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

-------
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.

-------
     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

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                                          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

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                                        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

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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

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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

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                                            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

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                                                              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.

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                                                                      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, ,,

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                                                                 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

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                                    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

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                                                               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

-------
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

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     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.

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     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;
                                34

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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-
££*«•',•. ^-0-  cepa:-r 41 ,^.
3/12/81'    rett BorrV- ftcm ^; re-. -a"

^^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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