Urezxi Stales
Environ
Agency
Office of
Emergency and
r'c-titjial Response
EPA/ROCVR03-9
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50272 101
REPORT DOCUMENTATION 11. REPORT NO. I ~ 3.. Rec:lpi8n1'1 ACCH8Ion No.
PAGE EPA/ROD/R03-90/103 '..
4. TItle end Subtl.. S. A8pan 0.18
SUPERFUND RECORD OF DECISION 06/29/90
East Mt. zion, PA
IS.
First Remedial Action - Final
7. Allthor(l) IS. Pwfonnlng Organization Rept. No.
a. Pertonnll19 OrgljnlDdon - end Add- - 10. ProjectIT ulllWorII Unll No.
11. ContrIC1(C) at Gr"",G) No.
(C)
(0)
12. Sponeoril19 Org8nlU1lon - end AddrIM 13.. Type ot Report . Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
1 S. Supplemlnll1'f NoIII
16. AbetrlC1 (Uml1: 200 _Idl)
The 10-acre East Mt. Zion site is a privately owned, inactive landfill in Springettsbury
TownShip, York County, Pennsylvania. The landfill is on a forested ridge along with
recreational park lands and a residential subdivision. From 1955 to 1972, domestic,
municipal and industrial wastes were disposed of onsite. In 1969 and 1971, the landfill
was cited for improper disposal practices and was subsequently closed by the State in
1972. In 1983 and 1988, State investigations identified several contaminants in onsite
ground water and leachate. This Record of Decision (ROD) addresses the ground water
contamination by inhibiting the mobility of contaminants from the landfill. The primary
contaminants of concern affecting the ground water are VOCs including vinyl chloride and
benzene.
The selected remedial action for this site includes capping the landfill with an
impermeable mUlti-layer cap; constructing a passive vent system to control methane
offgasses; installing surface water control systems for the cap; allowing natural
attenuation to reduce ground water contamination to background levels; conducting ground
water monitoring to monitor natural attenuation of contaminants; and implementing
(See Attached Page)
11. Docurnenl An8/y8I8 .. DMafpIo,.
Record of Decision - East Mt. Zion, PA
First Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (benzene, vinyl chloride)
b. Identlt\lr8lOpen.End8d T-
Co COSA n FIIIcIIGt-.
18. Avlillbllly SI-.- 18. SIcutty CIau (ThI8 ~ 21. No. ot PIli"
None 81
211. SIcutty CIau (ThI8 P8g8) 22. PrfC8
None
: (4-71)
(See AN$oZ3t.18)
s.1MIrtd_on~
(formllfy Nf1S.35)
Di,.- L._.I of CorNl8rC8
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EPA/ROD/R03-90/103
East Mt. Zion, PA
First Remedial Action
- Final
Abstract (Continued)
institutional controls, including deed restrictions, and site access restrictions, such
as fencing. The estimated present worth cost for this remedial action is $2,230,000,
which includes an annual O&M cost for ground water monitoring.
PERFORMANCE STANDARDS OR GOALS: Based on ground water velocity and the elimination of
the source, ground water concentrations are expected to meet background levels within
five years through natural attenuation. Chemical-specific goals for ground water
include benzene 5 ug/l (MCL), and vinyl chloride 2 ug/l (MCL).
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DECLARATION
FOR THE
RECORD OP DECISION
site Name and Location
East Mt. Zion LAndfill
springettsbury Township, York County, Pennsylvania
Statement of Basis and Pureose
The decision document presents the selected remedial action
for the East Mt. Zion site in Springettsbury Township,
Pennsylvania, which was chosen in accordance with the Comprehensive
Environmental 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 oil and Hazardous Substance Pollution Contingency Plan
(NCP) . This decision is based upon the contents of the
administrative record for the East Mt. Zion site.
The United States Environmental Protection Agency (EPA) and
the pennsylvania Department of Environmental Resources (PADER)
agree on the selected remedy.
Assessment of the site
Actual or threatened release of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
Descriction of the Remedy
This remedy addresses remediation of ground water
contamination by eliminating or reducing the risks posed by the
site through engineering and institutional controls.
The selected remedy includes the following major components:
o
Installation and maintenance of an impermeable cap and
gas vents over the 10-acre landfill
o
Installation and maintenance of surface water control
systems for the cap
Installation and maintenance of a fence around the site
o
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SUBJECT:
FROM:
TO:
i
I ~
"
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 1/1
841 Chestnut BUildIng
Philadelp"Ha. PennsylvanIa 19107
Record of Decision - Transmittal Memo
DATE:
June 28. 1990
Thomas C. Vo~taggio. Associate
Office of Superfund (3HW02)
Dir~
/
Edwin B. Erickson
Regional Administrator
(JRAOO)
Attached is the Record of Decision (ROD) for the East Mt. Zion
Superfund Site.
The decision outlines all necessary remedial
actions which must be performed in order to be protective of
th~ public health and the environment.
There were no significant
changes from the Proposed Plan to the ROD.
I recommend that you
sign the attached document.
The Commonwealth of Pennsylvania
has concurred with this decision.
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o
Monitoring ground water contaminant attenuation after
installation of the cap
o
Initiation of a deed
activities at the site.
restriction
regarding
future
Declaration
The selected remedy is protective of human health and the
environment, complies with Federal and state requirements that are
legally applicable 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 the site.
However, because treatment of the principal threats of the site was
not found to be practicable; this remedy does not satisfy the
statutory preference for treatment as a principal element. As this
remedy will result in hazardous substances remaining onsite above
health based levels, a review will be conducted within five years
after the initiation of the remedial action to ensure that the
remedy continues to provide adequate protection of human health and
the environment.
C-.~.
~~/A-"
Date
. Erick n
~gional Administrator
Region III
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Site Description and Summary of
Remedial Alternative Selection for the
East Mt. Zion Superfund site.
York County, Pennsylvania
SITE LOCATION AND DESCRIPTION
The East Mount Zion site is located in Springettsbury
Township, York County, Pennsylvania, upon a wooded ridge east of
Mount Zion and approximately 15 miles southeast of Harrisburg.
It is located along the south side of Deininger Road just before
the entrance to Rocky Ridge County Park. The site location is
shown in Figure 1.
The site is situated on 10 acres atop an 860-ft-high .
forested ridge. Bounding the site to the east, north, and south
is the York County Recreation Park, Rocky Ridge; Doersam Woods
subdivision bounds the site to the immediate west. Also
dispersed among the woodlands areas and at lower elevations to
the south (Ridgewood Road), west (Mount Zion Road), and north
(Deininger Road and Druck Valley Road) are numerous private
dwellings.
On the southern side of the property, the height of the
landfill gradually increases from east to west until, at the
southwestern end, there is a steep rise culminating with an
approximately 70 percent toe slope. The toe slope averages 70-80
percent along the southern edge of the landfill. The northern
half of the landfill, which bounds Deininger Road, is flatter and
gradually approaches the grade of the roadway. Exposed refuse is
located on the steep side slopes. Figure 2 shows the site
topography and approximate fil.l boundary.
The East Mount Zion site is located in the Conestoga Valley
Section of the Piedmont Physiographic Province. The Conestoga
Valley section includes a relatively flat central valley and two
prominent hill areas on the northwest edge of the section--the
Pigeon Hills north of Hanover and the Hellam Hills northeast of
York. The hill areas coincide with the outcrops of hard
quartzite and conglomerate.
The predominant bedrock underlying the site has been mapped
as the Hellam Member of the Lower Cambrian Chickies Formation.
The Chickies Formation is typically a massive, prominently
bedded, white arkosic quartzite and quartz pebble conglomerate in
a sericitic, arkosic matrix. Structurally, the site is situated
on the upper plate of the Glades Overthrust on the northwest limb
of the Mount Zion Anticline, which strikes east-northeast to
south-southeast. . Bordering the site to the southeast is the
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2
Highmount Overthrust. In the vicinity of the site, bedding plane
strike and dip is approximately 32 degree E, 29 degree SEe Field
measurements indicate the orientation of the primary joint set to
be N66 degree SW with joint spacings on the order of 10-15 ft
(Lloyd and Growitz 1977). The site is situated at an average
elevation of 860 ft mean sea level (MSL) , just north of the ridge
crest of 880 ft MSL. The topography primarily slopes to the
northwest, west-southwest and southeast.
The in situ soil underlying the site consists of highly
permeable Edgemont Channery stoney loam which ranges in thickness
from <2 to 15 ft. The soil is well drained. Much of the in situ
soil was stripped away and redistributed over the site during
waste disposal operations. Additionally, other soil from offsite
locations may have been utilized for the final cover fill.
The site is situated within the Susquehanna River Basin and
lies at the divide of the Codorus and Kreutz Creek watersheds to
the west and southeast, respectively. Subsurface drainage is
channeled via two tributaries. Both drainage density and
patterns are controlled by geologic features (i.e., topography,
bedding, and jointing). Near the site, the dominant drainage
pattern is semirectangular to the south and east, and semiradial
to the west. Surface runoff exits the site to the west along an
adjoining intermittent stream which turns south toward the
township of East York. Surface runoff exiting the southern and
eastern slopes of the landfill enters an unnamed intermittent
stream which flows south to Kreutz Creek. A leachate seep
emanating from the southeast corner of the site previously
discharged to the intermittent stream at the southeast boundary
of the site: however, recent regrading of a dirt access road has
dammed the seep and formed a small leachate pond.
The Chickies Formation, Hellam Member, constitutes the major
aquifer beneath the site. Secondary porosity in the form of
fractures and joints control both the storage and flow
characteristics of the aquifer. Ground water flow is typically
controlled by surface topography (i.e., recharge topographic high
areas, discharge adjacent low-lying streams and springs). Data
from the existing Doersam Woods test well adjacent to the
northwest property boundary indicate bedrock aquifer water levels
are on the order of 100-120 ft below the surface. Typical of
this type of ground water regime, fluctuations of 20-30 ft are
not uncommon, especially in the recharge zones (i.e., hills).
Water-bearing zones (open fractures and joints) are reported to
occur with consistent frequency to about 200 ft below the
surface. The average specific capacity of a well drilled in the
Chickies Formation is 0.34 gpmjft. Average well yields are about
8 gpm with 50 ft of drawdown after 1 day of pumping. The maximum
reported well yield for the Chickies Formation is 100 gpm.
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3
Typically, fracture density and aperture decrease
increased depth. Below 250-300 ft, fracture apertures
and few: water contribution from these deeper fracture
usually negligible.
with
are small
sets is
since the initiation of pennsylvania Department of
Environmental Resources (PADER) investigations pertinent to the
site, Springettsbury Township has installed municipal water
supply lines along portions of Mount Zion, Deininger, Druck
Valley, and Ridgewood roads. As a result, many of the residences
that were once dependent on private supply wells are now using
the township water supply. However, the water line installation
is incomplete along Druck Valley and Ridgewood roads and some
residences along portions of these roads are still using ground
water obtained from private wells that withdraw from the Chickies
Aquifer. As part of the RI, the private wells of residences on
Druck Valley and Ridgewood roads not serviced by the municipal
water line were sampled. Since these samples were taken, these
residences have also been hooked up to the township water supply.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Over the course of its active life (approximately 1955 to
1972), the site was a repository for domestic and industrial
wastes. It operated as an area-type landfill in which areas for
filling were excavated (at times to nonrippable bedrock), filled,
and covered with native materials. There is evidence that the
site was operated as an open-burning dump at some period in its
history. The site presently exists as an open field on which
weeds and small woody plants grow. The cover placed on the site
at and since closure of the site is thin, and in some locations
waste materials, such as tires, are protruding.
The site was purchased in January 1952 by Charles H. Fetrow.
Mr. Fetrow used the property as a nonpermitted disposal site for
residential and industrial wastes. The date when disposal
operations commenced is unknown: however, a 1955 aerial
photograph shows signs of some excavation activity at the site.
Early 1963 PADER inspection reports on the landfill indicate
improper disposal of residential and industrial wastes. Notes of
interviews conducted by PADER personnel indicate that paint
thinner, paint filters, and metal sludge wastes were disposed at
the site.
Throughout 1969 and 1971 PADER personnel completed numerous
Sanitation Establishment Inspections on the site. Discrepancies
were frequently cited, pointing out that garbage and trash were
being placed directly on bedrock in open trenches, and that
proper cover was not being applied on a daily basis, as required.
Litter control was also inadequate. The landfill was closed in
1972 by court order and has remained inactive since. Some
additional grading, covering, and seeding was conducted by the
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4
site owner under court order from 1974 to 1976.
property has changed owners several times.
Since 1974 the
In 1983 EPA conducted a Preliminary Assessment and Site
Inspection (PA/SI) at the site. The site inspection revealed
trace levels of trichloroethylene (TCE) in ground water samples.
Benzene was reported in a leachate sample, and dichlorobenzene
was found in a leachate and pond sediment samples. Previous
investigations by the Pennsylvania Department of Environmental
Resources (PADER) indicated low level contamination of one
monitoring well and surface water samples. A test well near the
northwest boundary of the site was reported by PADER to contain
trace levels of several organic compounds including vinyl
chloride and benzene. PADER also sampled wells serving Rocky
Ridge County Park. No organic pollutants were detected in these
samples. The landfill was listed on the Superfund National
Priorities List (NPL) in September 1984. An RI/FS was conducted
to quantify any contamination which might be attributable to the
site; to assess any risks to human health and the environment;
and to develop a set of alternatives which could be used to
address any risks posed by the site.
Eleven potentially responsible parties (PRPs) have been
identified as being associated with the site. These PRPS were
sent General Notice Letters in April 1989 to come forward and
take responsibility for part, if not all, of the RI/FS. Due to
inadequate interest on the part of the PRPs to perform the RI/FS,
the State of Pennsylvania took the lead for performing the RI/FS
under a Cooperative Agreement with EPA. Field work for the RI/FS
commenced in February 1988 and was completed by April 1989.
COMMUNITY RELATIONS
Pursuant to section 300.67(c) of the National Contingency
Plan (NCP), a Community Relations Plan was developed for the
Proposed Plan that was based on the Remedial
Investigation/Feasibility Study (RI/FS). In compliance with
sections 113(k) (2) (i-v) and 117 of SARA, the Administrative
Record, including the Proposed Remedial Action Plan, was placed
for public viewing at the Springettsbury Township Building on
Friday, May 18, 1990.
An announcement of the availability of the Administrative
Record was placed in the York Dailv Record on May 18, 1990. The
Administrative Record contained the Draft Remedial
Investigation/Feasibility Study Reports which listed the
alternatives developed as part of the Feasibility Study. A
period for public review and comment on the P~oposed Remedial
Action Plan was held from May 18, 1990 to June 18, 1990. A
public meeting was held on May 30, 1990, at the springettsbury
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5
Township Building rega~ding EPA and PADER selection of the
preferred alternative. Approximately 25 people were in
attendance at the meeting.
SCOPE AND ROLE OF RESPONSE ACTIONS
The scope and role of the response action for the East Mt.
Zion landfill is to prevent further contamination of the deep
ground water aquifer by controlling or eliminating the source of
contamination to the aquifer. The response action addresses the
ground water contamination at the site which is the principal
threat posed by the site.
SUMMARY OF SITE CHARACTERISTICS
Waste Fill Characterization
The areal extent and volume of the fill material were
estimated using geophysical survey results and identifying high
conductivity anomalies of the fill that may be associated with
high concentration of metallic constituents. The results of the
terrain conductivity survey indicated a relatively heterogeneous,
moderately high to very high conductive fill. The survey
estimated the approximate thickness of the fill to be typically
less than 15 ft thick in the east to a maximum thickness greater
than 45 ft along the southwest and west portions of the site.
The results of the soil vapor contaminant assessment (SVCA)
indicated significant levels of methane gas in the soil vapor at
the site. In general, the northern portion of the site contains
the highest levels of methane. Organic compounds (benzene and
toluene) were also detected during the SVCA in the fill. The
highest organic compound concentrations occurred in the eastern
and northeastern portions of the fill.
Data from the geophysical survey and SVCA were used to pick
locations for the waste characterization borings. The results of
soil borings performed in the fill indicated that the fill ranges
from 11 to 33 ft in thickness and may be up to 50 ft thick in the
.southwest and west-central portions of the site. The waste
material, which was saturated at some borings, typically
consisted of general household and munictpal refuse, including
wire, paper, cloth, brick, wood, glass, plastic, and cans, with a
matrix of silty sand. Significant decomposed organic debris
apparently accounts for much of the methane generated. Sample
locations are shown in Figure 3.
Eighteen waste samples were obtained at varying depths from
six waste characterization boring locations. Additionally, one
waste material sample was observed and then collected at the
surface near the toe of the fill. Analytical results show that
trace metals concentrations were elevated in the majority of
samples. Trace metal concentrations are shown in Table 1. In
..
..
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6
general, the concentrations ranged from 2 to 500 times
concentrations normally found as an average in background soil
samples. In general, the greatest number of trace metals were
detected in boring B-5. However, the highest concentrations of
several trace metals (i.e., copper and aluminum) contamination
were detected in the exposed waste sample. The metals observed
are generally consistent with known past disposal practices at
the site and metals such as cadmium, chromium, and zinc were
previously sampled in sludges that were reportedly disposed of at
the site.
~.
various volatile organic compounds (VOCs) and semivolatile
compounds were detected in the waste. The volatile organic
compounds which were observed at significant levels in the fill
included acetone, 2-butanone, toluene, chlorobenzene,
ethylbenzene, and xylenes. Although the soil vapor indicated the
presence of TCE and PCE, those chlorinated compounds were not
observed during the waste sampling.
Pesticides were detected in a total of four of the composite
samples from waste borings B-1 through B-4. PCBs were detected
in several soil boring samples collected. Two borings, B-3 and
B-5, had concentrations above Ippm (although estimated values) of
Arochlor 1016 and 1254.
Ground Water
Ground water was sampled from each of ten monitoring wells
during three different sampling rounds conducted 19-20 April, 24-
25 May, and 15 September 1988. Analytical results for ground
water samples from the monitoring wells around the perimeter of
the site reflected low level contamination from the fill. The
population at risk were area residents that were still using
ground water as a drinking water source.
The majority of the ground water trace metal concentrations
were less than the drinking water standards or at naturally
occurring concentration levels, as defined by. the literature
. value ranges. The only trace metal contaminants consistently
(for two or more sampling events) detected above the literature
concentration ranges and/or drinking water standard MCLs in
various wells were cobalt,- iron, magnesium, and manganese.
There were no PCBs detected in any of the ground water
samples. Also, with the exception of a relatively low level of
endosulfan sulfate detected in Well EA-SD during the May sampling
round, no pesticides were detected.
There were only a few monitoring well samples containing
relatively low concentrations of a small group of volatile and
semivolatile compounds. Almost all organics observed were not
consisteritly measured in more than one sampling round. Also, all
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7
were observed at low concentrations. A few compounds (volatile
and semivolatile) were consistently detected during all three
sampling rounds. The volatile compounds consistently detected in
all three sampling rounds included 1,1, dichloroethane, benzene,
and chlorobenzene. The semivolatile compounds detected in all
three sampling rounds at low concentrations were 1,4
dichlorobenzene and bis(2ethylhexyl)phthalate.
Also, vinyl chloride concentrations in EA-4D and EA-6D were
6 and 7 ug/L, respectively, during only the April sampling event.
Also, since TCE was detected during the SVCA and since vinyl
chloride is a degradation product of TCE (and PCE) the observed
vinyl chloride concentrations may be a direct result of leachate
generation during the spring months.
Figure 3 presents reasonable worst case average
concentrations of detected compounds for the monitoring wells.
As illustrated in Figure 3, vinyl chloride and benzene
concentrations marginally exceed their primary maximum
contaminant levels (MCLs) in the deep aquifer zone at the site
perimeter. The MCLs for vinyl chloride and benzene are 2 ug/L
and 5 ug/L, respectively. Manganese also exceeded the secondary
maximum contaminant level (SMCL) in the majority of samples at
the site perimeter.
Ground water samples were also obtained on 28-29 August 1988
from 14 residential wells, two wells on the Rocky Ridge Park
property, and one well on a lot for Doersam Woods. The locations
of the residential, Doersam Woods test and park wells in relation
to the East Mount Zion site are shown in Figure 4.
The trace metal concentrations for the residential wells
(Table 2)- were within the acceptable levels as defined by MCLs
and SMCLs. The iron and manganese concentrations exceeded the
SMCLs for seven and three residential locations, respectively.
No elevated levels of cadmium, chromium, or zinc were observed.
The Old Park Well had a high lead concentration (68.6 ug/L) :
however, since no monitoring wells showed high levels, the
concentration is not believed to be related to the site.
Furthermore, the water in the Old Park Well was stagnant for a
long period of time. This may also be a reason why lead levels
in this well were elevated.
No detectable levels of PCBs, pesticides, or volatile
organics were observed during any sampling events. One
semivolatile compound, di-n-butylphthalate, was detected at 6
ug/L at one residence, which may be a result of laboratory
contamination, since (1) the compound was also detected in the
method blank, and (2) it was not detected in any other domestic
or ground water samples (di-n-butylphthalate is a known
laboratory contaminant).
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8
The ground water flow patterns identified at the site
include several interrelated regimes. The flow regimes include a
shallow water-bearing zone, which is seasonal in nature, an
intermediate zone, and a deep water-bearing zone. The depth to
ground water is generally less than 20 ft. The shallow zone is
in intimate hydraulic communication with the saturated portion of
the landfill. Based on the waste characterization data, shallow
water-level data, and surface topography, a radial flow pattern
from the fill is inferred. outside the radial flow influences,
the shallow water flows predominantly in a westerly and
southeasterly direction where it discharges into intermittent
streams. The intermediate zone is also seasonal in occurrence.
and serves as a transitional zone from the shallow to the deep
zone.
The deep water zone is the regional aquifer and exists under
unconfined conditions. Ground water flow in this zone is through
fractures, joints, and weathered seams. Based on the seasonal
nature of the shallow and intermediate zones and the contaminant
levels observed in the deep wells, it is believed that the
primary zone of ground water transport of contamination is the
deep water-bearing zone. Ground water flow in the deep aquifer
is to the north-northwest. Linear ground water velocities in the
deep zone are relatively high-9 ft/day. Therefore, residences
located along the linear fracture traces would have received
ground water that passed under the site within a 9-month period.
This fact also points out the dilution of leachate infiltration
to the deep-flow zone. The relatively high transmissivity range
calculated for the aquifer ranges from 4,840 to 8,470 gpd/ft.
The resultant average concentrations observed in the
monitoring wells at the site are presented in Figure 3. The
average concentrations of the most soluble/mobile constituents
are at or below the contract required detection limits (CRDLs)
for those compounds. These constituents also averaged
concentrations marginally above the MCLs. Therefore, minimal
ground water dilution will result in concentrations below MCLs.
Based on the low concentrations, no offsite ground water modeling
was conducted, and concentrations observed in the monitoring
wells at the site were used for input to the risk assessment.
It is EPA's Superfund policy to use EPA's Groundwater
Protection Strategy and Groundwater Classification Guidelines to
assist in determining the appropriate type of remediation for a
Superfund site. Three classes of ground water have been
established on the basis of ground water value and vulnerability
to contamination. The deep aquifer at the site is a Class II
aquifer. A Class II aquifer is one which is a current or
potential source of drinking water and water having other
beneficial uses.
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9
Surface Water and Sediment
Surface water and sediment samples are grouped together
because of the close association between the two groups.
Populations at risk are wildlife and aquatic life that may be
impacted by the. surface water and sediment contamination.
The site is situated within the Susquehanna River Basin and
.lies at the divide of the Codorus and Kreutz Creek watersheds to
the west and southeast, respectively. Subsurface drainage is
channeled via two tributaries. Both drainage density and
patterns are controlled by geologic features (i.e., topography,
bedding, and jointing). Near the site, the dominant drainage
pattern is semirectanqular to the south and east and semiradial
to the west. Figure 5 shows the general surface water flow
patterns at the site.
Surface water runoff and seepage of leachate from the
eastern portion of the fill are currently channeled to a
perimeter ditch along the southwestern boundary, which in turn
empties into a surface water/leachate collection pond at the
southeastern corner of the site.
Surface water runoff and seepage of leachate from the
western portion of the fill are collected along the southwestern
site boundary by a shallow ditch and channeled to a large
diameter corrugated pipe, which in turn is connected to the
Doersam Woods Subdivision storm sewer system. Surface water
runoff from the central portion of the fill is directed toward a
depression near the center of the fill where, during the later
winter months, it remains ponded.
Analytical results for surface water samples collected at
the seeps at the southeast and western portions of the fill
showed limited contribution of contaminants from the waste fill.
The only detected organics in the leachate seep were acetone,
benzoic acid, lindane, xylenes, and bis(2-ethylhexyl)phthalate,
all at very low levels.
The metals concentrations for the west leachate seep were
generally higher than the southeast leachate 'seep. Elevated
inorganics included copper; manganese, and mercury. The
potential impacts, however, appear minimal based on the
following:
copper
Perennial upstream concentrations were higher
than downstream concentrations
manganese
downstream concentrations, from both seeps,
were the same relative concentrations as the
background upstream
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10
mercury
no detectable levels were observed downstream
Also to assess potential partitioning of contaminants into
the sediments at the leachate seeps and possible downstream
waters, samples were collected at observed seeps and local
surface waters.. Since backgrounq sediment concentrations were
not available, the sediment samples were compared to background
soil concentrations and average soil concentrations for
Southeastern Pennsylvania. comparison of average sediment
concentrations to regional background levels show that, with the
exception of cadmium in the southeast leachate sediment sample,
all average sediment concentrations were within or below the
range of regional concentrations. For cadmium, concentrations
above 1.8 mg/kg were observed in the leachate watercourse
sediment and the southeast leachate pond.
No pesticides or PCBs found in the fill were detected ,in any
of the surface water samples. One pesticide, 4,4-00E, was
detected in a composite sediment sample from the southeast
leachate pond watercourse. No other pesticides were identified
in the sediment samples. PCBs were identified in two sediment
samples. Arochlor 1016 was detected in two composite sediment
samples from the southeast leachate pond watercourse at 100 ppb
(a very low level).
Surficial Soil
The results of the samples indicate the presence of only
background levels of metals, and levels of volatile and
semivolatile contaminants were less than the contract required
quantification limits.
SUMMARY OF SITE RISKS
The purpose of the risk assessment performed for the East
Mount Zion landfill site was to evaluate the human health risk
posed by any releases from the site. In order to estimate the
human health risk, the risk assessment focused on the following:
(1) the contaminants detected during the remedial investigation
at the site: (2) the potential environmental pathways by which
populations might be exposed to compounds released from the site;
(3) the estimated exposure. point concentrations of the compounds
of concern: (4) applicable or relevant and appropriate
requirements (ARARs), criteria, and advisories: (5) the estimated
intake levels of the compounds of concern: and.(6) the toxicity
values of the compounds of concern. The level of risk that the
site poses to human health was then quantified.
It was determined that the number of compounds detected at
the site was small enough that a subset of the constituents did
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11
not need to be selected for use in the risk assessment, i,e.,
selection of indicator chemicals was not nece'ssary. Therefore,
all compounds that could be quantitatively evaluated were
included.
Excosure Assess~ent
This step in the risk assessment process involves
determining the potential routes of exposure to the human
population, the estimated concentrations to which the population
is exposed, and the population at risk. The baseline risk
assessment at the East Mount zion site considered the potential
exposure routes, including ground water (drinking water), surface
water (and sediment), air, and direct contact. Of these routes
of exposure, ingestion of ground water (drinking water) was the
only significant human health exposure route identified.
Excosure Point Concentrations
As indicated in previous sections ground water samples
collected from monitoring wells onsite, from nearby offsite
residential wells, and from two offsite nonresidential wells
(i,e., the Abandoned Park Well and the Old Park Well).
were
The ground water data from the wells located at the site
(Figure 3) are indicative of releases occurring to ground water
from the contamination at the site, but are not indicative of the
contamination to which the population is currently being exposed
given that there are no domestic wells at the site. These
moni~oring well data, however, will be used to evaluate the
potential risk associated with hypothetical ingestion of ground
water at the site. Data from the residential wells (Table 3) are
the best available indicators of current risk to the neighboring
population. The two nonresidential wells (the Abandoned Park
Well and the Old Park Well) can be used as potential indicators
of offsite migration, but neither is an actual monitoring well
built to current construction specifications and neither is
currently used as a source of drinking water. These two wells
could, potentially be used as drinking water sources. However,
PADER has notified the well owners that these wells need to be
abandoned. Therefore, the exposure of individuals ingesting
water from these wells is not expected, and the data must be
evaluated within this context.
For the monitoring wells, two exposure cases, an average
case and a reasonable worst-case, were considered based on the
average and reasonable worst-case concentrations detected in
these wells. To calculate these two exposure point
concentrations, the average individual well concentration over
the time period sampled (April to september in most cases) was
calculated first. One-half the instrument detection limit (IDL)
was used in these calculations when a chemical was not detected.
"
, "
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12
An arithmetic mean was then calculated using the individual well
average concentrations to obtain an estimate of the most likely
concentration of chemicals in onsite monitoring well ground
water. The reasonable worst-case concentration of chemicals in
the monitoring wells was defined for the purpose of this risk
assessment as the highest average individual well concentration.
Average and rea~onable worst-case monitoring well concentrations
are presented in Tables 4 and 5.
For the residential wells and nonresidential (i.e., the Old
Park Well and the Abandoned Park Well) offsite wells, each of
which had one valid sample, exposure point concentrations were
considered to be the concentrations of chemicals detected in each
well (i.e., each well was evaluated separately). These
concentrations (corrected for blank contamination and samples
considered invalid) are presented in Table 3. The reasonable
worst-case concentrations of chemicals in any residential well
were also determined and are presented in Table 6. .
Comcarison to Acclicable or Relevant and Accrocriate Reauirements
In the case of ground water concentrations, the appropriate
ARARs are the Drinking Water Standards and Health Advisories,
given that the ground water is used as a source of drinking water
in the area. The pertinent standards are the primary Maximum
Contaminant Levels (MCLs), the Secondary Maximum Contaminant
Levels (SMCLs) and the Lifetime Health Advisories (HAs). The
MCLs are based upon health, technological feasibility and cost
concerns, and carry regulatory authority for public water supply
systems. They have also been considered in many cases to be
appropriate standards for ground water that is used for drinking
water. SMCLs have been established based upon aesthetic
qualities, i.e., odor and taste. They do not carry regulatory
authority, but are meant to serve as reasonable goals for
drinking water quality. The Lifetime HAs are based upon health
concerns and have been established for many compounds which do
not have MCLs. They do not have regulatory authority and are
meant to serve as guidelines for government officials responsible
for protecting public health in the case of spills or
contamination situations.
Concentrations of compounds detected in the ground water at
the site and in wells in the neighboring vicinity of the site,
and MCLs, SMCLs, and Lifetime HAs are presented in Tables 4 and
7. In the case of ground water in monitoring wells at the site
only reasonable worst case concentrations of vinyl chloride and
benzene marginally exceeded their MCLs. Average concentrations
of these two chemicals were less than their respective MCLs.
Average and reasonable worst-case iron and manganese
concentrations exceeded the aesthetically-based SMCLs.
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13
Estimation of Dailv Intake
Because there are not health-based ARARs for each
contaminant of toxicological concern detected in the ground
water, the daily intake of each contaminant was estimated in
order to be use~ in conjunction with appropriate risk values to
determine the total potential risk posed by the site to the
surrounding population. In order to calculate the estimated
daily intake levels (EDIs), the U.S. EPA's standard assumption of
ingestion of 2 L of drinking water per day for an adult with a
body weight of 70 kg was used in the following equation (U.S. EPA
1986a and 1988a)
EDI (mg/kg/day)
=
( C) ( IR )
(BW)
Where
C =
IR =
BW =
concentration of contaminant in ground water (mg/L)
daily drinking water ingestion rate (L/day)
body weight (kg)
The EDIs for the contaminants of concern are presented in Tables
5 and 6. It should also be noted that it was not necessary to
calculate exposure to the residential population via
volatilization of constituents from their well water (e.g., while
showering) given that no volatiles were detected in any
residential water samples.
Toxicitv Assessment
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals.. CPFs, which are expressed in units of (mg/kg-day) -1,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting noncarcinogenic effects. RfDs, which are
exposure levels for humans, including sensitive individuals, that
is not likely to be without an appreciable risk of adverse health
effects. Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated
drinking water) can be compared to the Rfd. Rfds are derived
,
...
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14
from human epidemiological studies or animal studies to which
uncertainty factors have been applied (e.g., to account for the
use of animal data to predict effects on humans). These
uncertainly factors help ensure that the RfDs will not
underestimate the ,potential for adverse noncarcinogenic effects
to occur.
The carcinogenic potency factors for carcinogenic compounds
and RfDs for noncarcinogenic compounds are presented in Tables 5
and 6.
Excess lifetime cancer risks are determined by multiplying
the intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., 1x10-6 or 1E-6). An excess lifetime cancer risk of 1E-6
indicates that, as a plausible upper bound, an individual has a
one in million chance of developing cancer as a result of site-
related exposure to a carcinogen over a 70-year lifetime under
the specific exposure conditions at a site.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived from
the reference dose). By adding the HQs for all contaminants
within a medium or across all media to which a given population
may reasonable be exposed, the Hazard Index (HI) can be
generated. The HI provides a useful reference point for gauging
the potential significance of multiple contaminant exposures
within a single medium or across media.
In the case of contaminants detected in the monitoring wells
at the site, the total HI exceeds one, i.e., 1.5, only under
reasonable worst-case exposure conditions (Table 5). Cadmium and
manganese are the compounds having the greatest impact on the HI,
i.e., 3.4E-l and 1.OE+O, respectively. The estimated daily
intake of either compound does not exceed respective RfD,
although manganese is clearly at its RfD. Risks are assumed to
be additive within type of critical effect. The critical toxic
effects for cadmium are renal effects, and for manganese, nervous
system effects. Therefore, additivity is not assumed for these
compounds. Based on this, the only noncarcinogen of potential
concern is manganese, which under reasonable worst-case
conditions is just at a concentration which would result in a
daily intake equal to its RfD.
For carcinogens detected in the monitoring wells, the total
carcinogenic risks under average and reasonable worst-case
exposure conditions were 1.7E-4 and 3.8E-4, respectively (Table
5). These values are just outside the target range of lE-4 to
1E-6 which is used by the U.s. EPA for selecting remedies at
CERCLA sites. Arsenic and vinyl chloride are the contaminants
most significantly contributing to total cancer risk estimates.
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I
I
15
There is some concern, however, about the certainty of the
data and the concentrations used to calculate the carcinogenic
risks. In the case of arsenic, it should be noted that the
maximum concentration of 1.8 ug/L is well below the current
drinking water standard of 50 ug/L. In reviewing the data on
arsenic, one se~s that arsenic was detected in only one valid
sample in only one well, EA-4D. On the other two sampling
occasions at EA-4D, no arsenic was detected. It should also be
noted that for the one sampling event in which arsenic was
detected at EA-4D, the analyte was detected below the contract
required detection limit (CRDL), but above the instrument
detection limit (IDL). In evaluating the metals detected in the
onsite and surficial soil at East Mount Zion, arsenic levels do
not appear to be of concern in soil.
In reviewing the vinyl chloride data, this compound was
detected in only two wells, EA-4D and EA-6D, and only during the
first of three sampling rounds at each well. Both times that
vinyl chloride was detected, it was at a level below the CRDL,
but above the IDL. Therefore, the concentration was estimated
each time. It should also be noted that vinyl chloride was not
detected in the waste or surficial soil samples at the site.
Two other compounds that potentially contribute in a less
significant manner to the total carcinogenic risk are 1,1-
dichloroethane and bis(2-ethylhexyl)phthalate, which were
associated with carcinogenic risks of 1.4E-5 and 2.7E-6,
respectively, at reasonable worst-case concentrations, and 2.5E-6
and 6.2E-6, respectively, for average concentrations. In
evaluating the monitoring well data, these compounds were
consistently detected in the waste samples (Figure 3).
Benzene at reasonable worst-case concentrations marginally
exceeds its MCL, i.e., 5.3 ug/L versus 5 ug/L. The average
benzene concentration of 1.1 ug/L, however, is well below the
MCL. The only well where benzene was consistently detected was
EA-4D (Figure J). Benzene was also detected during the soil
. vapor survey.
In the case of residential wells, risk values were available
only for the noncarcinogenic effects associated with the detected
compounds. Therefore, potential carcinogenic effects could not
be quantified. The total HI for all compounds, regardless of
critical effect, was less than one for each individual
residential well. Using the maximum concentration of chemicals
detected in any residential well, the HI was still less than one
(i.e., 4.2E-1) (Table 6). Therefore, no deleterious effects
associated with the residential wells are expected.
In the case of the two nonresidential wells, neither of
which is used as a source of drinking water, all the compounds
for which risk values were available were associated with
"
"
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16
noncarcinogenic effects. The HIs for the Abandoned Park Well and
the Old Park Well were 2E-1 and 6.7E-2, respectively, which are
less than 1. Therefore, no deleterious effects associated with
ingestion of ground water in the area of each well are expected
based on the compounds evaluated. However, as indicated
previously, lead in the Old Park Well was detected at a
concentration which exceeds the existing and proposed drinking
water standards. This does not appear to be related to the
landfill given that lead was detected in only one monitoring well
at the site at a concentration well below the existing MCL and
just equal to the proposed MCL. Also, the levels of lead
detected in waste and surficial soil samples did not indicate
that lead was a contaminant of concern at the site.
In summary, exposure pathways quantitatively evaluated in
this risk assessment were for ingestion of ground water from
onsite monitoring wells, residential wells, and non-residential
wells. Evaluation of the monitoring well data indicates that
there would be potential risk associated with ingestion of ground
water onsite and at the site perimeter. The noncarcinogenic
compound of greatest concern is manganese. The carcinogenic
compounds potentially of concern are arsenic, vinyl chloride,
benzene, 1,1,-dichloroethane, and bis (2-ethylhexyl) phthalate. As
previously noted, arsenic was detected in only one well (below
the CRDL) and only during one of three sampling rounds in that
well. In one shallow monitoring well, the concentration of lead
was less than its MCL and just equal to the proposed MCL.
Evaluation of the residential and nonresidential wells in
the neighboring area indicates that there is no significant risk
being posed to the population ingesting ground water based on the
samples, chemicals and exposure pathways evaluated. For
residential ground water, the hazard index was less than one even
under reasonable worst case conditions. No carcinogenic
chemicals of concern were identified. Lead concentrations in all
residential wells were less than the MCL, although levels in some
wells exceeded the proposed MCL. The only compound of concern in
the nonresidential wells was lead detected in the Old Park well
. sample. The source of the lead problem in the well is unknown,
but it does not appear to be associated with the contamination at
the site based on the sample results of the RI. It should also
be noted that the Old Park well is not used as a source of
drinking water. No carcinogenic chemicals of concern were
identified in the nonresidential wells.
Environmental Assessment
Surface water samples were collected from the southeast and
west leachate seeps, east and west intermittent streams, and the
east and west perennial streams. The samples collected were
analyzed for metals and organics. The observed concentrations
were compared to Pennsylvania Water Quality criteria for Toxic
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17
Substances and the Federal Ambient Water Quality Criteria.
Analytical results for surface water samples collected at the
southeast and western leachate seeps showed limited contribution
of contaminants from the waste fill. Comparison of the inorganic
data to the appropriate criteria resulted in the identification
of two compound~ that exceeded acute and chronic water criteria.
These compounds were copper and mercury. However, these
compounds were not found in elevated levels downstream of the
site.
In evaluating the surface water organics data, only those
compounds with established Pennsylvania or EPA water quality
criteria were reviewed (Table 8). This evaluation indicated that
none of the organics identified were observed to exceed any
aquatic life criteria.
Sediment samples were collected within the leachate seeps
and analyzed for metals and organics. There were no organics
detected in the sediment that were of concern. Comparison of
average sediment concentrations to Regional background
concentrations show that, with the exception of cadmium in the
southeast leachate sediment samples, all average sediment
concentrations were within or below the range of regional
concentrations, For cadmium, concentrations above 1.8 mg/kg were
observed in the southeast leachate pond and watercourse
sediments. The southeast leachate watercourse sediment had the
highest concentration of cadmium at 6.5 mg\kg. No aquatic
toxicological significance is known to be associated with these
elevated levels of cadmium sediment values.
In summary, several compounds were observed to exceed
identified water quality or sediment quality criteria, these
compounds are not expected to adversely impact aquatic systems
because of the flow restrictions placed on the leachate seeps.
The west leachate seep flows into the Doersam Woods storm
drainage system where it is impounded in a sediment pond.
Extensive dilution is expected within this system prior to its
eventual discharge during storm events. Similarly, leachate from
the southeast portion of the landfill is impounded in the surface
water/leachate collection pond. Any flow from the southeast
leachate pond is expected to be diluted prior to combining with
Kreutz Creek, thereby minimizing any aquatic life impacts.
In assessing potential impacts to terrestrial life which may
use surficial waters in the site vicinity as drinking water,
health and risk based calculations have revealed that the
utilization of surficial waters associated with the site by local
populations of wild or feral vertebrate animals would not elicit
any cancerous risk or noncancerous health threat to these
animals. These calculations assumed combined impacts from
contaminants found in the surface waters and the sediments and
employed health-based criteria normally used in risk calculations
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18
in humans. Except for occasional transient species, no federally
listed or proposed threatened or endangered species are known to
exist in the East Mt. Zion site area.
DESCRIPTION OF ALTERNATIVES
The remedial action objectives for the East Mt. Zion site
are (1) to prevent ingestion of ground water which has
concentrations (that are related to the East Mt. Zion site)
greater than established MCLs and (2) protect downstream water
quality to assure concentrations of parameters that are
associated with the site meet Federal and State Water Quality
criteria. Applicable or relevant and appropriate requirements
which pertain to the alternatives below are listed in Table 10.
There are no historical or archeological sites in the East Mt.
Zion site vicinity that would be impacted by implementation of
the following alternatives.
Based on these remedial action objectives, the alternatives
developed to address contamination at the East Mt. Zion site are:
Alternative #1
No Action
The Superfund program is required to evaluate the No Action
alternative. Under this alternative, no remedial action would be
taken to address contaminant sources or their potential migration
pathways, and any site posed risk would remain unchanged. This
alternative would be selected only if the site posed little or no
risk to public health or the environment from hazardous
substances as addressed in the Superfund law. Long-term
monitoring (30-years) of the ground water, surface water,
sediment, and soil would be performed.
There are no capital costs associated with the no action
alternative. The sampling costs are estimated to be $320,000 for
the first year and $80,000 for each subsequent year for thirty
years. Present net worth for 30 years at 8% interest would be
$1,220,000.
Alternative #2
Monitorina
Restricted Access with Environmental
Under this alternative a chain link fence would be installed
around the landfill so that public access to the landfill would
be restricted. Also, a long-term (30-year) monitoring program
consisting of ground water, surface water, sediment and soil
sampling would be implemented. Deed restrictions would also be
implemented to limit future use of the site.
The capital cost for installation of the fence is estimated
to be $45,000. The sampling costs are estimated to be $320,000
for the first year (quarterly sampling at $80,000 per event) and
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19
$80,000 for each subsequent year for thirty years. Present net
worth cost for this alternative for 30 years at 8% interest would
be $1,265,000.
Alternative #3
Multilaver CaD with Methane Ventina
Under this. alternative, the landfill would be closed as a
municipal waste landfill under Pennsylvania Municipal Waste
Regulations. This alternative consists of surface water
diversions, methane venting through gas vents, constructing a
multilayer cap consisting of a clay layer or synthetic liner,
sand drainage layer, and a soil cover. In conjunction with cap
installation, regrading of the fill may be necessary due to the
steepness of the slopes on the south and west sides of the fill.
This alternative would act to inhibit the mobility of
contaminants. Ground water monitoring and deed restrictions
would be integral components of this alternative. A chain~link
fence would be installed around the site so that public access to
the site would be restricted.
The estimated capital expenditure for this alternative would
be $1,945,000. The operation and maintenance expenditures are
estimated to be $100,000 for ground water monitoring for the
first year (quarterly at $25,000 per event) and $25,000 annually
thereafter for thirty years. Present net worth cost for this
alternative for 30 years at 8% interest would be $2,230,000.
Alternative #4
Excavation and Off Site Incineration
This alternative would involve the excavation and disposal
of the waste material at a municipal incinerator. This
alternative would require the excavation and disposal of
approximately 300,000 cubic yards of waste material.
Incineration involves the thermal destruction of organic
compounds to a nonhazardous product. Treatability testing of the
waste may be required to determine the ability of the incinerator
to handle the physical properties of the waste involved and to
e~fectively destroy the waste based on its chemical properties.
Metal contaminants will remain in the incinerator ash and will
require disposal in a secure offsite facility. Also large bulk
items in the fill may be unsuitable for incineration and require
offsite landfill disposal. A staging area for the waste material
would be required. After excavation, clean fill would be
imported to bring the site back to grade. The existing cover
material would be stripped, stockpiled, and then backfilled.
Based on existing waste characterization, the landfill waste
is not believed to be RCRA hazardous waste. This would be
confirmed prior to offsite incineration or disposal.
The estimated capital expenditure for this alternative would
be $12,83~,000. No operation and maintenance expenditures are
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20
expected for this alternative. Present net worth cost for this
alternative therefore would be $12,830,000.
Alternative #5
Excavation and Off-Site Landfillina
This alternative is similar to alternative 4 with the
exception that offsite disposal would be by landfi11ing and not
incineration.
The estimated capital expenditure for this alternative would
be $13,260,000. No operation and maintenance expenditures are
expected for this alternative. Present net worth cost for this
alternative therefore would be $13,620,000.
Alternative #6
Rearadina
This alternative consists of regrading ares of the landfill
which do not facilitate surface water runoff from the site~ This
would entail importing fill material and soil from offsite and
providing slopes to promote runoff. The reduction of
infiltration to the fill material will reduce the leachate
production at the site thereby alleviating the ground water
contamination at the site. Ground water monitoring and deed
restrictions to limit future use of the site would also be
included as components of this alternative. A fence would also
be installed at the site to restrict public access.
The estimated capital expenditure for this site would be
$115,000. Ground water sampling costs are estimated to be
$100,000 for the first year (quarterly at $25,000 per sampling
event) and $25,000 for each subsequent year for thirty years.
Present net worth cost for this alternative for 30-years at 8%
interest would be $460,000.
COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed analysis was performed on the six alternatives
using the nine evaluation criteria presented in Table 9 in order
to select a remedy. The following is a summary of the comparison
of each alternatives' strength and weakness with respect to the
nine evaluation criteria.
Overall Protection of Public Health and the Environment
All of the remedial alternatives considered for the East Mt.
Zion site, except for Alternative 1 (no action), 2 (restricted
access with environmental monitoring), and 6 (regrading) are
protective of human health and the environment by eliminating,
reducing, or controlling risks through various combinations of
treatment and engineering controls and/or institutional controls.
Current site conditions can be expected to persist should the no
action or restricted access with monitoring alternatives be
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21
chosen. Calculations for leachate reduction by regrading the
fill reveal that only a 10% reduction in leachate contamination
can be expected. MCLs would not be achieved under the regrading
alternative, therefore the remedy is not protective of human
health and the environment. As the no action, restricted access
with environmental monitoring, and regrading alternatives do not
provide for protection of human health and the environment for
ground water at the site perimeter, they are not eligible for
selection and shall not be discussed further in this document.
Alternatives 4 and 5 both involve the excavation and off-
site disposal of the waste material from the landfill. However,
alternative 4 requires incineration of the waste material as a
component. Residual ash would then be disposed of in a secure
facility. Under alternative 5 the excavated waste would be
containerized and transported to a secure facility without any
further treatment prior to disposal. Based on current
information, the waste in the fill is not a RCRA hazardous 'waste.
However, prior to implementation of alternatives 4 or 5, the
waste would have to be characterized and handled appropriately.
Complete removal of the waste would eliminate the risk of any
future ground water contamination at the site. Residual risks
associated with the site would be much less than 1E-6 at
completion.
Alternative 3 entails the installation of an impervious cap
at the site. The cap would effectively reduce infiltration to
the fill thereby alleviating ground water contamination at the
site and site perimeter resulting in achievement of background
levels of contaminants in the ground water. Access and deed
restrictions would be components of alternative 3. If, as
assumed, capping eliminates leachate generation, residual ground
water risks are estimated at much less than 1E-6.
Compliance with ARARs
SARA requires that remedial actions meet applicable or
relevant and appropriate requirements (ARARs) of other
environmental laws. These laws may include: the Toxic Substances
Control Act, the Clean Water Act, the Resource Conservation and
Recovery Act, and any state law which has stricter requirements
than the corresponding federal law.
A "legally applicable" requirement is one which would
legally apply to the response action if that action were not
taken pursuant to sections 104, 106, or 122 of CERCLA. A
"relevant and appropriate" requirement is one that, while not
"applicable", is designed to apply to problems' sufficiently
similar that their application is appropriate. A list of ARARs
for each of the considered alternatives is presented in Table 10.
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22
Alternatives 3, 4 ,and 5 will comply with their respective
ARARs identified in Table 10. Alternatives 1, 2, and 6 would not
comply with all respective ARARs identified in Table 10 and are
not protective of human health and the environment.
Lona-Term Effectiveness and Permanence
Each of the alternatives considered addresses the ground
water contamination at the site. By eliminating the source of
contaminants to the ground water each alternative achieves a
certain degree of long-term effectiveness and permanence. The
difference between the alternatives with regard to long-term
effectiveness and permanence is directly related to how each
alternative addresses ground water contamination at the site.
Alternatives 4 and 5 provide the greatest degree of
permanence. They both involve the excavation and offsite .
transport of the fill material. Alternative 4 requires the
incineration of the fill material and subsequent disposal of
residual ash in a secure offsite landfill. Under alternative 5,
the excavated material would be transported to an offsite
facility without prior treatment.
Alternative 3, while not removing the contaminants, also
offers long-term effectiveness by reducing the mObility of the
contaminants. This alternative includes an impermeable
multilayer cap that will limit the infiltration of precipitation
through the fill material and preclude the leaching of
contaminants into the ground water.
Reduction of Toxicitv. Mobilitv. or Volume throuah Treatment
Alternatives 4 provides for the complete
reduction/elimination of toxicity, mObility, and volume by
completely removing the source of the contamination and
incinerating the waste fill material. Incineration involves the
thermal destruction of the organic constituents of the fill
material to a nonhazardous product. Alternative 5, while
eliminating the toxicity, mobility, and volume of the waste
material at the site itself, does not provide for the overall
reduction of toxicity, mObility, and volume since the waste is
not treated prior to landfilling. Alternative 3 does not
provide treatment of the waste material directly and, therefore,
does not reduce the toxicity or volume. The mobility of the
contaminants in the fill, however, is significantly reduced or
eliminated by the cap and thereby the site's impact to the ground
water is reduced. Assuming that infiltration to the fill is the
sole source of leachate which subsequently migrates through the
fill, the migration of the constituents to the ground water will
be eliminated.
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Short-Term Effectiveness
Alternatives 4 and 5 would involve the excavation of the
cover material and the waste, the removal of the waste.offsite,
and backfilling with clean fill. The risks associated with the
excavation are associated with potential volatilization from the
waste and potential dust emissions from the cover material. Wind
erosion from the cover material may cause a problem with fugitive
dust emissions. The waste material, however, is expected to be
partially saturated and moist and is therefore expected to emit
almost no dust at all. These emissions are of concern (1) for
worker exposure and (2) for potential migration to neighboring
housing developments.
Because portions of the fill and existing cover material
will be significantly disturbed under alternative 3, there is
also potential for increased volatilization from the waste and
fugitive dust emissions from the cover material under this.
alternative also. Clearing, excavation, and redistribution of
the waste under alternative 3 is expected to take 3 to 4 months.
Short-term exposure therefore would be primarily limited to that
duration in contrast to the possible 3-4 years for total
excavation of the waste under alternatives 4 and 5. Based on
average waste characteristics, the daily emission rates for the
volatile compounds in the fill are very low. These emission
rates conservatively assume complete volatilization of the
compound in the waste excavated in a day which was estimated at
300 yd3/day. Fugitive dust emission from the fill material is
expected to be minimal since it is currently partially saturated.
In addition to volatile emissions from the site, it is also
expected that short-term odoriferous emissions are extremely
likely during the excavation.
Imclementabilitv
While all the alternatives considered are implementable,
some alternatives are technically easier to implement than
others.
Alternative 3 is the easiest to implement. Capping is a
well established technology which is commonly used in municipal
and hazardous waste site closures. Removal of the existing
vegetation and regrading of the site may be necessary. Regrading
of the landfill would require a cut volume of approximately
20,000 cubic yards. Clearing, excavation, and redistribution of
the waste is expected to take 3-4 months. Total cap installation
is expected to be complete within a year after construction
begins.
Alternatives 4 and 5 both involve excavation of the waste
material currently in the fill. The quantity of waste estimated
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24
to be excavated is 300,000 cubic yards. Total excavation of the
waste is expected to take 3-4 years. Additional clean fill would
have to be hauled back to the site to bring the site back to
grade. The difference between alternatives 4 and 5 is how the
waste will be disposed of once it is excavated. Under.
alternative 4, which includes incineration of the waste, an
incinerator with adequate capacity to handle the volume of waste
would have to be found prior to implementation of the
alternative. Residual ash from the incineration process would
then have to be taken to a secure offsite facility for disposal.
Alternative 5 would involve transporting the excavated waste
directly to an offsite facility. In order to implement both
alternatives 4 and 5, a suitable disposal facility would have to
be identified prior to disposal of the waste.
Cost
This evaluation examines the estimated costs for
implementing the remedial alternatives. Capital and annual O&M
costs are used to calculate estimated present worth costs for
each alternative. Alternative 3, multilayer cap with methane
venting, has a moderate capital cost and annual costs which
results in an estimated present worth of $2,230,000. Alternative
4, excavation and offsite incineration, has a high capital cost
which results in an estimated present worth cost of $12,830,000.
Alternative 5, excavation and offsite landfilling, also has a
high capital cost which results in a present worth cost of
$13,620,000. No annual O&M costs are expected for either
alternative 4 or 5.
state AcceDtance
Pennsylvania has concurred with the selected remedial
alternative.
Community AcceDtance
Community acceptance is assessed in the attached
Responsiveness Summary. The Responsiveness Summary provides a
thorough review of the public comments received on the RI/FS and
the Proposed Plan, and U.S. EPA's and PADER's responses to the
comments received. .
DESCRIPTION OF THE SELECTED REMEDY
The results of the RI/FS and base line risk assessment led
to the conclusion that the East Mt. Zion site has resulted in the
contamination of the ground water onsite and at the site
perimeter, and may pose an endangerment to human health and the
environment. The deep aquifer in the site vicinity is currently
-------
25
used as a source of drinking water by some area residents. The
principles used to select the remedy were based on the following
and supported by the comparative analysis:
(1) excess cancer risk for ingestion of the ground water at
the s}te perimeter is 3.8E-4
(2) the Hazard Index associated with noncarcinogenic
effects from the ingestion of ground water at the site
perimeter is 1.5
(3) there is no current impact to aquatic life downstream
of the site and there is no current impact to
terrestrial habitat using onsite surface water as
drinking water
Remedial action goals for the East Mt. zion site are (1) to
prevent ingestion of ground water which has concentrations' (that
are related to the East Mt. Zion site) greater than the MCL and
(2) protect downstream water quality to assure concentrations of
parameters associated with the East Mt. Zion site meet Federal
and state Water Quality Criteria.
Based upon consideration of the requirements of CERCLA, the
detailed analysis of alternatives, and public comments, EPA and
PADER have selected alternative 3, multilayer cap with methane
venting.
A cap provides a relatively impermeable barrier that
isolates infiltration to buried wastes, thereby minimizing the
potential for the leaching of contaminants to the ground water.
It will also significantly reduce leachate production and will
likely extend the periods where the leachate pond in the
southeastern corner of the site is dry. .
Construction of the cap would conform with the PADER capping
requirements under the Pennsylvania Municipal Waste Regulations.
These include, but are not limited to, the following:
a cap consisting of a 1-ft clay layer or a 30-mil
synthetic liner
a maximum cap permeability of 10-7 em/see
a drainage layer over the cap
a 2-ft soil layer over the drainage layer
a minimum surface slope of 3 percent
a maximum slope of 33 percent
"
"
-------
26
minimization of soil erosion and sedimentation
stormwater management based on a 24-hour, 25-year storm
event
The site w~rk prior to installation of the cap is likely to
include site and slope clearing; excavation; redistribution and
compaction; and cover with appropriate loam as required by PADER
regulations. Access to clear the slopes is limited and may only
be possible by clearing a road access through the park and/or the
Doersam Woods lots adjacent to the site. Purchase of property
may be necessary to ensure efficient access during construction.
In addition to capping, venting will be required to provide
methane and/or VOC off-gassing. Emissions from the gas vents
will be monitored, and if they are over acceptable levels, a
control system will be installed. Also, fencing and future site
use (i.e., deed restrictions) will be required to protect the
cap's integrity. Total installation is expected to be complete
within 1 year after construction begins.
The only long-term operation and maintenance costs
associated with this alternative are the inspection, maintenance,
and repair of the cap. Also, ground water monitoring would be
required to monitor the natural attenuation of contaminants in
the ground water. The monitoring wells currently in place at the
site would be used for the ground water monitoring of the
contaminant attenuation. Samples would be taken quarterly the
first year after completion of the cap and then annually
thereafter. Based on ground water velocity and the elimination
of the source, ground water concentrations at the landfill
perimeter are expected to meet background levels within five
years through natural attenuation. Residual risk for the
ingestion of ground water at the site perimeter is estimated to
be much less than lE-6. Present net worth costs for this
alternative are estimated to be $2,230,000. A summary of the
capping costs is presented in Table 11.
STATUTORY DETERMINATIONS
Protection of Human Health and the Environment
The baseline risk assessment performed during the RI
identified one pathway of concern--ingestion of ground water at
the site perimeter. As previously discussed, the risks
identified in the baseline risk assessment are marginally outside
the lE-4 to 1E-6 cancer risk range for average ground water
concentrations at the site perimeter. No significant risks were
identified for residential water supplies as they relate to the
East Mt. Zion site. The only quantifiable risks associated with
the site are limited to the scenario that ground water at the
site perimeter would be used as a drinking water supply.
-------
27
Therefore, the risk reduction objectives and criteria are based
on reduction of those risks associated with the ingestion of
ground water at the site perimeter and protection of the deep
aquifer from further contamination.
samples collected from the leachate seeps had two trace
metal concentrations (mercury and copper) which exceeded the
aquatic water quality criteria. These constituents, although not
detected in downstream samples, are of concern because they
exceeded the ambient water quality criteria in the seeps.
Although ambient water quality criteria in general do not apply
to such seeps, which are seasonal in nature, as a conservative
approach, the attainment of the aquatic water quality criteria
for copper and mercury were also remedial action objectives for
the East Mt. Zion site.
A cap provides a relatively impermeable barrier to isolate
stormwater infiltration from buried wastes, thereby minimizing
the potential for the leaching of contaminants into the ground
water and the potential for the migration of the contaminants
offsite. It will also reduce leachate production and will likely
extend the periods where the leachate pond in the southeastern
corner of the site will remain dry. Regrading of the site will
also promote better surface water runoff further alleviating on-
site ponding and migration of the contaminants offsite. Residual
risk associated with the ingestion of ground water at the site
perimeter is estimated at much less than 1E-6 once the cap is
complete. Therefore the remedial action objectives are met with
this alternative.
There will be no unacceptable short-term risks or cross-
media impacts caused by implementation of this remedy.
ComDliance with AC9licable or Relevant and ADDroDriate
Reauirements
The selected remedy of a multilayer cap with methane venting
and ground water monitoring will comply with all applicable or
relevant and appropriate chemical, action, and location specific
requirements (ARARs). A complete list of ARARs is presented in
Table 10. RCRA land ban is not an ARAR for this alternative
since the waste is being capped in place.
The Pennsylvania ARAR for ground water for hazardous
substances is that all groundwater must be remediated to
"background" quality as specified by 25 Pa. Code Chapter
75.264(n). The Commonwealth of Pennsylvania also maintains
the requirement to remediate to background is " also found in
legal authorities.
that
other
-------
28
ARARs specific to the selected remedy are presented below:
o
Chemical-specific ARARs
~5 Pa Code Chapter 123.1(c), Pennsylvania Air
Quality standards
25 Pa Code Chapter 127.12, Construction,
Modification, Reactivation and Operation of
Sources
25 Pa Code Chapter 93.1 et. sea., Pennsylvania
Water Quality Standards
25 Pa Code Chapter 75.264(n), "background" quality
for ground water remediation
o
Location-specific ARARs
- none
o
Action-specific ARARs
25 Pa Code Chapter 271.113, Pennsylvania Municipal
Waste Regulations
29 USC Parts 1910 and 1926 and 29 CFR Part 1910,
Occupational Health and Safety Act requirements
are applicable to all response activities
All the ARARs listed above will be met by the selected remedy.
Cost-Effectiveness
The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its
costs, the net present worth value being $2,230,000. The
selected remedy is the least costly of the alternatives 3, 4, and
5 which are equally protective of human health and the
environment.
utilization of Permanent Solutions to the Maximum Extent
Practicable
The EPA has determined that the selected remedy represents
the maximum extent to which permanent treatment technologies can
be utilized in a cost effective manner for the East Mt. Zion
site. Of those alternatives that are protective of human health
and the environment and comply with ARARs, the EPA has determined
that the selected remedy provides the best balance in terms of
short-term effectiveness: implementability: cost: reduction in
-------
29
toxicity, mobility, and volume; and long-term effectiveness.
The selected remedy does not offer as high a degree of long-
term effectiveness as the excavation and disposal options,
however, it will significantly reduce the risks to human health
and the environment posed by the contaminated ground water at the
site. The excess human cancer risk at the site has been
estimated to be 3.8E-4, which is above EPA's recommended upper
bound of 1E-4 to 1E-6. Due to the relatively low risk associated
with the site, EPA has determined that the use of more costly
treatment technologies at the East Mt. Zion site are not
justifiable. Because alternatives 3, 4, and 5 offer a comparable
level of protection of human health and the environment, the EPA
has selected alternative 3, which can be implemented quickly;
will have little or no adverse effects on the surrounding
community; and will cost considerably less than the other.
alternatives.
Preference for Treatment as a PrinciDal Element
The statutory preference for remedial alternatives that
employ treatment as the principal element has been determined by
the EPA to be impracticable at the East Mt. Zion site. Due to
the relatively low risk to human health and the environment, and
the nature and extent of the contamination, the EPA has
determined that alternative 3, including monitoring, access
restrictions, institutional controls, and installation of an
impermeable multilayer cap, can be implemented more quickly and
cost effectively than the other alternatives while still
providing an adequate level of protection to human health and the
environment.
EXPLANATION OF SIGNIFICANT CHANGES
The Proposed Plan for the East Mt. Zion site was released
for comment in May 1990. The Proposed Plan identified EPA's and
PADER's preferred alternative. EPA reviewed all of the comments
submitted during the public comment period. Upon review of these
comments, it was determined that no significant changes to the
remedy, as it was originally identified in the Proposed Plan,
were necessary.
-------
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-- -""""".""
- -1""1"'''""""""
o
'"
'!'
.-"';'7:~AO
d' ._"Ip~.
'- . - - Lu.,,,.... l....
. 11\0"'1" ~_.......
-......... It........ I ...... I'"", ...."
---- ::::':::'.:~:~..I" ..,,-
.----.-.-.
U'KOAllulWd hunoll
- ROCKY RIDGE PARK -
- "-
.~.
.-"
-. --- ---.
Ht. .1'
-. ....
tku.d '..Ie le~. lu
S L Intclnun...1
/ SI'...n
tltl
H!:. ~...
,..,
.
"."
- :"~I~~~:":~/:'I,)'
c..
.
Ii4 t'A (,Nl.iNEtcHINL
SCtENCl AND
Tl.l :t-tNOLCX;y INt.:
tfu....u
c'tu t 71. l.~'"
Su"4M:- wele. 'u'lUlI d'.ln~ ".Ue.".
.. ,h. .. .,. Mt l UHI . ..MJI.U
-------
TABLE 1
~ASTE CHARACTERIZATION RESULTS
Trace ~etals (~g/kg)
Aluminum
An C imony
Arsenic
Bari um
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Mang~nese
Mercury
Nickel
Silver
Tin
Vanadium
Zinc
Pesticides (ug/kg)
Dieldrin
4,4'-DDE
Endrin
4,4'-DDD
4,4'-DDT
.PCBs (ug/kg)
Aroclor 1016
Aroclor 1254
Aroclor 1260
Volatiles (ug/kg)
Methylene Chloride
Acetone
2-butanone
2-hexanone
2-methyl-2-pentanone
Range
A'/erage
1,400-93,700 10,885
ND-6.9 0.6
0.34-72 . 1 2.04
141-268 57.5
ND-0.a8 0.21
0.61-26.5 7.1
1. B-154 26.1
1.0-12.6 3.7
ND-3,150 2ZB
656-939,000 761,546
ND-490 130
3.4-593 103
0.57-1. 7 0.85
ND-208 20.1
ND-98.B 5.6
ND-343 26
1. 7 -104 19
5.3-5,540 1,645
ND- 716 . 1
ND-542
ND-IO.2
ND-120
ND-1,380
39.8
61.8
1.1
8.6
78.2
ND-1,600
ND-1,900
ND-141
266
273
27.7
ND-94
ND-l,300
ND-l,aOO
ND-20
ND-72
20.
195
200
1.0
3.8
-------
TA8LE 1
(Cont.)
Volatiles (Cont,)
Toluene
Chlorobenzene
Ethylbenzene
Xylenes
Semivolatiles (ug/kg)
1,4-Dichlorobenzene
4-Methylphenol
1,Z,4-Trichlorobenzene
Naphthalene
2-Methylnaphthalene
Acenaphthene
Dibenzofuran
Diethylphthalate
Fluorene
N-Nitrosodiphenylamine
Phenanthrene
Anthracene
Di-n-Butylphthalate
Fluoranthene
Pyrene
8utylbenzylphthalate
bis(2~ethylhexyl)phthalate
Chrysene
Di-n-Ocryl Phthalate
8enzo(b)fluoranthene
8enzo(k)fluoranthene
Benzo(a)pyrene
Indeno(1,2,3-cd)pyrene
Benzo(g,h,i)perylene
Pentachlorophenol
Range
ND-3,200
ND-400
ND-2,600
ND-12,000
ND-2,000
ND-l,600
ND-700
ND-2,400
ND-l,lOO
ND-3S0
ND-280
ND-840
ND-SSO
ND-930
ND-S,SOO
ND-l,300
ND-l,400
ND-7,600
ND-6,lOO
ND-7aO
ND-310,000
ND-4,700
ND-110
ND-4,000
ND-840
ND-3,800
ND-2,400
ND-2,300
ND-9,300
A'/erage
176
29
188
885
345
206
46
327
131
18
17
39
31
49
472
68
452
526
469
128
29,330
290
5.8
210
44
200
126
121
489
-------
TABI.E
'l.
ANALWTICAL M~£ULT£ '~~/L' '08 ~A£T "OUNT liON OO"~STIC WELL SAftPLES COLLECTED 10 AU~U£T 19" AND )0 "AMCN 19.9
,,1..1...
..'I...,
"r...le
..rl..
..rrlll..
C."I..
C.lel..
Cllr..I..
C.II.U
C.".r
Ir..
Cr..I..
L...
..,...1..
...,.....
..rc.r,
.lc..1
'.'...1..
..1..1..
'I h.r
.'..1..
WII.III..
.....1..
lI.e
WI.
U06 110.'.. tOoo'.'
D.uell nul.. uu". 11011.. U.l'.'
V.".Y UOJ un O.uell O.uell O,ue. Hoe
80.d 8Id,.,,004 814'."004 '....ood 814'."004 814,.,,00d V.II.r V.II.r V.II.!1 D.lnln",.,
un ." u.. 101 U~
J.'. 1.1. J." n.. as.t I.J 1.1 I." II. ~ H.J
.
J. n.. I.J.'. t.... I.t... J.t.. II, t.. no. 1,'00' I,' loa ',160'
U., .... as.S U.. I J. ~
H.lI
JI.J IU JU n.. 10.l
6.'" 1a.1 Stl .. In ,. ',UI l.JI' ,. 'J .1.
.... 11.' ".6 ..t '.U 1.0. l.se J.' ~.J
1..18. .... 1.611. I. .... 1,1'" " .u. .u. . ,JOO. I,' JO. ',110.
u.. '.J. 'J.'. n.1 II.'. 1.18 II.I II.' u.. SlI
.., I.'
lI.n
...... nJa I,IU. J.UO. .61. n.. uu 1,110' I,~.O' J, ~IO'
J, .... 1,1'" 6168 u.no '.'.' J.II" 1.1.'8 I.JlO. 1,10'. U,900
I.. I.' '.1 ... I.' '.1 '.1 I., I.,
".1 15.' U t.t
IJ.t. II.'. JO. l'
.n"LI CWOY"LI
..'WICID..
C.... ..'.c'.dl
'C~.
C.... ..'.c'..1
WOUWIU'
C.... ..'.c'..1
'..I.OUYIL..
DI-.-II."I ,11'11.1.'.
,.I,
t.. L..., ...c..Y, a.. .I.c co.c..'.a'lo.. or. ,.a.lt. ',0. II .a.cll Itl' ...,11.,; all ot~.. v.lu.. .,. '.0. 10 Autu.t I'"
...1'11.,.
1111 ..11 ....t ..Y du.I., co.II...tlo. ...1'11., o. .0 ...c~ 1.1..
Ccl "....,. ..Iu. 01 ...,1. a.d dupllcat. ...,1. tall.. 10 "..e~ I"'.
. . Co.e..t.atlo. 11.10.. c..tlll.4 ..t.ctlo. 11.lt. lIut .110.. I.."u..., d.t.etlon 11.lt.
.I . ..tl..t.4 tua.tlt,.
-------
TAUI.E !.
t:XTt:NDt:D
))19Ia' Oidia' U~Ola' U)~la' Abandon.d
"to l'a..II ))66 1'...11
%10n w.ll 81d'J.wood 8id'Jawood 8a..wood Wall T...t WoOl I
"ETALS ITOTALt
Alu8in'18 120B 801 hili
Anti80nV'
A...anie
lali'18 1.9 1.1 U.l 6.1 11. t8 H.t )8.9
lalV'lliu8
Cad8i'18
Calei'18 I,SOOI l,9101 6,OtO 6,110 11,100 1,1108 l, SUB
Cbl08iu8 11.)
Cobalt 16.u U. 911
Coppar lH Ul ))1 )~.) 111 ll.18
I..on n 1,16' U U.6 1, SU 1,SOO 111,SOO
Cyanida Ule»
Laad l.'8 S.) I.U Ibt 12. t t. III
"agna.i'18 l,t008 I,St08 1, 6t08 ),0'08 6,'tO IS88 1,61011
"angane.a 6.18 11.11 I t 11.11 1.18 91.S 15.6 1,))0
"a"cuIV' O. a c I b t
lIicllal 20.68 a.)8
'ota..i'18 1,0808 6128 l,Ol08 SH8 l, )008 I,UOB 1,SII01I
Salan&u8 l.Su l.~u
Silve.. 1.0u 1. OU
Sodiu8 I, U08 1,8108 S,'10 1,1608 11,100 1.0008 11,600
Tball1u8 0.6 1.0 1.0 0.6 0.1 0.1
Vanadiu.
line 18.6 1.t
Tin 19 .08 11. t8 U.18 11. t 11.)11
'ESTICIOES
'llone datac~adt
PCI.
'Ilona datectedt
VOLATILES
Illone detected»
SE"IVOLATIL£S
Pi-a-butyl phthalate 6JB
-------
TAIU.E
)
COHPOUNDS US~D IN T"~ MISK ASS~SSH~NT TUAT WER~ D~T~CTED IN R~SID~NTIAL AND NONMESIOENTIAL WELL SA"~LE5 I~~/L,
N~Aa EAST MOUNT ZION ICOLL~CT~D 10 AUGUST 1988,
1906
Onack
V.I1.y
1901
aa~q8..ood
"ETALS I TOTAL I
..,iu.
Cblo.au. U.6 H.l
COpp., U.2
1100 6,018 U.J
L..d 10.0 1.1
. ".Og.08118 H.t 1.2
".,CU'Y 1.6 0.'
..ack.l
Tb.l hu. 0.1
Tao
lanc 10.'
SE"IVOLATILES
oa-n-butylphth.l~t. 6
)62)
aadq8wood
18'~
aadq8..ood(.1
))99 I
..,woodl.
U.O IS.S
lS.~' 21.1
121 lItO
Sit u US
11.' H.6 .. S
J.J "'.1 1),\1
0.6
0.1
1.0
11. S
n.6
I.'
Ibl
V.lu.~ tor 1.4~. ..ecuey, .nd &inc ...18 flo. ...p18a col18ct8d 10 ".Icb 1989.
Value as the 4(ath..tac ...n of duplicat. ...pl...
1801
(oil ,
Radq8..ood
1.1
69
0.9
. .2
0.1
1..
)804
oeue"'.a,
V.all..y
~uou
U(uck
t ..,
V..II..y
1.8
1 . ~
".168 2,111
),0 2.S
81.4 14.1
0.8
0.11
11. "
6~
h91
Ihue"
V II t. I
. .y
jj. )
11. )
)7.4
119
7.9
11.4
21.4
1.0
-------
TAtiLE
J
t:XTt:NDt:D
HU AlJ.U.JuhU..J OI.J
HOI "t. 1.1 11$0 1IH )Jbb I'... ~ .......
D81nlnq.H 1"1 1"1 W.III" »
Zion Rld'J.wood IIld'J8wood lI..cwoo..s w..11
----
"ETALS ITOTALI
..riu8 51.) 2.9 U.2 6.1 21.4 JJ.4 I . I
Cbro81u8 H.) .
Copper 80.2 IH HI H.) 111 1 J. 1 HI
Iron 61 H 12.6 1,$11 ),UI 4,1bll
L..d $.1 2.1 5. ) 1.4 2.4 1.0 Ulbl
. ".nIJ.n8s8 541 6.) 11.1 1.1 91.$ 1~.b 12. 1
"8rcury O.llllbi
.ickel 20.6 lS.)
Tb.lhu8 1.0 0.6 1.0 0.6 O. -, 1.0
Tin 20.1 11.4 12.) 11.4 B.O
11nc 4.5 11.6
St:"IVOLAT I Lt:S
01-n-butbylphtb..I"te
1
-------
TABLE
GROUND-UATER CONCENTRATIONS DETECTED IN ONSITE MONITORING WELLS
AT EAST HOUNT ZION COMPARED TO DRINKING WATER STANDARDS AND CRITERIA
(c)
Metals
Arsenic
Barium
Cadmium
Iron
Lead
Manganese
Hercury
Nickel
Zinc
Volatlies
Vinyl chloride
Benzene
Chlorobenzene
Ethylbenzene
Xylenes, o- & p-
Semivolatiles
1,4-Dichlorobenzene
Average
Concentration
(Mg/L)
1.3
25
2.8
5,450
2.6
1,460
0.10
12.5
17
1.4
1.1
4.1
1.0
1.0
2.3
Well Location with
Reasonable Worst
Case Concentrations
EA-4D
EA-5D
EA-3D
Test Well
EA-2S
EA-3S
EA-6D
EA-5D
EA-1S
EA-6D
EA-4D
EA-40
EA-1D
EA ID
EA-4D
Reasonable
Worst Case ...
Concentrations1 '
(Mg/L)
(a)
(a)
1.8
46
5.8
29,448
3.8
7,310
0.15
24
60
3
5.3
23
2
1.2
12.7 75
Li telime
Heal lit
MCL Advisory SMCL
(Mg/L) (Mg/L) (Mg/L)
50
1,000
10
300
50
150
5,000
2
5
300
680
400
(a) This concentration represents one single sampling event for the veil and is not an average.
(b) Reasonable worst case concentrations are the highest average concentrations in any one veil.
Individual veil concentrations vere determined by averaging the samples collected trora each particular
veil.
(c) This table presents only those chemicals for vhich MCLs, HAs, or SMCLs are available.
(d) Proposed MCL.
-------
TAIiLE
5
EST1KATEU PAIL. INTA~ES ANO .IS~ VALUES '0. CONTAMINANTS OETECTEO IN GMOUNU WATER AT EAST KUUNT ZIU~
E.ta..t.4 C.nce(
...u 191 CORe.AtratioAI'1 Oa i I, IAtak. pot.ncV
A".rag. ~ A".r.'). N..I.u. IUD .....,4 10".. 'actu( ~. ~ !.i1~utJ.h t '- _. ~~ ~ ~
- 1
M.t.I. Loc.tio.. .",/LI (.g/kg/d.,I (.OJ/kg/da,1 A"ar.Oj. "..i.ua .a'J/k'J/".l..!.- AV.(tI'J8 "..iau.
~--
Ar....ac EA-'O 1.) 1.1 ).1E-S S.1&-S 1.IE_O Ii. H:-~ t.)(;-~
.. r ita. ~a.-SO 'IS U ') .1&-' I.U-) SE-l 1.U-l 1.'1:-1
C.4.iu. &A-)O 1.1 S.I I. 08-S 1.11-' U-. 1.6£-1 )..1: -1
N...,..... Ia.- IS 1,"1 1,UI(.) 1.1&-1 1.1&-1 I&-llbl 1.01:-1 I.OE-O
N.rcur, &a.-'O 1.11 I.U 1.1&-' 1.11-' U-I t.U-I 1.'E-l
8ick.l &a.-SO &J.t U ).6&-1 '.U-' II-I 1.8&-1 ).U-l
'Iti.auua &a.-'D 1.1 J. I (I ).U-S I. OI-S 1&-1 '.U-' 1. (£-1
"a. "..C ".U 1.1 II.). 1.6&-' ).1&-1 6&-1 1.1&-' '.u-.
li.c &A-I. &1 U 1.1&-1 1.11-1 1&-1 J.U-) I.SE-I
Vol.til..
vi..,a chlorid. Ia.-,O I.' ) I.OI-S I. U:-S 1.li-O 9.lE-S 1. Ot: - t
N.Cb,I... ctilora4. &A-1S} 1.1 I.) J.I&-t ). 1I-t 1...E-1ICI t..E-I k. 1 i -.
IA-)D
Ia.-,O
AC.COR. lA-SO '.1 I.) 1.U-' I.U-' 1&-1 l.lI:-) l. U-l
C.rbo. 4hulta... Ia.-ID 1.1 II. J I.U-I I. II-I 11-1 I.U-) t.lE-I
I,I-Dichloro.th.n. &A-'D 1.1 t.) I.U-t I. U-I 9.(£-1 1.~E-b 1.tE-~
tr...-I,I-oachloro.th.n. EA-'O .., 1.1 I.'J&-t ).U-S t. (£-1 1.l>i-1i L Ia:-I>
....... IA-'O 1.1 S.) '.II-t .. t&-. l.U-l t. U-1 t.ti-b
Ctilorob........ &a.-'D I. I U 1.11-' ,.,&-. U-I ). tE- I l.la:-l
IttirUI."'.". EA-ID I.' 1.1 1.1&-S S. 'J&-S Ie-I '.OE-' S.1E-'
.,a...., 0- .. p- EA-ID 1.1 1.114) 1.1&-t 1.U-S 1&.0 I.U-S 1.1E-S
1&", I .tb.r Ea.-Io I. I I.) '.11-' I.l~-' S&-1 1.0£-' 1.'E-t
Sourc. 0' .t05 .n" c.re,..og...,c pot.ACr '.ctor.:
u.s. E'a. 1'1'. .nd b.
141
'Iha. co..e...tr.t,on r.pr...Rt. 0". .a..,l. ...pl,..g ."...t .Ad I. ..ot .a .".r.'I.
80 4a.t'Rctao.. wa. ..4. .. to vh.tti.r ..rcurr v.. aA the org..,c or aAor9.Alc 1o,.. Th.r.to,., the ato to, O,'J.nac ,a.thvll .e,eu,y
v.. 0..4 ,n.'.." ot the ato tor laorg.Alc ...curv b.c.u.. it i. lov.r, i..., .or. protect'"..
'Ih. c.rcanu'J."'c pot.aey t.ctor tor ..thyl.... chlorad. i. eurr.atlr uRd.r'l0laCJ r."'.V vathaa EPA. A ,e"a.." POt.PLY t.ctoe ut 1.8t&:-1
I. b.,a, eon&,4.,.4. E'A .t.tt h.". In4Ic.t.4 tha' th. .."'..d (Iot...c, '.ctor ,. tb. .o.t .p(Ilopr'at. 00. to u~. .t tha~ t,.. IU.5.
I.A "1ge I.
8o ,..tru....t ".t.et,o.. l,.,t v.. .".,I.bl. lor .thrl .tb.r.
purpo... ot a".ra'J''''I tb. oo.b.r..
80 "0 wa. .".,I.bl. 'or l-..thrlnapbth.l.o., but b...d on 1t. .'.il.r,ty to A.phtb.l...., the KtP 'oa n.phth.l.n. w.. u.... .~ .
8ub8"'U'..
a...on.bl. wOI~l C.58 ..we) CORcentration. 818 the bagb..t concentrAtaon. In 00. well .v.I.~.d uV.C d,tt.l.nt ~..~&ln~ p.'.u~~.
w.al loc.taun ut c...Qoebl. W~I.t c... CODce.L..taD.
Tb.r.tor., tb. ".1'1. tOf . Qon-~.t.cte" ..apl. w.. a~.u.e" to b.
I..,U CUI
I.'
(bl
Ic I
1.1
ctl
1.,1
-------
TAtitE
'>(EXTENIIEII)
£.t...t.'" C.nc..
Cooc.ot~.t'QOII. 0..1'1 10'.". ...>l...... V
W. &I 1 'ill "v.~.... ~ "v.~.... ".I. i..... IIID ".1..4 1..4.. r.':lu. t' ~ '.~ ~ ~:j'!'!!!.-: k I:."
".t.16 '"t/LI 18../.../d.'11 1.'1/.../4.'11 "v.~"':I. .1
L"c.t,o. M....U8 . .'.I/"'J/""~l..- ~!!.~ "...8ua
S..avoaataa.a
1.'-OaclllD~ob..a.D. &"-'0 3.1 U.J '.S£-S 1.'£-' 1. U;-l I. U;-a '.1>&:-1>
...aD'c .cid .A-'O 1.1 I.J 1.1£-S 1. &1;-, .£.0 11.1£-'; 1. u:-s
..plltll.a... 1:"-'0 1.1 3 I.I&-S S.ll:-S '1:-1 1.U:-S I.U-'
3-..tll,I..plltb.I... I:A-'O 1.' . '.6c-S J.U-' .£-11.. 1.1&-' s.a&:-'
0'8tll,.plltll.l.t. .,,-J. S.. , 1.1£-' ..1E-' 8£-1 1.1£-' 1.11:-'
Di.a-.Mt,lplitbal.t8 I:A-J. 1.1 '.1 1.11-' I.U-' 1&-1 1.1&-, 1. H;-I
.'813-8tll,.II..,11
plltll.18t8 1:"-10 n.' " '.1£-' ..1£-1 L '£-1 1>.1&:-1> 1. }&:-)
..ataca"..
&.dD8Ml,... 8Mlt.t. E"-SO 0.0&3 0.13' 1.1£-1 '.0£-1 SE-S '.'£-1 1.1>&:-1
WOWAL '.'£-1 I.S£.O &. I&: -. J.'&:-,
-------
'l'AULE
b
"AXI"U" £STI"ATED DAILY INTA.ES AND RISK VALUES fOR CONTA"INANTS DETECTED IN DO"E~TIC WELLS AT EAST HUUNT ZION
"_"leue £..tie.t.d
lte51dentl.l D.lly
Conc.nte.tion Intak. RtD
".tals lI'g/LI W.ll Location leg/kg/d.yl leg/k
-------
TAULE
6
£XT£ND£ND
"a.a.u. £:it a.at.d
Hon-le~a4enta.t.1 Daalv
Concentration Int.ka
"et.l:> (p'J/LI WlIll Loc.tion '.'J/klJ/daVI It.al..ad lu~"w.
a8riu. 'll.. "onitor Well 6.U:-4 1.Jt:-l
Cbro.iu. U.l "onitor Well 1.!U:-4 1 . II £ - 1
"8ng80e.e 1S.' "onitor Well 2.2£-) 1 . It;-.l
"erc:ury 8D
8ic:lI.l U.) 014 Park Well 1.2£-4 ). 6£-2
~balliu. 1.0 014 '8rll Well 2.9£-~ 4.1£-4
Tin :It 014 1'81"11 Well 1.1£-4 1.4£-)
Ii n c: tn.' 014 Pel"lI Well 1.2£- 1 0.0£-2
S..ivol.tal...
.
Oi-n-buty1pbtbal.te 110
TOTAL J.O£-l
-------
TAIiLE 7
CONCENTRATIONS (~g/L) OF COHPOUNDS DETECTED IN DOHESTIC VELLS AT EAST HOUNT ZION COHPARED TO
DRINKING VATER STANDARDS AND CRITERIA (~g/L)
Range for Range for Li f e ( i m~
Residential Non-residrCJial Ueal (h
Hetals I "ells Vells HCL Advisory
Bariuli NO-57.3 1.1-22.4 1,000
Chromium NO-21.7 NO-31. 3 50
Copper NO-331 22.7-511 1,300(b)
Icon NO-7,538 3,448-4,768
Lead NO-14.6 7.0-99 50
5(b)
Hanganese 6.3-543 12.7-75.6
Hercury NO-1. 6 NO-0.28 2
Nickel NO-21.4 NO-25.3 150
Tha 11 i UIU NO-I. 4. 0.7-1.0
Tin NO-20.7 11. 4-29.0
Zinc NO-65 NO
Selllivola(iles
Oi-n-bu(ylph(halate NO-6 NO
SHCa.
1 , 000
]00
50
5,000
(a)NoJl-resiJeJl( ial wells include the Old Park Uell ..HId (he AbaJ\doJ\~d Vell.
(b) Prupu~eJ HCL.
-------
TAIiLE
8
AVt:IIAG£ GIlOUNO-WATt:1I AND Lt:ACUATt: CONCt:NTIlATIONS I~'J/LI AND Ai'PIlOPIlIATt: WU'I:II IJUAL l'rY CHITI:HIA ("'JILl
"CL:i or W.t.r 0...011 ~ CCll.ca.
Propoliad Acuta Chronic -1I-'-;II~;rli\
Ground W..t.r La.ch.ta "CLI! EPA PolDER EPA ....01:" -t:pA-p~oEa-
Vi"yl Cblorida ... eIO 2 ~ O.O~
.a".a". 1.1 eIO 5 litO 1211 1
Cblorob.".a". ..1 eIO 250. 1,1 eo 50. ~h ~II~. 20
Etbrlb.D.aD. 1.0 110 100 n,ooo 2,900 )110. ..00
Irl.D.. 1.0 . 10,000 1,120 1,055 HI HI )00.
l,.-oicblorob.p..D. 2.J liD 1)0 lh tOO
.btb.1at. S.t.r. 9tO )
,"lu.iDu. 10 liD ')SO 11
,"pti.GDY liD liD 1095 2U "5
Ar..Dic 1.1 liD 50 160 190 SO
.al'iu. l5 100 1000 20,SOO .,100 I,UOO
..l'y11iu. liD liD 1)0 5.) 0.001
Cad.iu. l.. .0 10 1,9-1.'.. l.1-LO.. LO 10
Cbl'o.iu. (1 8ID 100 1116-HH." 221-)11.. 110,050
Copp.1' (1 61 11-)... 12-21.. 1000
II'0P 5t50 110 1000 100
L.ad ;t.' 2.} 50 12-200.. ),2-1.1.. SO
"apga"... lUO })}
".I'cul'r 0.1 0.1 2 2.. 0.012 0.144
lIick.1 U.5 eIO ltOO-2500" 1110-210.. cd ~
liDc 11 11 110-110" 110-190.. 5000
..
Chloripatad bap.a"a. watal' qualitr cl'ital'ia.
"al'dp... ba.ad cl'it.l'iai a..u... bal'dD... 100 .g/L to 200 .g/L a. Caca"
'I'opo..d 'aO£8 cl'it.ria.
+
-------
Table 9
DESCRIPTION OF EVALUATION CRITERIA
Overall Protection ot Human Health and the Environment -
addresses whether or not a remedy will: cleanup a site to within
the risk range; . result in any unacceptaDle impacts: control the
inherent hazards (e.g., toxicity and mODility) associated with a
site; and minimize the short-term impacts asaociated with
cleaning up the site.
Compliance with ARAR's - addresses whether or not a remedy will
meet allot the applicaDle or relevant and appropriate
requirements ot other environmental statue. and/or provide
grounds tor invoking a waiver.
Long-term Ettectivene.a and Permanence - reters to the aDility of
a remedy to maintain reliaDle protection ot human health and the
environment over time, once cleanup goals have been met.
Reduction ot Toxicity, MODility, or Volume through Treatment -
reters to the anticipated pertormance ot the treatm.nt
technologies that may De employed in a remedy.
Short~term Ettectiveness - reter. to the p.riod ot time needed to
achieve protection, and any adver.e impact. on human health and
the environment that may b. po.ed durinq the con.truction and
implementation period until cleanup goa18 are achieved.
ImplementaDility - d..criD.. the technical and administrative
teasiDility of a rem.dy, includinq the availability ot materials
and service. n.eded to implem.nt the cho.en solution.
Cost - include. the capital for materials, equipm.nt, etc. and
the operation and maintenance costs.
Support Aqancy Acceptanc. - indicate. wheth.r, Da.ed on its
review ot the RI, PS and the Propo.ed Plan, the Stat. concurs
with, oppo..., or has no comment on the preterred alternative.
Community Acceptance - vill b. a.....ed in the Record ot
Decision followinq a review of the public comment. received on
the Rt, FS, and the propo.ed Plan.
-------
Standard, Requirement,
Criteria, or Limitation
'Resource Conservation
Recovery ~
Standards Applicable
to Generators of
Hazardous Waste
Standards Applicable
to Transporters of
Hazardous Waste
Placement of Waste in
a Land Disposal Unit
Standards Applicable
for landfills
Standards Applicable
to incineration of
hazardous waste
Citation
42 U.S.C.
6901-6987
40 C.F.R.
Part 262
Subparts
A-E
40 C.F.R.
Part 263
40 C.F.R.
Part 268
40 C.F.R.
Section
264.110-
120
40 C.F.R.
Section
264.340-
351
TABLE 10
FEDERAL ACTION SPEICIFIC ARARs
Description
Establishes standards for
generators of hazardous
waste
Establishes Standards which
apply to transporters of
hazardous waste within the
U.S.
Establishes land disposal
restrictions for hazardous
waste
Establishes standards for
closure of landfills
Establishes standards for
incinerators
Applicable/
Relevant and
Appropriate
No/Yes
No/Yes
No/Yes
No/Yes
No/Yes
Comment
ARAR for Alterantives 4
and 5, if remedial action
alternative involves
offsite transportation of
either soil or source
material for treatment
or disposal.
ARAR for Alternative 4 and
5. If remedial action
involves offsite transporta-
tion of soil or source
material for treatment or
disposal..
ARAR for Alternatives 4 and
5. Would be applicable if
waste was determined to be
RCRA waste and waste was
to be placed in a landfill
uni to
ARAR for Alternative 3.
ARAR for Alterative 4.
* Since the waste has not yet been characterized as RCRA hazardous wast~, the standards dr~
not licable. Uowever, since hazardous subst,H are involved, the sti..lnddni::> are relevan
I .
and rOpt-late.
-------
,tandard, Requirement,
'riteria, or Limitation
~cupationa1 Safety and
leal th Act
lazardous Materials
'ransportatlon Act
lazardous Materials
'r anspor ta t i on
tegulations
Citation
29 U.S.C.
1910 , 1926
29 CFR 1910-
120 or 54 FR
\ 9294
49 U.S.C.
1801-1813
49 C.F.R.
Parts 107,
171-177
TABLE 10 (EXTENDED)
FEDERAL ACTION SPECIFIC ARARS
Description
Applicable/
Relevant and
Appropriate
Regulates worker health
and safety in industry
and construction.
Health and Safety
standards for employees
engaged in hazardous
waste operations.
Regulates transporation
of hazardous materials.
Yes/No
Yes/No
Yes/No
Discussion
ARAR for Alternatives
3,4, and 5. Under 40 C.F.R.
360.38, requirements, of the
Act apply to all response
activities under the NCP.
Applies to all response
activities. ARAR for
Alternatives 3,4, and 5.
Only if an alternative
developed would involve
transportation of
hazardous materials.
ARAR for Alternative 4
and 5.
-------
Standard, Requirement
Criteria, or Limiation
Citation
pa Water Quality
Criteria
25 Pa Code
Chapter
93.1 et. seq.
pa Air Quality
Standards
25 pa Code
Chapter
l23.l( c)
8Background8
Quality for
Ground Water
25 pa Code
Chapter
75.264(n)
Pa Municipal
Waste
25 pa Code
Chapter
Regulations
271.113
25 pa Code
Chapter
263.303
Construction,
Modification,
Reactivation
and Ope~tion
of Sou r
25 pa Code
Chapter
127.12
TABELE 10 (EXTENTED)
STATE ARARs
Description
CHEMICAL-SPECIFIC ARARs
Establishes water
quality criteria as
determined by the dis-
charge point and point
of first aquatic use
Establishes require-
ments for fugitive dust
emissions
Hazardous substances
in ground water must
be remediated to
8background8 quality
ACTION-SPECIFIC ARARs
Applies to closure
of municipal landfills
Applicable/
Re levant and
Appropriate
No/Yes
Yes/No
Yes/No
Yes/No
Establishes requirements Yes/No
for municipal waste
incineration
Establishes requirements
for municipal landfill
gas venting and incin-
eration
Yes/No
Discussion
WQCs for contaminants
of concern are relevant
and pppropriate for
alternatives 3,4,and 5.
ARAR for alternatives
3,4, and 5. Applicable
since fill will be re-
graded or excavated.
ARAR for alternative
3,4, and 5 since
contaminants of con-
cern exceed background
ARAR for alternative 3
ARAR for alternative 4.
Applicable since
remedial action takes
place after effective
date of regulation
ARAR for alternative
3 and 4
-------
TABLE 11
SUXXARY OF CAPPING caSTS
LIGKT CLEAR AND GRUB
HEAVY CLEAR AND GRUB
EXCAVATION AND REGRADING
OF 20.000 CY ~ASTE
7,000 CY FILL
- MATERIAL
- DELIVERY
- BACKFILL/COMPACT
GAS VENTING SYSTEK
30 MIL MEMBRANE
GEONET
GEOTEXTILE
FINAL COVER
- MATERIAL
- DELIVERY
- BACKFILL/COMPACT
REVEGETATION
STORXWATER XABAGEXEBT
TOTAL
ASSUXE .
FEBCI_a
GROU~Y.TER XOHITORING
- FIRST YEAR
PRESENT WORTH COST FOR 30 YEARS AT 8% = 12.230.000
-------
RESPONSIVENESS SUHHARY
This community relations responsiveness summary-is divided into the
following sections:
section I
Overview - A discussion of EPA's preferred remedial
alternative and the public's response to this
alternative.
Section II
Background of community Involvement and Concerns -
A discussion of the history of community interest
and concerns raised during remedial planning
activities at the East Mt. Zion Superfund Site.
Section III
Summary of Major Comments Received During the
Public Comment Period and Agency Responses - A
summary of comments and responses categorized by
topic.
I.
OVERVIEW
EPA's preferred alternative for the East Mt. Zion Site is
Alternative 3 as outlined in EPA's Proposed Remedial Action Plan.
Under this alternative an impervious cap would be placed on the
landfill. The cap would provide a relatively impermeable barrier
to infiltration, thereby minimizing the potential for leaching of
contaminants into the groundwater. Surface water controls would be
included in the cap design. This alternative would also include
groundwater monitoring to ensure the effectiveness of the cap and
to monitor the natural attenuation of the contaminants in the
groundwater. Groundwater sampling will be performed and analyzed
quarterly- the first year, and annually thereafter. A formal review
of the site will be conducted within five years. If during this
time, additional contamination is detected, the risk posed by that
contamination would be determined and appropriate action taken.
Deed restrictions and construction of a chain-like fence would be
included as components of this alternative to limit future use of
the Site and restrict access to the Site.
Based on currently available information, EPA anticipates this
alternative will be protective of human health and the environment.
During the public comment period, all written comments regarding
the selection of a remedial alternative were received from law
firms representing potentially responsible parties. These comments
focused on the preference for the no-action alternative and raised
specific questions on various aspects of the RIfFS report.
A public meeting was held on May 30, 1990 and comments from
residents at the meeting centered around who was responsible for
1
-------
the costs of the clean up, future use of the Site, and any possible
health effects to residents. Limited comments were made at the
public meeting concerning EPA's preferred alternative. Since
the current human health risk is negligible, several residents did
question why action needed to be taken. EPA staff explained that
their goal is also to protect the environment and that was the main
concern at the Site.
II.
BACKGROUND OP COHHtrNITY IHVOLVBKBNT AND CONCERNS
Community interest in the East Mount Zion Superfund site dates back
to the 1970' s when a group of citizens first expressed concern
about the landfill to their local officials. Since that time,
community concern and involvement have grown.
In 1983 EPA conducted a Preliminary Assessment and site Inspection
at the Site. The Site Inspection revealed trace levels of
trichloroethylene in groundwater samples. Benzene was reported in
a leachate sample, and dichlorobenzene was found in a leachate and
pond sediment samples.
When these findings threatened to hold up the construction of the
Doersam Woods housing development, residents and officials voiced
their concerns and participated in public meetings. Maj or concerns
expressed at that time related to stagnant pools of water around
the landfill, debris which had worked its way to the surface of the
landfill, and contamination of the area water supp~y.
In 1986 springettsbury Township installed a municipal water supply.
While this eased community concern to a degree, some residences
along portions of Druck Valley and Ridgewood Roads are still using
ground water obtained from private wells.
These concerns, along with comments about EPA's
alternative, and EPA's responses are described below.
preferred
III. SUMKARY OP KAJOR COlIMBlrrS RBCBIVBD DURING TD COMMENT PERIOD
AND AGENCY RBSPONSES.
Comments raised during the East Mt. Zion Superfund site public
comment period on the RI/FS and the Proposed 'Remedial Action Plan
are summarized below. The comment period was held from May 18,
1990 to June 18, 1990. The comments are categorized by relevant
topic.
2
-------
EPA'S preferred Alternative
1.
At the public meeting, a question was raised as to what
happens with the water that is running off the landfill and
whether or not it was getting into residents' wells or into
the different streams in the Rocky Ridge Park.
2.
While the runoff is going into the different
streams, the contaminant levels are within
acceptable ranges. EPA's preferred alternative
calls for putting an impermeable cap over top
of the landfill and thus prevent surface water
from getting into the landfill and
contaminating the deep aquifer. The leachate
areas will be eliminated as a result of
capping the Site.
A concern was raised as to whether EPA's preferred alternative
would present any dangers to residents and what safeguards
would be in place to monitor emissions.
EPA Response:
EPA Response:
A decision will be made during the remedial
design stage as to whether it is necessary to
construct a cap over the entire Site or
whether a partial cap is sufficient. In
addition, modeling has been done to estimate
the volatile emission and it is expected to be
insignificant. Nor are significant dust
emissions expected. Also, monitoring will be
done during implementation of the remedial
action.
3.
A question was raised on the life expectancy of the synthetic
liner, the type of liner to be used and whether the cap has
been used before.
EPA Response:
The life expectancy of the synthetic liner is
in excess of 50 years. There are also clay
materials that meet the same permeability
requirements that synthetic materials do and
this is something that would be looked at
during the remedial design stage. Capping is
an established technology which is often used
for closing municipal and hazardous waste
sites.
4.
A comment was raised on the FS, specifically, would a more
technically adequate RI reveal significant differences in the
nature and extent of contamination and thus generate a
different remedial design alternative.
3
-------
EPA response:
EPA feels that this RI represents a
technically adequate investigation and that
the findings have allowed the Agency to assess
the remedial alternatives and select the best
option. Additionally, there will be
continuing monitoring and review of data
annually to assess the performance of the
selected alternative.
5.
A comment was raised that the design parameters for the
selected remedial alternative are not adequately supported
and, in some cases, have not been evaluated at all., Le.
methane extraction is proposed but the volume of methane gas
generation is not discussed.
EPA response:
The design parameters for the selected
alternative will be developed during the
design phase of the remedial process.
Specifics concerning methane generation and
the development of a collection and venting
system will be addressed during this next
phase of the process.
Remedial Alternative Preference
1.
A comment was made that the recommended alternative be
Alternative No.6 due to its lowest cost or the No Action
alternative.
EPA response:
See response to comment #2 below.
Specifically, the regrading option was
evaluated in the detailed analysis section of
the FS.
2.
A comment was made that the recommended alternative be No
Action or Limited Action Alternative No.1.
EPA response:
All the alternative remedial action scenarios
were evaluated according to the screening and
detailed analysis requirements of the National
Contingency Plan (NCP) and the al ternati ve
that provided the best overall acceptance of
the nine criteria was selected. One single
criteria is not highly weighted, but each are
considered separately. Communi ty and state
acceptance, implementability, long term
effectiveness, as well as cost are considered.
Alternative number 3, capping and methane
venting, was selected as the alternative that
best fulfilled all the criteria.
4
-------
3.
3.
At the public meeting, a question was raised as to whether in
situ treatment was considered.
EPA Response:
The feasibility study did look at some in situ
treatments. However, it was determined that
they either were not feasible or insufficient
evidence existed on their effectiveness; thus
they were screened out.
Remedial Investiaation/Peasibilitv studY
1.
A comment was made on the sampling results and the compounds
driving the action.
EPA response:
Anytime there is a sampling result which
indicates that the maximum contaminant level
(MCL) has been exceeded, the EPA is triqgered
into taking an action to evaluate the cause
and likely extent of the contamination. At
this site the MCL was exceeded for vinyl
chloride and benzene, which are the compounds
that have triggered the action.
Sampling results of specific wells over a
three-round sampling period, for both arsenic
and vinyl chloride were evaluated by using an
averaging technique involving identifying 1/2
the detection limit when there was a non-
detect during a sampling occasion.
2.
A comment was made as to the ARARs (applicable or relevant and
appropriate requirements), i.e., that the Pennsylvania
Municipal Waste Management Regulations are not an ARAR as they
did not go into effect until 1988. -
EPA response:
Because the regulation is presently in effect
all cleanup options or actions at the Site
must consider the regulation as an ARAR. The
Pennsylvania Municipal Waste Regulations are
an ARAR for capping and closure due to non
compliance with the Solid Waste Regulations in
effect at the time initial closure was
ordered.
A comment was made that the Feasibility Study does not set
forth the specific monitoring requirements associated with any
of the remedial alternatives. .
5
-------
EPA response:
Sampling costs are an important item in the
present worth analysis of all the alternative
options. Specific monitoring procedures may
not have been documented in the FS but
estimates were provided for the range of
associated costs involved with .monitoring
programs related to each alternative.
Comments were raised concerning the mismanagement of data
collection, failure to adjust to field conditions, and failure
to collect an optimal amount of information via a particular
method.
4.
- mismanagement of data collected
EPA response:
Aerial photography was used to evaluate past
waste disposal practices and assist in scoping
the work at the Site. Specifically, a 1955
image was reviewed to identify site conditions
and activities at the earliest stage.
Geophysical techniques are a standard practice
used to remotely assess subsurface site
conditions. A range of techniques are usually
selected to provide overlapping and supporting
data that can be analyzed individually to
provide confirmation (or negative evidence) of
an evaluation. At a highly disturbed and
complex site, such as a landfill, resistivity
and conductivity surveys provide a "gross"
analysis of physical aspects of site
conditions, the extent of disturbed
conditions, and an approximation of the
direction or trend of potential offsite
migration of contaminated fluids. In short
geophysics are one of the many tools used at a
site for characterization, with the potential
to provide valuable data. At this site,
geophysical data was used to help decide on
the location of selected soil borings.
Ground water mounding was proposed at the site
and is. based on two lines of evidence: (1)
contamination was identified in the deep
monitoring wells on both the "upgradient"
perimeter wells and in the "downgradient"
monitoring wells, and (2) professional
judgement and evaluation that mounding
commonly occurs below saturated landfills and
surface impoundments.
6
-------
Subsurface data was collected during drilling;
including one rock core, that was completely
described, descriptions of lithology, based on
cuttings and presented on boring logs, and
additional data provided by drilling rates.
Fracture analysis was provided by data from
the core description, and evaluation of the
subsurface flow characteristics. Fracture
analysis was helpful in monitoring well
placement. Soil and borehole logs were
prepared for the -report and are available.
The test borings in the fill were grouted
almost immediately after sampling to protect
the health and safety of the public. This was
necessary because of excess methane levels,
sometimes exceeding 60%.
The purpose of the pump test at the site was
to demonstrate the hydrologic interconnection
between the different flow zones and to
identify any potential hydrogeologic barrier
that would restrict flow at the site. The
pump test was successful in both these areas:
showing the response in all three bedrock flow
zones and by indicating that a barrier does
exist, that affects the amount of recharge or
flow to the site, thereby defining a limited
aquifer. Specific aquifer characteristics,
such as accurate storage coefficient and
transmissivity values, would have been an
extra piece of information for the site, but
this data may not be needed with the
alternative selected.
concerning
5.
Comments were made
analytical data.
EPA response:
the
development
of
poor
Field analytical results such as pH, specific
conductivity, temperature. and the results of
method blanks should have been included in the
appendix of the RI report. This information
is reported in Section 2 of the report in
Tables 2-5, 2-6, and 2-7.
The phthalates, reported from many of the
field samples also were reported from the
method blanks, indicating possible laboratory
contamination.
7
-------
All the composite sampling of the waste
indicates an iron rich metalliferous waste.
Inorganic and organic analyses are presented
in the RI indicating the compounds may leach
from the waste into the ground water.
Compositing can effect the results of
volatiles and semi-volatiles, however, for
indicating the characterization of the waste,
compositing is a reliable indicator of the
potential for all compounds that may migrate
from the waste.
Detection limits are presented for the
organics on Table 6-2 and for inorganics in
the tables of Appendix G. Appendix G presents
the results as they were reported while tables
4-1 to 4-11 report results that are corrected
for detections in field, trip, or rinsate
blanks. Modifiers, "Bn and "un are defined on
most of the tables in the Appendix and the
text.
Early in the investigation, it was decided to
use the method of subtracting the
concentrations detected in field blanks from
the sample results and reporting the final
result. Both the raw results and the reported
results are included in the RI report.
The lack of a QA/QC section in the RI report
is a shortcoming. The QA/QC data is
available, and the analytical results on field
blanks is presented in Appendix G.
Comments were received concerning the failure to report or
collect significant information. Examples of this include:
decontamination procedures
6.
EPA response:
Decontamination procedures are presented in
the Field Operations Plan (FOP).
procedures for compositing
EPA response:
These procedures are presented in the FOP or
Field Sampling Plan and in Table 2-2 of the RI
for waste characterization.
8
-------
no documentation of PID readings or how taken
EPA response:
The methods for taking PID reading and the
frequency of taking the reading are in the
Quality Assurance Project Plan (QAPjP) or the
FOP. The results should be available in the
field logbook.
poor detail in lithology for monitoring wells.
EPA response:
Boring logs for all the wells are prepared and
detailed core log was prepared for well EA-ID.
This information is available.
EPA response:
rock quality designation (RQD) collected but not reported
RQD was prepared for the core from well EA-ID
and is available on the core log.
background concentrations not cited
EPA response:
soil background concentrations are presented
in Section 4, Tables 4-8 and 4-9.
no detection limits on analyses tables
EPA response:
Detection limits are presented in other
sections of the report and in the Sampling and
Analysis Plan.
Comments were received concerning specific comments in the
remedial investigation report.
Page 2-19: "Each Monitoring Well Was Developed By Air Surge
Method. " Air surging when sampling for volatile or semi-
volatile organics is highly inappropriate in that air could
volatilize many of the organics in the ground water and
subsequent samples could be unrepresentative.
7.
EPA response:
Sampling of the monitoring wells took place
long after development. This time lag allowed
the wells to re-equilibrate to the surrounding
ground water conditions and the samples are
representative of those conditions. At this
site, sampling events took place several
months after development.
9
-------
page 2-30: "Typically, corrections are made when drawdown in
the pumping well exceed(sic) 20 percent of the total saturated
thickness..." No case was made in the text that the saturated
thickness of any of the water-bearing zones was of a definite
thickness. A correction for 20 percent of the undefined
thickness is inappropriate.
EPA response:
EPA agrees that 20% of an undefined thickness
is inappropriate. However, the corrections
this statement refers to are for an unconfined
water table condition with a known thickness
of saturated aquifer. The drawdown in the
pump test at the site did not use this 20%
correcting value.
Page 2-24 to 2-38: The analyses of the ground water and the
analytical section has many problems. wi thout going into
detail, the analysis presented is not sufficiently supported
by good data and the arguments and correction factors used to
justify the poor results render the results very questionable.
EPA response:
EPA disagrees with the final conclusion of
this comment. The raw results are presented
in Appendix G, including the analytical data
for the trip and field blanks.
Page 3-13: Re: Test borings in fill; "..., borings were not
left open a sufficient amount of time to allow for water level
stabilization. .. to keep methane expulsion to a minimum."
"Nonetheless, it can be assumed that the majority of the fill
is saturated at least on a seasonal basis." There is no basis
for this assumption.
EPA response:
EPA disagrees. The fill material was
partially saturated during the field
investigation and based on projection, during
a wet season the fill would continue as
partial to fully saturated.
Page 3-14: "... a northeast-southwest trending trench is
apparent in the east-central portion of the si te. This
feature is illustrated on the isopachous map by the 10-, 15-,
and 20-foot isopach contour configurations." Looking at the
map, this appears to be a bench.
EPA response:
The contours show the distribution of
thickness of waste as. interpreted from
geophysical soundings. The change in contours
in a northeast to southwest trend shows a
10
-------
thickening of waste,
trench.
which may represent a
Page 3-15: "Ash material, incendiary in nature, is also
prevalent throughout (the fill)." Knowing that part of the
proposed remediation is exhumation and regrading, this
statement had best be explained and proven. There is no
ignitability testing reported in this report. This could
present a significant hazard if regrading of the landfill is
part of the remediation.
EPA response:
The selected alternative does not include
excavation, nor removal of the waste materials
in the landfill. If areas of the landfill
need to be excavated during regrading, then
ignitability testing will be part of the
design phase.
Page 3-18: "...Drilling cuttings and drill stem advancement
rates were the only method of lithology identification for
these boreholes." Very poor methodology. This was done for
all monitoring wells except one.
EPA response:
The description of the drill cuttings was
compared to the detailed core description
prepared for well EA-1D.
"Semischist" is not a rock type.
EPA response:
EPA agrees with this comment.
Page 3-21: "On the basis of this information, well EA-1D was
located at the intersection of 2 linears just north of the
site." There is no mention of whether they thought they had
intersected these linears and there was certainly no basis for
comparison with other test borings.
EPA response:
The well location was selected to test an area
with the potential for intercepting fractures.
Fracture analysis of the site indicated
fractures were present and may affect the flow
of ground water. One objective of well
location EA-1D was to detect fracture and a
second objective was to provide a means to
determine if the flow zones were
interconnected. The density of the fractures
encountered were reported on page 3-39 and 3-
42.
11
-------
Page 3-27: This section presents a discussion of leachate
generation and the fact that landfill is unlined and in direct
contact with bedrock and residual soil. Recognition of this
fact and the assumption that significant amounts of leachate
is generated during wet weather periods is reasonable, but can
not be substantiated by the data generated in this report.
EPA response:
EPA believes that it is reasonable to assume
that leachate is generated during wet weather
and could contact the saturated bedrock.
Page 3-20: "Based on unforeseen conditions encountered during
the drilling and installation of EA-1D and EA-2D a
modification in deep well design was implemented." section
2.1.6.2 details th~drilling activities at the two wells when
it was realized that there was water cascading into the wells
from fractures above the zones they proposed to monitor. An
attempt was made to grout these zones, EA-1D was lost, had to
be grouted shut and was redrilled; EA-2D was converted to a
medium depth well. In view of the discussion on page 3-27,
cited previously, there were indications in the field that
shallow to medium depth water-bearing units existed and only
one well was completed in order to investigate the
intermediate zone. This is a very poor response to some
significant information.
EPA response:
The major aquifer in this area, and the one
commonly supplying water to the residents in
the area is the deep zone. One of the prime
objectives of the investigation was to
determine if this zone was contaminated.
Page 3-31: n.. . Water-bearing fractures were common throughout
the entire cored sequence, indicative of some degree of
vertical hydraulic interconnection. It was also anticipated
that even the shallow (seasonal) perched water within the
overburden/saprolite may, in part, eventually migrate
vertically towards the deeper zone. . If this was truly
anticipated, it went unheeded during the planning stage of
this project. .
EPA response:
This information was developed after the
drilling and coring of well EA-1D. The
planning stage of the projects was mostly
complete at this time, however one of the
reasons for drilling at location EA-1D was to
determine the interconnection provided by the
12
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proposed fractures. This objective
developed in the planning stage.
was
Page 3-33: "Deterministic characterization of the hydraulic
properties of the fracture system was not within the scope of
work." The paragraph following this sentence goes on to make
unsupported assumptions about the fracture system for purposes
of characterizing the aquifer.
EPA response:
The main objective of the investigation was
not to determine accurate hydraulic properties
of the fracture system but to determine how
the fracture network affected the site
hydrogeology. Some of the assumptions
concerning the fracture are based on
professional judgement.
Page 3-34: "... Potentiometric level fluctuations greater than
40 feet were observed." This may be due to the fact that more
than one water-bearing zone is being monitored in the deep
zone. No distinct zones were shown in this report.
EPA response:
This magnitude of potentiometric level
fluctuation can occur as recharge conditions
change and the levels are reaching a new
equilibrium. Another explanation for this
change in water level is that the site is
located near a ground water divide and there
is a limited aquifer to resupply to zone
beneath the site.
Page 3-37: "Recovery data were non existent in wells EA-3D,
EA-4D, and EA-5D, and incomplete in wells EA-6D, EA-7D and EA-
ID." This statement gives us an indication that the pumping
well EA-1D was over pumped and the aquifer never approached a
steady state condition. As a result, calculations of
transmissivity, storativity and permeability are of doubtful
accuracy.
EPA response:
See response to commertt #4 of this section.
Page 3-40: "The shallow ground water zone is in direct
hydraulic communication with water mounded beneath the
landfill." This is an important concept .if it is correct;
there is no data to substantiate this statement.
EPA response:
See response to comment #4 of this section.
13
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Page 3-41: "No effort was made to construct a water table map
of the shallow zone since waste characterization boring water
levels were inconsistent and taken at a time before the
shallow wells were installed." A missed opportunity to obtain
information that would substantiate the claim that there is
radial flow to the underlying water-bearing zones below the
fill. This observation hints at the possibility that the
landfill may contain distinct zones, some saturated, others
not. This would naturally be important information to
collect, and was not done on this project.
EPA response:
EPA understands that, if the field
circumstances concerning methane gas problems
were different, ground water elevation
measurements of test borings in the fill at
the same time as measurements in the shallow
wells would have been a good opportunity to
demonstrate the potential mounding effect.
The test borings in the fill had to be grouted
because they posed a hazard. EPA also
understands that at any disturbed site there
might be zones of differing saturation as well
as different permeabilities. However, this
information does not affect the selected
remedy.
Page 3-43: "Intermediate depth water-bearing zones were also
encountered during several other deep well drilling operations
at locations EA-7D, EA-6D, and EA-4D, .. . intervals were
encountered at 62-72, 47, and 38 feet, respectively. EA-7 was
the only location to exhibit a significant yield from this
intermediate zone." A second, intermediate water-bearing zone
is for all purposes encountered and ignored. Significant flow
is recognized. This section does not mention the intermediate
zones encountered in EA-1D and EA-2D.
EPA response:
only one of the deep wells reported
significant yield from the intermediate zone,
well EA-7. The other four wells did not find
the important flow that would characterize a
major flow zone. One intermediate well was
installed in this intermediate zone, well EA-
2M.
Page 3-44: "It is uncertain whether the drop in water level
in EA-2M during the 72 hours pumping test was associated with
pumping or was a result of local water table lowering." This
is an apparent effort to explain away the fact that the
intermediate depth well responded better than the shallow
wells during the pumping test. The shallow wells responded,
14
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but to a lesser degree. This information reveals that EA
placed only one well in the" intermediate zone," the one
hydrostatigraphic zone of greatest vulnerability.
EPA response:
EPA does not agree with the last statement.
There is no evidence that the intermediate
zone is a major flow zone or that it is at
greatest vulnerability. This zone was
monitored and did respond to pump tests in the
lower aquifer, demonstrating some
interconnection between the two zones.
Page 3-46, 47: "The vertical flow patterns at the site are
not well defined. vertical gradients within the deep zone
were not characterized. Vertical migration from the shallow
zone to deeper zones is evident and is the primary source of
ground water recharge to the deep zone." The three sentences
all occur in the same paragraph. This continues EA's pattern
of statements continuously being made with no information to
back it up. The conclusions appear reasonable, but no effort
was made to see if they are correct.
EPA response:
EPA disagrees with the format of this comment.
The statements were taken out of context of
the paragraph in which they occur. Each
statement is followed by an explanation of the
methods or limited analysis used to assess the
site conditions.
Page 5-1: "In summary, waste characteristics for organic
compounds identified include... bis (2-ethylhexyl) phthalate
(310,000 ug/kg)." This phthalate was found in method blanks
and is a common laboratory contaminant. It is Remcor' s
understanding that this phthalate was left out of the
contaminants of concern mentioned during the EPA meeting on
May 30, 1990.
EPA response:
EPA agrees that phthalate is a common
laboratory contaminant and that this high
concentration was detected in sample Comp 3RE
of test boring number four. EPA feels that
.while the phthalate is of concern, it was not
the compound that triggered the site response
action. Benzene and vinyl chloride are the
two important compounds that have triggered
the action.
Page 5-1: "Elevated metal concentrations were observed. . . iron
(939,000 mg/kg) ." Obviously a piece of metal was collected in
the sample, and the laboratory analyzed it and found it to
..
~
15
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consist of 93.9% iron.
landfill.
Metal fragments are to be expected in
EPA response:
EPA agrees that metal fragments are expected
in a landfill. Sampling in a complex landfill
can identify metalliferous waste.
Page 5-1: "...The primary mechanisms of contaminant loading
into the surround environments is leachate generation from
water percolating into the fill." There is no data available
regarding the waters in the fill nor is there any' leachate
derived from the fill collected.
EPA response:
Water levels were observed in the test boring
in the fill. There are diversion ditches and
pond to control the water (leachate) that
seeps out near the border of the slope. Two
leachate seeps, one at the southeast .comer
and one at the western slope of the fill, were
sampled during the investigation.
Page 5-3: liThe intermediate zone is not really extensive, as
it was not encountered in all monitoring well borings. II This
statement contradicts information in previous sections.
EPA response:
EPA disagrees with this comment. Previous
sections discuss the extent and hydrologic
flow characteristic of the intermediate zone
across the site.
Page 5-3: "The deeper water-bearing zone...is under semi-
confined conditions." There is no data to substantiate this
information.
EPA response:
EPA agrees that the word "semi-confined" may
be a misleading term.
Page 5-3, 4: ". . . The ground water transport scenario is
composed of...pulsed leachate generation...radial flow away
from the landfill...the intermediate ground water
zone...appears not to be an important transport
mechanism. . . however. . . data suggests that water in the
immediate zone moves downward to deeper water zones." It is
important in the three items characterizing the ground water
flow below the fill, not one statement can be substantiated by
information collected during the ground water investigation.
EPA response:
"
"
Water level data, boring logs, a core
description, and hydrographs all suggest there
16
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"
"
is a dominant vertically downward migration of
infiltration.
Page 5-5: "The relative absence of volatile compounds above
detectable levels in the shallow wells suggests that the
majority of leachate is migrating vertically rather
than...moving laterally in the shallow zone,...detailed
modeling of ground water transport is not warranted at this
site." This states the case that the monitoring of the
intermediate zone is of paramount importance in determining
ground water flow and comes to the conclusion that it is not
important; when in truth there was so little significant
information collected. No modeling is possible.
EPA response:
EPA disagrees. As the report states, the low-
level of volatiles detected in the monitoring
wells proximal to the site, would not justify
a costly, data intensive ground water flow or
transport model.
Pages 1-9 and 1-20 - Manganese was not proven to be site
related.
EPA response:
Manganese does occur in the sample resul ts
from the waste and the groundwater. The
association with the site may not be proven
but seems to be indicated.
8.
A comment was raised on the available technologies for site
remediation.
Pages 2-6 and 2-7 - Permitting is discussed during the
ARARs presentation, but actual permit requirements for
the site were not presented.
EPA response:
The discussion refers to the requirement for
an NPDES permit to discharge the effluent from
onsite ground water treatment processes. The
selected alternative does' not require pumping
or treating of ground water so the actual
permit requirements are not fully presented.
Pages 2-12 - The remedial objective for vinyl chloride
and benzene have been met for two of three sampling
rounds. More information is required before certain
benzene and vinyl chloride concentrations become the
remedial goal of the site.
17
-------
EPA response:
Continued monitoring of the ground water at
the site, after implementation of the selected
alternative will determine the effectiveness
of the actions in reaching the remedial goals.
Page 2-14 - Technologies are supposed to be initially
screened on implementability only. A second screening
then accounts for administrative implementability,
effectiveness, and cost. This procedure was not
followed.
EPA response:
The procedures for evaluating potential
remedial alternatives is presented in the
RI/FS Guidance (Oct. 1988). The initial
screening of alternatives involves three
criteria: implementability, effectiveness, and
cost. .
Page 2-17 - The 30-mil listed in the capping technology
is not in accordance with current guidanc~ documents.
EPA response:
The 30-mil lining is exactly what is required
by the Pennsylvania municipal landfill
regulation. A recent EPA technical guidance
document (EPA 530-SW-89-047) lists a 20-mil
minimum thickness for these liners.
Page 2-19 - Vertical and horizontal barriers are not
technically implementable at this site.
EPA response:
EPA agrees
Page 2-26 - The exca~ation and disposal option for
300,000 cubic yards (yd) of material is unrealistic.
EPA response:
EPA agrees.
Page 2-26 - Cost should also include:
Excavation
Soil erosion and sediment controls
Regrading site at completion
site administration
Air controls
Design (engineering cost).
18
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EPA response:
EPA agrees that these are valid costs to be
considered for the excavation option. During
the screening review of alternatives, basic
costs are considered for each option and
compared to the basic costs for the other
alternatives.
Page 2-26 - Daily cover would be required over the
excavated portion of the landfill to comply with
Pennsylvania municipal waste regulations.
EPA Response:
EPA agrees.
Page 2-27 - Incineration did not consider sorting the
wastes.
EPA Response:
EPA does not agree. During the discussion of
remedial section alternatives, on page 3-5 the
issue of bulk items was discussed.
Page 2-28 - Several important points were neglected when
considering in-situ vitrification ISV including:
Is power available to perform this project?
The technology does not work below the water table.
Metals in the landfill could prohibit the use of
this technology.
The short-term hazards are high.
The cost of in3situ vitrification is typica~lY $400
to $500 per yd and not $100 to $250 per yd, as is
assumed.
EPA response:
All these items are important considerations
to assess the implementability of ISV. EPA
recognizes these issues and considered the ISV
alternative as a costly, and impractical
alternative for this site.
Page 2-31 - Ground water pumping and treatment will only
limit the mobility of the contaminants in the fracture
systems intercepted by the wells. Tnis will do nothing
to remediate the perched ground water.
19
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9.
10.
11.
12.
13.
EPA response:
EPA agrees with this comment. Ground water
pumping with either onsite or offsite
treatment would require additional "design-
phase" site assessment wells.
A comment was made that the alternatives presented are not in
full compl~ance with Pennsylvania municipal landfill closure
regulations unless daily cover, etc is to be included in the
action.
EPA response:
EPA agrees that all alternatives would indeed
require a daily cover placed on the exposed
site to bring the alternative into compliance
with the regulation. Some of the alternatives
have a cover already designed in the option,
such as the selected alternative.
Alternative numbers changed identification numbers going from
Chapter 3 to Chapter 4. It is difficult to follow the text
due to this detail.
EPA response:
This is regrettable, EPA hopes there were no
major problems.
A limited action alternative entitled regrading was added to
the list'of alternatives but was not discussed in the previous
chapters.
EPA response:
This is true; the limited action alternative
is, as the name implies, a slightly different
version of the no action alternative. Because
of the slight difference between the two
options the limited action alternative was
assumed to pass the screening review and was
considered only under the detailed review.
Page 4-6 -
term.
The use of the word "sponge" is not a technical
EPA response:
EPA agrees, but as a conceptual aid, the term
describes the processes and occurence of
fluids within a landfill.
Page 4-8 - Costs are lower than Remcor's recent experience
wi th FSs would indicate. Several factors have not been
considered, specifically:
20
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14.
15.
16.
EPA response:
Wastes must be sorted prior to incineration
The longer construction schedule
efficiency, therefore, increases cost
reduces
Engineering costs have not been included
Site administration
included.
costs
have
not
been
The identified costs associated with each
alternative are just estimates based on the
range of acceptable cost associated with
construction activities developed at other
Superfund sites. The cost factor for each
alternative is one component of the selection
process that is evaluated in a relative sense
to the other potential alternatives.
A comment was made that the conceptual cap grades and sections
are not realistic for placing a mUlti-layer cap over the
landfill.
EPA response:
EPA considers these comments to be design
considerations and will properly address all
specific design parameters during the design
phase. The final grade at the site will meet
the requirements of Pennsylvania municipal
landfill regulations. The diagrams presented
in the FS report were presented as conceptual
aid to understand the proposed remedial
action.
A comment was made that the assumption that the waste being
partially saturated will lower the dust emissions is not
realistic; as soils are exposed and handled, they will dry
quickly.
EPA response:
The EPA agrees with this assessment.
selected alternative's design
implementation will include a plan for
control activities.
The
and
dust
A comment was made that there will be increased mobility of
contaminants, not decreased, as the landfill will be exposed
for four years, and the surface will be irregular.
EPA response:
EPA agrees that in the short term, during the
four years of excavation proposed under the
21
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source removal alternative, there would be
increased mobility of contaminants. due to wind
erosion and ponding on the irregular surface
of the landfill. However, the selected
alternative will not excavate materials, and
contamination will last less than two years.
17.
A comment was made that the RI/FS failed to procure an
adequate basis for evaluating remedial alternatives.
EPA response:
EPA disagrees with this comment. The RI
identified the critical site characterization
data needed to evaluate the potential remedial
alternatives. All the criteria, referenced in
the NCP, were reviewed for each option and
with state concurrence. The best overall
alternative was selected.
18.
A question was raised as to what the ambient air tests showed.
EPA Response:
No contamination was detected.
19. Residents
contamination.
asked
if there was a
possibility of offsite
From the information currently available,
there appears to be no offsite contamination
above any kind of risk levels. The only
contamination found was immediately adjacent
to the Site and no one is drinking that water.
A question was raised as to whether there was any testing for
dioxins and what the results of such testing showed.
EPA Response:
20.
EPA Response:
A high level dioxin test was done and no
dioxin was found. It is not a significant
concern at this time.
Risk Assessment
1.
Page 1-9 - The selection of parameters and justification for
their use in determining risks can be questioned. Use of the
instrument detection limit (IDL) has no bearing on risk
assessment. Vinyl chloride and 1,1-dichloroethane do not
belong in the risk assessment because they were found in both
upgradient and downgradient wells.
22
-------
5.
-------
wells demonstrated that groundwater
contamination exists outside the landfill
perimeter boundary. The assumption that the
concentration of contaminants detected below
the site serves as a worst-case scenario for
potential risk to future use of the aquifer.
Worst case assumptions concerning ingestion of
groundwater at a rate of 2 liter per day for
70 years was the conventional standard used
for risk assessments as of late 1988. By
March 1989, reasonable worst-case exposure
scenarios used an average ingestion rate of
1.4 liters per/day for only 30 years. This is
the average ingestion rate and length of time
people live in a single house. This analysis
has no impact on the alternative that has been
chosen for the site.
6.
A comment was made on the use of the methodology for potential
excess cancer risk and non-carcinogenic hazard index.
EPA response:
EPA accepts methodology used in this report
for potential excess cancer risk and non-
carcinogenic hazard index. The procedures
used are an acceptable method for risk
assessment.
7.
A comment was raised as to the accuracy of the Risk Assessment
based on questions raised on the analytical results.
EPA response:
The assumption that maximum concentrations for
all contaminants are located in one well and
that on-site wells are used as a drinking
water source is a worst-case scenario and the
EPA concedes that it is unlikely to occur.
However, the risk assessment worst-case
analysis is an important step to evaluate the
potential range of possible exposure to
contaminants and groundwater intakes.
Cost of the Remedial Action
1.
A question was raised at the public meeting as to who would be
paying for the cost of the remedial action.
EPA Response:
EPA has identified 11 potentially responsible
parties and is continuing its efforts to
negotiate with these parties regarding the
24
-------
I.
I
cost of the actions taken at the site. The
RI/FS was paid for from "Superfund" through a
cooperative agreement with the State. Should
the potentially responsible parties not reach
agreement with EPA for the remedial design and
remedial action, Superfund money would again
be used and EPA would then attempt to later
recover the costs from these potentially
responsible parties.
Future Use of the Site
1.
Residents questioned how the Site could be used in the future.
2.
As part of the remediation of the Site, there
would be deed restrictions placed on the Site
to limit entry and a chain link fence put up
to protect the integrity of the cap.
A question was raised at the public meeting as to whether or
not any future construction activity in the area could have
any negative effects.
EPA Response:
Future construction acti vi ty would have
minimal effect. The remedial action would dry
out the landfill and thus eliminate the source
of contamination from migrating offsite. In
addition, the groundwater will be monitored.
A resident asked what the site would look like upon completion.
EPA Response:
3.
EPA Response:
There will be a vegetative cover on top of the
cap. It will look like a field with some
methane vents.
Remainino Concerns
1.
A comment was made that Mr. Clyde Zeigler has been improperly
designated as a potentially responsible party.
EPA response:
This is an issue that will be reviewed and
evaluated at a later time. At present, this
issue does not affect the selection of an
appropriate remedial alternative.
2.
A comment was made that the East Mount Zion Site has been
improperly designated as a Superfund Site on the National
25
" "
-------
priorities List and requested the Site be deleted from the
National Priorities List.
EPA response:
This is also an issue that will be addressed
and determined at a later time. At present
this site is on the NPL and has been properly
evaluated for remedial action.
26
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~
,eNNSYLVANIA
~
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL ReSOURCES
June 29, 1990
Deputy Secretary
Environmental Protection
717-787-5028
'. .
,
Mr. Edwin B. Erickson
Regional Administrator
US EPA, Reqion III
841 Chestnut Building
Philadelphia, PA 19107
Re:
Record of Decision (ROD) Concurrence
East Mt. Zion, Sprinqettsburq Twp., York Co.
Pinal Remedy - Groundwater Remediation
Dear Mr. Erickson a
The Record of Decision for the final remedy will
address remediation of qroundwater contamination at the site
perimeter by el~natinq or reducing the risk. through engineering
and institutional controls.
The major components of ~e selected remedy include:
1. Install and maintain an impe:meable cap over the 10
acre landfill.
2. Install and maintain surface water control systems
tor the cap.
3. Install and maintain a fence around the .i te .
4. Monitor groundwater contaminant attenuation after
installation of the cap.
5. Initiate a deed notification regarding future
activities at the aite.
I hereby concur with the EPA's proposed remedy, with the
following condition..
*
EPA will assure that the Department is provided an
opportunity to fully participate in any negotiations
with responsible parti...
The Department will be given the opportunity to concur
with decision. related to the de.ign of the remedial
action, to aS8ure compliance with DBa design specific
ARAR8 .
*
-------
Mr. EQwin B. Erick.on
Regional Administrator
- 2 -
June 29, 1989
..
The Department's position is that its design standards
are ARAR8 pursuant to SARA Section 121, and we will
reserve our right to enforce those design 8tandards.
The Department will reserve our right and responsibility
to take independent enforcement actions pursuant to
8tate ~nd federal law.
..
..
This concurrence with the selected remedial 'action is
not intended to provide any a..uranC8S pursuant to SARA
Section 104(c)(3).
If you have any que.tions reqardinq this matter please
do not hesitate to contact me.
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