United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/110
March 1991
Superfund
Record of Decision:
Brodhead Creek, PA
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50272-101
REPORT DOCUMENTATION i. REPORT NO. 2.
PAGE EPA/ROD/R03-91/110
4. Tl»e end Subtil*
SUPERFUND RECORD OF DECISION
Brodhead Creek, PA
First Remedial Action
7. Autiorfe)
g. fertormmg OrgeJnlzrton Neme md Addreu
12. Sponsoring Orgmlzition Num and Addreee
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
1. Recipient' • Acceeelon No.
5. Report Dete
03/29/91
6.
•. Pfenning Orgenllition RepL No.
10. Pro|ecVTMk/Work Unit No.
11. ContncKC) or QranMO No.
(C)
(0)
IX Type of Report 1 Period Covered
800/000
14.
IS. Supplementery Noiee
18. Abetract (Limit: 200 worde)
The 12-acre Brodhead Creek site is a former coal gasification plant in the Borough of
Stroudsburg, Monroe County, Pennsylvania. The site occupies the floodplain area at
the confluence of Brodhead and McMichael Creeks. Surrounding land use is commercial
and residential. Site features include two earthen levees constructed to protect a
nearby sewage treatment plant from potential floodwaters. From approximately 1888 to
1944, the coal gasification plant was operated along the west bank of Brodhead Creek.
These activities produced a liquid coal tar product comprised of PAHs, which was
disposed of in an onsite open pit until the mid-1940s. In 1980, during construction
repairs to the toe of the flood control levee, coal tar was observed seeping into
Brodhead Creek. From 1981 to 1984, several state and federal emergency response
measures and investigations were initiated onsite. These included installing filter
fences and underflow dams to intercept coal tar seepage, installing a coal tar
recovery pit on the bank of Brodhead Creek, and constructing a slurry wall to
mitigate onsite coal tar migration toward Brodhead Creek. In addition, from 1982 to
1983, the State and EPA conducted a program designed to remove coal tar from a
backwater channel area, which involved excavating and dewatering 900 cubic yards of
(See Attached Page)
17. Document Anelyeie e. Dmcriptor*
Record of Decision - Brodhead Creek, PA
First Remedial Action
Contaminated Medium: soil
Key Contaminants: VOCs (benzene, toluene,
(arsenic)
xylenes), other organics (PAHs), metals
c. COSAH Hem/Grot*
IB. AvtiUbitty Stelement
11. Security Cliu (Ttii* Report)
None
20. Security Out (Thie Pefle)
None
21. No. ofPtget
106
22. Price
(See ANSt-Z39.lB)
See frwtructfone on f
OPHONAL FORM 272 (4-77)
(Formerly MTIS-K)
Department d Commerce
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EPA/ROD/R03-91/110
Brodhead Creek, PA
First Remedial Action
Abstract (Continued)
sediment and backfilling the area with clay and clean soil. Also during this time
period, the PRPs installed recovery wells in the main coal tar pool and subsequently
removed 8,000 gallons of coal tar. This Record of Decision (ROD) addresses
contaminated subsurface soil containing free coal tar, and provides an interim remedy
for the site. A future ROD will address onsite ground water contamination and provide
the final remedy for the subsurface soil. The primary contaminants of concern
affecting the soil are VOCs including benzene, toluene, and xylenes; other organics
including PAHs; and metals including arsenic.
The selected remedial action for this site includes an in-situ innovative enhanced
recovery process which entails installing hot water injection and extraction wells in
the free coal tar areas comprised of approximately 200 cubic yards of subsurface soil;
recovering both coal tar and process water from extraction wells; separating the coal
tar from the process water and disposing of the recovered coal tar at an offsite
permitted incineration facility; treating the process water; discharging a portion of
the treated process water to Brodhead Creek, and reinjecting the remainder of the
treated water into the subsurface soil to enhance coal tar recovery; conducting a
treatability study to evaluate the coal tar recovery process; monitoring ground water,
sediment, and biota; and implementing deed restrictions, and site access restrictions
such as fencing. The estimated present worth cost for this remedial action is
$4,120,000, which includes a total O&M cost of $1,112,000.
PERFORMANCE STANDARDS OR GOALS; The enhanced recovery process will be applied to the
free coal tar (i.e., coal tar at 100% pore volume saturation) areas, and will remove
and treat 60-70% of the free coal tar. This process will prevent further leaching of
contaminants into the shallow ground water.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region III
841 Chestnut Building
Philadelphia, PA 19107
SUBJECT: Record of Decision - Transmittal DATE: March ?», 1991
Memo
FROM: Abraham Ferdas, Director
Office of Superfund (3HW01
TO: Edwin B. Erickson
Regional Administrator (3RAOO)
Attached is the Record of Decision (ROD) for the
Brodhead Creek Superfund Site. The decision outlines
all necessary remedial actions which must be performed
in order to be protective of the public health and the
environment. There were no significant changes from '
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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RECORD OF DECISION
BRODHEAD CREEK SITE
DECLARATION
Brodhead Creek Site
Stroudsburg, Pennsylvania
Operable Unit One
Statement of Basis and Purpose
This Record of Decision (ROD) presents a selected interim remedial
action for a source of ground water contamination located in the
subsurface soils at the Brodhead Creek Site (the "Site") in
Stroudsburg, 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 Substances Pollution Contingency
Plan (NCP) , 40 CFR Part 300. This decision is based upon the
administrative record file for the Brodhead Creek Site.
The Commonwealth of Pennsylvania concurs with the selected remedy.
Assessment of the Site
Pursuant to duly delegated authority, I hereby determine, pursuant
to Section 106 of CERCLA, that actual or threatened releases of
hazardous substances from this Site, as discussed under Summary of
Site Risks in this document, 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.
Description of the Remedy
This interim remedy (Operable Unit One, or OU-1) addresses a source
of ground water contamination located in the subsurface soils
through recovery and treatment of the principal source of
contamination. The primary objectives of this remedy are to
minimize the migration of contaminants in the ground water, to
initiate the reduction of toxicity, mobility, and volume of
subsurface soil contaminants to ground water, and to collect data
on contaminant response to remediation measures. This remedy is
considered an interim action for subsurface soil contamination.
A final action addressing subsurface soils and ground water will
be selected in a later ROD after data generated during the
implementation of the interim action is evaluated and further
investigations are conducted on ground water for the Site. Further
actions will address threats at the Site presented by additional
contaminated soils and ground water.
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The selected remedy includes the following major components:
(1) Installation of extraction wells and injection wells in.
the free coal tar areas of the subsurface soils
(2) Recovery of coal tar and process water from the
extraction wells by using the innovative technology of"
enhanced recovery
(3) Separation of the coal tar from the process water
followed by treatment of the process water
(4) Discharge of a portion of the treated process water to
Brodhead Creek and the reinjection of the remaining
treated process water into the subsurface soils to
enhance coal tar recovery
(5) Disposal of the recovered coal tar at an off site
permitted incineration facility
(6) Installation of a fence to prevent public access durifig
remedial activities
(7) Imposition of deed restrictions to limit future use of
the Site
(8) Monitoring of ground water and biota in Brodhead Creek
to ensure protection to human health and the environment.
Statutory Determinations
This interim action is protective of human health and the
environment, complies with Federal and State applicable or relevant
and appropriate requirements for this limited-scope action, and is
cost-effective. This action is interim and is not intended to
utilize permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable for this
Operable Unit. This interim action utilizes'treatment and thus is
in furtherance of the statutory preference for treatment. Because
this action does not constitute the final remedy for the operable
unit, the statutory preference for remedies that employ treatment
(although partially addressed in this remedy) that reduces
toxicity, mobility, or volume as a principal element will be
addressed by a final response action. Subsequent actions are
planned to address fully the threats posed by this Site.
Because this interim remedy will result in hazardous substances
remaining onsite above health based levels, a review will be
conducted within five years after commencement of the interim
remedial action as EPA continues to develop final remedial
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alternatives for this operable unit. The review will be conducted
to ensure that the remedy continues to provide adequate protection
of human health and the environment. Because this is an interim
action ROD, review of this Site and of this remedy will be
continuing as part of the development of the final remedy.
Erickson Date 7
jy\ Regionjal Administrator
Region1 III
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TABLE OF CONTENTS
FOR
DECISION SUMMARY
SECTION PAGE
I. SITE NAME, LOCATION, AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 4
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 6
IV. SCOPE AND ROLE OF RESPONSE ACTION 6 ,
V. SUMMARY OF SITE CHARACTERISTICS 7
VI. SUMMARY OF SITE RISKS 17
VII. DESCRIPTION OF ALTERNATIVES 24
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . . .28
IX. SELECTED REMEDY 31
X. STATUTORY DETERMINATIONS 33
XI. EXPLANATION OF SIGNIFICANT CHANGES 37
APPENDIX A. RESPONSIVENESS SUMMARY
APPENDIX B. ADMINISTRATIVE RECORD INDEX
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RECORD OF DECISION
BRODHEAD CREEK SITE
DECISION SUMMARY
I. SITE NAME. LOCATION. AND DESCRIPTION
The Brodhead Creek Site encompasses approximately 12 acres in
the Borough of Stroudsburg in Monroe County, Pennsylvania (Figure
1). The Site lies on the west bank of Brodhead Creek between the
bridges of Route 209 (Interborough Bridge) and Interstate 80. The
detailed site plan is shown on Figure 2.
The Site occupies the flood plain area at the confluence of
Brodhead Creek and McMichael Creek. The natural topography over
most of the Site is one of low relief. Surface elevations of the
natural land surface over the flood plain areas of the Site range
between about 377 feet above mean sea level (MSL) at the respective
creek banks to 381 feet in the flood plain interior. This is
contrasted in the northern one-third of the Site, where the land
surface rises abruptly from the flood plain to an elevation of
about 400 feet.
Superimposed over the natural topography is a large man-made
earthen levee constructed to protect the Stroudsburg Municipal
Sewage Treatment Plant from flood waters such as those experienced
in the aftermath of Hurricane Hazel in 1955. On the Site proper,
this levee is arcuate in plan, curving from out of the north and
to the west, effectively blocking any potential flooding from
either Brodhead Creek or McMichael Creek. The levee crown
(elevation of 408 feet) is about 25 to 30 feet above the
surrounding flood plain. The creek side of the levee is sloped at
2.5:1 while the opposite side is sloped at 2:1.
To the west, the levee extends out of the Site area. To the
north, the levee abuts the natural land surface and a concrete
flood wall which protects a Pennsylvania Power and Light Company
(PP&L) substation. The concrete flood wall extends from the levee
embankment northward and is keyed into the west abutment for the
Interborough Bridge. The flood wall is a 22-foot tall reinforced,
cast-in-place concrete wall constructed on top of an interlocking
sheet pile foundation which extends down to elevation 361 feet.
The elevation at the top of the concrete wall is about 407 feet
above mean sea level.
A smaller, and presumably older earthen levee, which extends
northward from the main flood control levee, separates the flood
plain area of the Site from the grounds of the Stroudsburg
Municipal Sewage Treatment Plant. This smaller levee rises about
13 feet above the flood plain with its crown reaching about
elevation 394 feet above mean sea level.
Two small drainage channels enter the Site, join in the Site
interior, and flow through the former flood plain area. The
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FIGURE 1
Brodhead Creek Site Location Map
Brodhead Creek Remedial Investigation
Stroudsburg, Pennsylvania
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FIGURE 2
Site Plan
Brodhead Creek Remedial Investigation
Stroudsburg, Pennsylvania
>.».t,/iM. (.Mi1 ii/11/mi
>.!»•»!/IIJll
tJ (
I e sJ *i o d
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smaller of the two is intermittent in nature, as it carries storm
run-off, entering the Site at the northeast corner via a storm
sewer outfall. The smaller channel is not considered to be a major
Site feature for this reason. The larger channel is perennial in
nature and enters the Site from the west-northwest, flowing across
the central portion of the Site through a flood gate in the levee
to its-outlet on Brodhead Creek. It is referred to herein as the
urban run-off channel.
The northern Site boundary is a combination of private
commercial properties and a cemetery located along Main Street in
Stroudsburg.
The Brodhead Creek Site is located within the Valley and Ridge
physiographic province of the Appalachian Mountains. Bedrock at
the Site is the Devonian Age Marcellus Shale which is described as
a dark, fissile, carbonaceous shale, with some notably calcerous
zones. Directly underlying the Marcellus Shale in the vicinity of
the Brodhead Creek Site is the Devonian Age Buttermilk Falls
Formation which is a viable water supply. This formation supplies
the City of East Stroudsburg municipal wells #1 and #2. The areal
structural geology of the bedrock is complex, with many small folds
superimposed on major folds. However, the dominant alignment o^
major bedrock structures in the region is northeast to southwest.
The wide valley through which Brodhead Creek flows has been
filled by up to 100 feet of unconsolidated glacial deposits. The
Brodhead Creek Site is underlain by at least 60 feet of
unconsolidated sediments of both glacial, recent fluvial, and huma
origin. Four distinct strata can be identified within this
interval: surficial fill, floodplain deposits, stream gravels, and
silty sands.
Surficial fine sands and silts deposited during flood events
of Brodhead and McMichael Creeks comprise the flood plain deposits.
Fluvial origin stream gravels underlie the flood plain/fill
deposits beneath much of the Site, and are the surficial materials
in some areas of the Site. The lithology of the stream gravels can
be characterized as loosely consolidated, stratified, well rounded,
coarse gravels. These gravels are most likely reworked glacial
drift transported and deposited by the streams as they migrated
across the valley floor during the past; therefore, this gravel
deposit correlates with the streambed gravels in the Brodhead Creek
channel.
Historic site borings and test pit observations indicate that
the stream gravel deposits are limited in horizontal extent,
pinching out in the west-central and southern portion of the study
area. The stream gravel thickness averages about 10 to 15 feet,
but ranges from absent in some parts of the study area to a maximum
of over 25 feet in a stratigraphic depression near the center of
the Site. Figure 3 shows a contour map of the base of the stream
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KICURK J
Top of Silty Sand Unit
Brodhead Creek Remedial Investigation
Stroudsburg, Pennsylvania
.,'..- .«IM«*
— « U« » «*.< .
,„,., ' Mi'ii/iMi'.i .M,i,nf,»^ H iv.iiiij/i I/H-I
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gravels (or the top of the underlying silty sands) which shows this
stratigraphic depression. The shape and location of the
stratigraphic depression suggest that it may have been coincident
with a confluence of the ancestral Brodhead Creek and another
ancestral drainage. However, it is postulated that the depression
is a kettle feature created by the melting of a large block of
glacial ice embedded in the silty sand.
The thickness of the stream gravel unit beneath and
immediately east of Brodhead Creek is well defined. However, the
extent of the stream gravel east of the eastern levee is not known.
Because the stream gravel is a channel deposit, it is not expected
to be extensive. The unit is thin in this area, ranging between
approximately 10 feet thick on the north near the Interborough
Bridge to approximately 16 feet thick across from the island
located in Brodhead Creek. Borings and backhoe pits on the island
indicated a significant thinning of the gravel unit beneath
Brodhead Creek due to downcutting by erosion and/or dredging.
Under the island, the unit thins to 4 to 6 feet thick. Since the
stream bed itself is at a lower elevation than the island surface,
the unit is even thinner under the stream, and may possibly be
absent in some areas.
A deposit of stratified fine sands and silts, with some clayey
and gravelly lenses underlies the stream gravels at the Site.
These sediments have been described as fairly uniform silty sands
with virtually no clay fraction present. Available data indicates
that these sediments appear to be about 60 feet thick. Underlying
the deposits is a glacial till deposit. The thickness of the till
beneath the Site is presently not known, but buried valleys as deep
as 300 feet occur in this region.
The Stroudsburg Borough is zoned with areas designated
residential, commercial, and open space. At the Brodhead Creek
Site, the creek, its eastern and western banks, and the small
promontory at the confluence of Brodhead and McMichael Creeks are
zoned as open space. The land from the top of the flood control
levee westward through Main street is zoned as general commercial
land. Land use at the Brodhead Creek Site is categorized as
undeveloped, with some areas (sewage treatment plant and
Stroudsburg Gas Company) being classified as utilities.
The region surrounding the Borough of Stroudsburg includes a
Pocono Mountains recreational area used for- skiing, hiking,
camping, hunting, and fishing. Stroudsburg Borough occupies 1.3
square miles and has a population density of 4,571. In 1988, the
borough had 5,943 residents. Stroudsburg Borough is served by a
public water supply owned by the Stroudsburg Municipal Authority.
The urban areas of Stroudsburg and East Stroudsburg are supplied
by surface and ground water. The Stroudsburg Municipal Authority
obtains its water supply from Brodhead Creek (upstream of the Site)
from water that is pumped directly to the Municipal Authority
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Plant. The Borough of East Stroudsburg receives its water via a
gravity feed from two impoundment reservoirs in Smithfield
Township,- and from three wells in the City of East Stroudsburg.
Two of the wells are located on the campus of East Stroudsburg
while the third is a well screened at the top of bedrock and
located over 2,000 feet upstream of the Site, on the opposite side
of Brodhead Creek in Dansbury Park.
A total of forty potable wells are present within a two mile
radius of the Brodhead Creek Site, of which 33 wells are domestic
wells. Most of these wells are installed in bedrock. Because of
Borough of Stroudsburg ordinances restricting their use, private
wells cannot be used for drinking water or bathing purposes within
the Borough. Residents must hook up to the municipal water supply.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Union Gas Company is a successor to companies which operated
a coal gasification plant along the west bank of Brodhead Creek in
Stroudsburg, Pennsylvania, from approximately 1888 to 1944. A
waste product from these operations was a black tar-like liquid
(coal tar) with a density greater than water and principally
composed of polynuclear aromatic hydrocarbons (PAHs). These wastes
were placed in an open pit located on the property. This practice
continued until the mid-1940's.
In 1917, Pennsylvania Power & Light Company (PP&L) purchased
the electrical section of the Union Gas Company facilities. From
1917 until the 1960's, PP&L acquired adjoining properties in
sections, among which was property owned by Union Gas Company.
On October 7, 1980, during construction repairs to the toe
of the flood control levee at the Site, materials identified as
coal tar were observed seeping into Brodhead Creek. As a result,
several investigations and emergency response measures were
initiated from 1981 through 1984 under the direction of EPA
including:
(1) Installation of filter fences and underflow dams by
the Pennsylvania Department of Environmental
Resources (PADER) and EPA to intercept coal
tar seepage;
(2) Installation of a coal tar recovery pit by PADER on the
bank of Brodhead Creek;
(3) Construction of a slurry wall by EPA to mitigate coal tar
migration from the Site toward Brodhead Creek;
(4) Excavation of backwater channel area where coal tar
seepage appeared to be particularly significant; and
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(5) Installation of recovery wells in the main coal tar pool
by PP&L with subsequent recovery of approximately 8,000
• gallons of coal tar.
The installation of filter fences and underflow dams were
temporary measures to control the immediate discharges to Brodhead
Creek.' The installation of a coal tar recovery pit was discovered
not to be a viable method of coal tar recovery.
The slurry wall installed at the Site was designed to halt the
lateral flow of free phase coal tar to Brodhead Creek through the
stream gravel unit at the Site. The wall is 648 feet in length,
1 foot wide, and 17 feet deep with the lower two feet keyed (i.e.,
penetrating) into the silty sand unit onsite. The surface
elevation of the slurry wall is 380 feet except for a 100 foot
section in the northern area of the Site where the surface
elevation is 382 feet. The wall bottom elevation is 365 feet
except for a section 170 feet in length across the stratigraphic
depression where the wall bottom extends downward to 358.5 feet.
The upstream end of the slurry wall abuts the sheet piling base of
the concrete flood wall. The downstream end of the slurry wall is
keyed into a cement/bentonite grout curtain 50 feet in length that
joins the levee core. Since the wall is keyed at its base into the
finer grained and lower permeability silty sand unit, the slurry
wall prevents the migration of free phase coal tar. However, the
wall does not constitute an absolute barrier to ground water flow
toward Brodhead Creek since ground water may flow beneath ant"
around it.
In January, 1982 EPA and PADER conducted a program designed
to remove coal tar from a backwater-channel area formerly located
just upstream of the urban runoff channel on the creek side of the
levee. This program entailed the excavation of sediment from an
area 350 feet long, 10 feet wide, and 7 feet deep. A total of
about 900 cubic yards were removed with approximately 280 cubic
yards drummed and disposed of at a secure landfill. Upon
completion of the excavation programs, the excavation was dewatered
and backfilled with 600 cubic yards of clay and 300 cubic yards of
clean soil, overlain by stone rip rap. Thus, the backwater channel
no longer exists.
PP&L began operation of a coal-tar recovery system in February
1982. The recovery of coal tar was conducted principally at the
central recovery well nest (RCC) which intercepted a coal tar pool
located in a stratigraphic depression onsite. A total of 8,000
gallons of relatively pure coal tar was removed from the
stratigraphic depression. The recovery system was decommissioned
in July 1983.
Under provisions of CERCLA, the Site was placed on the
National Priorities List (NPL) in December, 1982 with a hazard
ranking score (HRS) of 31.09. The regulations enacted pursuant to
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CERCLA require that a Remedial Investigation and Feasibility Study
(RI/FS) and baseline risk assessment be conducted at each NPL site.
The purpose of an RI is to characterize conditions at the site.
The subsequent FS then develops, screens, and analyzes a series of
remedial alternatives for addressing contamination at the site.
On August 20," 1987, PP&L and Union Gas Company entered into a
Consent Order and Agreement with PADER to conduct the RI/FS for the
Brodhead Creek Site. Field work for the remedial investigation was
initiated on August 16, 1988 and was completed by April 4, 1989.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS and Proposed Plan for OU-1 were released for public
comment as part of the administrative record file on February 15,
1991, in accordance with Sections 113(k)(2)(B), 117(a), and 121
(f)(l)(G) of CERCLA. These and other related documents were roade
available to the public in both the administrative record file
located in EPA Region III offices and at the Stroudsburg Borough
Building in Stroudsburg, Pennsylvania; a notice of their
availability was published in the Pocono Record on February 15,
1991. A public meeting to discuss the Proposed Plan for OU-1 was
held on February 27, 1991 in Stroudsburg, Pennsylvania. EPA^s
response to all comments on the Proposed Plan received during the
comment period is included in the Responsiveness Summary in this
ROD. In addition, a copy of the transcript of the public meeting
has been placed in the administrative record file and information
repository.
IV. SCOPE AND ROLE OF RESPONSE ACTION
Actual or threatened releases of hazardous substances from the
Site, if not addressed through a remedial action, may present a
current or potential threat to public health, welfare, or the
environment.
Section 300.430(a)(1)(ii)(A) of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), 40 CFR
300.430(a)(1)(ii)(A), provides that Superfund NPL sites "should
generally be remediated in operable units when early actions are
necessary or appropriate to achieve significant risk reduction
quickly, when phased analysis or response is necessary or
appropriate given the size or complexity of the site, or to
expedite the completion of a total cleanup".
EPA has divided the remedial work to be undertaken at the
Brodhead Creek Site into two manageable components called "operable
units (OUs)". These are as fellows:
OU-1: Contaminated subsurface soils containing free coal tar
in the stream gravel unit
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OU-2: All ground water in the subsurface units from the stream
gravel to and including bedrock
This Record of Decision has been prepared to document the
selected interim remedy for OU-l. The materials to be addressed
in OU-J. present the principal threats posed by the Site. OU-2 will
be addressed in a future Proposed Plan and Record of Decision after
further investigations are conducted to assess all ground water in
the subsurface units from the stream gravel to and including
bedrock at the Site.
It has been determined that an interim remedial action should
be taken under OU-l to initiate reduction of toxicity, mobility,
and volume of contaminants in the stream gravel unit at the Site.
This interim action will entail the removal of the free coal tar
(i.e., coal tar at 100% pore volume saturation) from the stream
gravel unit. The free coal tar is a principal threat to human
health and the environment as it imparts high levels of
contaminants into the ground water in the stream gravel unit and
may serve as a potential source of release of contamination to the
ground water in bedrock. Implementation of this interim action
will remove the source of the highest level of contamination and
will also reduce further leaching of contaminants into the ground
water.
In addition to minimizing the migration of contaminants by
this interim action, data generated during the implementation of
the interim remedial design and the further investigations for OU
2 will provide the information necessary to determine whether (anc
where) restoration of ground water to beneficial use and/or ground
water "background" quality conditions is feasible. A final
remedial action addressing ground water and subsurface soil
contamination shall be selected through a subsequent Record of
Decision (ROD).
V. SUMMARY OF SITE CHARACTERISTICS
A. Waste Characterization
The coal tar disposed of in the subsurface soils at the
Brodhead Creek Site was the waste product of a coal gasification
plant which operated at the Site between 1888 and 1944. No factual
accounts of actual operations at the plant exist nor is there any
certainty of the actual process or processes used to manufacture
the gas. However, the tars generated by gas manufacturing plants
have several general characteristics including: (1) a density
slightly greater than water; and (2) a composition lacking tar
acids (primarily phenolics) but containing large amounts of high
molecular weight residual material with 40-75% of the tars boiling
above 300-C.
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The chemical constituents of coal tars are primarily
polynuclear aromatic hydrocarbons (PAHs), including heterocyclic
compounds. Coal tars typically consist of the following:
Composition
Light-Oil
Middle Oil
Heavy Oil
Anthracene Oil
Pitch
Distillation
Range
Up to 200«C
200-250-C
250-300-C
300-350-C
Typical Composition
Monocyclic Aromatics
Substituted monocyclic
and dicyclic aromatics
Substituted dicyclic
aromatics
Substituted dicyclic
aromatics; tri- and
polycyclic aromatics
Carbon, wax, bottoms
During the RI at the Site, a sample of coal tar from well RCC-C was
collected and submitted for percent water and fractional
distillation testing. The distillation data and specific gravity
(which approached that of water) indicate that the coal tar at the
Brodhead Creek Site consists of approximately 50% light and middle
oil components. Based on the distillation data, the light and
middle oil component would suggest that naphthalene and substituted
naphthalene are the likely major component of the coal tar.
Metals analysis of the coal tar revealed slightly elevated
arsenic concentrations in the tar. The remaining metals values
were below average concentrations observed in the natural soil
environment occupied by the coal tar.
Coal tar is not a Resource Conservation and Recovery Act, as
amended, (RCRA) listed waste. However, the coal tar constituents
are sufficiently similar to the RCRA listed K087 waste that it is
both relevant and appropriate to meet some of the RCRA requirements
for said listed waste.
B. Mechanics and Extent of coal Tar Migration
The coal tar at the Brodhead Creek Site has a density slightly
greater than water. Once coal tar was introduced into the
subsurface at the Site, the density differential caused the coal
tar to sink downward through both the unsaturated and saturated
sections of the stream gravel unit to the interface with the silty
sand unit.
The coal tar movement downward into the finer grained silty
sand is prevented by the higher capillary pressures within the much
smaller diameter pores of that unit. From the source area,
8
-------
continued migration has been lateral downgradient along the sloping
surfaces of the silty sand unit to lower points where it
accumulated if sufficient coal tar volume was present. This
process accounts for the historic accumulation of recoverable
volumes of coal tar within the stratigraphic depression in the
silty sand unit located directly downgradient of the former
gasification plant facilities.
Figure 4 depicts the areas defined as the extent of the coal
tar contamination. The area defined as the extent of the coal tar
presence encloses all historical coal tar observations, and it
cannot be inferred that the entire area is contaminated by a
continuous layer of mobile coal tar. It is the area where coal tar
may have migrated through coarser grained material in the stream
gravel unit and where coal tar may remain at residual saturation
levels. The region of the Site outside of the area defining the
extent of coal tar presence, based on all available information,
appears to be unaffected ?y coal tar and the coal tar does not
appear to have migrated ir.-o these areas in the past. No coal tar
was found to be present east of Brodhead Creek. This is consistent
with the configuration of the surface of the silty sand unit.
The horizontal and vertical extent of potentially recoverable
coal tar has been identified through periodic surveys of the RI
monitoring wells for the presence of a free coal tar (i.e., coal
tar at 100 % pore volume saturation) surface. Figure 4 depicts the
likely extent of stratigraphically bound, but potentially
recoverable coal tar based on the data that are available. Thi
figure was compiled from stratigraphic data, the well measurements
of the free coal tar surface during the RI, and the historic coal
tar observations. As can be seen from Figure 4, potentially
recoverable coal tar is trapped in a portion of the stratigraphic
depression east of the slurry wall proximal to monitoring well-2
(MW-2) and in the lowest ortion (below about elevation 360 feet)
of the stratigraphic depression west of the slurry wall as measured
in the central recovery well cluster (RCC) . Both of these free
coal tar accumulations can reasonably be considered to be
immobilized by the configuration of the top of the silty sand, and
thus are not capable of further migration as bulk non-aqueous
phase. Based on the RI data, it has been concluded that the coal
tar observed in MW-2 is currently immobile material which was
present prior to construction of the slurry wall onsite, and which
was trapped in the portion of the stratigraphic depression east of
the slurry wall. It was also concluded that the coal tar observed
in the area of RCC is material which has slowly drained into the
stratigraphic depression west of the slurry wall from upgradient
areas onsite. This pooled coal tar is effectively immobile.
Figure 5 shows a stratigraphic cross-section depicting this
configuration.
The total areal extent of subsurface stream gravel affected by
free coal (areas MW-2 and RCC) is estimated to be 1,463 square feet
-------
I'lCIIHK A
Maximum Probable Extent of
Free Coal-Tar Surface
Brodhead Creek Remedial Investigation
Stroudsburg, PA
lir>ililirMl I'lui.)
-------
FIGURE 5
Cross Section B-B'
Brodhead Creek Remedial Investigation
Stroudsburg, PA
8
No*. Oimcnuont in Fit*
25325-05
Ofiwt IT / 0«t*
O.L 5/1/89
BrrfrH >T / 0«tr
O.L. 7/27/89
ChtckM W / 0
-------
(0.03 acres), and the volume is estimated at 179 cubic yards. The
total volume of free coal tar associated with these areas is
estimated-to be approximately 9,000 gallons, with 8,715 gallons and
338 gallons of free coal tar associated with the RCC and the MW-
2 areas, respectively. Based on these volume estimates, the RCC
area contains greater than 96% of the free coal tar present at the
Brodhead Creek Site.
The extent of subsurface stream gravels affected by coal tar
at residual saturation levels (i.e., coal tar at less than 100%
pore volume saturation) is estimated to be 128,702 square feet
(2.96 acres), and the volume is estimated at 27,558 cubic yards.
The total volume of residual coal tar at the Site is estimated to
range from 303,000 gallons to 409,348 gallons.
Therefore, the results of the total coal tar (both free and
residual) volume estimates for the Site indicate that between
312,053 gallons and 418,053 gallons of coal tar are present in the
subsurface soils at the Site. Details on the coal tar volume
calculations are contained in the Brodhead Creek Feasibility Study
Report.
C. Ground Water
The principal shallow water bearing strata at the Site are the
stream gravel unit and the underlying silty sand unit. Together,
they comprise a water table aquifer. While the two stratigraphic
units of the water table aquifer differ with respect to hydraulic
characteristics, they may be considered to be a single aquifer with
regard to ground water flow direction and gradient as they are not
separated by any intervening confining layers.
The median depth to ground water at the Site was 10 feet prior
to the construction of the slurry wall. Construction of the slurry
wall at the Site as a response measure to prevent coal tar
migration has resulted in a significant alteration of the water
table flow regimes. At present, the water table is nearly
coincident with the ground surface in the flood plain areas
upgradient of the slurry wall, and 3 to 7 feet below surface
downgradient of the slurry wall. A ground water head loss of 2 to
3 feet across the slurry wall is present. The sheet pile base of
the concrete flood wall extends (to a lesser extent) the head loss
effect of the slurry wall northward from the slurry wall to at
least the InterBorough Bridge abutment.
Hydraulic head levels appear to indicate that an upward flow
component may exist between the water table and the underlying
strata. Hydraulic head levels indicate that the urban run-off
channel likely recharges the ground water system. Hydraulic head
levels appear to indicate that Brodhead Creek and McMichael Creek
are hydraulic boundaries, and, along Brodhead Creek the majority
10
-------
of this boundary is characterized by ground water discharge
conditions.
Ground water flow from the upgradient side of the slurry wall
is both downward beneath the slurry wall/flood wall and southward
to Brodhead Creek south of the urban run-off channel outlet. This
ground water flow likely does carry aqueous phase coal tar
constituents from the upgradient side of the slurry wall to the
downgradient side with subsequent discharge to Brodhead Creek.
North of the urban run-off channel outlet, the ground water system
on cne downgradient side of the slurry wall discharges to Brodhead
Creek in the northern most portion, is recharged by Brodhead Creek
in the middle portion of the study area, and discharges to Brodhead
Creek in the southern portion. South of the urban run-off channel
outlet to the confluence with McMichael Creek, the ground water
system discharges to Brodhead Creek.
The recharge/discharge conditions along Brodhead Creek are
altered by high creek stage at times of high precipitation. RI
data indicates that at these times, the ground water system is
recharged along the entire length of Brodhead Creek.
Two rounds of ground water sampling were conducted at the Site
during the RI. Samples were collected from both monitoring wells
and stream piezometers of the RI monitoring network (see Figure 6)-.
The first round of sampling was conducted from October 17-21, 1988
and the second round of ground water sampling was conducted from
December 13-15, 1988. A number of volatile, semivolatile, and
inorganic constituents were detected in the sample analyses.
Volatiles detected included benzene, toluene, ethylbenzene, and
total xylenes; semivolatiles included naphthalene, acenaphthene,
fluorene, anthracene, fluoranthene, pyrene, benzo(a)pyrene,
benzo(b)fluoranthene, benzo(k)fluoranthene, chrysene,
dibenz(a,h)anthracene, and indeno(l,2,3-cd)pyrene; inorganics
included cyanide, arsenic, barium, iron, and manganese. Maximum
and average concentrations of those chemicals which exceeded Safe
Drinking Water Act maximum contaminant levels (MCLs) are presented
in Table 1.
The distribution of organic chemicals in the aqueous phase is
the best representation of ground water contamination due to coal
tar at the Site and is presented in Figure 7 as an isoconcentration
map. It is evident from the sampling data that the highest
concentrations of organic coal tar related constituents dissolved
in the ground water are centered around the areas of known coal tar
presence near MW-2 and RCC. Total organic concentrations in the
range of 30,000 ppb to over 50,000 ppb were observed near MW-2 and
the RCC area, diminishing rapidly to 10 ppb or less with distance
away from these locations.
It is EPA's Superfund policy to use EPA's Ground Water
Protection Strategy and Ground Water Classification Guidelines to
11
-------
I IUIKK 6
Rl Monitoring Network
Well Locations
Brodhead Creek Remedial Investigation
Slroudsburg, PA
I I ."<(>',
I ih*.» », , n .if
< Ml' M/l l/ll'l
'I ''."I II.' I MI'I
-------
TABLE 1
EXCEEDANCES OF MAXIMUM CONTAMINANT LEVELS
FOR CONTAMINANTS IN GROUND WATER
(all concentrations are in ug/1)
GROUND WATER CONCENTRATIONS
CHEMICAL
Benzene
Ben20(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(1,2,3-cd)pyrene
Dibenz(a,h)anthracene
Arsenic
MAXIMUM
1100
290
300
270
270
250
68
35
108
AVERAGE
213
22.6
22.6
20.2
20.2
19.4
8.36
€.64
31.3
MCL
5
•3.2 *
0.2 *
0.2 *
3.2 *
0.2 *
0.2 *
0.2 *
53
* Proposed MCLs
-------
KICIIRK 7
Log of Sum of Total
Detected Organics
Brodhead Creek Remedial Investigation
Slroudsburg, PA
I «; i j ti 1 1 .!«»!/ IIJlf
. !.,.>,« t,'li«' "Iv.lll IM MCI
I krtkctf k| , l'«lff
-------
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. Ground water at the Brodhead Creek Site may be
classified as..Class II. Class II ground water is ground water
which is a current or potential source of drinking water and water
having" other beneficial uses.
D. Surface water
Stream flow information for Brodhead Creek was obtained from
two U.S. Geological Survey (USGS) gauging stations, one located
upstream of the Site and one located downstream of the Site. The
northerly (upstream) station is the Analomink Station; the
southerly (downstream) station is near Minisink Hills. The
drainage area of Brodhead Creek at the Minisink Hills station is
259 square miles. The mean discharge between the statior.3 has
varied between 150 and 570 cubic feet per second (cfs).
McMichael Creek, the tributary to Brodhead Creek which lies
along the southern boundary of the Site, has a drainage area of
63.9 square miles. Discharge in this creek has ranged from 23.9
cfs, on September 11, 1985 to 2,890 cfs on September 27, 1985. -
Samples of stream water were collected from Brodhead Creek on
two occasions during the RI. Seven stream water samples (ST-1 to
ST-7) were collected during the first sampling round on October 21,
1987 at the locations shown on Figure 8. All samples from thi
round, with the exception of ST-2, were submitted for targev.
compound list (TCL) coal tar related constituent analyses. The
sample from ST-2 was submitted for full TCL volatile organic,
semivolatile organic, inorganic and PCB/pesticide analyses.
Three stream water samples, designated ST-1, ST-2, and ST-4,
were collected during the water sampling round on October 26, 1988.
Each of these samples was submitted for TCL coal tar related
constituent analyses. In addition, a sample of floating sheen
material designated "Oily Sheen" was collected and submitted for
TCL coal tar related constituent analyses during the second round.
Analytical results from the first round reveals no volatile
organics. No semivolatile organics, pesticides, and PCBs were
reported above detection limits. .In the first round stream water
samples, iron ranged from 39 ppb to 75 ppb, however, iron was
detected in blank samples above these concentrations. Manganese
was reported at 7.7 ppb to 28 ppb in the first round stream water
samples. Barium was detected in the oily sheen sample at 510 ppb.
Analytical results from the second round stream water sampling
report some low level concentrations of volatile organics. All of
the detections occurred at ST-2 where benzene, ethylbenzene, and
total xylenes were reported at 3 ppb, 1 ppb, and 2 ppb,
12
-------
FIGURE 8
Approximate Stream/Sediment Sample Locations
Brodhead Creek Remedial Investigation
Stroudsburg, Pennsylvania
LEGEND
O Approximate Sediment Sampling Point
• Approximate Stream Sampling Point
Will
21)3 2$ U!>
lltim< tp/UJI)
ih.a.oi/ixi. JIA^"U./!I/M'J
0 UK) I'dll
Si.illi.- In I j;t;l
-------
respectively. The same volatile compounds were detected in the
oily sheen sample at 32 ppb, 10 ppb, and 33 ppb, respectively. All
of these 'compounds are components of petroleum fuels. Upstream
influences of ST-2, such as highway run-off, may have been present.
No semivolatite compounds were detected.
E. Soils
Analytical data are available for four samples of overburden
materials collected during the drilling of wells MW-9, MW-io, MW-
11, and MW-12. Soil samples from MW-9 and MW-10 were collected
from the lowest depth reached during drilling (the silty sand unit)
as no evidence of contamination was observed above the boring
termination depth. Soil samples from MW-11 and .MW-12 were
collected from the gravel unit. Traces of coal tar were observed
at very low residual saturation levels in the stream gravel unit
in the MW-11 installation boring. Tables 2 and 3 give the data
from volatile/semivolatile organics and inorganics, respectively.
Volatile organic compound analytical results from samples
collected within the silty sand (MW-9 and MW-10) indicated the
presence of chloroform at 2 ppb in MW-10. Volatile results from
soil samples collected within the gravel unit (MW-ll and MW-12)
show evidence of low level contamination in only MW-ll where traces
of coal tar were noted in the sampled materials. four volatile
compounds were detected; ethylbenzene and total xylenes at 61 ppb
and 100 ppb, respectively, were most prominent.
The semivolatile organic results for the four soil samples
range from no detection in the silty sand of MW-9 to high
concentrations in the gravel unit at MW-11 where traces of coal tar
were observed. The semivolatile organic results from MW-9 showed
total unidentified hydrocarbons at 170 ppb. These results suggest
that the southerly extent of the contamination, if any, in the
silty sand lies north of MW-9 on the west side of the slurry wall.
Semivolatile results from the silty sand at MW-10 show low
concentrations of acenaphthene, phenanthrene, and pyrene at 62 ppb,
130 ppb, and 58 ppb, respectively. Given the very low mobility of
these compounds and their relatively low level concentrations,
their detection within the silty sand may be the result of auger
dragdown during drilling. However, their presence in the silty
sand sample from MW-10, located immediately downgradient of the
slurry wall, may also be the result of aqueous phase transport and
ground water flow under the slurry wall.
The semivolatile organics results for gravel samples collected
from MW-11 and MW-12 indicated the presence of site-related
semivolatile organics. The concentration of individual
semivolatile compounds present in the MW-ll results are very high,
suggesting the presence of residual saturation coal tar within the
sample matrix. The MW-12 results show much lower concentrations
and are inconclusive. In MW-ll, reported concentrations ranged
13
-------
TABLE 2
SOIL SAMPLE RESULTS
TCL Organic Analyeoa
Collected 27-29 Seo'emoer 1964
Brodhead C/ae* Remeoal Inveatigauon
Slroudaburg,. PA
ERM Traffla Report Number 1
Sample Location
CompuChom Number
Data of Collaetlen
Percent Moisture
VOLATILE ANALYSES
Dilution Factor
Methyiono Chloride
Aerano
Chloroform
Benxano
Etfiytjonnn*
Slyrene
Total Xylanas
Tentatively Identified Compound*
SEMTVOLATfLE ANALYSES
Dilution Factor
PH
Naohtialana
2-Motnyinapntnaiene
AeanaBntnytano
Oibontofuntn
Ffuorano
PhanantnnMi*
Anilvaoan*
di-n-Buiyiphthaiai*
Fhjoranmano
Pyrana
9utyibonryipnmaia.M
Banxo(a)Aomracan«
CnryMM
bi»(2- Elhyihaiyl! Phihalata
9anzo(D or MFluoraniMn*'
Banio(a)Pyrar<«
lnaano(l.2.3-«d)Pyrana
8anso(g.lt.i)P*ryi*ii*
Tantatf«*4y Mantlflaal Campownda
Total Porynuctaaf AromaBea
Tout UMnoww
TOTAL PHENOUCS
12068
UW-(
220092
9/29/86
22
1.0
12 B
18 B
2 J
NO
1.0
7.1
1100 a
170 J
m
12068
MW-10
220063
9/28/88
10
1.0
7 a
14 a
so
1.0
7.0
A 9 1
92 J
130 J
58 J
2200 B
150 J
300 J
M
12064
MW-1 1
219716
9/26/88
24
1.0
14 a
23 a
2 J
61
2 J
100
re
S/lS
7.1
27000
S4000
2700
• QAAA
1 VQQO
2700
tsooo
34000
9800
6400
1SOOO
4500
3500
1000 B
2900
2600
590 J
•600 J
25000 J
450000 J
130
12061
MW-1 J
219706
9/27'S8
20
1 0
22 9
1 1 a
NC
1.0
7.1
49 J
140 J
T 1 ]
73 J
140 J
310 J
170 J
60 J
310 J
550
1000
220 J
220 J
970 3
210 J
220 J
46 J
63 J
2300 J
2400 J
QUALIFIER COOES:
B • Th* ra*Uf ia qu«liUBv«ty invalid sine* thia compound was daiactad in a blank at a aunilar coneamrauon.
J • Thia raautt a a Quantitative. Mtanaie.
NR • AnaJywa lor thu panvnaiar not required.
Note: No conomiraaon « entered lor compounds wrtiefi war* not isetaetad.
* UnnMonwd isomara.
Th»
-------
TABI.K 3
SOIL SAMPLE RESULTS
Full TAL Tola! Inorganic Analyses
Colluded 2729 Seplumbur I98«
Biodhaad CiauK Rttmttdial Invasligauun
Slroudsburg. PA
(All concentrations leported in mq/Kq on
Trallic Report No.
Sample Location
CompuChmi No.
Dal* ol Collodion
% Solids
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
ion
Laad
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
12068
MW-9
220100
9/29/68
78
4570
39
23
0.49
2100 J
44
60
18 B
10800
8.9 J
1950 J
404 J
0 61 B
5.8
47 J
12066
MW-10
220099
9/28/88
90
6550
38
31
0.42
2120 J
to
6.0
15 B
15900
8.4 J
2460 J
348 J
14
76
59 J
a dry wuiqhl basis
12064
MW 11
219723
9/27/88
82
8350
4.1
47
0.44
9790 J
13
83
19 B
18000
15 J
7890 J
676 J
20
2.3' J
345 B
1 1
80 J
12061
MW-12
219721
9/27/88
80
5090
2.3
24
0.48
381 J
61
74
14 B
1 1400
7.6 J
1920 J
1 /I J
14
730 B
588 B
7.0
53 J
CXJA1IHtilCOOtS U This rustill is qiKihl.iiivuly invalid since ihis dnalylu w.is duluclud in
blank ,n ,i 'jiiNil.ii i oiK.riilt.iliuii
.1 Illlb IC'jIlll It, .1 I|II,II||I|.|||VU UblllkMlu '
Hut. M'Mill it, ii:|iin|i-il I ,. (lii(j|ii ,ili- .in.ily .1:. nl Hub :,.mi|.l..'
Null.- tin < inn I'Mli.iiiiin i . i| Itn .in.ilyli.'t, whii li wriii mil ili-li.-i !.•
-------
from 590 ppb for indeno(l,2,3-cd)pyrene and up to 54,000 ppb for
2-methylnaphthalene. Total PAHs were tentatively identified as
present a* 450,000 ppb. The results from MW-12 indicate that
concentrations ranged from 46 ppb for indeno(l,2,3-cd)pyrene up to
1,000 ppb for .benzo(a) anthracene.
Total phenolics were analyzed only for the stream gravel
sample from MW-11. They were reported at 130 ppb.
Inorganics analyses were performed for all collected soil
samples. Most of the inorganic concentrations reported for the
soil samples lie within normal ranges. Exceptions are aluminum,
iron, and sodium, which appear to be somewhat below normal ranges.
F. stream Sediments
RI analytical data are available for six stream sediment
samples collected along the reach of Brodhead Creek directly
adjacent to the Site. These were collected as "grab" samples at
locations from upstream of the InterBorough Bridge to the
confluence of McMichael Creek.
The results of volatile organic analyses indicate the
detection of these chemicals in only one sample. Methylene
chloride at 710 ppb at location ST-1, upstream of the Site. As
methylene chloride is a common laboratory contaminant, thi's
chemical is not considered to be of Site origin.
Coal tar related semivolatile organics were detected in
samples from two locations, ST-1 and ST-6. At ST-1, phenanthrene,
fluoranthene, pyrene, and chrysene were detected at 58 ppb, 85 ppb,
120 ppb, and 62 ppb, respectively. As ST-1 is upstream of the Site
and well beyond the documented presence of coal tar presence, it
is not considered to be of Site origin. Also, the absence of a
larger suite of coal tar related compounds suggests an alternative
origin from an upstream location.
The results from location ST-6 indicate that coal tar related
compounds are present. Location ST-6 is downstream of the Site and
is located just at the outlet of-the urban run-off channel into
Brodhead Creek (Figure 8). In view of the historic releases of
coal tar from the former backwater channel with subsequent
migration to Brodhead Creek via the urban run-off channel,
detection of coal tar related compounds at this location is not
unexpected. At ST-6, a larger suite of coal tar related compounds,
phenanthrene, fluoranthene, pyrene, benzo(a)anthracene, chrysene,
and benzo (b) f luoranthene were detected at 55 ppb, 160 ppb, 180 ppb,
110 ppb, 110 ppb, and 59 ppb, respectively.
Inorganics were analyzed in all stream sediment samples
collected at the Site. Most inorganics concentrations were within
normally expected limits for soils except aluminum and calcium,
14
-------
which appear to be below normal limits. Cyanide was not detected
in any sample.
G. Air Quality
&n air quality investigation was conducted to assess the
presence of volatile organic compounds at the Site. No volatile
organic compounds were detected during the investigation.
H. Biota
The results of the numerous aquatic biological surveys
conducted at the Brodhead Creek Site indicate that the creek
exhibits relatively diverse, healthy benthic and macroinvertebrate
and fish communities (including trout), with no significant effect
by the Site either within or downstream of the coal tar area.
Two species were sampled at the Site during the RI. The
tissues of the sampled biota were submitted for TCL coal tar
related constituent analyses to assess any Site contributions to
the body burden of the biota. Both trout and sea lamprey larvae
were collected from locations upstream and downstream of the Site.
Volatile organic compound results for both the upstream and
downstream fish tissue samples indicate detection of these
chemicals at low concentrations in all three upstream tissue
samples and only one downstream sample. Four volatile organ!
compounds, carbon disulfide, 2-butanone, benzene, and total xylen-
were reported at maximum concentrations of 7 ppb, 41 ppb, 10 ppb
and 11 ppb, respectively. Neither carbon disulfide nor 2-butanone
are coal tar related and likely originate from a source other than
the Site. It is commonly recognized that 2-butanone is a
laboratory contaminant. These two compounds were detected in
ground water only once at separate locations and at very low levels
during the Site ground water survey. Similarly, although benzene
and xylene are the most prevalent volatile organic compounds
detected in onsite ground water, there presence in fish tissue may
be due to an offsite source.
Semivolatile organic compound results from the fish tissue
samples indicate detections of these chemicals in one upstream
tissue sample and one downstream fish tissue sample. Analytical
results indicate that bis(2-ethylhexyl)phthalate was present in an
upstream tissue sample at 160 ppb, and 4-methylphenol was present
in a downstream tissue sample at 380 ppb. Neither compound is a
major constituent of coal tar. However, the latter could be a
metabolite of PAHs. Twenty-nine other semivolatile organics were
tentatively identified in upstream and downstream fish tissue
samples. Of these, 16 are typical of fish tissue and do not
represent contamination. Of the remaining 13, three were
identified only in downstream fish tissue samples or were present
at concentrations greater than upstream samples. No relationship
15
-------
can be established between these and the coal tar at the Site, as
these compounds are neither identified as constituents of coal tar
nor are they naturally occurring in fish tissue.
There is ..no consistent relationship between coal tar at the
Site and the number of organic compounds detected or the frequency
of detection in either upstream or downstream fish tissue samples.
Some of the compounds found in the fish tissue (such as phenols and
diols) could represent metabolites of PAHs. In addition, the
organic compounds detected are either typical of fish tissue or can
be associated with many sources. Thus, their presence in fish
tissue collected at the Site does not conclusively demonstrate an
impact by the Site on fish in Brodhead Creek. If fish do uptake
PAHs originating from the Site, they rapidly metabolize them, as
evidenced by their absence in the fish tissue samples collected.
It is to be noted that Brodhead Creek is periodically stocked,
therefore, actual fish residence time may not be sufficiently long
to reflect Site impacts.
Sea lamprey were also collected at the Site at both upstream
and downstream locations. Sea lamprey larvae analytical results
for TCL coal tar related constituents revealed the presence of coal
tar constituents in the sea lamprey samples analyzed.
Volatile compounds in the sea lamprey larvae samples were
found in nearly the same total concentration at both the upstream
and downstream stations. Most of the compounds found were
tentatively identified below their detection limit. Ethylbenzene,
benzene, and 2-butanone were the only volatile compounds found
above their detection limits in downstream samples. 2-butanone was
the only compound found above its detection limit in the upstream
sample and may be due to laboratory contamination. Ethylbenzene
and benzene are found in coal tar but their presence in sea lamprey
samples may be due to offsite sources.
Semivolatile compounds were also identified in both upstream
and downstream samples. Compounds typical of the biochemical
processes of fish were also identified and are not of concern.
Semivolatile data from the sea lamprey tissue indicates that the
sea lampreys have accumulated levels of PAHs above what would be
expected at uncontaminated sites. The lampreys can be regarded as
a worst-case scenario for fish flesh contamination. Their tendency
to accumulate high levels of contaminants is due to their life
cycle. Larval lampreys are relatively non-mobile, burrow in the
sediments, and feed on algae and other organic particulates. These
organic particulates readily absorb PAHs and other organic
compounds.
Inorganic analyses were conducted for iron, manganese, and
cyanides. None of these inorganics were detected at concentrations
of concern.
16
-------
During the aquatic biota sampling activities, no visible
adverse effects on the biota were observed (such as tumors or skin
lesions).- The sea lamprey population was thriving, as well as the
fish population in Brodhead Creek. Fish species that were observed
included brown, trout, American eels, blue gills and other panfish,
white suckers, shiners, etc. In addition, the fish tissue sampling
indicated no bioaccumulation of PAHS in tissues.
I. wetlands
A majority of the land encompassed by the Site boundary is
characteristic of wetlands except for the flood control levee
icself which is elevated well above the flood plain.
The earthen flood control levee divides the functional flood
plain adjacent to Brodhead Creek from the former and presently non-
functional flood plain behind the levee. The former flood plain
area behind the levee is covered by a dense growth of herbs, vines,
shrubs, and saplings. No visual evidence of stressed vegetation
was observed. The flood plain areas adjacent to Brodhead Creek are
dominated by herbs, except for the area that also borders McMichael
Creek, which is characteristic of young forest area. The islands
in Brodhead Creek are dominated by herbs and saplings. Six areas
designated Wetlands A through F were identified during the remedial
investigation and are presented in Figure 9.
VI. SUMMARY OF SITE RISKS
The purpose of the risk assessment performed for the Brodheac.
Creek 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 RI 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.
A. Indicator Chemical Selection
The contaminants identified in the Brodhead Creek Site RI are
comprised of a diverse group of compounds with different physical,
chemical, environmental, and toxicological properties. The extent
of contamination varied widely in concentration and occurrence
throughout the Brodhead Creek Site. Moreover, some contaminants
represent a greater potential for risk to human health and the
environment than others because of the differences in toxicity,
17
-------
KIUURK 9
Wetlands Areas
Brodhead Creek Remedial Investigation
Stroudsburg, Pennsylvania
leg tsncJ
.". t .'flll'l
in... t,,i>,., < Ml-MM i, in
«' /V ISO
,/n.,, H h,in II I I/M'I
-------
capacity to migrate to receptors, and likelihood of exposure
concentrations at levels high enough to pose human health and
environmental risks.
The indicator chemicals selected for the Brodhead Creek site
are: benzo(a)pyrene (to represent carcinogenic PAHs); naphthalene
(to represent noncarcinogenic PAHs); benzene; and arsenic. The
rationale for the selection of these indicator chemicals is
presented in the Risk Assessment Report for the Brodhead Creek
Site.
B. Exposure Pathways
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
Brodhead Creek Site considered the potential exposure routes, which
included: (1) dermal contact with surface soils, sediments, and
surface water; (2) accidental ingestion of surface soils,
sediments, and surface water; (3) ingestion of fish from Brodhead
Creek; (4) vapor inhalation from surface water; and (5) dust
inhalation from surface soils.
Currently, there are no significant risks associated with
direct contact with the subsurface soils containing free or
residual levels of coal tar. Long-term potential for direr
contact with subsurface coal tar would be limited to worker
excavating for utility and/or levee construction or maintenance.
The infrequency of any such exposures would likely render the risks
insignificant.
Due to the steady-state Site conditions, there would be no
long term risks related to the recreational use of Brodhead Creek,
nor via ingestion of fish from Brodhead Creek. Also, as shown in
the Risk Assessment Report for the Site, there are no significant
potential risks associated with flood scouring of the residual coal
tar beneath the creek bed.
The risk assessment did not analyze the health effects
associated with the ingestion of ground water at the Site.
As identified in the RI/FS, the ground water in the stream gravel
unit at the Site is highly contaminated. Peak, concentrations of
arsenic, benzene, and other organics measured in the surficial
ground water exceed current and proposed Federal drinking water
standards. Federal maximum contaminant levels (MCLs) are exceeded
for benzene and arsenic in the ground water in the stream gravel
unit. Proposed MCLs are exceeded in the ground water for the
following PAHs: benzo(a)pyrene; benzo(a)anthracene;
benzo(b)fluoranthene; benzo(k)fluoranthene; chrysene;
dibenz(a,h)anthracene; and indeno(l,2,3-cd)pyrene (see Table 1).
18
-------
The coal tar wastes are currently contaminating and/or would
continue to contaminate this ground water. The RI data suggests
that the -free coal tar located in the stratigraphic depression is
the principal source of the ground water contamination onsite. The
stream gravel ..unit is not currently used as a water supply onsite.
However, exposure to ground water in this stream gravel unit might
occur: In addition, the free coal tar located in the stratigraphic
depression may serve as a potential source of release of
contamination to ground water in the bedrock which is currently
used as a drinking water source offsite. Since contaminants
detected in this stream gravel unit exceed current and proposed
MCLs, there is a potential health risk associated with ingestion
of ground water at the Site. Ground water will be the subject of
further analysis in OU-2.
C. 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 bioassay 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 are exposure
levels for humans, including sensitive individuals, that are 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 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 uncertainty factors help
ensure that the RfDs will not underestimate the potential for
adverse noncarcinogenic effects to occur.
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 to the reference dose).
By adding the HQs for all contaminants within a medium or across
all media to which a given population may reasonably be exposed,
the Hazard Index (HI) can be generated. The HI provides a useful
19
-------
reference point for gauging the potential significance of multiple
contaminant exposures within a single medium or across media.
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 one 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.
A summary of the toxicological indices for the indicator
chemicals selected for the Brodhead Creek Site are presented in
Table 4.
D. Risk Characterization
The potential carcinogenic risks associated with the Brodhead
Creek Site were calculated by multiplying chronic daily intakes by
the appropriate carcinogenic potency factors. The resultant
potential risks are presented in Tables 5 through 9. Table 9 also
lists the potential Total Lifetime Carcinogenic Risk posed from
exposure to all indicator chemicals and to all the evaluated
potential exposure pathways (excluding ground water). This
calculated risk, using a CPF of 11.5 (mg/kg/day)E-l for calculating
the carcinogenic risk posed by the PAHs, was found to be 1.98E-5
for adults, 4.02E-5 for children ages 6-12, and 2.84E-5 fc
children ages 2-6. These calculated risks fall within EPA1
recommended range of l.OE-4 to l.OE-6 for CERCLA sites.
This risk includes an increment of risk from arsenic which
does not exceed background in surface waters at the Site. The
current RI sampling data for arsenic indicates a maximum
concentration of 23 ppb (less than the MCL of 50 ppb) and an
average concentration equal to 7.5 ppb. Both of these results are
well below the acute and chronic Federal Ambient Water Quality
Criteria (AWQC). Therefore, no significant risk is posed by
arsenic in surface water. In addition, the sediment data indicate
arsenic levels (3.1 ppm) within the expected natural soil values
(6.0 ppm). Furthermore, the ground water discharging to Brodhead
Creek does not increase the arsenic levels in surface water due to
the significant dilution at the stream/aquifer interface.
E. Worst Case Risk
Since no PAHs were detected in surface water or in fish tissue
during the RI, the carcinogenic risk estimate assumed no PAH-
related risk from fish consumption. However, due to the practical
limitations of the fish tissue sampling/analysis methodologies, to
obtain an absolute worst case carcinogenic risk resulting from fish
ingestion, the sea lamprey tissue concentrations are assumed to
20
-------
TAI1I.I-: 4
TOXICOLOGICAL INDICES FOR BRODHEAO CREEK SITE INDICATOR CHEMICALS
Indicator Chemical
Arsenic. Inorganic
Benzene
Benzo|a)pyrene lo
Represent Carcinogenic
PAHs
Naphthalene to Represent
Noncarclnogenlc PAHs
Federal
MCL Value
(ntf/U
0.05
0.005
NA
NA
ToxJcologlc
Class
HC
HC
HC
PC
PC
NC
EPA
Killing i
A
A
A
A
U2
U2
NC
CPF
l/nifi/kji/day
1.75
50
2.9 E-2
2.9 E-2
6.1 E+O//
6.1 E*0«
NA
»
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
RfDor
AIC
(nif>/kj{/dayl
I.4E03*
4.0E02*
4.0EOI*
4.0EOI*
4.0E-OI*
4.0E-OI*
4.0 El
Source
CI'F IRIS
CI'F IRIS
CI'F IRIS
CI'F SI'IIEM
CI'F- SI 'HEM
KUI IIKA
All RfDs are oral values unless otherwise specified.
NA - Not Available
ND - No Data
IRIS - USEPA's On Une Integrated Risk Information System (Accessed 5/10/89)
HEA - Health Effects Assessment Manuals. 5/19/88
NC - Noncarcinogeiitc
HC - Human Carcinogen
I"C - Potential Carcinogen
AIC - Acceptable Intake Chronic
PI I RED - Public Health Risk Evaluation Database
SI'IIEM - Superfund Public Health Evaluation Manual
MCL - Maximum Contaminant Level
CPF - Carcinogenic Potency Factor
RID - Reference Dose
• Either pending or no data available: values shown have been deilvcd by ERM
See text for explanation. t
// dr..) .-HI.I iiili;il.-itiiMi CI'K's I iir l.uM/..nrl lur limit: j ill orinat ion.
-------
TABLE 5
PPM. BRODHEAD CREEK SUE
CALCULATION Of CARCMOGEMC RISK
KM DERMAL EXPOSURE
NO ACTION SCENARIO
Eiposura Exposed Houia ol Aiaa ol
Scenaiu PopulMion Eiposua Eiposure Chamical
No Action Adulls Oarasal Contact Surlaca Soils Aisanic
Soils Baniana
Banio|a)Pyiana'
NapMhalana
Denial Contact Sediments Aisanic
SediateMS Baniana
Benio(a)Pyrene
Naphthalene
Dermal Contact Suilaca Water Aisanic
Surlaca Water Baniana
Beruo(a)Pyrone
Naphthalene
Children 6-12 Dermal Contact Surlaca Soils Aisanic
Soils Baniana
Benio(a)Pyiane
Naphthalene
Dermal Contact Sadimanis Aisanic
Sadimaras Baniana
Benio(a)Pyiana
Naphthalene
Oaimal Contact Suilaca Waiei Aisanic
Suilaca Waiai Baniana
Benio(a)Pyiana
Naphlhatona
NA Nul d|>)ilu .ililu
i.t'l t,.iiiiMoiji:n Puli.'Mi |r 1 .it lui
Lilelime Ad)
Chionic
Daily Iniaka
(mg/hg/day)
NA
NA
6408E 10
t 028E a
S894E 8
0
6 764 £09
0
1 I55E 7
2 226E 4
2 I72E 7
3 568E 7
NA
NA
1 783E 9
2862E 8
1 640E 7
0
I.882E-8
0
1 430E 7
2 754E 4
2 686E 7
4 4I5E 7
. t
Pdilial
CPF
(I'mg/kq/day)
1 75
0029
6 1*
NA
1 75
0029
6 1
NA
1 75
0029
6 1
NA
1 75
0029
6 1
MA
1 75
0029
6 1
NA
1 75
0029
6 1
NA
1 lli.'HIIIU (,.II| IMUiJr
A, lulls
Clillilirll 1. 1.'
Conliibulton 10
Liluiima Caic
Risk
NA
NA
3.909E-9
NA
1 03IE 7
0
4 I26E-8
NA
202IE 7
6063E 6
1 325E 6
NA
NA
NA
1 088E 8
NA
2 870E 7
0
1 148E 7
0
2 502E 7
7 9H6E 6
1 637E 6
NA
mi. llr.k
/ /.III! (•
1 OJMl b
nibk MM
CPF oil 1 5
loi B(a)P
7 36»E 9
7 779E 8
2 498E 6
2 05E 8
2 IG4E 7
J UUUE 6
U -J'jlt I,
» i •
i iur.l s
N,,li, NIIHI|II.-I% a,u p..-M.»lt.a ,„ ,...,„ „„,, „„,.,„„„ ouo, , ,„„ „,
•«..», ul.ihoi.:, j,u l,.,-,ul| on j t, | (.(•( |,lu ...,, ..i.,,,^,., ,,„ d ,.,.h u, ,,
-------
TABLK 6
PP4L BROOHEAD CREEK SITE
CALCULATION Of CAHCINOGEMC RISK
FOR VAPOR INHALATION
NO ACTION SCENARIO
Exposure EipOMd Rouw ol Aiea ol
Scenario Population Eiposur* Eipociue Chemical
No Action AdulU Vapor Inhalation Suilaca Walaf Aitemc
Benzene
Benzo(a)Pyren«i
Naphthalene
Vapot Inhalation Suiiaca Soils Aisemc
Benzene
Benzo(a)Pyiene
Naphthalene
ChiUken 6-12 Vapoi Inhalation Suitace Walei Ai&emc
Benzene
Benzo(a)Pyiene
Naphthalene
Vapot Inhalation Suilaca Soils Aitenic
Beniena
Benzo(a)Pyiane
Naphthalene
Lilenme Adj.*
Chronic
DaMy Intake
(mg/kg/day)
NA
S 185E 6
1 08E 9
1.7S7E-7
NA
2 376E 8
7 208E 10
4 4SE 6
NA
1 25IE 5
9 30E 9
4.237E-7
NA
S 73E 8
t 738E 9
1 074E 5
CPF
(I/ mg/kg/day)
500
0029
6 1
NA
SCO
0029
6 1
NA
500
0029
6 1
NA
500
0029
6 1
NA
Conuibulion 10
Lifetime Caic CPF ol 11 S
Risk of B(a)P
NA
1 504 E /
6 S88E 9 1 242E 8
NA
NA
6 B9E 10
4 397E 9 8 289E 9
NA
NA
3 628E 7
5673E 8 1 07E 7
NA
NA
1 662E 9
1 060E 8 1 999E 9
NA
NA Not applicable
CPF Caicmogen Potency Facioi
Nulu Numbuis am pioboniod in uiponunlidl nolalion 0001
I OOt 03
PailMl Liluliinu CdiLiimyunic HibK
AJulb . I b2lt 7 I 7lt)t /
ChllUM'll I) U> 4 31 Ml 7 4 'Jlbl; 7
-------
TABLE 7
HP4L BRODHEAD CHEEK SITE
CALCULATION OF CARCINOGENIC RISK
FOR FISH INGESTION
NO ACTION SCENARIO
Exposure ExpoMd Route ol . Area ol
Scenario Population Exposure Exposure Chemical
No Action Adult* Fish Ingaslion Brodhead Cruuk Arsenic
Benzene
Benio(a)Pyrene
Naphthalene
Children 612 Fish Ingeskon Brodhead Creek Arsenic
Benzene
Benzo(a)Pyrene
Naphthalene
Children 26 Fish Ingestion Brodhead Creek Arsenic
Btmzene
Benzo(a)Pyrene
Naphthalene
Lifetime Ad| *
Chronic
Daily Intake
(mg/kg/day)
3 062E 6
1 36E 6
0
2062E 5
8 9I9E 6
3962E 6
0
6008E 5
1 6I6E 5
7 IBB 6
0
1 089E 4
CPF
(1 /mg/kg/day)
1 75
0029
6 1
NA
1 75
0029
6 1
NA
1 75
0029
6 1
NA
Contribution to
Lifetime Care CPF ol 1 1 5
Risk : lor B(a)P
5 359E 6
3 944E 8
0
NA
1 56 IE 5
1 I49E 7
0
NA
2 828E 5
2 082E 7
0
NA
NA Not applicable
CPF • Carcinogen Potency Factor.
Note • Number* are presented in exponential notation 0.001
IOOE 3
Partial Lilulimu CdfCmoyomc Risk
Adults - 5 398E 6
CM ' -n 6 12 - I 572E 5
CfiiktfUii 26 - 2 84 9 E 5
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TABLE 8
PP&L BROOHEAO CREEK SITE
CALCULATION Of CARCNOGEMC RBK FOR MGESTIQN
NO-ACTION SCENARIO
,
EipouN* FnpoMd Roma ol ArM ol
Scwiailo Population Eipoaui* Eiposut* Chemical
No Action Adult* tngmtlon Surface Waui Aisanic
Baniana
Banzo(a)Pyrena
Ni«>hihalana
Ingatiion Siulaca Soil Acsanic
Banzana
Benzo(a)Pyi*n*
Naphlhaton*
Ingaslion Sadunanl Axantc
Banian*
Benzo
-------
TABLE 9
PP4L BRODHEAO CREEK SITE
CALCULATION OF CARCINOGENIC RISK
FOR OUST INHALATION
NO ACTION SCENARIO
Lileiime Adj •
Exposure
Scenaiio
^™* "*^*^"^™M»
Exposed
Population
Route ol
_ Exoosura
Area ol
§'P°s"'e Chen
Chronic
Daily (make
a**' (mo/fcq/dayi
CPF
(1 mq/kq/rtjyi
Contiibuiion to
Lileiime Care.
Risk
CPF ol || 5
_ tor 8(a)P
No Action
Adults
Out! Inhalation Suilaca Soils
Aisenlc
Bentene
Ben*o(a)Pyrene
Naphthalene
NA
NA
I 875E II
3009E 10
50
0029
6 I
NA
NA
NA
« I44E 10
NA
2 I56E 10
Children 6-12
Oust Inhalation Surlace Soils
Arsenic
Benzene
Bento(a)Pyrene
Naphthalene
NA
NA
4 522E II
7258E 10
SO
0029
6 I
NA
NA
NA
2 758E
NA
10
S 2E 10
P«rtl.l L.I.Mm. C.rclnog.n|c Rl.k
Adulis
Children 6 12 .
1 I44E 10
2 7S8E 10
2 1566 to
52E 10
Tol*l LlUtlrn* Carcinogenic Risk
NA • Nol applicable.
CPF Caicinogun Potency Facloi
Nuu.- Numbe,s a(a p,osenlod ,„
I OOE J
Adulis
Cluldiun 6 lij -
CliilJiuil 2 b
1 83E i
J U2E S
2 Ub4b b
1 90t S
4 02E S
-------
represent fish-flesh contamination. The resulting worst-case
carcinogenic risk resulting from fish ingestion is shown in Table
10. It .can be seen that the carcinogenic risk is 3.3E-6 for
children ages 6-12, 6.0E-6 for children ages 2 to 6, and 1.4E-6 for
adults. This results in a lifetime weighted risk equal to 1.8E-
6. By adding this risk to the total site-related risk increment,
it can be seen that under worst-case conditions, the total lifetime
carcinogenic risk falls within the l.OE-4 to l.OE-6 EPA recommended
risk range.
P. Non-carcinogenic Risk
The noncarcinogenic hazard index is the ratio of the expected
potential dose to acceptable exposure levels. Values of less than
unity (1.0) indicates that no hazard exists. The noncarcinogenic
hazard indices are listed in Tables 11 to 15 and were obtained by
dividing the chronic daily intakes by the appropriate reference
doses. As can be seen from Table 15, all noncarcinogenic chronic
hazard indices are several orders of magnitude less than unity,
therefore, no noncarcinogenic chronic risk is posed by the Site.
G. Environmental Risk Assessment
Potentially exposed nonhuman populations include the aquatic
life in Brodhead Creek. The potentially exposed populations at the
Site are the macroinvertebrates, fish, and benthic organisms such
as the sea lamprey larvae collected during the RI. The exposures
to these populations can occur from direct contact with
contaminants in water and sediment or by bioaccumulation in the
food chain. Both fish and sea lamprey tissue were analyzed during
the Brodhead Creek RI. No PAHs were detected in the fish samples
analyzed. However, the sea lamprey analysis indicated that the
lampreys have bioaccumulated PAHs.
1. Aquatic Effects
During the past studies, several habitat factors were measured
such as surface water temperature, dissolved oxygen, flow rates,
organic content in surface waters/sediments, and physical
characteristics of the substrate. The chemical water quality
conducted at the site revealed the following:
o Dissolved oxygen readings were relatively high, which
means that they are adequate for aquatic life sensitive
to low dissolved oxygen levels.
o The pH measurements of the surface waters were within a
range (6-8) where aquatic life would not be adversely
impacted.
A comparison of indicator and other chemical concentrations
in the waters of Brodhead Creek to available surface water quality
21
-------
TABLE 10
Relative Potency
(ICF-ciement, 1988)
Sea Lampreys
Tissue Concentration
Dose
Dose to
Children
Age 2-6
Risk to
Children
fr,|p
(Body weigntXUfetime)
.75E-07
kg-day
Dose to
Children
Age 6-12
Risk to
Children
-------
TABLE 11
PP«L BROOHEAD CREEK SITE
CALCULATION OF CHRONIC INTAKES KIR DERMAL EXPOSURE
NONCARCMOGEMC HAZARD MOCES
NO ACTION SCENARIO
Eiposuie Exposed Route ot Aiea ol
Scenaiio Population Etposuie Eiposuie Chemical
No Action Adults Dental Contact Suilace Soils Aisenic
Soils Benzene
Benzo(a)Pyiene
Naphthalene
Dermal Contact Sedimems Aisenic
SedM»snts Benzene
Bento(a)Pyiene
Naphthalene
Dermal Contact Suilace Walei Aisenic
Surface Water Benzene
Benzo(a)Pyiene
Naphthalene
ChiMien 6-12 Detmal Contact Suilace Soils Aisenic
Soils Benzene
Benzo(a)Pyiene
Naphthalene
Dermal Contact Sediments Aisenic
Sediments Benzene
Benzo|a)Pyiene
Naphthalene
Donnal Contact Suilace Watei Aisenic
Suilace Water Benzene
BenzofalPyiene
Naphthalene
NA Nul .ifiplH-jlilB
Lilelime Adj
Chionic
Daily Intake
(mg/kg/day)
NA
NA
6408E 10
I 028E 8
S894E 8
0
6764E 9
0
1 155E 7
2226E 4
2 I72E 7
3S68E 7
NA
NA
1 783E-9
2862E 8
1 640E 7
0
1.882E-8
0
1 430E 7
2 754E 4
2686E 7
44I5E 7
PttlM
•
Releience
Dose (RID)
(mg/kg/day)
1 40E-3
4 OOE 1
4 OOE t
4 OOE 1
1 40E-3
4 OOE 1
4 OOE t
4 OOE 1
1 40E-3
4 OOE 1
4 OOE 1
4 OOE 1
1 40E 3
4 OOE 1
4 OOE 1
4 OOE t
1 40E 3
4 OOE 1
4 OOE 1
4 OOE 1
1 40E 3
4 OOE 1
4. OOE t
4 OOE 1
lilulimu Cliiumc llj/
AiiuHb
Cliikliun t. U'
Conliibulion lo
Lilelime Chionic
Hataid
lnde>
NA
NA
NA
2 570E 8
4 2IOE 5
0
1 681 E 8
0
8 25E 5
S 56SE 4
543E 7
892E 7
NA
NA
4 458E
-------
TABLE 12
PP4L BBODHEAD CREEK SITE
CALCULATION OF CHRONIC INTAKES
FOR VAPOR INHALATION
NONCARCINOGEMC HAZARD INDICES
NO AC TON SCENARIO
Exposure Exposed Route ol Area ol
•Scenario Population Exposure Exposure Chemical
No Action Adull* Vapor Inhalation Surface Waioi Arsenic
Benzene
Benzo(a)Pyrene
Naphthalene
Vapor Inhalation Surlace Soils Arsenic
Benzene
Benzo(a)Pyrene
Naphthalene
Children 6 12 Vapor Inhalation Surlace Water Arsenic
Benzene
Benzo(a)Pyrene
Naphthalene
Vapor Inhalation Surlace Soils Arsenic
Benzene
Benzo(a)Pyrene
Naphthalene
Lilenme Adj '
Chronic
Daily Intake
(mg/kg/day)
NA
S IB5E 6
1 08E 09
1 757E 7
NA
2 376E 8
7 208E 10
4 4SE 6
NA
1 25IE 6
9 30E 9
4 237E 7
NA
5 73E 8
1 73BE 9
1 074E 5
Relerunce
Dose (RU)
(mg/kg/day)
1 40E 3
4 OOE 1
400E 1
4 OOE 1
1 40E 3
4 OOE I
4 OOE I
4 OOE 1
1 40E 3
4 OOE 1
4 OOE 1
4 OOE 1
1 40E 3
4 OOE 1
4 OOE 1
4 OOE I
Contribution to
Lilelime Cluunic
HdidiJ
lndu«
NA
1 L»J6l i,
2 7001
-------
TABLE 13
PP4L • BROOHEAD CREEK SITE
CALCULATION OF CHRONIC MTAKES
FOR FISH INGE STION
NONCARCMOGENC HAZARD INDCES
NO-ACTON SCENARIO
Exposure Exposed Route ol Area ol
Scenario Population Exposure Exposure Chemical
No Action Adults Fish Ingestion Brodhead Creek Arsenic
Benzene
Benzo(a)Pyrene
Naphthalene
Children 6-12 Fish Ingestion Brodhead Creek Arsenic
Benzene
Benzo(a)Pyrene
Naphthalene
Children 2-6 Fish Ingeslion Brodhead Creek Arsenic
Benzene
Benzo(a)Pyrene
Naphthalene
Lilelimu Adj.*
Chronic
Daily Intake
(mg/Hg/day)
3.062E-6
I.36E-6
0
2062E 5
B.9I9E-6
3962E-6
0
6 008E 5
1 6I6E 5
7 I8E 6
0
I.089E 4
Ruturencu
Dose (RIO)
(mg'kg/day)
1 40E 3
4.00E 1
4.00E 1
4.00E-I
1 40E 3
4.00E 1
4.00E 1
4 OOE-I
1 40E 3
4.00E 1
4.00E-I
4 OOE 1
Contribution to
Lilulime Chronic
Hazard
lnde»
2.I87E-3
3.400E 6
0
5.I55E 5
6.37IE 3
990SE 6
0
1 S02E 4
1 Ib4fc 2
I.795C S
0
2 /23t 4
NA - Not applicable.
Note • Numbers are presented in exponential notation O.OOt = 1 OOE 3
Partial Lifetime Chronic Hazard Index
Adults =- 22E-3
Childiun 6 12 - 6.SE 3
CtiiWiun 26 . l 2E 2
-------
TABLE 14
PP&L BROOHEAD CREEK SITE
CALCULATION OF CHRONIC INTAKES
FORMGESTON
NONCARCMOOENC HAZARD INDICES
NO ACTION SCENARIO
Eiposur* Eiposod RouM ol Area ol
Scenario Population Ewosura Exposure Chemical
No Action Adullt IngMlion Suilace Walui Arsenic
Beniun*
Benio(a)Pyiena
Naphlhatone
IngMlion Surlaca Soil Arsenic
Banian*
Banio)a)Pyren«
Naphlhatorw
Ingetlion S«dim«ni Ar»«nic
Banian*
Banio(a)Pyrene
Naphlhatona
Children 6-12 Ingaslion Surlaca Waiei Arsenic
Baniena
Benio|a)Pyrene
Naphlhalena
Inga^uon Surface Soil Atsenic
Benzene
Benzo(a)Pyrane
Naphlhatona
Ingaslion Sadimenl Arsenic
Benzene
Benzo|a)Pyrena
Naphlhalenu
Lilelima Adj '
Chror.ic
Daily Iniaka
(mg/kg/day)
22I1E 6
8 309E 6
0
6 825E 6
NA
NA
3 846E 9
6 I73E 8
3 537E 7
0
4 060E 8
0
S 332E 6
2004E 5
0
1 646E i
NA
NA
9 276E 9
1 489E 7
6 S32E 7
0
9 792E 8
0
Ruler ence
Dose (RID)
(mg/kg/day)
1 40E 3
4 OOE I
4 OOE • 1
4 OOE • 1
1 40E 3
4 OOE 1
4 OOE 1
4 OOE 1
1 40E 3
4 OOE 1
4 OOE 1
400E 1
1 40E-3
4 OOE 1
4 OOE 1
4. OOE 1
1 40E 3
400E 1
4 OOE 1
400E 1
1 40E 3
4 OOE 1
4 OOE 1
4 OOE 1
Coniiiriiiiinri lo
Liluliiic liioiuc
li iid
I...IUI
1 i7!)E 3
2 077E 5
0
1 706E 5
NA
NA
96I5E 9
1 S43E 7
2 S26E 4
0
1 OI5E 7
0
3 B09E 3
S OIOE 5
0
4 USE &
NA
NA
2 3I9£ a
3 723E 7
6 OU4E 4
0
2 448E 7
0
NA Not df>|ilic
-------
TABLE 15
PP4L BROOHEAD CREEK SITE
CALCULATION OF CHRONIC INTAKES
FOR OUST INHALATION
NONCAnCINOGEMC HAZARD MCNCES
NO ACTION SCENARIO
Exposure
Scenario
No Action
EipaMd Route ol ' Arua of
Population Exposure Enposuta Chemical
AdulU Dust Inhale Uon Surface Soils Arsenic
Benzene
Benzo(a)Pyiene
Naphthalune
Lilelime Adj *
Chronic
Daily IniaKe
(mg/kg/day)
NA
NA
1 875E 11
3009E 10
Reference
Dose (RID)
(mg/kg/day)
1 40E 3
4 OOE 1
4 OOE-I
4 OOE 1
Contribution to
Lilelimu Cluonic
Hazard
Indu i
NA
NA
4 6B8E II
7 520E 10
Children 6 12
Oust Inhalation Surface Soils Arsenic
Beniene
Benzo(a)Pyrune
Naphthalene
NA
NA
4 S22E II
7 2586 10
1 40E 3
4 OOE 1
4 OOE 1
4 OOE 1
NA
NA
1 I3IE 10
1 ai4E 9
Partial Lllallm* Chronic Haiard Index
Toll! Lltollnt* Chronic H«i«rd Index
Adutts • 4 HE 3
Children 612- 1 2E 2
Children 26 • I 2E 2
NA - Not applicable.
Note • Numbers are presented in eiponenlial notation OOOl - I OOE 3
-------
criteria indicates that the Site does not cause any exceedance of
acute or chronic ambient water quality criteria (AWQC) . The few-
chemicals- exceeding their respective AWQC occur in both upstream
and background locations; thus, the Site alone apparently does not
cause the AWQC exceedances. The PAH concentrations were also
compared with the acute LC50 values. None of these acute values
was exceeded.
Review of the numerous historical surveys and studies, as well
as recent observations during the RI, indicates that the fish and
macroinvertebrate populations are not adversely impacted by the
Site. The earliest studies on record were conducted in 1969, when
the stream habitats had been destroyed by the floods and the
rechannelization of Brodhead Creek. Since that time the conditions
in the stream . improved, as was found in the 1984 fish and
macroinvertebrate studies. Sensitive macroinvertebrate species
(stoneflies, mayflies) were found at all stations sampled. The
same observations were made during the RI activities; the presence
of stoneflies and mayflies is indicative of good water quality.
The species diversity index, a measure of species diversity,
calculated for several station samples in the past, indicated no
habitat differences between upstream, at the Site level, and
downstream locations. Conditions observed during the RI field
activities indicate the presence of healthy fish and
macroinvertebrate populations.
There are no threatened or endangered species at the Site, nc
are there any critical or unique habitats. Also, none of the fish,
amphibians, or reptiles listed as endangered or threatened are
known to occur at or in the vicinity of this Site.
The fish collection and tissue analysis during the RI
indicated the following:
o The fish collected or observed in the survey were robust
and displayed good coloration. There were no signs of
overt disease such as reddened areas, nodular growths,
skin lesions, and fungus.
o There were no observations of fish displaying behaviors
indicative of environmental stress or ill health.
o No PAHs or other coal tar related constituents were
detected in the fish samples analyzed.
Conversely, the sea lamprey analysis data indicate that
the lampreys have bioaccumulated PAHs. The ratios of the compounds
detected are similar to those ratios in the Brodhead Creek Site
coal tar; therefore, the PAH bioaccumulation appears to be site-
22
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related. The lampreys can be regarded as a worst-case scenario for
aquatic life exposure, due to their constant exposure to sediments
and interstitial water, high lipid content, long larval exposure
period (several years), and feeding habitats.
Adult sea lampreys migrate upstream and die soon after
spawning in the spring. The larvae drift to pool areas and burrow
into the substrate. The larvae feed by filtering minute plant and
animal materials, such as filamentous algae, detritus, diatoms,
desmids, and protozoans out of the water. They are sedentary and
only protrude slightly from their burrows while feeding. The
larval stage persists for about 4 to 7 years. The adults then
begin a predatory lifestyle and migrate downstream to the ocean.
The sea lamprey larvae captured in the Brodhead Creek during the
RI were young adults who had not yet begun their migration
downstream. They were therefore most likely exposed to Site
conditions for 4 to 7 years.
Comparison of the lamprey and trout data show little if any
similarity in the nature of the compounds detected. This is due
in part to the lesser amounts of time the mobile trout would be
exposed to Site-related compounds. Trout are also less exposed to
sediments, feed on a wide variety of organisms, and have lower
lipid content. In addition, PAHs are rapidly and extensively
metabolized and will be eliminated from the fish unless the
exposure is continuous.
No other species of fish inhabitating Brodhead Creek is
expected to have the long-term and continuous exposure to site-
related compounds as the sea lamprey. The implications of the PAH
accumulations to the sea lamprey larvae are unknown. However,
site-specific bioconcentration factors calculated for sea lamprey
at the Site are indicative of rapid metabolism of PAHs by the
lamprey and/or minimal amounts of PAHs discharging to the creek.
In addition, comparison of aquatic life criteria with actual
concentrations of chemicals in Brodhead Creek indicate that the
criteria for protection of aquatic life are not exceeded at the
Site. The comparison of concentrations of indicator chemicals
detected in Brodhead Creek sediments with calculated sediment
criteria revealed that the sediment criteria are not exceeded at
the Site.
3. Terrestrial Effects
During the wetland delineation activities of the RI, all areas
were surveyed for the presence of stressed vegetation. No areas
of stressed vegetation were observed. All the wetland areas
displayed healthy and diverse vegetative wetland species.
The terrestrial vegetation also appeared healthy and
unimpacted from the Site. No stressed terrestrial vegetation was
observed during the Site activities.
23
-------
Historical surface soil sampling did not indicate the presence
of elevated concentrations of PAHs. No carcinogenic PAHs were
detected. The observed concentrations of indicator compounds
should not have any adverse effect on the terrestrial fauna that
may come into contact with Site-related contamination. The PAH and
metal 'concentrations reported for sediments should not pose any
risk to the terrestrial community, since they are within the
naturally occurring concentration range.
Conclusion of Summary of Site Risfcs
Actual or threatened releases of hazardous substances from the
Site, if not addressed by implementing the response action selected
in the ROD, may present an imminent and substantial endangerment
to public health, welfare, or the environment.
VII. DESCRIPTION OF ALTERNATIVES
The Superfund statute and regulations (NCP) require that the
alternative chosen to clean up a hazardous waste site meet several
criteria. The alternative must protect human health and ttte
environment, be cost effective, and meet the requirements of
environmental regulations. Permanent solutions to contaminatio.n
problems should be developed wherever possible. The solutions
should reduce the volume, toxicity, or mobility of the
contaminants. Emphasis is also placed on treating the wastes a
the site, whenever this is possible, and on applying innovativt
technologies to clean up the contaminants.
The FS studied a variety of technologies to see if they were
applicable for addressing the contamination at the Site. The
technologies determined to be most applicable to these materials
were developed into remedial alternatives. These alternatives are
presented and discussed below. All costs and implementation
timeframes provided for the alternatives below are estimates.
COMMON ELEMENTS: All of the alternatives being considered
would include common components. Each alternative except the "no
action" alternative would include the following: (1) imposition
of deed, zoning, and/or ownership restrictions on the Site, to
limit future Site use; (2) a ground water monitoring program to
measure concentrations of coal tar related constituents and to
ensure that the integrity of the existing slurry wall is
maintained; (3) Brodhead Creek biota monitoring to ensure that the
Site continues to have no significant impact on the aquatic
ecological system in Brodhead Creek; and (4) construction and
maintenance of a fence with posted warning signs to restrict public
access to the Site. EPA would review the Site every five years to
ensure continued protection to human health and the environment for
each of the alternatives, including the no-action alternative.
24
-------
Alternatives 3, 4, and 6 include excavation of contaminated
subsurface soils. For each of these alternatives, sheet piling
will be required in the excavation to provide for slope
stabilization., during the excavation component of these
alternatives.
Alternative 1: No Action
Capital Cost: $o
Operation & Maintenance: $o
Present Worth: $0
Months to Implement: 0
The NCP, EPA's regulations governing the Superfund Program,
requires that the "no-action" alternative be evaluated at every
site to establish a baseline for comparison with the other
alternatives. In this alternative, no further remedial actions
would be taken on the subsurface soils at the Site. The Site would
be left in its current condition. EPA would review the Site every
five years to assure continued protection to human health and the
environment.
Alternative 2: Limited Action
Capital Cost: $153,000
Operation & Maintenance: $1,023,000
Present Worth: $1,176,000
Months to Implement: 6
This alternative would entail intermittent pumping of free
coal tar which accumulates in the stratigraphic depression west of
the slurry wall (RCC area). It is estimated that approximately
4500 gallons of the free coal tar contained in the stratigraphic
depression in the RCC area might be removed under this alternative.
It is expected that the free coal tar would be removed once per
year. The frequency of coal tar recovery might be increased or
decreased based on observed recovery effectiveness. The recovered
coal tar would be shipped to an offsite permitted incineration
facility for disposal.
The implementation of this alternative will comply with the
requirements under RCRA and the Pennsylvania Solid Waste Management
Act.
Alternative 3: OnSite Stabilization/Solidification (RCC Area)
Capital Cost: $1,455,000
Operation & Maintenance: $1,023,000
Present Worth: $2,478,000
Months to Implement: 9-12
25
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This alternative includes excavation of approximately 1,000
cubic yards of contaminated subsurface soils with coal tar in the
RCC area, stabilization/solidification of the excavated soils, and
replacement of the treated material. The stabilization/
solidification process involves the onsite mixing of cementious or
pozzolanic reagents with the contaminated soils thereby fixating
the contaminants in an inert matrix and reducing their mobility.
Approximately 1,300 cubic yards of clean soil would have to be
removed and stored to reach the contaminated soil. This clean soil
will then be used to backfill the excavation over the stabilized
soil. Grading, revegetation, and surface water run-on/run-off
controls will be provided in the area of the excavation. A
treatability study would be conducted to determine the most
appropriate stabilizing reagents for the contaminated soils and to
determine the leachability of coal tar related constituents from
the stabilized/solidified soils.
Dewatering during the excavation process would be necessary.
It is expected that free draining coal tar would also be recovered
during the dewatering process. The recovered coal tar and water
would be stored in a tank onsite. After completion of the
excavation and replacement operation, the coal tar would be shipped
to an offsite permitted incineration facility and the water to a
treatment, storage, disposal (TSD) facility for treatment/disposal.
The implementation of this alternative will comply with th*
requirements under RCRA and the Pennsylvania Solid Waste Managemer
Act.
Alternative 4: Excavation of Contaminated Subsurface Soils
and Soil Washing (RCC Area)
Capital Cost: $2,931,000
Operation and Maintenance: $1,023,000
Present Worth: $3,954,000
Months to Implement: 12
The specific components of this alternative are similar to
those for Alternative 3 differing only in the process used for
treating the excavated materials. The subsurface soils with coal
tar would be subjected to onsite soil washing. Soil washing is a
physical/chemical process in which the excavated soils are mixed
and agitated using surfactant/water solutions in an above ground
treatment system. During this process contaminants in the soil are
transferred to an aqueous solution which is then separated from the
soil and treated. A treatability study would be conducted to
select an appropriate soil washing procedure and surfactant/water
solution. The treated soils would be backfilled in the area of the
excavation and covered with clean soils.
26
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An estimated 9,000 gallons of free coal tar and approximately
17,845 to 23,529 gallons of coal tar at residual saturation levels
would be expected to be removed resulting in a 6% to 10 % decrease
in total coal tar volume at the Site.
The implementation of this alternative will comply with the
requirements under RCRA and the Pennsylvania Solid Waste Management
Act.
Alternative 5: Enhanced Recovery for the Free Coal Tar
Capital Cost: $3,008,000
Operation & Maintenance: $1,112,000
Present Worth: $4,120,000
Months to Implement: 6
Enhanced recovery is an in-situ application of contaminant
extraction from soils. It would consist of the physical
displacement of coal tar from the pore spaces within the soil
through thermal mobilization coupled with hydraulic containment to
exploit the apparent reduction in coal tar density to less than
that of water thereby mobilizing the coal tar for recovery by
pumping and extraction. The enhanced recovery process would entail
the installation of extraction and injection wells in the free coal
tar areas. Hot water will be injected into the subsurface soils
to displace the coal tar from within the pore spaces of the soil.
Recovered coal tar and process water from the extraction wells will
be subjected to oil-water separation to remove the coal tar. The
recovered process water will be treated to meet National Pollution
Discharge Elimination Requirements (NPDES) with subsequent
discharge of a portion of the process water to Brodhead creek with
the remainder being reinjected into the subsurface soils to enhance
coal tar recovery. The recovered coal tar will be shipped to an
offsite permitted incineration facility for disposal.
The enhanced recovery process would involve the treatment of
approximately 200 cubic yards of subsurface soils containing free
coal tar in the RCC area and take approximately three months to
complete. Some treatment of the overlying soils containing
residual coal tar would also occur. It is estimated that the
enhanced recovery process could recover an estimated volume of
7,200 gallons of free coal tar and as much as 10,800 gallons of
residual coal tar resulting in a 3% to 6% decrease in total coal
tar volume at the Site.
The implementation of this alternative will also comply with
the requirements under RCRA and the Pennsylvania Solid Waste
Management Act.
27
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Alternative 6: Excavation of Contaminated Subsurface Soils
(RCC Area) and Offsite Incineration
Capital Cost: $5,204,000
Operation & Maintenance: $1,023,000
Present Worth: $6,227,000
Months to Implement: 6-8
This alternative is similar to Alternatives 3 and 4, differing
only in the process used for treating the excavated contaminated
soils. The contaminated subsurface soils (approximately 1,000
cubic yards) would be shipped to an offsite permitted incineration
facility for disposal. Incineration involves the thermal
destruction of organic compounds. Additional clean fill material
would have to be imported to replace the volume of subsurface soils
removed from the Site for incineration.
The excavated subsurface soils would be stored in a staging
area onsite for dewatering and drying prior to being shipped
offsite for incineration. The water from the staging area would
be collected and also shipped offsite to a permitted TSD facility.
The implementation of this alternative will comply with ttte
requirements under RCRA and the Pennsylvania Solid Waste Management
Act.
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed analysis was performed on the six alternatives using
the nine evaluation criteria specified in the NCP in order to
select an interim remedy for OU-1. The following is a summary of
the comparison of each alternative's strength and weaknesses with
respect to the nine evaluation criteria. These nine evaluation
criteria are listed in Exhibit A.
OVERALL PROTECTION
All the alternatives, excluding the no action alternative
(Alternative 1) , would provide varying degrees of protection to
human health and the environment by eliminating, reducing, or
controlling risk through treatment, engineering controls, or
institutional controls. Alternatives 4 and 6 may be slightly more
protective than Alternative 5 since a significant portion of both
the residual and free coal tar would be excavated in the RCC area
and treated during the implementation of these alternatives likely
resulting in a slightly greater reduction of the overall coal tar
volume at the Site. Alternative 3 would also entail the excavation
of contaminated soils in the RCC area. However, the excavated soil
would be treated by onsite stabilization/solidification and
replaced in the area of the excavation. Under Alternative 3, there
would be no net reduction in volume of the coal tar, but its
mobility in the environment would be greatly reduced.
28
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EXHIBIT A
ALTERNATIVE EVALUATION
Overall Protection of Human Health and the Environment - Addresses whether the remedy
provides adequate protection and describes how risks posed through each pathway are
eliminated, reduced or controlled through treatment, engineering controls or institutional
controls.
Compliance with ARARs - Refers to whether or not a remedy will meet all Applicable or
Relevant and Appropriate Requirements (ARARs) of federal and state environmental
statues and/or provides grounds for invoking a waiver.
Long-Term Effectiveness and Permanence - The ability of the remedy to maintain reliable
protection of human health and the environment over time once the "clean-up" goals have
been met.
Reduction of Toxicity, Mobility or Volume Through Treatment - Relates to the anticipated
performance of the treatment technologies with respect to these criteria.
Short-Term Effectiveness - Refers to the period of time needed to achieve protection, and
any adverse impacts on human health and the environment that may be posed during, the
construction and implementation, until "clean-up" goals are achieved.
Implementability - The technical and administrative feasibility of a remedy, including'the
availability of materials and services needed to implement a particular option.
Cost • The following costs are evaluated: estimated capital, operation and maintenance, and
net present worth.
State Acceptance • This indicates whether, based on its review of the Feasibility Study and
the Proposed Plan, the State concurs with, opposes, or has no comment regarding the
preferred alternative.
Community Acceptance - Will be assessed in the Record of Decision following a review of
the public comments received on the Administrative Record and the Proposed Plan.
-------
Alternative 2 would be less protective than the Alternative
5 since Alternative 2 does not have the potential for recovering
as much coal tar from the subsurface soils as Alternative 5 which
uses thermal - mobilization to achieve greater recovery than
conventional pumping techniques.
The "no action" alternative is not protective of human health
and the environment since it would not address the source of the
contamination, and future releases and potential exposures might
occur. Therefore, it is not considered further in this analysis
for OU-1.
COMPLIANCE WITH ARARS
CERCLA requires that remedial actions meet applicable or
relevant and appropriate requirements (ARARs) of other federal and
state environmental laws. These laws may include: the Toxic
Substances Control Act, the Clean Water Act, the Safe Drinking
Water Act, and the Resource Conservation and Recovery Act.
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.
All the alternatives, except for the no-action alternativt
(Alternative 1), will meet their respective applicable or relevant
and appropriate requirements (ARARs) as referenced in the FS.
These include compliance with the Clean Air Act and PADER Air
Quality Standards for emissions from the Site. Offsite transport
of coal tar would be conducted in accordance with the Department
of Transportation rules for Hazardous Materials Transport and the
Pennsylvania Hazardous Substances Transportation regulations.
Onsite management of waste material at the Site would be conducted
in accordance with the Resource Conservation and Recovery Act
(RCRA), the Pennsylvania Solid Waste Management Act, and
Pennsylvania Title 25 Chapter 260 to 270 (Hazardous Waste). All
discharges of treated process water to Brodhead Creek from
Alternative 5 and Alternative 4 should meet National Pollution
Discharge Elimination System (.NPDES) requirements developed
pursuant to the Clean Water Act and PADER Bureau of Water Quality
Management Standards. Alternatives 3 and 4 would also have to meet
RCRA regulations for the replacement of treated soils onsite.
Since OU-1 does not address ground water, compliance with
Maximum Contaminant Levels under the Safe Drinking Water Act and
the Pennsylvania ARAR for remediation of ground water which
contains hazardous substances to "background" quality are beyond
the scope of this interim action and may not be met by any of the
29
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alternatives. However, because free coal tar will be removed from
the Site, some reduction in ground water contamination is expected
with all the alternatives. These ARARs for ground water will be
addressed" in a subsequent ROD after further investigations are
conducted at the Site during OU-2 to assess the quality of all
ground water in the subsurface units from the stream gravel to and
including bedrock.
LONG-TERM EFFECTIVENESS AND PERMANENCE
This criteria is not considered applicable in this case due
to the interim short-term nature of the remedy, and therefore, will
be addressed when the final remedy for the Site is selected.
However, by eliminating the source of the contamination to the
ground water, the principal threat posed by the Site will be
addressed and some degree of long-term effectiveness and permanence
will be offered.
REDUCTION OF TOXICITY ^MOBILITY. OR VOLUME THROUGH TREATMENT
Alternatives 4, 5, and 6 provide for the reduction of
toxicity, mobility, and volume by removing the source of the
contamination and treating it. Alternative 5 would utilize
enhanced recovery techniques to remove the free coal tar from tne
subsurface soils followed by incineration of the recovered coal
tar. Alternative 4 would employ soil washing to remove the coal
tar from the excavated soils followed by incineration of the coal
tar and backfilling of the treated soils in the excavation area.
Alternative 6 would entail the direct incineration of the excavated
soils and backfilling of the excavation area with clean imported
soils. Overall coal tar volume reduction for Alternatives 4 and
6 would be between 6% to 10%. Overall coal tar volume reduction
for Alternative 5 would be between 3% and 6%.
Alternative 3, which would employ onsite
stabilization/solidification, would not reduce the toxicity or the
volume of the coal tar. However, the mobility of the contaminants
in the subsurface would be significantly reduced thereby reducing
the Site's impact to ground water in the stream gravel unit.
SHORT-TERM EFFECTIVENESS
Potential risks to onsite workers and the community might
occur during excavation, transportation, and treatment activities
for alternatives 3, 4, and 6. Exposure to coal tar and volatile
releases could be minimized by the use of proper operating
procedures and personal protective gear for onsite workers. Some
emission of volatile organic compounds (VOCs) during the
excavation, treatment, replacement and disposal activities is
likely to occur. Precautions would be taken to ensure that these
emissions would not impact the community.
30
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For Alternative 5, potential risk to onsite workers and/or the
community might occur during water treatment and free coal tar
management. An advantage that Alternative 5 has over the other
alternatives is that it would be conducted in-situ. There would
be no large areas of excavation and stockpiled soils thereby
minimizing the amount of VOC emissions from the Site and the
potential of direct contact with any contaminated soils. During
implementation of Alternative 5, the enhanced recovery process
could promote mobility of coal tar related constituents into the
ground water. Complete hydraulic controls would have to be
maintained to minimize any impacts.
IMPLEMENTABILITY
Each of the alternatives under consideration would be
implementable at the Site. However, the availability of
professional services to implement Alternatives 4 and 5 may be
limited since both these alternatives employ emerging technologies.
Regulatory approval would be required for the replacement of
treated soils back into the subsurface for Alternatives 3 and 4.
The alternatives which employ excavation as a component must
overcome several significant site-specific constraints associated
with the excavation including several subsurface utilities, the
flood control levee, slope stability during excavation, and
upwelling of the silty sand unit. The ground water and Brodhead
Creek monitoring programs could be easily implemented under any df
the alternatives.
The lowest cost alternative is Alternative 3 (onsite
stabilization/solidification) at $2,478,000. The highest cost
alternative would be Alternative 6 (offsite incineration) at a cost
of $6,227,000. The oth " ~~ alternative costs are presented in the
alternative descriptic ,-tions.
STATE ACCEPTANCE
The Commonwealth of Pennsylvania has concurred with the
Selected Interim Remedy.
COMMUNITY ACCEPTANCE
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 EPA's responses to the comments received.
IX. SELECTED REMEDY
Based upon the consideration of the requirements of CERCLA,
the detailed analysis of the alternatives, and public comments, the
31
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interim remedial remedy selected for implementation at the Brodhead
Creek Superfund Site for OU-1 is Alternative 5, Enhanced Recovery
via Thermal Mobilization.
Goals
The primary goals of this selected interim remedial
alternative are to eliminate or reduce risks associated with the
potential ingestion of ground water in the stream gravel unit and
to reduce the potential for contaminant release to the ground water
in the bedrock at the Site. Ground water in the bedrock in the
Site vicinity is currently used as a source of drinking water.
Additional goals are to meet the statutory preference for remedies
that utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable, and that utilize
treatment to reduce the mobility, toxicity, or volume of the source
of the contamination.
of the Interim Remed
As discussed under the Description of Alternatives section,
this Selected Interim Remedy employs enhanced recovery of free coal
tar via thermal mobilization. The enhanced recovery process will
be applied to the free coal tar (i.e., coal tar at 100% pore volume
saturation) areas onsite at the RCC area and the MW-2 area. The
enhanced recovery process shall involve the removal and treatment
of approximately 60-70% of the free coal tar in both the RCC and
MW-2 areas. Some additional recovery and treatment of the overlying
soils containing residual coal tar (i.e., coal tar at less than
100% pore volume saturation) would also occur. The recovered coal
tar shall be disposed of at an offsite permitted incineration
facility. Process water used for flushing of the coal tar would
be treated with part of it discharged to the creek and the
remainder reinjected into the subsurface soils for further flushing
of the contaminated soil. A conceptual model of the enhanced
recovery process is shown in Figure 10.
The Feasibility Study for the Brodhead Creek Site evaluated
the enhanced recovery process for the RCC area only. The estimated
present worth cost as set forth in the Feasibility Study for
applying the enhanced recovery process to the RCC area is
$4,120,000. Extending the application of the enhanced recovery
process to the area proximal to MW-2 may increase the estimated
cost by approximately $600,000. A summary of the capital costs for
the enhanced recovery process is presented in Table 16.
A treatability study will be conducted for the enhanced
recovery process to confirm its effectiveness and remedial design
parameters for its application in removing free coal tar from the
subsurface soils located in the RCC area and the area proximal to
MW-2. If the treatability study reveals that more than 60-70% of
32
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I'ICIIKK 10
Brodhead Creek Feasibility Study
Stroudsburg, PA
Injection Well
Steam-Stripped
Water
Low-Quality
Production Well
Residual Oil ' • |__
Saturation .* ". . .'
Hot-Water
Reinjeclion
Absorption Layer
Oil and Water
Production
Hot-Water
Flotation •
Steam
Inieclion
(If
.". II 1 III) 1)1
Oiimn k» / Oalt A Dcll.l C.IIIN'I.I /;")<)
lit »nr d k| / title
CI,.cle
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TAHI.K lf>
BROOHEAD CREEK
CAPITAL COST ESTIMATE
ALTERNATIVE 5 ENHANCED RECOVERY OF FREE COAL TAR
Quantity
Unli Cost
IniialUd Cosi
Sue PiapaiMioa MotNlualion/DwMMuMion
Fmung
0««d Hmuidions
foal fgr OiKIOftAl
1 fa
2.000 LI
1 E»
II. 000 SI
11.000 Car
(200.00000 /Ea
IIS 00 /LI
t&.OOOOO /Ea
$200 /SI
$260 /Gal
SukloUl
CoMina«K|r 9 100.00%
PfOk*M* Contttuclton C«M (PCC|
infllnMflng. Lagal. HuNk t Sctoly. Coiulfucllon Mgml..
•mi btwMOTc* 9 3s.oo%. oi pec
Cost
E*lliMtod Telcl
** The above capital costs represent implementation of the enhanced recovery
process at the KCC area only. Extending the application ol the enhanced
recovery process to the area proximal to MW-2 may increase the capital
cost by approximately $600,000.
» JO 000
I5.0UO
lato.ooo
$22.000
M6 BOO
1 1. 1 1 4.000
si. iM.ooo
f2.22S.OOO
srso.ooo
I3.00C.OOO
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the free coal tar can be effectively recovered, the treatment shall
continue until such additional recovery is achieved.
The Selected Interim Remedial Alternative will also include
construction of a chain link fence to restrict public access to the
Site during remedial activities, and the imposition of deed and
zoning restrictions to limit future Site use. A ground water
monitoring program will be initiated at the Site to ensure
continued protection to human health and the environment. Ground
water monitoring will be conducted during the implementation of the
Selected Interim Remedy, quarterly for the first 18 months after
completion of the enhanced recovery process, and annually
thereafter for up to 30 years.
A Brodhead Creek biota monitoring program will also be
implemented at the Site. Monitoring of the benthic community for
species diversity and abundance will be conducted prior to the
implementation of the enhanced recovery process and during the
spring and fall seasons for a two year period thereafter.
Likewise, resident fish will be sampled and analyzed during the
spring and fall seasons for a two year period. The resident fish
sampling will include histopathological examinations and an
assessment of the levels of PAH metabolites in fish bile. Brodhead
Creek sediment sampling will be conducted for TCL coal tar related
constituents concurrently with the resident fish sampling and the
benthic community monitoring. This data will then be evaluated to
determine if further benthic community monitoring, resident fis^>
sampling, or sediment sampling is required. In addition to the'
monitoring efforts, long-term monitoring of sea lamprey larvae f<_
PAH bioaccumulation will be conducted once every five years for up
to 30 years.
X. STATUTORY DETERMINATIONS
A. Protection of HUB|an Health and the Environment
As identified in the RI/FS, the ground water in the stream
gravel unit at the Site is highly contaminated. Peak
concentrations of arsenic, benzene, and other organics measured in
the surficial ground water exceed current and proposed Federal
drinking water standards. The coal tar wastes are currently
contaminating and/or would continue to contaminate this ground
water. The RI data suggests that.the free coal tar located in the
stratigraphic depression is the principal source of the ground
water contamination onsite. The stream gravel unit is not
currently used as a water supply onsite. However, exposure to
ground water in this stream gravel unit might occur. In addition,
the free coal tar located in the stratigraphic depression may serve
as a potential source of release of contamination to ground water
in the bedrock which is currently used as a drinking water source
offsite. Since contaminants detected in this stream gravel unit
33
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exceed current and proposed MCLs, there is a potential health risk
associated with ingestion of ground water at the Site.
Therefore, the risk reduction objectives are based on
reduction of those risks associated with the ingestion of ground
water in the stream gravel unit at the Site and the protection of
the bedrock ground water from possible Site contamination.
This selected interim remedy for OU-1 will remove free coal
tar from the subsurface soils onsite thereby minimizing the
potential for the further leaching of contaminants into the shallow
ground water and the potential for migration of contaminants to the
ground water in bedrock underlying the Site and thus is protective
of human health and the environment.
B. Compliance with Applicable or Relevant and Appropriate
Requirements
The selected interim remedy of enhanced recovery and treatment
of coal tar will comply with all applicable and relevant and
appropriate chemical-, location-, and action-specific ARARs
pertinent to this limited action. These ARARs are as follows:
1. Chemical-Specific ARARs
a. The National Emissions Standards for Hazardous Air
Pollutants (NESHAPS) set forth at 40 CFR Part
61.64(b) and promulgated under the Clean Air Act,
42 U.S.C. Section 7401, contain emission standards
for fugitive leaks from equipment containing greater
than or equal to 10% benzene which is relevant and
appropriate to the enhanced recovery process and
treatment of process water. The benzene emission
standard is no detectable emissions (approximately
500 ppm).
b. 25 Pa. Code Chapter 123 on "Standards for
Contaminants" sets forth requirements for fugitive
emissions, including open burning and demolition
activities; specific limitations for particulate
matter sulfur dioxide, odor, and visible emissions.
c. 25 Pa. Code Chapter 93 sets forth general and
specific standards for the quality of Pennsylvania's
waters, and includes specific water quality criteria
and designated water use protection for each stream
in Pennsylvania;
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2. Location-Specific ARARs
a. Resource Conservation and Recovery Act requirements
set forth at 40 CFR 264.18(b) contain relevant and
- appropriate requirements for RCRA hazardous waste
treatment, storage, or disposal facilities located
within a 100 year floodplain. Such facilities must
be designed, constructed, operated, and maintained
to avoid wash-out.
b. 40 CFR 6, Appendix A sets EPA policy for carrying
out the provisions of Executive Orders 11988
(Floodplain Management) and 11990 (Protection of
Wetlands). These requirements are applicable for
actions that will occur in a floodplain or actions
involving construction of facilities or management
of properties in wetlands.
c. Regulations promulgated under the Dam Safety and
Encroachments Act at 25 Pa. Code Chapter 105 sets
forth the provisions for the regulation and
supervision of dams, reservoirs, water obstructions,
encroachments, and wetlands in the Commonwealth of
Pennsylvania.
3. Action-Specific ARARa
a. To the extent that new point source emissions resu;
from the implementation of the interim remedia.
alternative, 25 Pa. Code Section 127.l2(a)(5) will
apply, requiring that emissions be reduced to the
minimum obtainable levels through the use of best
available technology (BAT), as defined in 25 Pa.
Code Section 121.1.
b. Treatment and discharge of contaminated process
water to Brodhead Creek will cause the requirements
of the Pennsylvania NPDES program to apply. Those
requirements, as set forth in 25 Pa. Code Chapter
92, include permitting, design, discharge, and
monitoring requirements which will be met in
implementing the selected interim alternative.
c. The process water extraction and treatment
operations as well as the coal tar management
activities would be implemented consistently with
the requirements of 25 Pa. Code Part 262 (relating
to generators of hazardous waste) ; 25 Pa. Code Part
263 (relating to transporters of hazardous wastes);
and with the substantive requirements of 25 Pa. Code
Part 264 Subparts A-E, I (in the event hazardous
waste is stored or managed in containers) , and J (in
35
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the event hazardous waste generated as part of the
interim remedy is treated or stored in tanks).
d. Pennsylvania Wastewater Treatment Regulations, Pa.
Code, Title 25, Chapter 95, which regulate water
quality and include treatment requirements and
effluent limitations based on the best practical
control technologies are applicable to the treatment
of wastewater generated by the selected interim
remedy.
e. 29 CFR 1910.120 sets forth applicable requirements
regarding worker safety in the handling of hazardous
substances,
f. Department of Transportation (DOT) regulations at
49 CFR 171.1-171.16 sets forth applicable
requirements regarding offsite transportation of
hazardous wastes.
g. Pennsylvania Erosion Control Regulations, Pa. Code,
Title 25, Chapter 102, which govern erosion and
sedimentation control resulting from remedial
actions that may involve earth moving activities
may be applicable to the selected interim remedy.
h. Underground Injection Control Program regulations
promulgated at 40 CFR 144-148 would regulate the
underground injection of the selected interim
remedy's treated process water into the subsurface
soils.
EPA does not consider the Land Disposal Regulations at 40 CFR
Part 268 to be relevant and appropriate for the treated process
water that will be injected into the subsurface soils as part of
the selected interim remedy. The basis for this decision is
contained in OSWER Directive # 9334.1-06 "Applicability of Land
Disposal Restrictions to RCRA and CERCLA Ground Water Treatment"
dated December 27, 1989.
C. Coat-Effectiveness
The selected interim remedy is cost-effective because it has
been determined to provide overall effectiveness proportional to
its costs, the net present worth value being $4,720,000, which
includes the additional capital cost of extending the enhanced
recovery process to the area proximal to MW-2.
D. Preference for Treatment as a Principal Element
The Selected Interim Remedy utilizes treatment and thus is in
furtherance of the statutory preference for treatment. However,
36
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because this interim action does not constitute the final remedy
for this operable unit, the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a
principal element, although partially addressed in this remedy,
will be addressed by the final response action.
g. Utilization of Permanent Solutions and Alternative
Treatment Technologies to the Maximum Extent Practicable
This action is interim and is not intended to utilize
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable for this
operable unit. However, the Selected Interim Remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized while providing the best balance of
tradeoffs among alternatives with respect to pertinent criteria,
given the limited scope of the action.
XI. DOCUMENTATION OF SIGNIFICANT CHANGES FROM THE PROPOSED PLAN
The Proposed Plan for the Brodhead Creek Site was released for
comment in February, 1991. The Proposed Plan described the
alternatives studied in detail in the Feasibility Study, and EPA
reviewed all written and verbal comments submitted during the
comment period and at the public meeting. Upon review of these
comments, it was determined that no significant changes to the
remedy, as presented in the Proposed Plan, were necessary.
37
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APPENDIX &
RESPONSIVENESS SUMMARY
BRODHEAD CREEK SOPERFUND SITE
OPERABLE UNIT ONE
This Responsiveness Summary for Operable Unit One of the Brodhead
Creek Superfund Site is divided into the following sections:
Section I Overview - A summary of the public's
response to Alternatives for
Operable Unit One.
Section II Background Information on the
Community's Involvement and Concerns
- A discussion of the history of
community interest in the Site and
the concerns expressed during the
remedial planning activities at the
Brodhead Creek Superfund Site.
Section III A Summary of Major Comments Received
During the Public Meeting, Public
Comment Period and Agency Responses
to Those Comments and Questions -
This summary addresses comments and
EPA responses and is categorized by
topic.
I. OVERVIEW
During the public comment period held from February 15 through
March 18, 1991, written comments regarding the selection of a
remedial alternative were received by EPA. A request for the
extension of the comment period was denied by EPA because it was
not received in a timely manner, as contemplated by the NCP. A
public meeting was also held on February 27, 1991 which provided
the opportunity for the public to ask questions and express
opinions and concerns. The questions and comments expressed by
local residents were few in number; however, numerous comments
were made by several of the Potentially Responsible Parties
(PRPs). The comments and EPA's responses will be summarized in
Section III of this document.
II. BACKGROUND OF COMMUNITY INVOLVEMENT AND CONCERNS
The Brodhead Creek Superfund Site is located in the Stroudsburg
Borough of Monroe County, Pennsylvania. This area of Pennsylvania
is located between the Pocono Mountains and the Delaware River and
is a popular winter and summer resort area with tourism as the
mainstay of the area's economy. Brodhead Creek, which originates
in the Pocono Mountains and flows past the Site, has been
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identified as one of the best cold water trout fishing streams in
Pennsylvania. Many of the area's conservation groups and tourism
groups, as well as the local and county officials, are aware of
the problems at the Site. However, there has been limited
community interest and few inquiries about the Site.
Media - coverage cf the Site was extensive when the contamination
was first discovered in the early 1980's but has decreased to
sporadic newspaper • —u -.cles. The media did cover the public
meeting held on F;..---, LI, 1991 on the Proposed Remedial Action
Plan for Operable Unit One. The meeting was also attended by
approximately twenty residents, township council members and
attor-^ys representing the Potentially Responsible Parties.
The concerns and questions expressed during that meeting, the
ccnments received during the public comment period and EP.Vs
responses to those comments are described in the following
summary.
III. SUMMARY OF THE MAJOR COMMENTS EXPRESSED REGARDING THE
PROPOSED REMEDIAL ACTION PLAN FOR THE BRODHEAD CREEK
SUPERFUND SITE AND EPA RESPONSES TO THOSE COMMENTS
EPA's Preferred Alternative
1. Concerns were expressed over the selection of the enhanced
recovery process and the newness of that technology over a morr
proven cleanup method. Comments were made stating that tl-
preferred alternative is not cost effective, and not supported b
the Risk Assessment, Remedial Investigation or Feasibility Study
and not consistent with the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). Specific questions asked
included, where has this method been used before and, if it was
used previously, what were the results?
EPA Response: Superfund law encourages the use of innovative
technology such as the enhanced recovery process. Based on the
nine criteria set forth in the NCP that EPA uses to select its
preferred alternative, the enhanced recovery process has less
disadvantages than the other available alternatives that were
reviewed. Preliminary bench scale studies conducted on soil
samples from the Site indicate that this process will be a
successful cleanup method for the.Site.
The enhanced recovery process has been used in the petroleum
industry for years for increasing the recovery of oil from wells.
Bench scale studies of the enhanced recovery process on Site soils
indicate that it should also be effective in enhancing the recovery
of coal tar from subsurface soils. To EPA's knowledge, this will
be the first Superfund site at which the enhanced recovery process
will be applied.
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2. Comments were made questioning EPA's plan to conduct a
treatability study after the Record of Decision is issued instead
of prior to the Agency's final decision on a cleanup method. A
statement reads that "this approach risks remedy selection without
adequate consideration of key information on cost and
implemsntability, in contravention of the NCP." Other specific
questions on the treatability studies included: who will conduct
the studies; who will pay for the studies; and how long will they
take to complete?
EPA Response: As stated above, preliminary studies indicate that
the enhanced recovery process should be successful in cleaning up
the Site. EPA feels that there is enough information to support
a Record of Decision. However, treatability studies will be
conducted prior to the full scale implementation of the process to
ensure that it will be successful, to determine the optimum
performance of the process and to fine tune the process design.
The treatability studies will be initiated and completed as
expeditiously as possible to ensure that Site remediation may nove
forward.
The studies will be conducted either by the contractor hired by the
PRPs with EPA oversight or by EPA itself. Depending on
negotiations with the PRPS, the studies will be funded by the PRPs
or EPA.
3. If the treatability study concludes that the enhanced recovery
process will not be a successful cleanup remedy, can and will the
Record of Decision be revised by EPA?
EPA Response: EPA believes that the process will be effective at
this Site; however, if after site specific treatability studies it
is concluded that the process will not be successful, the Agency
will reconsider the alternatives and either issue an explanation
of significant differences (ESD) or a ROD amendment. The results
of the treatability study will be available to the public.
4. Several concerns were expressed regarding the temperature,
volume and chemical composition of the water that will be injected
into the subsurface soils and then discharged into the Creek and
re-injected into subsurface soils during the cleanup. Each
individual question is addressed in the following section:
A. What will be the temperature of the water and will
the temperature sterilize the micro-organisms in the
soil?
EPA Response: The subsurface soil is currently about 50
degrees Fahrenheit and the coal tar will have to be
heated to approximately 86 degrees Fahrenheit in order
to mobilize it. Bench scale studies reveal a water
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temperature of approximately 150 degrees will be
sufficient to mobilize the coal tar. EPA does not expect
that' the water temperature will pose a significant
problem to subsurface soils and that the microbial
population at those depths in the subsurface soil is not
expected to be significant. EPA will, however, want to
address the sterilization issue in the treatability
study. EPA certainly does not want to cause more of an
environmental impact trying to remediate the Site.
B. What will be the level of contamination in the water
that is discharged and re-injected back into the soil?
EPA Response: EPA will meet the National Pollution
Discharge Elimination System (NPDES) requirements under
the Clean Water Act for discharging process water. There
are several proven technologies available for water
treatment. The quality of the water that is re-injected
will be substantially better than the quality of ground
water presently there. Also, the re-injection of water
into the subsurface remediation cell will only continue
until the remedy is complete, then the water will be
treated and discharged.
C. A concern was expressed that the volume and
temperature of the water discharged into the Creek could
have a negative impact on the stock trout and wild trout
populations of the Creek.
EPA Response: Reducing the volume and regulating the
temperature of the process water will be considered
during the design phase of the enhanced recovery process.
EPA will recycle the enhanced recovery process water as
much as possible to minimize the amount being discharged
to Brodhead Creek. Current information indicates that
the volume of water being discharged to Brodhead Creek
will not be significant given the surface water flow data
of Brodhead Creek. The majority of the process water
will be recirculated through the enhanced recovery
process.
D. A comment was submitted stating that any discharge
to the Creek, although regulated, may be harmful to the
stream biota. Therefore, EPA is urged to select a
remedial action that does not include a stream discharge.
EPA Response: EPA understands the concern regarding
discharging of process water to the stream. As stated
above, the volume of water discharged to the Creek is not
expected to be significant compared to stream flow. For
an extra added degree of control, EPA has included
Brodhead Creek biota monitoring as part of the selected
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interim remedy. EPA will strive to minimize any impacts
to the Creek from process water discharge.
E. The Pennsylvania Fish Commission and the Brodhead
Chapter of Trout Unlimited requested a copy of the fish
tissue analysis that was conducted during the Remedial
Investigation for their file.
EPA Response: EPA will provide the Commission and Trout
Unlimited with a copy of that report.
5. A concern was expressed regarding the possibility that the
recovery process could increase the level of coal tar constituents
in the Creek as a result of the injection of water at a very high
temperature and under pressure into the ground. What precautions
can be taken to prevent ground water contamination during
implementation of the preferred alternative? Is there a provision
for ground water monitoring during implementation? If ground water
contamination is detected, what precautions will be taken to
protect the community?
EPA Response: A subsurface remediation cell using sheet piling
will be blocked off during the enhanced recovery process and
hydraulic controls will be maintained within the remediation cell
to ensure that the contaminated ground water will not escape the
cell thereby minimizing the chance of coal tar constituents seeping
into the ground water. Essentially, this hydraulic control will
be maintained by extracting process water from the remediation cell
at a rate faster than it is being re-injected. This will prevent
process water from escaping the subsurface remediation cell.
Ground water will be monitored during testing. The treatability
studies will determine what recovery role is necessary to ensure
the control of both injected water and released waste. In the
event that ground water contamination is detected, EPA will respond
with an appropriate response action.
6. A concern was expressed over whether the enhanced recovery
process could possibly pose a risk to maintaining the integrity of
the existing slurry wall.
EPA Response: The slurry wall is an integral part of the interim
remedy that would be implemented, at the Site. Maintaining the
integrity of the slurry wall is a primary concern. The selected
alternative, in-situ enhanced recovery, should not pose a risk to
the strength or stability of the existing slurry wall. As the free
coal tar is thermally displaced from the soil pores, it will be
recovered by pumping wells. Since the enhanced recovery process
will be conducted within the confines of a subsurface remediation
cell, this will minimize any impacts to the slurry wall or any
other subsurface features such as buried utilities.
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7. A statement was made regarding the implementation of the
preferred • alternative in the MW-2 area as well as the RCC area.
The statement reads, "Application of the process in the MW-2 area
is not feasible due to Site topography. In addition, it would not
provide any significant recovery of coal tar because 96% of the
free coal tar at the Site is in the RCC area. The RCC area should,
therefore, be the only area at which the process is applied."
EPA Response: Although the free coal tar volume at the MW-2 area
is small, this area also imparts high levels of contamination to
the Site ground water and therefore should be remediated. The
question as to whether the enhanced recovery process can be
implemented at the MW-2 area will be addressed during the
treatability studies and remedial design.
8. Several comments were made regarding the fact that EPA's
preferred remedial alternative will only result in a three percent
to six percent decrease in the total coal tar volume at the Site
which appears to be a relatively low percentage. Statements were
made to the effect that EPA's preferred alternative should be re-
evaluated in terms of efficiency of the use of funds in light of
the estimated volume of coal tar to be recovered.
EPA Response: The enhanced recovery process is the best remedy for
the Site with respect to short-term effectiveness arid
implementability compared to the other alternatives under
consideration. The enhanced recovery process may be conducted in
situ, which will alleviate the need to stockpile large amounts 01
contaminated soil thereby increasing exposure. Although the
estimated percentages for recovered coal tar may seem low, the free
coal tar is the main source of contamination at the Site. The
selected remedy is expected to remove between 60 to 70 percent of
the free coal tar onsite. In addition, approximately 10,000
gallons of residual coal tar will be collected which will help
prevent the coal tar from re-accumulating in the statagraphic sink.
Therefore, although overall coal tar reduction may seem small,
removal of free coal tar from the Site will significantly reduce
ground water contamination.
9. A question was asked regarding how EPA's proposed remedial
alternative would lower the Site's total carcinogenic risk.
EPA Response: The removal of the coal tar pools, by lowering the
concentration of coal tar constituents in the ground water, will
substantially reduce the threat to human health from ingestion of
that ground water and the potentia.1 for contaminant release to
ground water in the bedrock which is currently used as a drinking
water supply.
10. A resident questioned what type of steps would be taken to
minimize the possible threat to onsite workers and the community
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during the remedial activities. Also, since the enhanced recovery
process will be conducted in-situ, what types of risks are
associated with a potential accident occurring within the mechanics
of the process?
EPA Response: The selected alternative has been reviewed and
evaluated for implementability and overall protection at the Site,
which includes an assessment of possible risks to the community
during field activities. (See Section VIII of the Record of
Decision).
Before any remedial alternative is implemented, a site-specific
Health and Safety Plan for onsite workers and the community will
be reviewed by EPA and implemented by EPA or the PRPs. This Plan
outlines the steps required to keep all personnel working onsite
safe, and if an accident does occur, the Plan describes how to
respond.
11. A question was asked regarding how long it will take for the
activities outlined in the Proposed Plan to be completed and what
type of work will residents be able to see going on at the Site.
EPA Response: It will take approximately six months to implement
the enhanced recovery process and based on current information
about three months of operation at the Site for completion.
Remedial activities will include the installation of injection and
recovery wells, one remediation cell, a boiler to heat the water
to be injected into the subsurface soils, a phase separator to
process the recovered coal tar, an onsite water treatment facility,
and a holding tank to store recovered coal tar prior to its
shipment off-site.
12. A resident asked if Alternative 5 could pose any residual
problems in the future - "perhaps ten years down the road"?
EPA Response: The selected alternative will not be able to recover
all of the coal tar in the ground so that some future risk may
remain. However, that risk will be greatly reduced because of the
reduction in the volume of coal tar and its hazardous constituents.
In addition, EPA will be evaluating ground water further under a
second operable unit for the Site to determine what other actions
may be necessary at the Site to ensure protection to human health
and the environment.
13. A resident questioned how Alternative 5 would improve a future
ground water cleanup at the Site.
EPA Response: The selected alternative is an effective technique
to reduce the volume, mobility and toxic constituents of the coal
tar. This interim action will greatly reduce the potential for
future release of high concentrations of hazardous compounds to the
ground water and will assist in evaluating the feasibility of
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restoring ground water at the Site to beneficial uses.
14. EPA was asked to compare the amounts of both free coal tar and
residual coal tar that could be removed through Alternative 2:
Limited Action as opposed to the Preferred Alternative 5: Enhanced
Recovery for Free coal Tar. A comment was made stating that it
appears that "Alternative 5 costs more and poses more environmental
risk than Alternative 2, but the cleanup effects of both of these
treatments are expected to be slight".
EPA Response: The selected alternative will remove a
significantly higher amount of free coal tar from the most highly
contaminated area, about 60 percent to 70 percent of the free coal
tar. It would also remove approximately 10,000 gallons of residual
coal tar which will help prevent re-accumulation into the coal tar
sink areas. Alternative 2 is estimated to remove about 50 percent
of the coal tar in the Site's statagraphic depression but would
remove virtually none of the residual coal tar at the Site.
15. A comment was submitted stating that the proposed remedy
should be a final remedy, not an interim remedy. The statement
reads "Nothing in the Remedial Investigation, Risk Assessment or
Feasibility Study support EPA's decision to propose an interliri
remedy for this Site and address ground water as a second operable
unit."
EPA Response: EPA decides on a remedial alternative afte
reviewing the RI/FS and Risk Assessment reports, but is not boui
or limited by the conclusions of these studies. EPA determine^
that ground water needs to be investigated further because the free
coal tar may serve as a potential source of release to the ground
water in bedrock. EPA will confirm the quality of the ground water
in bedrock prior to making a final decision for addressing
contamination at the Site.
16. A comment was made suggesting that the work needed for
Operable Unit Two, which includes the installation of testing wells
in the bedrock aquifer, be conducted prior to the selection of a
recovery alternative.
EPA Response: It is not necessary to initiate Operable Unit Two
prior to the selection of a recovery alternative. Current site
data indicates that the ground • water at the Site is highly
contaminated. EPA has determined that it is appropriate to
address the major source of this ground water contamination while
at the same time confirming the quality of the bedrock ground
water. Furthermore, the design and implementation of the selected
alternative to start treatment for Operable Unit One in conjunction
with the installation of additional bedrock monitoring wells under
Operable Unit Two will assist EPA in making a final determination
for Site remediation.
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17. A comment was made regarding EPA's recommendation to expand
the monitoring program beyond the monitoring outlined in the
Feasibility Study. The statement termed the proposed long-term
monitoring of. biota, sediment, surface water and ground water
excessive in both content and frequency of monitoring. It is
believed that the monitoring program proposed in the Feasibility
Study is sufficient to the monitor the impcct of this site.
EPA Response: EPA does not believe its monitoring program for
ground water and stream biota/sediment is excessive in either
content or frequency of monitoring. Macrobenthic community,
resident fish sampling, and sediment sampling will be conducted
biannually for a two year period. Data generated by this
monitoring will be reviewed by EPA to determine if further
monitoring is required. Sea lamprey will be sampled once every
five years. The sea lamprey larvae are an excellent indicator,.
based on their lifestyle, of continuing effects, if any, of coal
tar on the aquatic life in Brodhead Creek. Quarterly ground water
monitoring for at least 18 months is necessary to form a
statistical data base for evaluating sample results. Ground water
monitoring will then revert to annual sampling and analysis.
EPA is not requiring the sampling and analysis of surface water as
part of this alternative.
18. A question was asked regarding whether the Pennsylvania
Department of Environmental Resources (PADER) has taken an official
position on the Proposed Remedial Action Plan and selection of
Alternative 5.
EPA Response: PADER supports the selection of Alternative 5
documented by its correspondence of March 29, 1991.
OTHER REMEDIAL ALTERNATIVES
1. A comment was made that the cleanup alternative recommended
by the contractor who had conducted the Remedial
Investigation/Feasibility Study was Alternative 2: Limited Action
and that the contractor was very critical of EPA's choice of
Alternative 5: Enhanced Recovery for the Free Coal Tar. The
statement questioned why the contractor's conclusions were removed
from the Feasibility Study and not part of the public record.
EPA Response: EPA disagrees with the characterization that the
contractor was "very critical" of the enhanced recovery process.
The purpose of the Feasibility Study is to have alternatives
studied and presented for EPA, in consultation with PADER, to
select a preferred alternative. We do not agree with the
recommendation. There is no requirement that EPA accept
recommendations made by PRPs* contractors. In fact, public policy
requires that EPA exercise its best independent judgement to
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determine what remedy will protect public health and the
environment. EPA makes whatever changes necessary to any report
including" an FS in accordance with its authority in CERCLA and the
NCP.
2. A comment was submitted stating a preference for Alternative
2: Limited Action over EPA's preferred Alternative 5: Enhanced
Recovery Process. The statement reads "EPA's proposed remedy is
no more protective of ^-r-.lth and the environment and does not meet
SARA mandate^ , intly more effectively than the Limited
Action Alternative which is much less expensive. The most cost
effective alternative evaluated in the Feasibility Study that would
accomplish a reduction in toxicity, mobility and volume appears to
be the Limited Action Alternative."
EPA Response: EPA is concerned with eliminating the source of
contaminants that is mobile and therefore has the capability to
migrate beneath the Site or possibly vertically to ground water in
the bedrock. The enhanced recovery process will accomplish this
task better than all other proposed remedies according to current
information.
3. A question was asked regarding what EPA's position is on tne
cleanup remedy that would involve the excavation and removal of all
onsite soil and its replacement with new soil.
EPA Response: Excavation and replacement of coal tar contaminate
subsurface soils would entail overcoming several site-specif
constraints associated with excavation including the re-routing o
several subsurface utilities, the flood control levee, slope
stability during excavation and upwelling of the silty sand unit.
In addition, excavated contaminated soil would have to be
stockpiled onsite prior to its shipment offsite for incineration.
This may allow for the increased chance of someone coming in
contact with the coal tar during the excavation process. Also, the
stockpiled soils as well as the open excavation would be a source
of volatile organic compound (VOC) emissions from the Site. With
respect to these factors, excavation did not seem appropriate.
4. A resident asked for an explanation as to why Alternative 5
is better than Alternative 4 when it seems that Alternative 4 costs
a little less and removes 6 percent to 10 percent of the total coal
tar volume at the Site, which is more than the percentages quoted
in Alternative 5.
EPA Response: Alternative 4 involves excavation of contaminated
subsurface soils in the RCC area of the Site. The excavation
process alone carries a number of site-specific constraints (See
Response to #3) which would make it difficult to implement. In
addition, due to the nature of the subsurface soils (i.e., cobbles
and gravels), material handling problems would likely occur. The
soils would have to be stockpiled onsite prior to soil washing
10
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which may increase the chance of someone coming in contact with
contaminated soils. Also, VOC emissions from the stockpiled soils
and the excavation area would have to be addressed.
Therefore, although Alternative 4 does remove a slightly greater
percentage of coal tar, the fact that Alternative 5 can be
conducted in-situ without excavation, makes it a more preferable
alternative.
5. A question was asked in regard to the excavation described in
Alternative 6: Excavation of Contaminated Subsurface Soils and
Off-Site Incineration being combined and/or supplemented with the
pumping process described in Alternative 2: Limited Action.
EPA Response: The excavation in Alternative 6 is limited to the
Site's bigger pool of coal tar because the second pool of coal tar
abuts the slurry wall and excavation could cause damage to the
wall. It is possible to take portions of alternatives and combine
them. In this case, however, excavation would cause a problem
because of the high water table and silty sand. This would cause
a running sand problem which would create significant problems in
addition to the other site-specific excavation constraints already
mentioned.
6. A resident asked about the threat posed by the free coal tar
to the environment if Alternative 1: No Action was selected.
EPA Response: The "No Action" alternative is not protective of
human health or the environment of the Site. The free coal tar
located in the subsurface soils is imparting high levels of
contaminant into Site ground water. Possible future releases and
the potential for exposure would not be controlled if Alternative
1 was selected. (See discussion in Section VIII of the Record of
Decision.)
7. A question was submitted regarding Alternative 3: On-Site
Stabilization/Solidification. The Summary of Alternatives section
of the Proposed Remedial Action Plan does not indicate the quantity
of free coal tar to be immobilized. This information would be
useful in assessing the suitability of this alternative.
EPA Response: Alternative 3 (On-Site Stabilization/Solidification)
would involve the excavation and treatment of approximately 1,000
cubic yards of contaminated soils (similar to the excavation
volumes of Alternative 4 and 6). Therefore, it is expected that
Alternative 3 would immobilize the same quantity of coal tar which
would be excavated and treated under Alternatives 4 and 6, which
is approximately 8,700 gallons of free coal tar and up to
approximately 23,000 gallons of residual coal tar. However, unlike
Alternatives 4, 5 and 6, the coal tar will not be permanently
removed from the environment; it will only be immobilized in an
inert matrix. Therefore, there will be no net reduction in the
11
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volume of coal tar. Indeed, the volume of the treated materials
replaced in the excavation will be greater due to the addition of
the stabilizing reagents.
8. Questions were submitted regarding the dewatering/and or
aqueous byproduct of processing described in Alternatives 3, 4, 5
and 6. Will these waters be treated onsite and discharged to the
Creek? If so, what contaminants are proposed to be discharged and
in what concentrations?
EPA Response: Contaminated water recovered during the dewatering
of the excavations under Alternatives 3 and 6 will be shipped off-
site to a treatment, storage or disposal (TSD) facility for
treatment/disposal. Recovered process water from Alternative 4
(Soil Washing) and Alternative 5 (Enhanced Recovery) will be
treated onsite and discharged to Brodhead Creek. The process water
is expected to be contaminated with benzene and various PAHs in
addition to other organic contaminants and metals. The discharge
to Brodhead Creek of any treated process water must comply with
the NPDES requirements for discharge to a surface water body.
9. Questions were submitted regarding the possibility of onsite
stockpiling of contaminated soils described in Alternatives 3, "4
and 6. The following information is requested to help determine
the alternative that is least harmful to the population and
environment.
A. Once the soils are uncovered, do they pose a
significant human health risk?
EPA Response: Contaminated soils should not be easily
accessible to the public and any excavated contaminated
soil must be stored in a restricted area. Some VOC
emissions from the soils may occur. However, EPA will
take all steps necessary to minimize any exposure to
onsite workers and the surrounding community.
B. Can soils be protected from precipitation? Are the
contaminants in the soil water soluble?
EPA Response: Soils can be protected from precipitation
by placing a cover on them. Some of the contaminants in
the soil are water soluble. Water leaching from the
contaminated soils would be collected and shipped offsite
for treatment.
C. How does exposure to VOC's compare to ground water
contamination in terms of health risk? How would the
community be protected from VOC's? Were specific
precautions considered to reduce the threat of exposure
to VOC's?
12
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EPA Response: Exposure to air borne contaminants at the
Site in its present condition was evaluated during the
Risk. Assessment of the Site and were determined not to
be of a potential concern. Ground water, on the other
hand, exceeds drinking water standards that are
protective of human health. During Site remedial
activities, some VOC emissions may occur. To the extent
that new emissions occur, Pennsylvania regulations
require that emissions be reduced to the minimum
obtainable levels through the use of the best available
technology.
10. A question was posed asking if aggressive action is warranted
at the Brodhead Site. The statement reads: "The Proposed Remedial
Action Plan identifies only one fact and one speculative concern
at Brodhead that could warrant action. The fact identified is that
ground water in the shallow aquifer fails drinking standards. This
fact, however, is invoked only weakly as a basis for action:
exposure to ground water in the stream gravel unit is considered
an "unlikely" event that might occur."
EPA Response: Aggressive action is warranted at the Site. A
source of hazardous constituents has been identified in the
subsurface soils and has been shown to impact the quality of ground
water. Maximum Contaminant Levels (MCLs), a health based standard
for drinking water, were exceeded for selected compounds and poses
a risk to the use of this ground water. In addition to any
obligations we have to protect this ground water, a potential may
exist for the release of contamination to the ground water in
bedrock which is currently used as a drinking water source.
COMMENTS REGARDING OPERABLE UNIT TWO
1. A question was asked regarding what work will be involved
during Operable Unit Two.
EPA Response: Work to be done under Operable Unit Two will involve
further investigation to assess the quality of the bedrock ground
water. That information will be used to help develop an overall
Site plan. Alternative cleanup methods will be analyzed and EPA
will then issue another Proposed Remedial Action Plan and Record
Of Decision.
EPA will be the lead agency for Operable Unit Two in either
implementing or overseeing the PRPs' implementation of a focused
Remedial Investigation/Feasibility Study.
2. A comment was made suggesting that EPA's plan to divide the
cleanup of the Site into two operable units "reflects a desire to
move forward an engineering experiment rather than a logical first
step in a cleanup plan."
13
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EPA Response: The contamination problems at the Site are complex
and may pose a current threat to human health and the environment.
Addressing this complex problem in two phases is the best and most"
logical approach to reducing the immediate risks. Reducing the
volume and mobility of the coal tar, the source of thet
contaminants, is the logical first step. Section
300.430(a)(i)(ii)(A) of the NCP contemplates the splitting of site '
remediation into Operable Units.
3. Questions were posed as to why EPA cannot recommend a
permanent solution for this Site based on the Remedial
Investigation/Feasibility Study. Why does EPA plan to conduct
future work on Operable Unit Two? Why would EPA want to go into
the bedrock aguifer and look for something else?
EPA Response: EPA cannot recommend a permanent solution without
additional data to be sure that there is no vertical migration of
contaminants down to the bedrock. This information will be
gathered by doing further work on Operable Unit Two.
4. A comment was submitted questioning the purpose of postponing
any action on Operable Unit Two which will address ground water in
the bedrock, the principal source of human exposure.
EPA Response: No data has been obtained on the bedrock aguifer
except in areas located too far away from the Site. This
information is necessary before a final strategy for addressir
ground water can be adequately contemplated. However,
addressing the subsurface soil contamination under this interi...
remedy, EPA is taking the first step in an overall Site cleanup
strategy.
COMMUNITY RELATIONS CONCERNS
1. A comment was made regarding the fact that EPA did not devote
sufficient time to exploring and soliciting public comment on the
five other proposed remedial action alternatives.
EPA Response: The Proposed Remedial Action Plan states that EPA
is soliciting comments on all alternatives, the Remedial
Investigation/Feasibility Study and the Administrative Record file.
The purpose of a public meeting is to provide the community with
a forum to pose questions and make comments. The NCP requires "a
reasonable opportunity, not less than 30 calendar days," for public
comment as stated in 40 CFR 300.430(f)(3)(C). The public comment
period, during which EPA accepted written comments, was open from
February 15, 1991 through March 18, 1991.
2. A question was asked regarding whether EPA will schedule
another public meeting if the Agency decides to replace the
preferred alternative with one of the other five alternatives
listed in the Proposed Remedial Action Plan.
14
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EPA Response: If any modification or substitution of the Preferred
Alternative involves elements of the other five proposed
alternatives, then another public comment period is not required.
3. A comment was submitted by an organization that had
investigated the possibility of applying for a Technical
Assistance Grant. The organization stated that they "found the
grant application itself beyond the capability of a volunteer
organization." They request that EPA review and simplify the
process associated with applying for a Technical Assistance Grant.
EPA Response: EPA staff are available to assist applicants in
filling out the application and in understanding and complying with
Technical Assistance Grant requirements both before and after award
of a Grant.
SECURITY CONCERNS
1. A question was asked as to why EPA has endorsed the erection
of a security fence since the Site poses no present danger to the
public and the public does not use the Site area on a regular
basis.
EPA Response: Although the possibility of human exposure is
limited, public access to the Site during remedial activities is
a consideration that will be addressed during the remedial design
phase. It may not be necessary to fence the entire Site area.
2. A question was asked regarding the possibility of EPA erecting
a fence if the public is opposed to the idea. Also, what plans
does EPA have for the Site after the remedial activities have been
completed?
EPA Response: As discussed earlier, EPA's plans for the Site
include issuing a subsequent Record of Decision for the Site. The
posting of a Site guard is a possible alternative to fencing.
Plans for long-term security will be determined at a later date.
OTHER ISSUES
1. One potentially responsible party is concerned that the
selection of the preferred alternative is a result of communication
between EPA and another potentially responsible party that
indicates that the enhanced recovery process would suit the
purposes of both EPA and the other potentially responsible party.
EPA Response: EPA selects a remedy for a site based on the
evaluation of alternatives against the nine criteria listed in the
NCP and what is best for the site. The criteria and basis for
selection are fully discussed in the administrative record file.
15
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EPA does not select a remedy on potentially responsible party's
willingness to implement a particular remedy.
2. A commenter has asked that the Record of Decision be delayed
until the Federal District Court for the Eastern District of
Pennsylvania hears and decides the negligence liability theory
presently being advanced in a suit against the Commonwealth of
Pennsylvania.
EPA Response: The pending litigation, to which the EPA is not a
party, addresses liability and has no effect on EPA's selection of
a remedy for this Site. EPA is fulfilling, in part, its statutory
and regulatory obligations with respect to the health and
environmental concerns at the Site.
3. A potentially responsible party suggests that the procedure
which would best serve the interests of all is to defer both the
Record of Decision and special notice letters six months so that
both EPA and the potentially responsible party are in an informed
position to take appropriate action.
EPA Response: EPA believes it is in an informed position to take
appropriate action at this time to mitigate potential threats posed
by the free coal tar at the Site. There is no reason for delaying
the Record of Decision or Special Notice Letters for six months.
16
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ArPFNDIX 3
SRCDHEAD CREEK SITE
ADMINISTRATIVE RECCRD_FILS •
INDEX OF £~~'"~
I.- SITE IDENTIFICATION
1. Report: Grour.dwater Development for the 3orcuzh of
East Stroudsburg, Ease Stroudsburg, Pennsylvania,
prepared by Moody and Associates, Inc., 6/H.
P. 100001-100049.
2. Report: The Borough of East Stroudsburg Water
Supply System and the In-.pact of East Strcudsbur?
State College on this System, prepared by R.K.S.
Kess Associates, 3/81. ?. 10C050-1CQC64.
3. U.S. Z?A Potential Hazardous Waste Site
Identification, 3/12/81. ?. 10C065-10CC65.
4 . Report: A Preliminary Assessre.r.t of Srcchead Cree<
Coal Plant, Stroudsburg, Pennsylvania, prepared by
Ecology and Environment, Inc., 6/10/31." ?'. i:CC-66-
100114.
5. U.S. EPA Potential Hazardous Waste Site
Identification & Preliminary Assessment, 6/10/51.
P. 100115-100118.
6. Report: Brodhead Extent of Contamination Report,
prepared by Barrett E. Sorry, 9/11/81. ?. i:CU9-
100162.
7. Report: A Site Inspection of Brodhead Creek,
Stroudsburg, PA, prepared by Ecology and
Environment, Inc., 6/29/82. P. 100163-100490.
8. Site Safety Plan, prepared by Ecology and
Environment, Inc., 8/31/82. P. 100491-100500.
9. Memorandum to Mr. Robin Aiken, U.S. EPA, from Ms.
Veronica Wancho O'Donnell, Ecology and Environment,
Inc., re: Discharge from Redmond Manufacturing ir.to
Brodhead Creek, 11/23/82. P. 100501-100501.
10. Report: Brodhead Creek Drilling Program, prepared
by Ecology and Environment, Inc., 12/30/82.
P. 100502-100707.
* Administrative Record File available 12/12/90, ucdatei
2/14/91.
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. REMEDIAL ENFORCEMENT PLANNING
1. . Consent Order and Agreement, In the Matter of-
Brcchead Creek Superfu.-.d Site, 3/20/37*"? / :" * -
2CC023. *
Holland Thread Manufacturing
2. Letter to Mr. Ralph Matergia, Holland Thread
Manufacturing Company, Inc., from Mr. William A.
Sullivan, Jr., U.S. EPA, re: Possibility of EPA's
spending public funds, 3/18/82. P. 2CC024 -2ZZ~Z3 .
3. Letter to Holland Thread Manufacturing Company fr:-.
Mr. Donald M. Becker, Pennsylvania Department c:
Environmental Resources (PADER), re: Nor if i'-a-• - -
of NPL status, 4/14/36. P. 200026-2CC027.
Lockwcod Engineering Corporation
4. Letter to Mr. Mark Wolfe, Lockwood Engineering
Corporation, from Mr. William A. Sullivan, J:'.,
EPA, re: Possibility of EPA's spending public .
funds, 3/18/82. P. 200028-200029.
5. Letter to Lockwood Engineering from Mr. Donald X.
Becker, (PADER), re: Notification of NPL status,
4/14/86. P. 200030-200031.
Pennsylvania Power & Light (PP&L)_
6. Notes of interview with Mr. Howard Lee, Stroudsburg
Coal Tar Investigation, prepared by J. F. Villau.-e,
6/9/81. P. 200032-200033.
7. Letter to Mr. Edwatd M. Nagel, Pennsylvania Power i
Light Company, from Mr. William A. Sullivan, Jr.,
U.S. EPA, re: Possibility of EPA's spending public
funds, 3/18/82. P. 200034-200035.
8. Letter to Mr. Gene Gockley, Pennsylvania Power and
Light Company, from J.E. Godfrey, PADER, re: Fin.il
Work Plan, 2/14/86. P. 200036-200182. The Work
Plan is attached.
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9. Letter to Mr. Gockley, Pennsylvania Power a.-.d li:
Company, from J. E. Godfrey, PADER, re: Agree~e:
to sponsor -eeting, 3/3/86. P. 200133-200133.
10. Letter to Mr. J. Xozlcsky, PADER, from Mr. Gere :•
Gockley, Pennsylvania Power & Light Company, re:
Agreement to undertake the RI/FS, 4/11/36.
P. 200184-200184.
Penn Fuel Gas, Inc.
11. Letter to Mr. John Ware, Penn Fuel Gas, Inc., fr:.~.
Mr. William A. Sullivan, Jr., U.S. EPA, re:
Possibility of EPA's spending public funds, 3/1= •-.2
P. 200185-200136.
LJnion Gas Co.
12. Letter to Mr. Rae Cornwall, Union Gas Ccrpany, fre-
Mr. William A. Sullivan, Jr., U.S. EPA, re:
Possibility of EPA's spending public funds, 3/13752
P. 200187-200188.
13. Letter to Mr. Nicholas DeBenedictis, Department z:
Environmental Resources, from Mr. Marc G. Srecher,
Pennsylvania Office of the Attorney General, re:
Hazardous waste clean-up of Brodhead Creek, 1/25/55.
P. 200189-200191.
14. Letter to Union Gas Company from J.E. Godfrey,
PADER, re: Final Work Plan, 2/14/86. P. 200152-
200193.
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III. REMEDIAL RESPONSE PLANNING
.1. Report: Remedial Action Master Plan, 5r;dr.ead :r-e-
Site, Stroudsburg, Monrce Ccur.ty, Pe.nr.sylvar, iT]'
..prepared by AZPCO, Inc., 10/83. P . ~3CCC01-3 55l 35*. '
2. Report: Case Studies 1-23; Remedial Rescorse at "'
Hazardous tfaste Sites, prepared bv U.S. EPA. 3/54*.
?. 300196-3GC246.
3.
Report: Evaluation of Stream Morphology a.-.d Ar-janr
Biological Data Related to the Union Gas Site :r.
Brcdhead Treek in Monroe County, Pennsylvania,
preparea by Energy & Environmental Mana-er.er.t, ~.r.z . .
7/31/84. P. 300247-300254.
4. Letter to Mr. Mark Carnon, PACES, from Mr. ^ccert A.
.Swift, Xchn, Savett, Marion 4 Graf, re: Grc_r.is ::r
Ur.icn Gas Co. ' s opposition to RI/FS Work Plan,
6/5/85. P. 300255-300287. A report entitled
Remarks for the Public Record Concerning Strear.s
Morphology and Aquatic Biological Data Related to •
the Union Gas Site on Srodhead Creek in Mcrr^e
County, Pennsylvania is attached..
5. Report: Brodhead Creek Site, Remedial
Investigation/Feasibility Study, Final Work Pla;.,
prepared by PADER, 1/86. P. 300238-300340.
6. Report: Technical Oversight Work Plan for 3rod.u.ead
Creek Site, Stroudsburg, Pennsylvania, Volu-e I,
prepared by Camp, Dresser & McKee, Inc., 6/36.
P. 300341-300378.
.7.' Memorandum to Ms. Patricia Tan, U.S. EPA, fr.cn Mr.
Nels Barrett, U.S. EPA, re: November 14, 1'936 site
visit, 12/2/86. P. 300379-300382. Four photos are
attached.
8. Report: Site Operations Plan for the Remedial
Investigation of the Srodhead Creek Site, prepared
by Environmental Resources Management, 10/87.
P. 300383-300534.
9. Report: Trip Report, Brodhead Creek, Site Visit
Monroe County, Pennsylvania, prepared by COM Federal
Programs Corporation, 4/8/88. P. 300535-300543.
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10. Report: September 1988 Monthly Summary, Remedial
Investigation Oversight, Srcdhead Creek Site,
Stroudsburg, Pennsylvania, prepared by Versar, Ir.~.
10/14/88. P. 300544-300613.
11. Letter to Mr. John Mellow, PADER, from Mr. Michael
F. Basta, Pennsylvania Power & Light Company, re:
Transmittal of QA/QC validated chemical data,
10/27/88. P. 300614-300628. The data is attached.
12. Report: October Monthly Summary Report for the
Remedial Investigation/Feasibility Study (RI/FS) *-
the Brodhead Creek Site, Stroudsburg, Per.r.sylvar.ia,
prepared by CDM Federal Programs Corporation,
' 11/21/88. P. 300629-300733. The transmittal letter
is attached.
13. Report: November Monthly Report, Remedial
Investigation Oversight at the Brodhead Cree< 3ite.
Stroudsburg, Pennsylvania, prepared by C3M Federal
Programs Corporation, 12/14/88. P. 3C0724-30C~fO.
14. Report: December Monthly Summary Report for the.
Remedial Investigation/Feasibility Study (RI/FS)..,
Brodhead Creek Site, Stroudsburg, Pennsylvania,
prepared by CDM Federal Programs Corporation,
1/16/89. P. 300751-300798.
15. Health Assessment for Brodhead Creek, Stroudsburg,
Pennsylvania, prepared by Agency for Toxic
Substances and Diseases Registry (ATSDR), 1/20/39.
P. 300799-300802.
16- Letter to Ms. Patricia Tan, U.S. EPA, from Mr. Ja.-.es
W. Ceiling, Pennsylvania Power & Light Company, re:
Request to eliminate sampling & analysis, 2/10/89.
P. 300803-300807. Four pages of samples & analyses
are attached.
17. Letter to Mr. James W. Ceiling, Pennsylvania Power i
Light Company, from Mr. Robert K. Lewis, PADER, re:
Request to eliminate mussel sampling, 4/7/89.
P. 300808-300808. .
18. Letter to Mr. Robert K. Lewis, PADER, from Mr.
Michael F. Basta, Pe-rvnsylvania Power & Light
Company, re: Follow-up and response to April 7th
letter, 5/8/89. P. 300809-300809.
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19. Letter to Mr. Michael F. Basta, Pennsylvania =-we-
Light Company, frcm Mr. Robert K. Lewis, PACZS," -«-
Request to eliminate 3rd round of surface wa-»^
sampling, 5/22/89. P. 300810-30C810. """ "
•
20. Transmittal letter to Ms. Rose Karvell, rJ.S. EPA,.
from Mr. Bruce R. Piuta, CDM Federal Programs "
Corporation, re: Letter Report for Work'Assig.-.r.e?-.-
791 Oversight and Split Sampling, 6/21/89.
P. 300811-300833. The Letter Report is attached.
21. Report: May Monthly Summary Report for the P.e.-gdia
Investigation/Feasibility Study (RI/FS) at the
Brodhead Creek Site, Stroudsburg, Pennsylvania,
prepared by CDM Federal Programs Corporation,
6/23/89. P. 3CC834-300859.
22. Report: Brodhead Creek Site, Final Remedial
Investigation Report, prepared by Environmental
Resources Management, Inc., 9/25/90. P. 23-C353-
301376.
23. Report: Risk Assessment, Brodhead Creek Site, .
Stroudsburq, Pennsylvania, 9/25/90. P. 3013^7-
301779.
24. Report: Broadhead Creek, Feasibility Study,
prepared by Environmental Resources Management,
Inc"., 1/91. P. 301780-302171.
25. Proposed Remedial Action Plan, Brodhead Creek Site,
Borough of Stroudsburg, Monroe County, Pennsylvania
prepared by U.S. EPA, 2/14/91. P. 302172-302192.
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IV.
3-
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^^gs^!':!:;S..
^^sJS^JSS^-1-'"
=?^«-n^oios. „,...«.«-.
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12. Safety Plan, prepared by Ecology and Er.vi~< e-t
Inc., 8/4/81. P. 400554-400555. " " '
13. Letter to Mr. Lawrence Pawlush, PADER, frc.-n Mr.
• Bradley A. Wise, Pennsylvania Power & Light Cc.r.p'a.-Tv,
re: Laboratory results of the Strcudsburg ~oa' >'=''
Site, 8/14/81. P. 400556-4CC602. The results'^'
attached.
14. '. = .ter to Mr. Thomas Massey, U.S. EPA, frcm Mr.
Allen Weichman, Monroe County Conservation District,
re: Concern over the possibility of winter flccii.-.r
at the Brodhead Creek, 8/20/81. P. 40C603-4::6C4.
15. Report: Pennsylvania Power & Light, Strpudsburg
Contamination Study, Technical Control
Recc.T-T.endation, prepared by TRC Envircn-ental
Consultants, Inc'. , 9/81. P. 400605-400617.
15. Letter to Mr. Ken McGill, Ecology and Envircr.rer.t,
Inc., from Mr. Andrew J. Drozda, J. E. 3rer.ne.ran
Company, re: Analysis of leachate sarr.ples, 3/24/5:.
P. 400618-400619.
17. Memorandum to Mr. Thcrr.as I. Massey, U.S. EPA, f
Royal J. Nadeau, U.S. EPA, re: Significance :.
toxicity tests, 11/4/81. P. 400620-40C625.
13. Report: Federal On-Scene _Cgp_r_d_i_natgr_s__Repprt, Ma;:r
Pollution Incident, Stroudsbur'g, ?A^ prepared by
Ecology and Environment, Inc., 11/81. P. 4CC626-
400735,
19. Letter to Mr. Thomas I. Massey, U.S. EPA, fr:r, Mr.
James F. Villaume, Pennsylvania Power & Light
Company, re: Final Phase II Field Investigaticr.
Report, 12/18/81. P. 400736-400757. The report is
attached.
20. Letter to United States Coast Guard from Mr. Tr.c.-as
I. Massey, U.S. EPA, re: On-Scene Coordinator's
Report for the oil spill, (undated) P.,400758-
400870. The report is attached.
21. Memorandum to Mr. Walter Burkhart, PADER, from Mr.
Craig W. Billingsley, PADER, re: Toxicity of c:al
tar discharge to rainbow trout, (undated).
P. 400871-400871.
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22. Memorandum to Mr. Walter Burkhart, PADER, frcr. Xr.
Craig W. Billingsley, PADER, re: Toxicity of 2-2:
tar discharge to rainbow trout, (undated) .
P. 400872-400872.
23. Report: Historical Background of Coal Tar Pollut;
Site, Brodhead Creek, Stroudsburg, PA, (author r.c:
cited), (undated). P. 400873-400876.
24. Amended Fund Authorization Report, (undated).
P. 400877-400882. The Staged Planned Removal
Alternative for Brodhead Creek is attached.
25. Fund Authorization Report, (undated). ?. 40C333-
400885.
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V. COMMUNITY INVOLVEMENT/CONGRESSIONAL
CORRESPONDENCE/IMAGERY~~
1. ..Letter to Mr. Craig Billingsley, Pennsylvania -iSr.*
Commission, from Mr. Jim Sashline, Field i Streag,
re: Historical significance of the Brodhead Cre»k:-
3/23/81. P. 500001-500002.
2. Letter to Mr. Larry Comunale, Borough of East
Stroudsburg, from Mr. Thomas I. Massey, U.S. EPA,
re: Notice of federal interest in a pollution
incident, 7/7/81. P. 500003-500004.
3. Letter to Mr. Nicholas DeBenedictis, U.S. EPA, fr;.~.
Rep. Joseph M. McDade, House of Representatives, re.
Request for a status report of the Brodhead Creek
cleanup, 7/22/81. P. 500005-500005.
4. Letter to Mr. Thc.r.as Massey, U.S. EPA, from Mr.
Patrick J. Calpin, Pocono Forestry Association,•re:
Support of the use of Superfund monies for 3rcd.u.ead
Creek cleanup, 7/23/81. P. 500006-500006.
5. Letter to Mr. Thomas Massey, U.S. EPA, from Ms.
^ancy Shukaitis, Monroe County Board of
Commissioners, re: Formal certification of t.u.e
pollution problem at Brodhead Creek, 7/29/81.
P. 500007-500007.
6. Letter to Mr. Thomas Massey U.S. EPA, from Mr.
Steven Crane, Monroe County Office of Emergency
Services, re: Support of the cleanup operation at
Brodhead Creek, 7/30/81. P. 500008-500008.
7. Letter to Mr. Thomas Massey, U.S. EPA, from. Mr.
Edmund G. Flynn, Bensinger & Pentz, re: Support of
Superfund cleanup at the site,' 7/30/81. P. 500CC3-
500009.
8. Letter to Mr. Thomas Massey, U.S.- EPA, from Dr. Jce.'
S. Samuelson, Pocono Allergy & Dermatology
Associates, re: Support of a cleanup operation at
the site, 7/30/81. P. 500010-500010.
9. Letter to Mr. Thomas I. Massey, U.S. EPA, from Dr.
James M. Fox, Pennsylvania Department of Health, re:
Health hazards concerning the site, 7/30/81.
P. 500011-500011.
10
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10. Letter to the Honorable Joseph M. McDade, House :f
Representatives, from Mr. Nicholas DeBenedictis,
U.S. EPA, re: Response to request for a status
_ report, 8/11/81. P. 500012-500015. A routing sl_?
and a copy of the request are attached.
11. Letter to the Honorable Joseph M. McDade, House of
Representatives, from Mr. Ralph W. Abele,
Pennsylvania Fish Commission, re: Request for
support of cleanup efforts at the site, 8/19/81.
P. 500016-500016.
12. Letter to Mr. Thomas Massey, U.S. EPA, from Mr.
Allen Weichman, Monroe County Conservation District,
re: Transmittal of a chart depicting the Brodhead
Creek's flow characteristics, 8/20/81. P. 5CC01'-
500019. A copy of the chart is attached.
13. Letter to the Honorable William B. Midder.dorf,
PADER, from Mr. Ralph W. Abele, Pennsylvania Fi.sh
Commission, re: Visit to the site and extent of tr.e
problem, 8/28/81. P. 500020-500021.
14. Transmittal memo for letter to Ms. Anne Gorsuch,
U.S. EPA, from Ms. Ann McManus, Monroe County Learue
of Women Voters, re: Request for support of
remediation project at the site, 9/20/81.
P. 500022-500023. A copy of the letter is attacr.ee.
15. Transmittal memo for letter to Ms. Anna Gorsuch,
U.S. EPA, from Ms. Nancy Shukaitis, Mr. Jesse D.
Pierson, & Mr. Thomas R. Joyce, Monroe County
Commissioner's Office, re: Request for Super fund
monies for site cleanup, 9/24/81. P. 500024-50002".
A copy of the letter and a table listing the
percentage of carcinogens present are attached.
16. Transmittal memo for letter to Mrs. Anne M. Gorsuch,
U.S. EPA, from Mr. Russell Kow.alyshyn, Pennsylvania
House of Representatives, re: Request for continued
EPA funding at the site, 9/25/81. P. 500028-500029.
A copy of the letter is attached.
17. Letter to Mr. Russell Kowalyshyn, Pennsylvania House
of Representatives, from Mr. Michael B. Cook, re:
Response to request for continued EPA funding at the
site, 10/28/81. P. 500030-500031. A copy of the
request is attached.
11
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18. Letter to Ms. Nancy Shukaitis, Monroe County Scari
of Commissioners, from Mr. Michael 8. Cook, re: «
Response to request for Superfund monies for si-p^
cleanup, 10/28/81. P. 500032-500035. A copy cf the
-request and a table listing the percentage of p •
carcinogens present are attached. *
19. Press Release from U.S. EPA Environmental News, *
entitled "Joint Release by EPA and PADER for Release
1 PM, November 4, 1981, Funding Announced for
Brodhead Creek." 11/4/81. P. 500036-500040. A
design of the proposed slurry wall and a fact sheet
are attached.
20. Community Relations Plan for Remedial Action,
Brodhead Creek Superfund Site, Stroudsburg 3orc-gh,
Monroe County, Pennsylvania, (undated) .
P. 500041-500055.
"• -3 •"' ~
21. Press Release from Pennsylvania Power &
Company, re: Plans to conduct studies to deterrni.-.e
extent of subsurface contamination, (undated).
P. 500056-500057.
22. Community Relations Plan for the Brodhead Cree.<
Superfund Site, prepared by Dynamac Corporaci;.-.,
2/15/91. P. 500058-500093.
12
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SITE SPECIFIC GUIDANCE DOCUMENTS
1 • Guidance for Conducting Remedial Investigations ar.rj
Feasability Studies Under CERCLA, prepared by
OSWER/CERR, 10/1/88.OSWER #9355.3-01.
2. Handbook Remedial Action at Waste Disposal Sites
(Revised), prepared by CRD/HWERL and OSWER/CERR,
10/1/88. EPA-625/6-85/006.
3. CERCLA Compliance with Other Environmental Statutes^
prepared by J.W. Porter, OSWER, 10/2/85. CSWER
#9234.0-2. Potentially Applicable or Relevant and
Appropriate Requirements are attached.
4 . CERCLA Compliance with Other Laws Manual Draft
Guidance, prepared by CERR, 8/8/88. CSWER #9234.1-
01.
5. Integrated Risk Information Systems (IRIS) (A
Computer-Based Health Risk Information System
Available Through E-Mail--3rochure on Access is*
Included), prepared by OHEA, (undated).
6. Superfund Exposure Assessment Manual, prepared by
CERR, 4/1/88. OSWER #9285.5-1.
7. Superfund Public Health Evaluation Manual, precarei
by OER* and OSWER, 10/1/86. OSWER #9285.4-1.
13
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COMMONWEALTH OF PENNSYLVANIA
OF ENVIRONMENTAL RESOURCES
of Environmental Protection
90 East Union Street - 2nd Floor
HHkes-Barre, Pennsylvania 18701-3296
(717) 826-2511
March 29, 1991
Mr. Edwin B. Erlckson
Regional Administrator
U. S. Environmental Protection Agency
Region III
841 Chestnut Building
Philadelphia, PA 19107
Dear Mr. Erlckson:
The Record of Decision received March 26, (991 for Operable Unit 1, which
addresses free coal-tar contaminated subsurface soils at the Brodhead Creek *NPL
Site 1n the Borough of Stroudsburg, Monroe County, has been reviewed by the
Department.
The major components of the selected Interim remedy Include:
* The innovative technology of enhanced recovery entailing the Installa-
tion of extraction wells and injection wells In the free coal tar areas
of the subsurface soils;
* Recovery of coal tar and process water from the extraction wells;
* Separation of the coal tar from the process water followed by
treatment of the process water;
* Discharge of a portion of the treated process water to Brodhead Creek
and the relnjectlon of the remaining treated process water Into the
subsurface soils to enhance coal tar recovery;
* Disposal of the recovered coal tar at an off-site permitted Incinera-
tion facility;
* Instillation of a fence to prevent public access during remedial
activities;
* Imposition of deed restrictions to limit future use of the Site; and
* Ground water and biota monitoring 1n Brodhead Creek to ensure
protection to human health and the environment.
I hereby concur with the EPA's proposed Interim remedy with the following
conditions:
* The Department will be given the opportunity to concur with
decisions related to the design of the Interim Remedial Action for the
Operable Unit 1, to assure compliance with DER cleanup ARARs and
design specific ARARs.
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1391 39:49 ?50M ^£R-s?-CVC->i3 TO
Mp. Edwin 8. Erickson
Regional Administrator
U. S. Environmental Protection Agency -2- March 29, 1991
* The Department win be given the opportunity to concur with decisions
related to subsequent operable units (specifically, the final remedies
for Operable Unit 1 and Operable Unit 2), and evaluate appropriate
remedial alternatives to assure compliance with DER cleanup ARARs
and design specific ARARs.
* EPA will assure that the Department Is provided an opportunity :
to fully participate in any negotiations with responsible parties.
* The Department will reserve our right and responsibility to
take independent enforcement actions pursuant to state law.
* This concurrence with the selected remedial action 1s not Intended
to provide any assurances pursuant to SARA Section 104(c)(3).
* The Department continues to assert that our ARAR for groundwater for
hazardous substances is that all groundwater must be remediated to
"background" quality as specified by 25 Pa. Code §§264.90-264.100 and
in particular by 25 Pa. Code §264.97(1), (J) and 264.100(a)(9). The
Commonwealth of Pennsylvania also maintains that the requirement to
remediate to background Is found in other legal authorities' We also
assert that contaminated soils must be remediated to prevent contamina-
tion of groundwater above "background" levels. Given the above, the
Department expects that the final remedies for Operable Units 1 and 2
will meet these ARARs.
Thank you for this opportunity for the Department to states its concurrence with
the Interim remedy selected by EPA. The Department's concurrence is limited to
its agreement that the proposed selected remedy is the appropriate one. The
Department does not agree that every detail set forth in the Record of Decision
is accurate. If you have any questions regarding this matter, please do not
hesitate to contact me.
Sincerely
Her
Regional Environmental
Protection Director
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