructibility
* Health and Environmental impacts
* Institutional consideration
In the RI/FS report, each technology was evaluated not only
in terms of theoretical feasibility, but a180 in terms of whether
the technology is applicable to the site specific conditions.
Various technologies were screened out before undergoing a detailed
. analysis. Those technologies that were dismissed and the justification
for elimination are presented in Table 6. (An expanded discussion is in
the RI/FS report).
The technologies that have been retained for further analysis
can be grouped into the following five alternatives:
* Minimal/No Action
* Soil. Cover
* Multi-Layer Cap
* On-Site RCRA Landfill
* On-Site Incineration
. All of the alternatives evaluated include monitoring of air and
on-site ponded waters before, during, and after cleanup activities.
The costs for implementing each alternative include current estimates
of construction, implementation, operations, and maintenance. A more
indepth analysis of each alternative is presented in the RI/FS report.
The following is a summary of the evaluation:
Alternative 1:
Minimal/No-Action
The No-Action alternative is required by the National Contingency
Plan (NCP) to be considered through the detailed analysis. This altern-
ative is included in the RI/FS for comparison with the other alternatives
under consideration. This alternative would he selected only if the
site posed little or no risk to puhlic health or the environment.
Existing site security would he upgraded on the site to restrict pedes-
trian and animal traffic across the site. A long-term periodic ground
water, air, pond water, and sediment monitoring program would also
he instituted on a semiannual hasis to determine the extent and severity
of contaminant migration off the site.
The No-Action alternative does not meet SARA's mandate to he
protective of human health and the environment. It also does not
address the majority of the puhlic health and environmental issues
identified in the RI/FS and does not meet the State ARAR requiring
proper landfill closure as defined in the Pennsylvania Solid Waste
Management Act and requirements issued under the same.
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-18-
Table 6
Summary of Eliminated Technologies
[Technology]
Containment
1. Asphalt Cap
2. Concrete Cap
Disposal
1. Off-site .RCRA Landfill
Treatment
1. Soil Vapor Extraction
2. Vitrification
3. Biological Treatment
4. Water or Solvent Leaching
5. Supercritical Fluid Extraction
6. Low-Temperature Therma~ Aeration
7. Oxidation/Reduction
[Justification for Elimination]
Potential for cracking and
incompatibility with site wastes.
Potential for cracking.
On-site RCRA Landfill will perform
the same function at much lower
cost. Lack of available facilities
. in the area.
Implementation difficulties and
limited effectiveness.
Landfill waste not compatible.
Implementability difficulties
caused by multicontaminant
environment.
Implementation difficulties.
Still in experimental stage.
Does not remove all organics.
Does not address inorganics.
Implementability difficulties
caused by multicontaminant
environment.
-------
-19-
Table 6 (continued)
8. Ultrasonic/Ultraviolet Treatment
9. Solidification and Fixation
10. Off-site Incineration
11. POTW Water Treatment
12. On-site Water Treatment
Ancillary Actions
1. Active Vents
Unproven effectiveness.
Implementation difficulties.
On-site thermal treatment performs
the same function at significantly
lower cost.
Difficulty in getting POTW to
accept Superfund waste water.
RCRA facility treatment would be
equally effective and less costly.
Passive vents should provide
sufficient venting at lower cost.
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-20-
The major components of this alternative include:
* Installation and maintenance of a chain link perimeter
fence.
* Establishment of institutional controls (land use/d~ed
notices).
* Performance of a site review every five years.
The only component of this alternative that involves implementation
is the installation of the perimeter fence which could be installed within
less than one year of the signing of the ROD.
The total estimated cost
is $120,000 for capital costs
(30 years at 5%) of operation
$640,000.
for implementing the No-Action alternative
(such as construction). The present worth
and maintenance activities is equal to
Alternative 2:
Soil Cover
This alternative includes draining the ponds, regrading the landfill
surface, and covering the entire landfill with 2 feet of compacted clean
fill and 6 inches of topsoil. The soil cover would act as a physical
barrier over the contaminated landfill solid material to reduce the risk
of exposure to potential human .and animal receptors by direct contact
and incidental ingestion. Migration of contaminants to the ground
water would not be significantly reduced.
The Soil Cover alternative would also include installation of a
perimeter fence, deed notices, runon/runoff controls and surface
water/ground water monitoring.
A soil cover does not reduce the toxicity or volume of the
hazardous materials on-site, is not permanent, does not utilize
an alternative treatment technology, and does not meet State ARAR
requirements for landfill closure.. Site contamination would remain
in place.
Complete implementation of this alternative including pond water
elimination, site grading, and soil cover construction, could be
accomplished in approximately six months to one. year.
I.
The total estimated cost for implementing the Soil Cover alternative
is $5,300,000 for capitals costs (such as installation of fence and
regrading). The present worth (30 years at 5%) of operation and maintenance
activities is equal to $1,600,000.
Alternative 3A: RCRA - Type Multi-Layer Cap
Installation of a multi-layer cap meeting the Resource Conservation
Recovery Act (RCRA) standards would eliminate the direct contact
risk (i.e., absorption and incidental ingestion of site contaminants)
and would protect the environment by minimizing infiltration of
-------
-21-
contaminants to ground water via percolating ponded water/rainwater.
The RCRA cap would include, from the hottom up, a 6-inch gravel
gas collection layer, a two foot thick compacted clay layer, a 50
mil flexihle synthetic liner, a synthetic drainage layer, a two foot
layer of clean earth fill, and a one foot layer of topsoil to support
vegetation. A cross section of the RCRA - Type Multi-Layer Cap is
shown in Figure 3.
Some landfill materials would he excavated and placed in a
central area for eventual capping. The excavated zones would he
hackfilled with clean soil. By consolidating landfill soils, the
area to he capped would he limited, therehy reducing the total cost.
The R~RA-Type Multi-Layer Cap alternative does not reduce the
volume or toxicity of the contaminated media. Direct contact with
site contaminants and migration via percolating rain water are
hlocked. This alternative meets the State ARAR for proper landfill
closure.
The total estimated cost for implementing the RCRA-Type Cap
alternative is $13,000,000 for capital costs such as soil excavation
and cap installation. The present worth (30 years at 5%) of operation
and maintenance activities is equal to $1,800,000. Construction of the
cap, including regrading the site and pond elimination, could he
accomplished in ahout one year, following design.
Alternative 3B:
PA - Type Multi-Layer Cap
This alternative has the same major component and is similar
to Alternative 3A except that the standard for the cap design would
he developed in accordance with the Pennsylvania Solid Waste Management
Act rather that RCRA guidance. As RCRA closure standards are not
applicahle at this pre-RCRA site, and the Commonwealth of Pennsylvania
has solid waste regulations in place which directly relate to this
type of municipal landfill, these state requirements will he followed.
Because this site contains hazardous contaminants, the RCRA cap
requirements may he considered relevant and appropriate. However, the
Pennsylvania State Cap also meets this requirement.
Tbe Pennsylvania State Cap would consist of, from the hottom
up, a 6-inch gravel gas collection layer, a one foot compacted earth
layer, a 50 mil flexible synthetic liner, a synthetic drainage layer
and a two foot loam layer on top to support vegetation. A cross
section of the Pennsylvania State Cap is shown in Figure 4.
Performance of this PA-Type Cap installation would be expected
to he similar to the RCRA-Type Cap. Construction considerations
would be the same as described for the RCRA-type cap. The total
estimated cost for implementing the PA-Type Cap alternative is
$12,000,000 for capital costs. The present worth (30 years at 5%) of
operation and maintenance activities is equal to $1,800,000.
-------
I ,
i
I j
,
Ii
!
1FT. LOAM
SYNTHETIC
DRAINAGE LAYER
50 MIL SYNTHETIC
MEMBRANE
2 FT.
CLAY
COMPACTED
I< ( 10-1 em/..e
6" GRAVEL GAS
COLLECTION LAYER
f
I:
GAS VENT
VEGETATIVE
COVE~
\ I ~ .... / - ,/ ,,/ ,-" ." - .....
.... :-:-..!"'-J\--;:"."'/';",......,
1-, ,'-... .,,- \ -.....' ,- -- '/'-.,
, \ I I' -... - ~ - ,'" "I' ...... / / / '/ '" ..... \
- \ ", J -- - ./ \/"
{:.(,; t.,::{k}~:F:;[::i\.~
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// \ - \ '" ..", - \, ...... "" '..... , ~ 1-.,. , -:.. I
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'/, , - /" 1,/ ,/. \ ,..- , / -..- " ," ,,'.-
: ~:..: ,: .~',' ;,~,.., '~:' :", '.., :;:: :::, ,:'~',::' :~':: '::~':,:~',", ~,',' :'~,:
'",'..' 0, . ': ,...,,' 0 " ",.., -,' ,~2 FT, CLEAN
: ..>.. ;', ....' ': :' : "...' '," '. ",,' ': ~"o ',: '" ~,~ ~'~ -: -: RANDOM EARTH
" ", -":p ',,', ,'C), ~" ""'D"".:',' ",0", FILL
..f ..t. ~ . . : . ~. '.: ~.. .' ~ ,': ~. ~. ~ .'. '..' .." ~. . ~ . .'
I
N
N
I
..
FIL TER
FABRIC
FIL TER
FABRIC
CONTAMINATED
SOIL MATERIAL
FIGURE 3
RCRA.- T YPE MULTI
,YER, CAP,
-------
GAS VENT
2 FT.
VEGETATIVE COVER
.-- /
, / \
\
1\
/ /
/ ..
.. ,
I I
/
//~/-,'.... ..,',
./' I 1....- \ - / .'" ,,'" ./;- ,
..., II' ,/,'" "" - / f _I.. ..
/ \ I , /
I' / ,,; .. I , /" I"
, I - ,
~ - /
LOAM
SYNTHETIC
DRAINAGE LAYER
\
/
.. '
/ ,,; / ,'" ,; /- I
/,,;/\ ',"I
,
- ,
- \
, ..
. /
1FT. CLEAN ~>}:'>:~:::/'~'.'.'O:
RANDOM EARTH " .,;:':-,:,'",,,,' ''''''n''':'':' ',;.,..
F I L L::..:~..:/-.'~/.:? {'N..:>. ..'.:.
6" GRAVEL GAS ~ .
COLLECTION
LAYER
~.,"'..:"'~~' ,'.::' ~: ,.",','>:' :"'0: .~,', '0 ",' i . ,0' . ',',
CQNTAM1NATED
SOLID MATERIAL
fiGURE 4
PA - TYPE
FIL TER
FABRIC
50 MIL.
SYNTHETIC
-MEMBRANE
I
N
W
I
FILTER
FABRIC
MUL TI- LAYER CAP
-------
---k''''-
Alternative 4: On-site RCRA Landfill
This alternative would require the construction of a secure
landfill on-site incorporating a double liner and leachate collection
system. The landfill would be constructed on-site in compliance with
RCRA standards for both line.r and cover systems. Approximately 1.5
million cubic yards. of contaminated waste would be excavated from
depths ranging from 18 to 48 feet and placed in the on-site landfill.
Excavated areas would be backfilled with clean soil, regraded and
revegetated.
This alternative does not reduce the volume of hazardous materials
on-site, does not use alternative treatment technology, and may not
reduce the toxicity of the waste. Long-term monitoring would be
required (as in all previous alternatives) and major repair or main-
tenance may eventually be required. .
The construction period for completion of the landfill, including
the elimination of ponded waters, excavation, bottom liner construction,
backfill of waste, and capping, would be approximately five years.
~e total estimated cost for implementing the On-site
Landfill alternative is $19,000,000 for capital costs such
landfill construction. The present worth (30 years at 5%)
and maintenance activities is equal to $27,000,000.
RCRA
as
of operation
Alternative 5:
On-site Incineration
This alternative consists of on-site incineration of approximately
1.5 million cubic yards of contaminated soils and solid waste that would
be excavated from the landfill site. Disposal of the ash would depend
on results of an Extraction Procedure Toxicity Test (EP Tox). Due to
the high toxic metals content of the soils, which would not be destroyed
by incineration, it is expected that the ash would be required to be
disposed of in a RCRA-Type Landfill on-site. A RCRA Type Landfill,
similar to but smaller than the one described in Alternative 4, would
be constructed. on-site.
This alternative would reduce the volume of hazardous contaminated
media by about 50 percent. Organic contaminants such as phenols would
be destroyed by the incineration treatment. Metals in the soil would
not be destroyed and would be left in the ash.
Eliminat~on of on-site ponded waters, excavation and incineration
of all contaminated waste on-site with the construction of a RCRA-type
landfill for ash, would require approximately 12 years.
The total estimated cost for implementing the On-site Incineration
alternative is $28,000,000 for capital costs such as construction
of the on-site thermal incinerator. The present worth (30 years at 5%)
of operation and maintenance activities is equal to $640,000,000.
-------
-Zj~--
Comparative Analysis
The five alternatives assembled were evaluated based on the following
nine criteria:
* Overall protection of human health and the environment;
* Compliance with all federal and state applicable or relevant and
appropriate requirements (ARARs);
* Reduction of toxicity, mobility or volume;
* Short-term effectiveness;
* Long-term effectiveness;
* Implementability;
* Cos t ;
* Community acceptance; and
* State acceptance.
A summary of the relative performance of the alternatives with
respect to each of the nine criteria is presented in the following.
1.
Overall Protection of Human Health and the Environment
The alternatives evaluated offer a wide range of overall protec-
tiveness from almost no protection of human health or the environment
to maximization of protection. Alternative 1 would provide minimal
protection of human health and the environment. The current site
related risks identified in the RI would be unmitigated. Alternative
2 would greatly reduce the risks of incidental ingestion and dermal
absorption of contaminated surface water and solid waste by placing
a clean soil cover over the site. The leaching of solid waste
contaminants to ground water would not be significantly reduced by
implementation of this alternative. Alternative 3A and 3B would
offer the same protection of human health as Alternative 2, but with
the increased reliability of a multi-layer cap. In addition,
Alternative 3A and 3B would prevent infiltration of precipitation
into the waste, thus reducing the leaching of contaminants to ground
water. Implementation of Alternatives 1, 2, 3A and 3B would pose
minimal short-term risks during construction. Alternative 4 would
provide complete three-dimensional containment of the waste material,
thus eliminating human health and environmental risks. Alternative
4 would require approximately five years to implement, during which
time workers would be exposed to moderate health risks. Alternative
5 would afford maximum protection of both the environment and public
health since all organic contaminants would be destroyed and the
residual inorganic contaminants would be completely contained within
a 'lined landfill on-site. However, implementation of this alternative
would require about 12 years to complete, during which time site risks
would not be fully mitigated and workers would be exposed to moderate
health risks.
2.
Compliance with ARABs
All alternatives would be designed to meet action-specific
ARABs which would include State requirements for the proper closure
of municipal landfills. No location-specific ARARs were found to be
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-26-
applicable for any of the remedial actions considered. Chemical-specific
ARARs were considered as they apply to air quality. Water quality chemical
specific ARARs are not applicable because on-site ponded waters will not
be discharged to a surface water, nor spray irrigated on adjacent lands or
discharged to local drainage. For alternatives 2, 3A, 3B, 4 and S, all pond
waters will be transported off-site and disposed of at an approved facility.
Contaminated pond waters migrating off-site during periods of precipitation
in Alternative 1, would not meet water quality standards. Controls would
be implemented during excavation in alternatives 2, 3A, 3B, 4 and S to
reduce particulate and contaminant vapor concentrations in air to acceptahle
levels under State and Federal air quality requirements.
3.
Reduction of Toxicity, Mobility, or Volume (THY)
The TMV of site contaminants would be unaffected by implementation
of Alternative 1. The containment alternatives (2, 3A, 3B and 4), do
not utilize treatment to reduce TMV of the landfill materials. However,
containment does effect the mobility of wastes hy reducing infiltration,
therefore minimizing leachate generation. Alternative 2 would provide
little to moderate reduction of contaminant mobility. Alternative
3A and 3B would provide much greater reduction in contaminant mobility.-
These -three alternatives would reduce the mobility of surface contaminants,
while Alternatives 3A and 3B would also reduce the mohility of subsurface
contaminants leaching to groundwater. Contaminants would be completely
immobilized in Alternative 4, hut toxicity and volume would be unaffected.
Implementation of Alternative 5 would destroy all organic contaminants,
while residual inorganic contaminants would be immobilized Within
a lined landfill.
4.
Short-Term Effectiveness
Potential risks to the local population should not increase during
implementation of any of the remedial alternatives since there are no
residents living within 1,000 ft. of the site. Excavation of the
contaminated waste during construction of Alternatives 4 and 5 would,
however, pose low exposure risks due to inhalation of organic vapors
or fugitive dust for travelers on Dorney Road. Migratory waterfowl
and other wildlife currently residing near the site would be tempor-
arily displaced during construction of all alternatives, except
Alternative 1.
Workers responsihle for implementing the remedial actions may
he exposed to risks associated with dermal contract, incidental
ingestion, and inhalation of organic vapors or fugitive dust during
construction. These risks would be extremely low for implementation
of Alternative 1 since work would be performed at the site perimeter
and the construction period would be brief (less than one month).
Implementation of Alternative 2 and 3A/3B could pose low to moderate
risks to workers since the contaminated surface soils and waste would
be disturbed during regrading. The duration of the construction
period for Alternatives 2 and 3A/3B would, however, be less than one
year. Implementation of Alternatives 4 and 5 would present moderate
risks to workers due to the extensive excavation and handling of
-------
-- -27':'--
contaminated waste required and the relatively long construction
period (approximately 5 years for Alternative 4 and 12 years for
Alternative 5). Standard safety and health practices used in the
Hazardous Materials Handling Field Plan, would provide adequate
protection for both the workers and travelers on Dorney Road. These
practices can be easily implemented for each alternative.
s.
Long-Term Effectiveness
Alternative 1 would provide minimal reduction of the identified,
existing risks by limiting access of hunters and other site trespassers
and deterring future use of the site. Monitoring of pond and
ground water would indicate the need for subsequent action. The reli-
ability of the site fence is relatively high, but is dependent upon
continued inspection and maintenance, while enforcement of deed
restrictions would be difficult to ensure. Monitoring technologies
are well developed and reliable, but only indicate the presence of
a problem rather that performing a protective function.
Alternatives 2, 3A and 3B should be equally effective in reducing
the risks of dermal contact and incidental ingestion of contaminated
soil, solid waste, and ponded water. Alternative l would not be
protective of ground water, while Alternatives 3A and 3B would reduce
infiltration and the associated leaching of solid waste contaminants
to the water table. The reliability of the soil cover in Alternative
2 is considerably less than that afforded by the multi-layer caps of
Alternatives 3A and 3B. Of the RCRA and PA-type caps, the RCRA cap
offers slightly greater reliability since a clay liner layer is employed
in addition to the synthetic liner. Continued maintenance for alternatives
2, 3A, or 3B would be required to ensure effectiveness of these
alternatives.
Alternative 4 and 5 would provide maximum protectiveness as they
elimina~e both exposure risks and leaching of contaminants to ground
water. Properly constructed, a lined landfill should be very reli-
able; however, the reliability is dependent upon continued maintenance
and monitoring. All organic contaminants would be destroyed in
Alternative 5, thus minimizing the potential fQr future risks from
organics.
6.
Implementability
.
Implementability of Al.ternative 1 would be extremely simple,
requiring only the construction of a fence around the site and periodic
monitoring of existing wells and pond water. 'Implementation of
Alternative 2 should also prove relatively easy as the civil construct-
ion techniques required are well developed and commonly used.
Alternatives 3A and 3B would be somewhat more difficult to implement
due to the complex construction of the multi-layer cap. Multi-layer
cap construction, however, is well developed and should not pose a
major problem with adequate engineering design. Implementation of
Alternatives 4 and 5 would be extremely difficult due to the volume
(approximately 1.5 million. cubic yards) of contaminated waste to be
handled and the necessity for staged construction with simultaneous
-------
~.~~,.
excavation and liner construction. Operations and coordination of the
incinerator with excavation and backfilling of the waste would increase
the complexity of the engineering design and site work for Alternative 5.
Implementation of Alternative 4 and 5 would require complex design and
construction techniques.
7.
Cost
The total capital cost, annual operation and maintenance cost
(O&M), and total present worth costs for all alternatives are
summarized and presented below.
Total Annual Total
Alternative Capital Cost O&M Present Worth
1 $ 120,000 $ 39,000 $ 760,000
2 5,300,000 42',000 6,900,000
3A 13,000,000 42,000 15,000,000
3B 12,000,000 42,000 14,000,000
4 19,000,000 5,887,000 46,000,000
5 28,000,000 72 ,247 , 000 670,000,000
8. Community Acceptance
A public meeting for the Proposed Remedy was held on August
31, 1988, in Upper Macungie Township, Pennsylvania. The meeting
was attended by 15 Township residents and questions were received
by those present. Township residents had no objection to the selected
remedial alternative which was presented in the Public Notice and in
the Proposed Plan prior to the public meeting. The responsiveness
summary attached to this Record of Decision (ROD) summarizes the
public meeting and answers those questions/concerns that were received
during the public comment period.
9.
State Acceptance
The Commonwealth of Pennsylvania has reviewed the RI/FS and
this ROD and concurs with the Selected Alternative.
.
Selected Remedy
Based on available data and analysis conducted to date, Alterna-
tive 3B is selected as the most appropriate remedy for meeting the
goals of the initial operable unit at the Dorney Road Landfill
site. This alternative consists of:
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-29-
..
..
..
..
..
..
..
..
Perimeter Fence
Deed Notice
Elimination of On-site Ponded Waters
Regrading
Runon/Runoff Controls
PA - Type Multi-Layer Cap
Runoff Monitoring
Ground Water Monitoring
This action is an operable unit measure to control
contaminant migration off-site by containment of contaminated
landfill soil and waste material, thereby preventing dermal
contact and incidental ingestion of .these materials. It will
also prevent the continued leaching of precipitation and pond
waters through the contaminated landfill media, which in turn
will isolate the source of ground water contamination. This
alternative will also not be inconsistent with~a final remedial
action for this site. A summary of each of the individual major
components of this selected remedy is described in the following:
- Perimeter Fence: A chain link fence will be constructed around
the site perimeter to reduce pedestrian and animal traffic across the
site. Approximately 6,600 linear feet of fence would be. erected to
enclose the entire area of concern. .
- Deed Notice: A notice will be placed in the deed of the land within
the site boundaries.
. .
- On-site Ponded Water Elimination: The five existing. on-site ponds
mtist be eliminated to allow proper construction of the landfill cap.
A total of approximately 700,000 gallons of water are contained in
two ponds located .in the southwest portion of the site and three smaller
ponds located in the north-central and northwest portions. All on-site
ponded waters will he transported off-site and disposed of at an approved
facility.
Regrading: Regrading is required to provide positive drainage
across the site, preventing the retention of surface water. 50il
will be cut from high areas on-site and used to fill low areas which
will include the filling of drained pond areas.
- Runon/Runoff Controls: A dike and diversion ditch system will
. be constructed around the site to eliminate site runon and to divert
precipitation to two sedimentation ponds, located to the north and
the other to the south of the site.
- PA-Type Multi-Layer Cap: The landfill cap will consist of a
one foot thick compacted earth base course, a 50 mil flexible
synthetic liner, a synthetic drainage layer, an4 a two foot thick
vegetative loam layer. A gas collection system consisting of a
6-inch thick gravel layer and well type vents will also he
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,-30-
included beneath the ~ompacted earth base course.
- Runoff Monitoring:
drain from site at the
collected and analyzed
on a scheduled basis.
Surface water and sediment which will
northeast and southeast corners, will be
for a select list of chemical contaminants
- Ground Water Monitoring: Ground water will be monitored both
upgradient and downgradient of the site for a period of 30 years
to detect any changes in ground water quality due to leaching of
landfill contaminants. Sampling of monitoring wells will take
place on a periodic basis and will be analyzed for a select list
of chemical contaminants.'
Statutory Findings:
The selected remedy meets statutory mandates for utilizing
permanent solutions and alternative treatment technologies to the
maximum extent practicable.
Treatment of the principal threats of the site was not found
to be practicable, therefore this remedy does not satisfy the statutory
preference for treatment as a principal element of the remedy. Treat-
ment was deemed impracticable at this site due to the volume and multi
contaminated nature of the landfill material, and the uniformity of
site contaminants.
Applicable or relevant and appropriate requirements (ARARs)
pertaining to this remedy will be attained. These ARARs include:
- Chemical,
.
Clean Air Act: National Air Quality Standards (NAQS), 40 CFR Part 50
- Location
.
No location specific ARARs have been identified.
- Action
.
Pennsylvania Solid Waste Management Act, Act of July 7, 1980,
P.L. 380, 35 P.S.Chapters 691.1 et. seq. and requirements
issued under the Pennsylvania Solid Waste Management Act
.
Pennsylvania Air Pollution Control Act, Act of January 8, 1960,
P.L. 2119, 35 P.S. Chapters 4001 et. seq. and requirements
issued under the Pennsylvania Air Pollution Control Act
.
Clean Water Act, Pretreatment Requirements, 40 CrR Part 403
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-31-
The selected remedy is cost-effective as it provides the best
balance between cost and effectiveness in comparison with the other
alternatives. Alternative 3B is protective of human health and the
environment and will be easier to implement that alternatives 4 and S.
Unlike alternative 2, alternative 3B will reduce the migration of
contaminants to ground water, and has a considerable cost savings when
compared to Alternative 3A.
Schedule
The anticipated schedule is for the remedial design to begin
in the Winter of 1988 or early 1989. Once the landfill cap design is
completed, implementation of the design will require a construction
period of approximately one year.
-------
Enforcement Status
Operations as a municipal and industrial landfill at an abandoned
iron mine pit have caused contamination of the soil and ground water
at the site. . An RI/FS for the soil contamination was completed in
June, 1988.
In a letter dated September 2, 1988, EPA gave the Potential
Responsible Parties (PRP) notice of their potential liability with
regard to implementation of the first operable uni t remedial action.
Enclosed with this letter was a copy of EPA' s proposed remedial
alternative. The PRP's were extended the opportunity to present a
good faith proposal to conduct the Remedial Design and Remedial
Action to the agency within sixty (60) days of receipt of the
September 2, 1988, special notice letter.
Prepared by: Terry Stilman
Hazardous Waste Enforcement Branch
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FINAL RESPONSIVENESS SUMMARY
FOB. 'mE
OORREY ROAD LANDFILL SITE
LEHIGH CUUlITY. PERRSYLVAlfIA
From August 16, 1988 through September 14, 1988, the U.S. Environmental
Protection Agency (EPA) and Pennsylvania Department of Environmental Resources
(PADER) , held a public comment period on the Proposed Plan and Remedial
Investigation/Feasibility Study (RI/FS) for the Dorney Road Landfill Superfund
site in Upper Macungie Township, Lehigh County, Pennsylvania.
On August 31,
1988, EPA and PADER co-sponsored a public meeting to receive comments from the
public on the Proposed Plan and RI/FS.
The RI/FS and other information
utilized by the EPA.and PADER to select a preferred remedial alternative is
available to the public at the information repositories at the Upper Macungie
Township Building in Breinigsville or the Parkland Community Library in
Allentown.
The purpose of this responsiveness summary is to summarize comments
received on these documents, as expressed by residents and local officials,
during the public comment period and to provide EPA and PADER's responses to
the comments.
Comments submitted to EPA and PADER during the public comment
period are included in this summary.
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2
SITE BAr.Jrr.JltmBJ)
The Dorney Road Landfill site (also called Oswald's Landfill) is located
along the southwest boundary of Upper Macungie Township in Lehigh County,
Pennsylvania, approximately eight miles southwest of the City of Allentown.
The site is composed of approximately 27 acres and is bounded to the east by
Dorney Road and extends westward into Longswamp Townshi~, Berks County.
site is surrounded by agricultural land where corn is grown for dairy and beef
The
industries.
The site is referred to locally as Oswald's Landfill because it
was leased and operated from 1970 to 1978 by Harold Oswald.
According to site records, initially the site was operated as an open pit
iron mine.
Between 1952 and 1966, however, the site was operated as an open
dump with waste disposed in the abandoned iron mine pit.
From 1970 to
December 1978, the Dorney Road Landfill was operated primarily as a municipal
waste dump.
During this time, industrial waste disposal was documented.
A
Sanitary Landfill Survey report, prepared in 1970 by PADER, maps an area of
the landfill designated for disposal of waste sludges from th~ General
Electric Allentown plant.
During operations, the facility was cited by the
State for illegal dumping practices.
Although Oswald initiated a permit
application for operation of the landfill, he never completed the application
and subsequently never received a permit.
Oswald ceased operation of the
landfill in 1978.
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3
The site was not properly prepared for closure and was not regraded or
seeded.
In late 1982, PADER representatives collected surface water and
ground-water samples from the site.
High levels of lead were detected in the
surface water samples and phenols were detected in the ground-water samples.
In January 1983, PADER sampled residential wells and surface soils on the
site.
No adverse impacts to the ground water were identified in the well
samples but elevated levels of lead were detected in soil samples collected at
the site.
In 1983, the State requested that the site be included on the
National Priorities List.
The NPL is a list of hazardous waste sites across
the country eligible to receive Federal Superfund monies for cleanup.
In
response to the NPL listing request, EPA initiated sampling at the site.
In
April 1983, EPA'contractors visited the site and monitored air quality but did
not detect any readings above levels that are considered harmful to human.
health or the environment.
The site was proposed for inclusion on the
National Priorities List (NPL) in September 1983.
Sampling of soil,
sediments, and surface water, conducted in April 1984 by EPA contractors,
detected elevated levels of metals, phenols, and toluene in the samples.
Responding to a May 1986 removal request by the State, EPA's Environmental
Response Cleanup Service (ERCS) regraded the surface, seeded the site, and
installed earthen berms to control migration of surface contaminants onto
neighboring property in June 1986.
S100fAIlY OF IfAJOR COMMENTS AND KPA RESPONSES
During the public comment period on the RIjFS and Proposed Plan, EPA and
PADER co-sponsored a public hearing at the Upper Macungie Township Building on
-------
4
AugusC 31, 1988 aC 7:00 p.m. to discuss the proposed plan for cleaning up
contaminacion aC the landfill.
Those accending the meecing included
represencatives from EPA, PADER, consul Cants to EPA and PADER, an area news
reporter, and approximacely 15 communicy residents.
During the meeting, the
consultants summarized the'results of investigations conducted aC che sice and
reviewed che cleanup alternatives ev~luaced in the FS reporc.
The PADER
representatives described how the Superfund cleanup program works and
explained EPA's and PADER's preferred alternative for addressing contamination
at the Dorney Road Landfill site.
They explained that the RI/FS report and
the proposed alternative address the initial phase, or Operable Unit, of
cleanup at the site.
The first Operable Unit is directed at limiting human
contact wich soils and waste from che site.
PADER also explained Chat ground-
water contamination will be addressed in a supplemental report which currently
is being prepared.
This second phase of the study is referred to as the
second Operable Unit.
A public meeting, planned for February, will provide
citizens with an opportunity to discuss issues related to site ground-water
contamination.
Questions, comments, and concerns received during the Augusc 1988 meeting
are summarized below and are categorized into the following topics:
1) scope
and findings of the Remedial Investigation; 2) proposed remedy; 3) residential
well testing; and 4) potentially responsible parties.
Each comment is
followed by the response provided by EPA and/or PADER.
The purpose of this
document is to summarize che public's concerns and EPA and PADER's responses,
however, the official transcript of the meeting contains a complete account of
the questions and responses.
A copy of the transcript is available to the
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5
public at the site information repositories.
Additionally, one letter was
received by EPA during the public comment period.
The written comments and
PADER responses are included in this summary.
SCOPE AND FINDINGS OF THE RFJmDIAL INVESTIGATION
Comment:
A resident asked if any determination had been made of what had
killed several walnut trees on the Wessner property bordering the landfill and
if it was caused by contamination in the ground-water.
Response:
A PADER consultant explained that the dead vegetation in the area
is probably.related to surface contamination rather than ground-water
contamination.
Comment:
A resident explained that his water supply had a water quality
problem and asked if the RI study had included an assessment of the water
quality in the Terry Hill area.
Response:
A PADER consultant responded that the water system that affects the
landfill does not extend to the area that the resident described.
He
explained that the water north of Terry Hill is affected by a different system
and, because it was unlikely that contamination from the landfill would extend
to that area, it was not included in the scope of the study.
Comment:
A resident asked what contaminants were identified at the site and
at what concentrations they were found.
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~ -
6
Response:
An EPA representative said that the contaminants identified at the
site included volatile organic compounds (VOCs), polyaromatic hydrocarbons
(PAHs) , and inorganics such as lead.
The PAHs were present in concentrations
that pose a threat to human health.
A VOC, trichlorethylene, was found in a
nearby residential well but not in on-site ground-water samples.
Lead also
was identified at the site but not in residential wells.
Comment:
One resident stated her belief that the geology of the area is prone
to sinkholes and claimed that testimony offered at a hearing in 1979 indicated
that there were sinkholes on the site that had been filled.
(Note:
The 1979
hearing was held by the State to review a permit application to reopen the
landfill.
The permit was denied because of the public reaction to the dangers
posed by sinkholes that had been identified in the neighboring area.)
Response:
A PADER consultant explained that seismic mapping of the site
during the RI did not indicate the presence of sinkholes on the site and no
sinkholes were identified within one quarter mile of the site boundary.
PROPOSED REllKDY
Comment:
A resident asked what the remedy would look like and another
resident asked how far the cap would extend beyond the contaminated soil and
if it would help prevent the leachate from migrating onto neighboring
property.
The written comment stated concern over encroachment of leachate
from the landfill onto the Bauer-Wessner property.
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7
Resuonse:
A PADER consultant responded that the cap will consist of a
foundation made up of one foot of compacted soil, tWo layers of fabric filter
material interspersed by a liner and synthetic drainage layer, followed by one
foot of soil and a tWo foot loam layer that would be vegetated.
A gas
collection system and vents also would be included beneath the foundation
base.
Specific design components of the remedy are not complete because it
must be formally approved by EPA first.
Generally, however, the cap extends
into clean material.
It is expected that the cap will help prevent the off-
site migration of leachate by drying up the material beneath it.
PADER's response to the written comment stated that the Department has no
knowledge of landfill waste encroachment into the farm fields.
They also
asked the commentor to specifically indicate the areas of cpncern.
A resident asked if top soil used in constructing the cap would come
Comment:
from the site.
Response:
A PADER representative explained that the so:~ used in constructing
the layers would be clean soil brought onto the site.
It would not be taken
from on-site.
Comment:
A citizen inquired about the durability of the cap and several
residents asked about the success of such caps where they are currently in
use, where and when a cap was most recently installed, and whether these caps
had been used to close toxic dumps.
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8
Resoonse:
A PADER representative stated that the layers created during the
placement of the cap have enough flexibility to withstand hea~ equipment used
during installation.
The materials used for caps have been used successfully
as caps and liners at toxic waste sites.
The nearest landfills where similar
materials are used include Pottsdown and Rose Landfills in Bucks County,
Pennsylvania.
Ouestion:
One citizen asked how rainwater run-off would be controlled once
the cap was in place.
The written comment expressed concern over the height
of the landfill after the cap is installed, stating that the volume and force
of water runoff will erode the Bauer-Wessner land.
Response:
A PADER consultant said that the water. would be diverted into ponds
constructed on the site designed to contain water from a 24 hour, 25 year rain
storm.
This measure is used to estimate the capacity needed to protect the
surrounding area from run-off during a worst case storm.
PADER responded to the written comment by explaining that runoff
controls, designed to prevent surface water from leaving .the site, would be
installed along with the cap.
The runoff controls will discharge into the
ponds described earlier.
Comment:
A resident asked how often the wells that were installed for
sampling during the investigation would be monitored, if they would continue
to be monitored after the cap was installed, and if the wells are being
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9
monitored currently.
Another citizen asked if all the wells were installed at
a uniform depth.
Response:
A PADER representative responded that samples are not being
collected currently from the monitoring wells.
However, the well monitoring
program that is part of the proposed remedy includes monitoring a total of
four wells, two times each year.
The well network used for the investigation
extends to a maximum depth of just over 100 feet.
The ground-water samples
were collected from an interval that extended from five feet above the water
t~ble to just over 100 teet in depth.
This large of an interval was used
because some of the contaminants of concern would be found along the top of
the ground water, if they were present, and others would sink.
Comment:
In the letter submitted to PADER, the commentor stated that the
Bauer-Wessner property owners are reluctant to give license for the use of the
monitoring wells on the
property over a period of 20 to 30 years.
Response:
PADER responded to the written comment that EPA will be
administering the cleanup operations beyond the Remedial Design.
Consequently, the commentor should. make their position known to EPA.
Comment:
A resident asked if the monitoring well sampling would pick up any
indication of sinkhole formation.
Response:
A PADER representative explained that the monitoring wells only
detect changes in water quality.
The sampling would detect contaminants
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10
reaching the water table and becoming mobile through the ground water.
Ifa
sinkhole were to form rapidly, this would not be picked up by the monitoring
wells but would be noticed visually.
Comment:
Another resident asked if there would be lateral migration of water
from the surrounding field through the cap.
Resuonse:
A PADER consultant said that there may be minor ground-water
lateral migration but the edge of that cap is covered sufficiently to
intercept water migrating under the cap.
Comment:
A resident living near the site asked how methane gas is generated,
if it has a scent, and why it has to be vented.
Resuonse:
A PADER re~resentative described methane gas as odorless,
colorless, and flamable.
\
Methane is generated through the natural
decomposition of waste material located under the cap.
It should be vented
because it could build up sufficiently to lift the cap or migrate laterally
and pose a threat to neighboring homes.
Comment:
A resident asked when construction of the cap was expected to begin.
Resuonse:
A PADER representative estimated that after the public comments are
considered and a Record of Decision is signed, the cap construction could
begin by the Spring of 1990.
Cap implantation would take less than one year
once construction begins.
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11
RESIDERTIAL VELL TESTING
Comment:
Several citizens asked how many residential wells were tested during
the course of the site investigation and if residents living near the landfill
could have their drinking water wells tested.
Resoonse:
A PADER representative said that a total of seven residential wells
were tested during the RI.
He explained that the RI for the first Operable
Unit relates to preventing the spread of contaminants.
The next study will
address ground-water contamination and this question can be considered then.
A
public meeting on the results of the supplementary study on ground water is
planned for February 1989.
f01:~IALLY RESPONSIBLE PARTIES
Comment:
One commenter asked if the former landfill owners or operators had
been identified or contacted to help with the cleanup of the site.
Resoonse:
A PADER representative stated that EPA is in the process of
identifying and contacting parties responsible for the contamination at the
site.
These individuals or companies are referred to as potentially
responsible parties (PRP).
EPA will send out notice letters to the PRPs
informing them of the cleanup actions that will be conducted at the site.
...
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12
Comment:
The citizen also asked if the amount of money spent on the remedy
would be affected by whether or not money is recovered from the responsible
parties.
Reponse:
A PADER representative explained that the amount of money spent on
the multi-layer cap remedy would not be affected by the results of EPA's cost
recovery.
Once the alternative is chosen, EPA issues a Record of Decision
which dictates which remedy is to be implemented at the site.
-------
OORNEY ROAD lANDFILL SITE
ArMINISTRATIVE RECORD *
INDEX OF rxx:UMENTS
SITE IDENTIFICATION
Prel~inary Assessment and Site Inspection P~ports
1)
2)
Site Inspection Report, 6/19/80.
P. 1-10.
Identification and Preliminary Assessment, 7/28/80.
P. 11-14.
* Administrative Record available 7/8/88, update 9/27/88.
Note:
Company or organizational affiliation is identified in the index
only when it appears in the record.
1
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REMEDIAL ENFORCEMENT' PlANNING
Potentially Responsible Pa~ty - Correspondence
1)
Letter f~an M~. Dwiqht D. Wo~ley ~e: Pennsylvania Department of
Envi~onmental Resources (DER) and EPA conside~ation to investigate
and take action at Do~ey Road Site, 5/8/85. P. 1-3. A list of
Potentially Responsible Parties is attached.
Co~respOndence by Potentially Responsible Party
1)
Lette~ to Mr. Dwiqht D. Wot"ley, Pennsylvania Depa~tment of Environmental
Resources, fram Mr. Daniel G. Dellicker, East Penn Manufacturing Co.,
re: request for a copy of the Draft Work Plan, 5/15/85. P. 1-1.
2)
Letter to Mr. Dwight D. Worley fram Mr. T. M. Armstrong, General Electric,
re: participating in the implementation of the Remedial Investigation/
Feasibility Study, 5/16/85. P. '2-2.
3)
Letter to Mr. Dwiqht D. Worley, Pennsylvania Department of Environmental
Resources, fran Mr. T. M. Armstrong, General Electric, re: requestinq an
extension to June 26, 1985 to respond to the Draft Work Plan, 6/13/85.
P. 3-3. .
4)
Letter to Mr. Dwiqht D. Worley, Pennsylvania Department of Environmental
Resources, fram Mr. Donald A. Wojton, East Penn Manufacturing Co., re:
pa~ticipating in 'the liruplementation of the Remedial Investigation/
Feasibility Study, 6/20/85. P. 4-4.
5)
Letter to Reichard-Coulston, Inc. fram Mr. Dwight D. Worley re: DER and
EPA consideration to investigate and take action at Dorney Road Site,
10/22/85. P. 5-6.
6)
Letter to Glidden 'Coatings and Resins fram Mr. Dwight D. Worley re: DER
and EPA consideration to investiqate and take action at Dorney Road Site,
10/22/85. P. 7-8.
2
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REHEDlAL RESPONSE PLANNING
\~ork Plans
1)
Report: Draft Remedial Action Master Plan (R;MP) for the IX>rney Road
Site, prepared by Ecology and Envi~nment, Inc., 12/84. P. 1-43a.
References are listed on P. 43-43a.
~)
Report: Remedial Investigation/Feasibility Study of IX>rney Road Site
(aka Oswald's Landfill), Final Draftwork Plan, prepared by Ecology and
Environment, Inc., 12/84. P. 44-90.
3)
Repo rt :
Investi
County,
4)
Letter to Mr. Tim Alexander, Pennsylvania Cepartroent of Envi~nmental
Resources, from Mr. Earl H. Brown, Jr., ICF/SRW Associates, re: transmittal
of the addendum to the October 2, 1987 IX>rney Road Operations Plan,
12/16/87. P. 228-272. The addendum is attached.
Report: Final Quality Assurance Project Plan, Remedial Investigation/
Feasibility Study, prepared by ICF/SRW Associates, 1/27/88. P. 272a-457.
Remedial Investigation/Feasibility Study Rep?rts
5)
1)
Report: Final Remedial Investigation Report, Volume 1 of 2, Dorney Road
Landfill, Lehigh County, Pennsylvania, prepared by ICF Technology
Incorporated, 8/11/88. P. 1-313. Refe~nces are listed on P. 308-313.
Report: Final Remedial Investigation Report, Volume 2 of 2, Dorney Road
Landf ill, Lehigh County, Pennsylvania, prepared by ICF Technology
Incorporated, 8/1~/88. P. 314-647.
2)
Correspondence and Supporting Documentation
1)
Letter from Mr. !Might D. WOrley, Pennsylvania Cepartment of Environmental
Resources, re: soliciting qualifications and proposals fran fimtS
interested in providing engineering services to conduct a Remedial
Investigation and Feasibility Study, 3/26/86. P. 1-1.
2)
Letter to Mr. C. Kutz from Mr. Timothy A. Alexander, Pennsylvania
Cepartment of Environmental Resources, re: water sample results, 7/6/88.
P. 2- 3 .
3)
Letter to Mr. Henry Shade fran Mr. Tirnothy A. Alexander, Pennsylvania
Cepartment of Environmental Resources, re: well water sample results,
7/6/88. P. 4-5.
4)
Letter to Mr. Vern Shade fran Mr. Tirnothy A. Alexander, Pennsylvania
Cepartrrent of Environmental Resources, re: water sample results,
7/6/88. P. 6-7.
3
-------
5)
Letter to Mr. Edgar Moth fran Mr. Timothy A. Alexander, Pennsylvania
CepartJrent of Environmental Resources, re: well water sample results,
7/6/88. P. 8-10.
6)
Letter to Mr. Bill Corney from Mr. Timothy A. Alexander, Pennsylvania
Cepart.rrent of Envi ronmental Resources, re: wate r sample results,
7/6/88. P. 11-12.
7)
Letter to Mr. C. °Fenstezmaker fran Mr. Timothy A. Alexander, Pennsylvania
CepartJrent of Environmental Resources, re: well water sample results,
7/7/88. P. 13-15. The sample results are attached.
8)
Letter to Mr. Tim Alexander, Pennsylvania Cepartment of Environmental
Resources, fran Mr. Earl H. Brown, ICF/SRW Associates, Inc., re:
transndttal of a memorandum presenting a brief discussion of the
analytical results fran the second groundwater samp'nng period, 9/7/88.
P. 16- 23 . The rnemJ randum is attached.
4
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CCMMUNITY INVOLVEMENT
Community Relations Plans
1)
Report: Community Relations Plan, Dorney Road Site (Oswald's Landfill),
Upper Macungie Township, Lehigh County, Pennsylvania (no author cited),
(undated). P. 1-8.
2)
Report: The Citizens' Guidance Manual For The Technical Assistance
Grant Program, prepared by the U.S. EPA, 6/88. P. 9-327.
Fact Sheets, Press Releases, Public Notices
1)
2)
Dorney Road Site (aka Oswald's Landfill), (undated) P. 1-1.
Fact: Sheets re:
Public Notice: Pennsylvania Department of Environmental Resources Seeks
Comments on the Dorney Road Landfill Superfund Site, 8/16/88. P. 2-2.
3)
Superfund Program Fact Sheet re: Proposed Plan, Dorney Road Landfill,
Upper Macungie Township, PA, (undated). P. 3-11~
Meeting S\.1ImIaries, Trip Reports, Correspondence with Public
1)
2)
Public meeting agenda, 3/19/85.
A list of attendees is attached.
P. 1-2.
Transcript of public meeting, 8/8/88.
P. 3-110.
5
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GENERAL GUIDANCE DOCUMENTS *
l)
2)
"Promulgation of Sites from Updates 1-4," Federal Register, dated 6/10/86.
"Proposal of Update 4," Federal Re~ister, dated 9/18/85.
\
Memorandum to U. S. EPA from Mr. Gene Lucero regarding community relations
at Superfund Enforcement sites, dated 8/28/85.
3)
4)
Groundwater Contamination and Protection, undated by Mr. Donald V.
Feliciano on 8/28/85.
5)
Memorandum to Toxic Waste Management Division Directors Regions I-X from
Mr. William Hedeman and Mr. Gene Lucero re: Policy on Floodplains and
Wetlands Assessments for CERCLA Actions, 8/6/85.
6)
7)
Guidance on Remedial Investigations under CERCLA, dated 6/85.
Guidance on Feasibility Studies under CERCLA. dated 6/85.
"Proposal of Update 3," Federal Register, dated 4/10/85.
8)
9)
Memorandum to Mr. Jack McGraw entitled "Community Relations Activites
at Superfund Sites - Interim Guidance," dated 3/22/85. .
10)
11)
"?roposal of Update 2," Federal Register, dated 10/15/84
EPA Groundwater Protection Strategy, dated 9/84.
12)
Memorandum to U.S. EPA from Mr. William Heckman, Jr. entitled
"Transmittal at Superfund Removal Procedures - Revision 2." dated 8/20/84.
13)
14 )
"Proposal of Update 1," Federal Register, dated 9/8/83.
Community Relations in Superfund: A Handbook (interim version), dated
9/83.
15 )
"Proposal of First National Priority List." Federal Register. dated
12/30/82.
16)
17)
"Expanded Eligibility List." Federal Re~ister. dated 7/23/82.
"Interim Priorities List," Federal Register, dated 10/23/81.
18) Uncontrolled Hazardous Waste Site Ranking System: A User.s Manual
(undated).
19) Field Standard Operating Procedures - Air Surveillance (undated).
20) Field Standard Operating Procedures - Site Safety Plan (undated).
* Located in EPA Region III office.
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I,~
I PENNSYLVANIA
~~~~2
;
I
1 Deputy Secretary for
: Environmental Protection
!-
.
~
.. "\
r'; :
'O~N~~ OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Hararda\;3 'i;.:5t~ :fPDstEOffic~'1t~~ 2063
(H8rriG~~.mnsylvania 17120
September 29, 1988
(717) 787-5028
Stephen R. Wassersug, Director
Hazardous Waste Management Division
EPA Region III
841 Chestnut Building
Philadelphia, PA 19107
Re:
Letter of Concurrence
Dorney Road Superfund Site, Record Of Decision (ROD)
Dear Mr. Wassersug:
The Record of Decision declaration for the Dorney Road
Superfund Site has been reviewed by the Department. The Record Of .
Decision details remedial actions developed for the initial landfill.
proper operable unit. -
i
,
r
The major components of the selected remedy for the landfill
proper include:
f:
t
l'
*
Elimination of on-site ponde~ waters.
Regrading.
*
*
Pennsylvania-tyPe multi-layer cap.
Run-on/run-off controls.
*
*
Groundwater monitoring.
*
Perimeter fence.
..
Deed notice.
I hereby concur with the EPA's proposed remedy with the
following conditions:
*
The Department will be given the opportunity to concur with
decisions related to subsequent supplemental remedial
investigations and studies to identify the extent of, and
future potential for, groundwater contamination and
remaining sources of that contamination, and evaluate
appropriate remedial alternatives to assure compliance with
DER cleanup ARARs and design specific ARARs.
-------
Stephen R. Wassersug, Director 2 September 29, 1988
* EPA will assure that the Department is provided an
opportunity to fully participate in any negotiations
responsible parties.
* The Department will reserve our right and responsibi
take independent enforcement actions pursuant to stat
federal law.
* This concurrence with the selected remedial action is not
intended to provide any assurances pursuant to SARA Section
104(c)(3).
Thank you for the opportunity to concur with this EPA Record
of Decision. If you have any questions regarding this matter please
do not hesitate to contact me.
Sincerely,
. Mark M. HcClellan
Deputy Secretary
Environmental Protection
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DORNEY ROAD
LANDFILL
EXPLANATION OP SIGNIPICANT DIPPERENCES
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EXPLANATION OF SIGNIFICANT DIFFERENCES
DORNEY ROAD LANDFILL SITS
UPPER MACUNGIS, PA
contents
Introduction
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site History, contamination Problems, and Selected Remedy. .
Description of Significant Differences
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Support Agency Comments. . . . . . . . .
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Affirmation of Statutory Determinations. .
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Public Participation
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Explanation of Significant Differences
Dorney Road Landfill site
Lehigh County, pennsylvania
Introduction
This Explanation of Significant Differences (ESD) presents
the proposed details of a change to the remedy selected in the
September 28, 1988 Record of Decision (ROD) for Operable Unit 1
(OU 1). An operable unit is a portion of a Superfund site that
is conceptually separated from the rest of the site to allow for
easier management. Operable Unit 1 at the Dorney Road Landfill
Site addresses the landfill waste, soil, and surface water.
This ESD is issued in accordance with Section 117(c) of the
Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) as amended, 42 U.S.C. S 9617(c) and the National oil
and Hazardous Substances Pollution contingency Plan (NCP),
Section 300.435.(c)(2)(i). This document will be incorporated
into the Administrative Record maintained for this Site, as
required by the NCP Section 300.825(a) (2). The Administrative
Record is available for review at:
. The Upper Macungie Township Building located at 8330 Schantz
Road, Breiningsville, PA 18031 (215) 398-3641 or
. The U.S. Environmental Protection Agency (EPA) located at
841 Chestnut Building, Philadelphia, PA 19107 (215) 597-3037.
currently, EPA intends to provide direct oversight of the
Potentially Responsible Parties (PRPs) actinq under
administrative orders to conduct the remedy outlined in the 1988
ROD. This ESD will be incorporated into the requirements of the
orders.
The Pennsylvania Department of Environmental Resources
(PADER) was the lead agency for the Remedial
Investigation/Feasibility Study (RI/FS) for Operable unit 1
(OU 1), and EPA was the support agency. The RI/FS is a two-part
study that supports the selection of a remedial action for a
site. The first part, the RI, identifies the nature and extent
of the contamination at the site. The second part, the FS,
identifies and evaluates alternatives for addressing the
contamination. At the ROD, EPA assumed the lead, and PADER
became the support agency for OU 1. The PADER is the lead agency
for OU 2, which focuses on the ground water portion of the site.
OU 2 is currently in the RI/FS phase.
The State Project Officer, while conducting the RI field
work for OU 2, observed the active wetlands habitat in the
depressed ~reas in the upper portion of the landfill. This
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indicated that the Applicable or Relevant and Appropriate
Requirement (ARAR) for wetlands, which was identified in the ROD
as not applicable, should be reviewed. ARARs are federal and
state requirements that a selected remedy must attain pursuant to
section 121 of CERCLA. EPA now believes that these areas are
wetlands and that an ESD should be issued to address compliance
with wetlands ARARs.
This ESD, therefore, addresses an ARAR not identified in the
1988 ROD.
site History, contamination Problems, and Selected Remedy
The Dorney Road Landfill Site, also known as Oswald's
Landfill Site, is located along the southwest boundary of Upper
Macungie Township in Lehigh County, Pennsylvania, approximately
eight miles southwest of Allentown. A portion of the site
extends over into Longswamp Township, Berks County.
The Site consists of an abandoned iron mine pit that was
used as a landfill, a surrounding soil berm, and adjacent land.
Beginning in 1962, the site was operated as an open dump, with
the majority of the waste disposed in the abandoned iron mine
pit. Initially, R. Emory Mabry, and subsequently, Harold Oswald
gradually expanded the unpermitted landfill until operations
ceased in December 1978. Mr. Oswald states that he was advised
by an engineering firm to slope the top of the landfill inward.
This was to collect water on the site and minimize runoff onto
surrounding farm fields.
EPA proposed the site for the National priority List in
september 1983, and finalized it in september 1984. In 1986, at
the request of the PADER, EPA conducted a removal action to
control runoff onto neighboring farm fields. The removal action
involved partial regrading of the site, and the construction of
two water retention ponds on the south end of the site to control
runoff thorough a stone-lined drainage ditch.
The RIfFS for OU 1 was completed in August 1988, and EPA
issued the ROD in September 1988.
The major components of the ROD are:
o
Elimination of On-site Ponded Waters
Regrading
Pennsylvania-Type MUlti-Layer Cap
RunonfRunoff Controls
Runoff Monitoring
Ground Water Monitoring
Perimeter Fencing
Deed Notice
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A complete description of EPA's selected remedy is presented
in the ROD.
Description of Significant Differences
The requirement to comply with the wetlands ARAR is the
significant difference between the 1988 ROD and this ESD.
Approximately seven acres of the surface of the landfill are
covered by wetlands. These wetlands must be removed in order to
cap the landfill and reduce infiltration through the waste and
subsequent contamination release into the ground water. Section
404 of the Clean Water Act is the location-specific Federal ARAR
for the Dorney Road site OU 1 and Executive Order 11990
"Protection of Wetlands" is a To Be Considered (TBC) document.
The Dam Safety and Encroachments Act, 32 P.S. S 693.1 et seq. and
the Dam Safety and Waterway Management Regulations, 25 PA Code
Chapter 105 are the State ARARs.
A wetlands delineation and preliminary cost analysis has
been done, and a summary of this is included in the
AdministratIve Record. The goal of "one to one" mitigation is to
replace the wetlands that will be eliminated when the site is
capped. Essentially, the total area of the new wetlands should
also be seven acres, with 4.5 to 5 acres inundated a majority of
the time. The 1988 ROD called for "runon/runoff controls", and
discussed constructing sedimentation ponds to contain the clean
surface runoff from the capped area. These ponds, which are
already required for the remedy, could serve a multiple purpose
of containing runoff, mitigating wetlands and becoming quality
habitat for the varied wildlife at the Site.
The costs of constructing this mitigation measure are
estimated and include the conservative assumption that the
wetlands mitigation would not be incorporated into the
sedimentation ponds. The estimated capital cost to mitigate the
wetlands under this scenario is $270,000, and the Operation and
Maintenance is estimated to be approximately $5,000 per year.
The sedimentation ponds whose size is similar to that required
for the wetlands, could be used for this purpose. The actual
incremental cost for this option is not able to be estimated, but
is expected to be less than the costs estimated above.
This ESD will not significantly effect the scope,
, performance, or cost of the remedy.
support Agency Comments
The Commonwealth of Pennsylvania has concurred on this ESD.
Affirmation of Statutory Determinations
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Considering the new information that has been developed and
the changes that have been made to the selected remedy, EPA and
PADER believe that the remedy remains protective of human health
and the environment. This remedy is cost-effective, and
complies with federal and state requirements that were identified
by the lead agency in the ROD and this ESD as applicable or
relevant and appropriate to this remedial action. In addition,
the revised remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable for this
site.
Public participation
This ESD and the information upon which it is based are
included in the Administrative Record file for this site.
EPA placed a notice informing the public of a fourteen day
public comment period for this ESD in the Allentown Morning Call
on April 10, 1991. The comment period will run from April 10 to
April 24, 1991.
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PENNSYLVANIA
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Waste Management Program
Northeast Regional Office
90 East Union Street - 2nd Floor
Wilkes-Barre, PA 18701-3296
(717) 826-2511
June 13, 1991
US Environmental Protection Agency (3WW 22)
841 Chestnut Building
Philadelphia, PA 19107
Attention: Fran Costanzi
RPM-Northeast Pennsylvania Section
RE: Letter of Concurrence
Explanation of Significant Differences
Dorney Road Landfill-Operable Unit #1
Lehigh County
Dear Ms. Costanzi:
This is in reply to your letter dated June 7, 1971, concerning the Dorney Road
Landfill Superfund site. The Department has reviewed the draft document
associated with this site entitled, "Explanation of Significant Differences".
The Department concurs with EPA's proposed significant change as follows:
Wetlands encountered on the landfill surface, which will be
eliminated when the site 1s capped, will be mitigated on a
"one to one" basis.
Thank you for the opportunity to concur with this EPA Explanation of Significant
Differences. If you have any questions regarding this letter, do not hesitate
to contact me:
Sincerely,
William F. McDonnell
Regional Solid Waste Manager
Recycled Paper
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DORNBY ROAD LA!mPILL
BXPLANATION OP SIGHIPICAHT DIPPERBHCBS
Response to Comments
A.
INTRODOCTION
On April 10, 1991, the Environmental Protection Agency (EPA)
issued a draft Explanation of Significant Differences (ESD) for
Operable Unit 1 (OU 1) of the Dorney Road Landfill Superfund
Site. Although public comment periods are not required by law
for ESDs, it was decided to hold a two week public comment period
to gather public input concerning the proposed wetlands
mitigation at the site. The comment period ran from April 10 to
April 24, 1991. On April 11, 1991 a meeting was held with
representatives of the Potentially Responsible Parties (PRPs).
The PRPs have agreed to comply with the Unilateral Administrative
Orders (UAOs) which require implementation of the remedy
described in the Record of Decision (ROD) for OU 1.
R. Emory Mabry, primary owner and initial operator of the
landfill, was informed of the proposed ESD in a meeting at his
daughter's house on April 3, 1991. Upper Macungie Township, was
informed of, and provided copies of the draft ESD and supporting
documents to ensure the availability of these documents for
public use during the comment period. The Public Repository for
the Site is located at the Township Building. Comments from the
Pennsylvania Department of Environmental Resources (PADER) had
been solicited during the drafting of the ESD, and were included
in the draft that was released for pUblic comment.
The only comments received concerning the ESD were from the
PRP group which has already stated it will comply with the UAOs.
The comments received from this group are addressed below. The
comments are listed numerically, as received, with EPA's response
following each comment.
B.
SUJlKARY OP COJOUDrl'S RBCBIVED DURIJrG HB PUBLIC COJOlBJrT PERIOD
1. EPA has incorrectly determined the limits and nature of any
jurisdictional wetlands present at the site.
EPA ReSDonse: The Federal Manual for the Identification and
Delineation of Jurisdictional Wetlands, January 1990, sets forth
. the procedure for identifying wetlands using three parameters:
hydrophytic plants, wetlands hydrology, and hydric soils.
Representatives of EPA and the U.S. Army Corps of Engineers
(COE) conducted several site visits, as reflected in the various
reports and other documentation supporting the ESD. During these
visits, data concerning all three wetlands parameters was
collected.. This data formed the basis for the final wetlands
determination.
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Hydrophytic vegetation was found in the depressional
settings on the landfill. Several species of wetlands obligates
(cattail, spike rush, and bull rush) were observed. In addition,
EPA officials found both saturated soil conditions as well as
standing water in the depressional settings. Site-specific soil
borings indicate that the soil is made up of silty clay of low
permeability, as evidenced by the large areas of ponded water.
Both EPA and COE representatives observed the obvious soil
saturation and inundation of water, which is typical of wetlands
hydrology. Therefore, all three wetlands parameters were
demonstrably satisfied. In fact, the PRPs' own consultant does
not dispute the finding that the landfill contains wetlands.
section 3B of the EPA-COE Memorandum of Agreement (MOA)
states, "In the absence of more definitive information on the
functions and values of specific wetlands sites, a minimum of 1:1
acreage replacement may be used as a reasonable surrogate for no
net loss 'of function and values."
As the report done by the COE for the Site states on page 2,
approximately 7 acres of potential wetlands habitat was
identified during the field visit, including 4.5 acres of
vegetated/open water wetlands. Therefore, EPA is requiring the
minimum acreage replacement allowed by the MOA.
2. EPA has recognized that mitigation under section 404 of the
Clean Water Act is not required in all instances.
a. EPA has recognized that mitigation under Section 404 of
the Clean Water Act is not required in all instances.
EPA ReSDonse: Mitigation for lost wetlands may not necessarily
be required by federal agencies in all cases of adverse impact to
wetlands. However, EPA and the COE have discretionary authority
to require mitigation for lost wetlands in the condition of
issuing a permit. ~ 33 C.F.R. S. 325.4. [Although section
121(e) of the Comprehensive Environmental Response, compensation
and Liability Act (CERCLA) as amended, 42 U.S.C. S 9621(e)
provides for exemption from obtaining a permit for any response
actions which are conducted entirely on-site, the Party
responsible for the response action must still comply with the
substantive requirements of the Applicable or Relevant and
Appropriate Requirements (ARARs).] This discretionary authority
. is very broad, and applies to All federally protected wetlands,
regardless of the method of creation, function or apparent value
of the particular wetlands system.
The commentor cites to the EPA-COE MOA on Mitigation as
supporting the position that mitigation should not be required at
all at the Dorney Site. However, the MOA while addressing the
concepts ~t function and value of impacted wetlands does so only
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with regard to the "level" of mitigation required in any
particular case. The MOA addresses the three prong conceptive
"mitigation" as including avoidance, minimization and finally,
compensatory mitigation. It provides that where avoidance and
minimization can not or have not prevented the destruction or
damage of the wetlands system, then compensatory mitigation is
required. (See MOA at page 4: "appropriate and practicable
compensatory mitigation is required for unavoidable adverse
impacts which remain after all appropriate and practicable
minimization has been required.")
Because of this significant degradation of the wetlands
system at the Dorney Site, EPA believes that requiring
compensatory mitigation is both appropriate and practicable.
The contamination at the Site and the n~ed for remediation
necessitates the landfill be capped to reduce ground water
contamination. This will result in wetlands destruction.
Enhancement of the already planned containment basins is an
appropriate, practical and cost-effective approach to replacing
the wetlands while remediating the threat at the site.
2.b. The activities required under the ROD are covered by the
nationwide permits under the CWA.
EPA ResDonse: Two specific nationwide permits were referenced
in the comments.
Nationwide Permit 20 (NW 20), 33 C.F.R. S 330.5(a) (20),
applies to emergency response actions, in which the Regional
Response Team is activated under the NCP. This is not the
situation at the site. The Regional Response Team has not been
activated with regard to the proposed remediation at the site,
therefore, NW 20 is not applicable..
Nationwide Permit 26 (NW 26), 33 C.F.R. S 330.5(a) (26),
provides for a general national permit for fills of wetlands in
headwaters or isolated wetland systems of less than 10-acres.
However, when the impact involves more than 1-acre but less than
10-acres (as in this case), the COE has discretionary authority
to require the individual permit applied for. ~ aenerally 33
C.F.R. S 330.8. That application is to be reviewed and analyzed
under applicable standards, including the guidelines under
section 404(b) (1) of the Clean Water Act (CWA) as amended, 33
U.S.C. S 1344. ~ 33 C.F.R. S 330.7(d). The guidelines require
. mitigation for lost wetlands. ~ generally, 40 C.F.R. Part 230.
Thus, the COE always retains the right to require compensatory
mitigation as a condition to issuing a permit, even when a
proposed fill is less than 10-acres.
3. Mitigation of wetlands at the site is not required under
Pennsylvania law.
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a. Wetlands mitigation under the Dam Safety and
Encroachments Act is not required for the wetlands at the site.
EPA ReSDonse: Section 105.15(b) (3) of PADER's Chapter 105 Rules
and Regulations require that the PADER consider, and the
applicant undertake, actions to mitigate any unavoidable adverse
impacts which would be created as a result of a proposed
activity. Roger Fickes, Chief of the Division of Rivers and
Wetlands at PADER, has reiterated the Commonwealth's position in
his memo dated June 14, 1991. In this letter he states that the
remedial action must include construction of replacement wetlands
resources of an equal areal extent for those areas being
eliminated.
3.b. Since there is no value to the wetlands allegedly found at
the site no mitigation is required under Pennsylvania law.
EPA ReSDonse: EPA disagrees with the statement that the wetlands
are without value. In Peter Stokely's memo dated May 6, 1991:
liAs compared to the surrounding landscape of corn fields and
farms the Dorney Rd. landfill stands out as an island of
biological diversity. The open water and vegetated wetlands act
as a beacon to passing waterfowl. The usage of this wetlands by
waterfowl and other birds which tend to utilize wetlands areas,
as well as terrestrial species is documented in my report dated
October 3, 1990. The diversity of both terrestrial and aquatic
flora that I observed in the field was very high as compared to
the surrounding area."
Further, the commentor's own consultant has concluded there
is wetlands hydrology and wildlife on the site. Additionally,
the value of the wetlands is factored into the level of
mitigation that will be required. EPA has considered this in
making a determination to require 1:1 mitigation. (See response
to comment #1 above.)
3.c. A waiver of the state ARAR is warranted at this Site. (The
commentor referred to the East Side Landfill as an example of
where the State has inconsistently applied the ARAR.)
EPA ResDonse: EPA disagrees. From information provided by
PADER, it appears that the East Side Landfill has contracted with
a wetlands specialty firm to oversee the construction of five
sediment basins to replace the wetlands areas which have become
. habitat at the site. Therefore, there appears to be no
inconsistency between the State asserting their ARAR for
mitigation at the site and the State's actions regarding the East
Side Landfill.
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