United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/111
March 1991
&EPA Superfund
Record of Decision:
Delta Quarries/Stotler Landfill,
PA
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53272.101
" REPORT DOCUMENTATION
PAGE
). REPORT NO.
EPA/ROD/R03-91/111
3. Recipient'* Accession No.
• 4. Tide and Subtitle
SUPERFUND RECORD OF DECISION
3elta Quarries/Stotler Landfill, PA
First Remedial Action - Final
5. Report Date
03/29/91
7. Author(a)
8. Performing Organization Rept No.
9. Performing Organization Name and Address
10. Proiect/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
15. Supplementary Notes
16. Abstract (Limit: 200 worda)
The 137-acre Delta Quarries/Stotler Landfill site includes a 57-acre former landfill,
and is located between the City of Altona, Logan Township and the Village of Pinecroft,
Antis Township, Pennsylvania. Land use in the area is rural. Several residences are
approximately 35 feet east of the landfill boundary, and wetlands areas exist to the
southeast and northeast. Residences and businesses in the vicinity of the site rely on
private wells adjacent to the landfill for their drinking water supply. Beginning in
1964, two adjacent municipal landfills were operated onsite, and in 1976 these
operations were merged into one landfill, known as the Stotler Landfill. Delta
Quarries and Disposal, Inc. purchased the landfill and continued to operate the
facility until its closure in 1985. Reports from EPA, the State, and previous landfill
operators indicate that municipal wastes comprise 98% of the total landfilled wastes;
however, the landfill had accepted some industrial wastes including organic solvents,
process sludges and metals from electroplating operation, tramp oils and residues from
sludge sedimentation basins, which have contaminated onsite soil and ground water in
the landfill area. In 1984, the State and Delta Quarries entered into a consent order
to develop and implement a closure plan for the landfill. In 1987, the site owners
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Delta Quarries/Stotler Landfill, PA
First Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (TCE, PCE), metals (manganese)
b. Identifiers/Open-Ended Terms
c. COSATI Reid/Group
' Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
22. Price
(SeeANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R03-91/111
Delta Quarries/Stotler Landfill, PA
.First Remedial Action - Final
stract (Continued)
initiated the plan by placing a 4-foot soil cap over the landfill, vegetating the area,
and installing sedimentation controls including interceptor berms, channels, and
sedimentation basins. All elements of the closure plan were completed except
installation of gas venting. This Record of Decision (ROD) addresses onsite ground
water contamination. The primary contaminants of concern affecting the ground water are
VOCs including PCE, TCE and vinyl chloride; and metals including manganese.
The selected remedial action for this site includes pumping and onsite pretreatment of
ground water using precipitation to remove metals, if necessary, followed by onsite
treatment using air stripping; discharging the treated water offsite to Little Juniata
River; controlling air emissions using activated carbon; monitoring ground water and
surface water; maintaining the cap, and installing a gas venting system; conducting
periodic site reviews; and implementing institutional controls including deed and land
use restrictions, and site access restrictions such as fencing. The estimated present
'worth cost for this remedial action is $2,344,581, which includes a present worth O&M
cost of $1,176,989 over 30 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water cleanup standards are
based on the more stringent of SDWA MCLs or background levels, and include
1,2-DCA 5 ug/1 (MCL); cis-l,2-DCE 70 ug/1 (MCL); trans-1,2-DCE 100 ug/1 (MCL);
chloroform 100 ug/1 (MCL); PCE 5 ug/1 (MCL); TCE 5 ug/1 (MCL); and vinyl chloride 2 ug/1
'MCL) .
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RECORD OF DECISION
DELTA QUARRIES AHD DISPOSAL SITE
SITE NAKB AND LOCATION
Delta Quarries and Disposal Site
Antis and Logan Townships, Blair County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action plan
for the Delta Quarries and Disposal Superfund Site (the Site) in
Blair County, Pennsylvania which was chosen in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended by the Superfund Amendments and
Reauthorization act of 1986, U.S.C. Section 9601 (CERCLA), and, to
the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan. This decision is based upon and
documented in the contents of the Administrative Record. The
attached index identifies the items which comprise the
Administrative Record.
The Commonwealth of Pennsylvania has reviewed, commented upon, and
concurred in this decision.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine, pursuant
to Section 106 of CERCLA, 42 U.S.C. Section 9606, that actual or
threatened releases of hazardous substances from this Site, as
specified in Section VI, Summary of Site Risks, if not addressed
by implementing the response action selected in this Record of
Decision (ROD), may present an imminent and substantial
endangerment to the public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedial action plan in this document is presented as the
permanent remedy for controlling the ground water contamination at
the Site. This remedy comprises the following components:
1. Extracting and treating the ground water to quickly halt
plume migration, with the long-term goal of returning the
ground water to its most beneficial use.
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2. Provide additional protection by implementing
institutional controls to restrict the use of the
landfill and the installing of security fencing around
the property in conjunction with the existing soil cap,
to prevent any possible direct human contact with
contaminants at the site, to provide protection to the
integrity of the cap by preventing any intrusion which
could compromise the cap.
3. Monitoring ground and surface water and implementing a
site maintenance program including the installation of
methane gas venting.
STATUTORY DETERMINATIONS
Pursuant to duly delegated authority, I hereby determine that the
selected remedy is protective of human health and the environment,
complies with Federal and State requirements that legally are
applicable or relevant and appropriate to the remedial action, and
is cost-effective as required under Section 121(d) of CERCLA, 42
U.S.C. Section 9621(d). With respept to a principal threat at the
site, the contaminated ground water, the remedy satisfies the
statutory preference, as set forth in Section 121(b) of CERCLA, 42
U.S.C. Section 9621(b), for remedial actions in which treatment
that reduces toxicity, mobility, or volume is a principal element.
Finally, it is determined that this remedy utilizes permanent
solutions and alternative technologies to the maximum extent
practicable.
Because this remedy will result in hazardous substances remaining
on site above health-based levels, a review will be conducted
within five years after the commencement of the remedial action to
ensure that human health and the environment continue to be
adequately protected by the remedy.
Edwin a. Erickson Date
Regional Administrator
Region^ III
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TABLE OP CONTENTS
FOR
DECISION SUMMARY
SECTION PAG1
I. SITE NAME, LOCATION, AND DESCRIPTION 2
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES. ... 3
III. SITE CHARACTERISTICS 4
IV. SUMMARY OF SITE RISKS 9
V. SCOPE OF REMEDIAL ACTION 14
VI. COMMUNITY RELATIONS HISTORY 14
VII. DOCUMENTATION OF SIGNIFICANT
CHANGES FROM PROPOSED PLAN 15
VIII. DESCRIPTION OF ALTERNATIVES 15
IX. COMPARATIVE ANALYSIS OF ALTERNATIVES 22
X. SELECTED REMEDIAL ALTERNATIVE 30
XI. STATUTORY DETERMINATIONS 31
APPENDIX A. RESPONSIVENESS SUMMARY
APPENDIX B. ADMINISTRATIVE RECORD INDEX
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RECORD OP DECISION
DHLTA OOARRIS3 AND DISPOSAL SITE
DECISION 8UMHARY
I. 8IT3 NAME. LOCATION AND DBaCRIPTIOM
The Delta Quarries and Disposal Site study area comprises an
approximately 137 acre parcel of property located about 2 miles
north of the City of Altoona, Logan Township, Pennsylvania and 1
:nile south of the Village of Pinecroft, Antis Township,
Pennsylvania (Figure 1). A former landfill occupies approximately
57 acres of the property. The landfill is bordered to the west .by
Sixth Avenue and to the east by Sandy Bank Road (Figure 2). The
area is rural in nature with some residential dwellings within 35
feet to the east of the landfill boundary. These residences are
trailer homes that are sporadically located in the study area.
Other residences are scattered several hundred feet or further from
the Site. No parks, recreation areas, wildlife refuges, historic
and/or archeological sites, or wild and scenic rivers are located
on or adjacent to the Site.
The Little Juniata River, which flows northeasterly, lies
approximately one-quarter mile west of the Site. The Little
Juniata watershed extends over 343 square miles. The City of
Altoona Sewage Treatment Plant and a privately owned solid waste
transfer station are located approximately 750 feet west of the
southern portion of the Site. Three junkyard operations are also
located to the west of the Site.
Sandy Run Creek originates in the northeast corner of the City
of Altoona. Sandy Run Creek flows parallel to the Little Juniata
River, creating a drainage divide off the northeast edge of the
landfill, and joins the Little Juniata River approximately 1 mile
downstream of the landfill. Approximately 50 percent of the
landfill surface area drains toward Sandy Run. The Sandy Run
watershed is 3.64 square miles.
The Delta Quarries and Disposal landfill is situated on a
hillside surrounded by areas of relatively high relief. Prior to
initiation of landfill activities, the property was characterized
as a natural depression. The landfill elevations presently range
from a low of 1,175 feet above sea level in the northeast section
to a high of 1,290 feet above sea level in the center. To the
east, the topography drops off to the Sandy Run before rising
rapidly to the Brush Mountain Range with elevations over 2,000 feet
above sea level. The topography undergoes a steep transition at
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' •*•' #• J>inecroft
POOR QUALITY
ORIGINAL
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the western edge of the landfill, dropping off to Sixth Avenue
before reaching the Little Juniata River floodplain elevation of
approximately 1,080 feet. Wetland areas exist to the southwest and
northeast of the landfill.
II. 8ITB HISTORY AND ENFORCEMENT ACTIVITIES
A natural depression originally existed on-site prior to the
onset of landfilling operations. In 1964, two adjacent municipal
waste landfilling operations, the Stotler and the Parshall/Kruise
landfills commenced. The owner of Stotler Landfill leased the
Parshall/Kruise landfill property in 1976 and merged the operations
into Stotler Landfill. Delta Quarries and Disposal Inc. (Delta
Quarries) purchased the Stotler landfill (and the Parshall/Kruise
Landfill incorporated therein) in 1978 and operated the facility
until its closure in 1985.
Reports from previous landfill operators and EPA and
Pennsylvania Department of Environmental Resources (PADER) file
information suggest that the majority of wastes (approximately 99.8
percent) contained in the landfill are municipal wastes. Both the
EPA and PADER files indicate that some industrial wastes were
accepted at the landfill by the Stotler landfill and by Delta
Quarries. The industrial wastes identified included organic
solvents, process sludges with heavy metals (including waste water
treatment sludges from electroplating operations), tramp oils and
residue from sludge sedimentation basin. The sludges from the
electroplating operations and the organic solvents included some
RCRA listed wastes.
In 1984, PADER and Delta Quarries entered into a Consent Order
under Pennsylvania Solid Waste Management Act requiring Delta
Quarries to develop and implement a closure plan for the landfill.
The Delta Quarries landfill ceased operations on February 28, 1985.
In the summer of 1987, a four-foot cap of soil materials borrowed
from an area southeast of the Site was placed over the landfill as
part of the Site closure activities. The cap was vegetated to
provide erosion control. Sedimentation control was provided by
utilizing interceptor berms, rock-lined channels, and sedimentation
basins. Delta Quarries completed all elements of the closure plan
with exception of installation of gas venting, and abatement of
ground water pollution.
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In 1936, the Site was listed on the National Priorities List
(NPL) in accordance with the provisions of CERCLA. On September
13, 1937, Delta Quarries entered into a Consent Order and Agreement
with EPA to conduct the Remedial Investigation and Feasibility
Study (RI/FS) for the Site. The regulations enacted pursuant to
CERCLA generally require that a RI/FS 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
remedial alternatives which are applicable to those site conditions
and might be implemented at the Site. The study area for the RI
for the Site included the landfill and ground water contamination
area, the area immediately surrounding the landfill, the adjacent
wetlands, Sandy Run Creek, the Little Juniata River, the drainage
patterns that make up the surface hydrology and the ground water
system below these areas ("study area").
The RI and FS reports were prepared by Delta Quarries in
November, 1990 and January 1991 respectively. These reports, after
being revised based on EPA and PADER'comments, were placed in the
information repositories described in Section VI.
Residences and businesses in the Site vicinity, including
those immediately adjacent to the landfill, rely on ground water
(private wells) for their drinking water supplies. Past and
ongoing monitoring of private well water supplies indicates that
contamination from the Site has not yet affected area water
supplies.
III. SITS CHARACTERISTICS
A. Regional _C Inmate
The regional climate in the vicinity of the Delta Quarries
Site is characterized by mild winters, moderate temperature range,
and moderate precipitation. The average annual precipitation,
including rain and snow, is approximately 36.2 inches, as water.
The average annual evaporation rate is approximately 16 inches, as
water. The average annual snow fall in Pittsburgh, located 70
miles to the west, is 43.8 inches, as snow. Prevailing winds are
from the west southwest during the summer shifting to the northwest
during the winter.
B. Surface Water Hydrology
The Site lies entirely in the Little Juniata River watershed
which drains ultimately into the Susquehanna River basin. The
Little Juniata River headwaters begin in the northwest corner of
Altoona and flow in a northeasterly direction along the eastern
edge of Conrail railroad tracks to the west of the Site. The
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Little Juniata River bends to the southeast along the Blair-
Huntingdon County line and eventually joins with the main Juniata
River. The mean annual discharge of the Little Juniata River is
measured at 372 cubic feet per second (cfs) at the nearest USGS
gauging station in Spruce Creek, Pennsylvania. The Little Juniata
watershed is approximately 343 square miles.
All Site runoff except that in the northeast section of the
Site flows directly toward the Little Juniata River. Runoff from
the northeast quadrant of the Site flows northeasterly to Gilbert
Pond, which feeds an intermittent unnamed tributary and ultimately
to Sandy Run. Sandy Run originates in the northeast area of
Altoona and flows northeasterly for 4.6 miles before joining the
Little Juniata River at the Borough of Pinecroft. Sandy Run has
an estimated mean annual flow of 15 cfs, and a watershed of 8.64
square miles.
There are three surface discharges from ground water in the
immediate Site vicinity: FAM Spring, West Flow, and East Flow.
FAM Spring is a limestone spring which emerges to the southwest of
the landfill near 6th Avenue. FAM Spring flows northwest toward
a wetland area adjacent to the Altoona Sewage Treatment Plant.
Flows ranging between 0.4 to 70 gpm have been measured with the
majority of flows between 10 to 45 gpm.
The West Flow emerges at the toe of the landfill and flows
through a culvert under 6th Avenue. The West Flow continues in a
westerly direction until it reaches the wetland area adjacent to
the Altoona Sewage Treatment Plant. Flows ranging from 0.8 to 24
gpm have been measured with most flows in the range of 1 to 13 gpra.
The East Flow originates in a sedimentation basin at the
northeast corner of the landfill, and flows eastward to the wetland
area culvert under Sandy Bank Road, feeding a small, unnamed
tributary. This tributary drains into Gilbert Pond and eventually
flows into Sandy Run. Flows ranging from 0 to 63 gpm have been
recorded. Flows are highly dependent on surface water runoff from
heavy rains and snow melt. The landfill underwent significant
changes in the fall of 1987 when the PADER-approved Site closure
plan was implemented. The plan incorporated the regrading and
capping of the landfill area with borrow material, as well as a
series of diversion ditches, drainage channels, and sedimentation
basins. This plan apparently had the most impact on the East Flow,
essentially limiting it to high precipitation events only.
C. Geology
The Delta Quarries landfill is situated on the western edge
of the Appalachian Mountain Province. Figure 3 shows the relevant
geological formations for the area. The Appalachians are a series
of thrust-faulted sedimentary wedges originating in the
Carboniferous age.
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TABLE I
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The landfill is situated along a central anticline running
north and south. The core of this anticline is comprised of the
Tonoloway formation, a Silurian age formation composed of medium
gray, thinly bedded to massive limestone. It is believed that the
Tonoloway limestone underlies the entire Site to great depths.
The Tonoloway is bounded on either side by synclinal
structures composed of limestone. The upper section is interbedded
with shale, and the basal section contains nodular and cherty
limestone. The Old Port formation is composed of an upper member,
Ridgely sandstone, and a lower member, Shriver shale. The Ridgeley
sandstone is a fine-grained sandstone with silty siltstone. The
Shriver shale is a massive calcareous dark gray shale.
D. Hydrogeology
The Site is located in an area of significant topographical
relief, with small isolated ponds and wetland areas. Precipitation
is the primary source of ground water recharge in the region and
the topography indicates that the landfill could be a major
potential ground water recharge area, however the soil cap
installed in 1987 limits this recharge. The presence of the
wetland area west of the Site is a' potential ground water
discharge, as is the Little Juniata River.
The Site subsurface is generally composed of a minimum four-
foot-thick clay loam over a natural sandy loam to loam material
ranging from several feet to 20 feet thick. Beneath the loam lies
fractured bed rock including limestone, shale, sandstone, and
siltstone. While the bed rock types generally have low porosity,
the extensive joints and bedding planes can increase secondary
porosities to greater than 20 percent.
The depth to static water level ranges from several feet in
the northeast to over 100 feet in the majority of the landfill
area. Thus, the ground water flow is predominantly in the bedrock.
Piezometric and pump test data indicate that the aquifer behaves
as a single unconfined unit.
Historical water level data from 1980 is provided in Table
1. Wells located in topographic highs indicate water level
fluctuation on the order of 10 to 20 feet, while those wells in
the low-lying western syncline show fluctuations of only a few
feet. The larger fluctuations are in areas where the ground water
table is approximately 100 feet below the surface. The piezometric
surface generally follows the topography sloping northwesterly
toward the Little Juniata River. There is a substantial change in
the ground water gradient corresponding to the abrupt topographic
transition from steep hillsides to a floodplain just west of the
site. Using August 26, 1989 data, the gradient changes from an
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average of 0.057 under the landfill to 0.020 west of the site.
This is due to differing geologic materials in these areas.
There is a slight ground water divide located off the
northeast section of the landfill, corresponding to a sloping
topographical transition to the east. Both surface and shallow
ground water flow in this area drain northeast to Sandy Run. While
the location of this divide changes with ground water fluctuations,
it does not appear that any infiltrations from the landfill would
flow eastward. Given that the ground water elevations in this area
are near the surface, this ground water movement is considered a
local flow phenomena.
E. Nature and Extent, of Contamination
Site Characterization
The nature and extent of chemical contamination within the
Delta Quarries study area was characterized through extensive
sampling of surface soils, ground water monitoring wells,
residential drinking water wells, surface water, and sediments.
Samples were analyzed for U.S. EPA's Target Compound List (TCL)
and Target Analyte List (TAL) constituents. For the organic
analyses this also included searches for non-target compounds.
The data with required sampling and analysis procedures underwent
a rigorous quality assurance review to ensure compliance, validity,
and usability of the results.
All analytical data obtained in the course of the remedial
investigation were compiled, sorted by environmental medium,
evaluated with respect to analytical qualifiers (including sample-
specific minimum quantitation limits), analyzed statistically to
generate upper 95 percent confidence limits of the average
concentrations for each chemical in each medium; and examined in
comparison to naturally occurring background levels in accordance
with U. S. EPA's guidelines. Environmental media evaluated
individually include surface water, sediments, surface soils, and
ground water. Ground water represented by downgradient monitoring
well samples was evaluated separately from ground water at
downgradient residential wells. Air samples were not extensively
collected because this medium was not regarded as a significant
pathway of exposure at the Site. This conclusion is based on the
absence of significant level of volatile organics or other
contaminants found in surface soils, and the landfill cover four
feet in depth. Soil gas monitoring was done on-site using an
organic vapor analyzer. This investigation found concentrations
of hydrocarbons, mostly methane, typical for a landfill. The
levels of methane found did not pose any explosive threat.
Ground Water Contamination
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Tables 2 through 5 present a summary of the sampling and
analyses for the groundwater medium. . Figure 4 shows the
approximate locations of the contaminant ground water and relevan;
concentrations based on the sampling work.
Mo point sources or "hot spots" of contamination were
identified as a result of the RI and previous sampling surveys.
Contamination at levels of potential human health concern appears
to be limited to the occurrence of volatile organic chemicals in
ground water as reflected by samples collected from monitoring
wells, situated around the boundary of the former landfill area.
The results of the RI survey of all residential wells in proximity
to the former landfill indicated that no organic compounds were
reliably detected in any residential well samples.
The following compounds which include organic and inorganic
compounds were found in the ground water samples at detectable
levels: acetone, chlorobenzene, chloroethane, chloroform, 1,1-
dichloroethane, 1,2-dichloroethene, 1,2-dichloroethane,
trichloroethene ("TCE"),1,1,1, trichloroethane tetrachloroethane,
tetrachlorethene ("PCE"), toluene, vinyl chloride, barium,
manganese, nickel, and zinc. Of these, the contaminants of primary
concern (i.e.. those contaminants that may pose a chronic health
affect, are vinyl chloride, 1,1-dichloroethane, 1,2-
dichloroethene, chloroform) 1,2-dichloroethene, chloroform, 1,2-
dichloroethane, TCE, PCE, and manganese.
Surficial Soils Contamination
Soil samples were taken and analyzed within the vicinity of
and on the Site. The following compounds were found at detectable
levels at the Site. 1,1-dichloroethane, 1,2-dichloroethene, 1,2-
dichloroethane, TCE, toluene, barium, cadmium, chromium, copper,
lead, mangenese, nickel, and zinc.
Soil sampling points are shown on Figure 5. Sample results
are shown on Table 6. In addition to soil samples a soil gas
survey was undertaken at the Site. High levels of hydrocarbons
were found in sporadic locations up to 1000 ppm, however, when
analyzed with a portable gas chromatograph, it was determined that
the majority of the gas was methane which is a natural by-product
of municipal/and fill degradation and in this case would not be
considered to be a hazardous substance. It was also determined
that as one moves further away from the landfill the concentrations
drop off rapidly.
Surface Water and Sediment Contamination
Surface water and sediment samples from the adjacent wetlands,
Sandy Run Creek and the Little Juniata River were taken and
analyzed.
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% •* ••l«t ••»» I
ICl . OMI NIICU MU IUIIO
-------
TAHI.K J
U Wtll »»om,AM*: AMAltkU UAIA *IJUUA*«
O(ilA OUAJMMft AMU (MkS>U»Ai/»IOIU«
4AMTUO AUUU4I MSItMMft I»M
COMTO4M0 IMflT MOMIOMMQ WtU lOCAItUM
AmIV t M • aj t at »H»^ IOA 44 MM u M j»»4 MM UM
41 a 41 lift II • lift
• 4
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• « !»•!»• 10
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10 »»• ftO
4» •>• II II* 111 14 »•• 111
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|«) I»OOO IftAOA 1MOA I»OOO IIM 1I*O I4IOO >»K» k»IO ll*tX> llkO Jt>*o JttuO
)• UNI 1IM 4 I 44 M 4*r*a ftl 1*4 4k 14
• «• okift okia oik* o*j« uu* i
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44 1IM« 1K»» *4*04
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ioa 14*00 Mia 11400 14100 4410 »o*o IMOOO % IIMB i»«o4 iiu> u*> uioa
a i
44 14 44
aa u 11 11 11 14 u j
at
MO It I All MftUllk MftMUOMH*«
1 All*. ..!•..« WM)C»MK««4<. m.»lll •««• H^ »>• »M« ».i»».r» IM UN>< IMIILIi AM lliHO AHOWt
1 tt *>•. •»• i«*i.i«« ^i^l.»..M» •ni>irt.»^»«. t.«*< «»IM. t
4 U i^ti«i * t' mil •<*• y i>nlil«>i»o !• **^y ^n^n>^n«i«
k On^tiai "H' MMk^at** w«M«*«M* l**«4M
-D
08
3D 3D
-------
TABLE J
64MMJNO WAIMMUMICMUMG (Mil MUMGAMC ANAI VMS UAIA &UMMAMV
(Mil* OUAJMMi AMD OarOkAiAIOIU
iOMMIO AAJ6USI tmt*4M« ISM
COMPOUND
DCTECflOM
UMflT
MOMITOaiMQ WtU tOCAIIOM
tU*JMl
MCI*
IAt
l»tt
? t
it
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»*f
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MM
II M
104*
MM**
A 4
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10
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Mil M«
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1*20
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ta
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12*0
141
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lit
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lAi UMV1MUCIS AM llillO AHOVt
in ---- ' " *"^* --•*"• *-*• "-- *•- —••-«• • --- •
o8
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ii
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TAHI.E 4
MIIMMIIM Mill CttMIC MM I tit Ml* UMM4I
Mil* «MMIIt MB •IVMM/tlMlta IMMIU
II
IIIM«IIM Mil IfltAllOB
MM Ml
maer
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MliCIU
MIICIM
T3
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oo
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i. All fe«l«MMi«l M»ll 6r<
I. •
4. •
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0
OO
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^d
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CM>4M4) tHtf
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teUhei 44 MM ISM
Otfealiei 1.4
t*k*4l 4 t
t*w*r 1.4 M U
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leed .4 4.1V 4 4.S4 0
leJweMee .4 SI 44
M*rl 41
TABLE 3
MtlMIIIM Milt IMOMMIIC MMIItlt Ml* UJMMI
4UU •*VMU* M* •IWVMl/lllMII* IMM 111
tMVtt* «MMI IM*
ICflM IMM^I
HMt
4(«M|M)M Mil I4UIII41 4q
MgriH^ |4yM •»•• M««l«r JM*> tl»4l«« 4. Mrlcft 4. Mr It* (4««i» *nlr
•II 4««i*MUI w«il
•uctille* ••- lndii
•u*lili*i "'" II«*K»I«»
MX »»lri«J IM I'M lull inM»wi<« IM OMI MllClt Ml I lilt*
M«|Mtl «>U«>.
it only •i^MtwiA*
-------
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oo
2 33
oo
TAtil.t
Mil*
Mill l«»tMU MlUltIV Ml*
kMUt M* •IVUfcM/IIIMIt*
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4
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08
OO
TABl.t 5
MtlMHIIM Mitt IflOMMMC
Mil* «UMNIIt «•>
llIt Ml*
MMCIMH
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• .4
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44)
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4.f
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tt • n •
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U
linn HIM
4
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U* M • 4* • II*
M M Sll 4M
UJM. I4MM MMM ..MM
I.* II II
»
nn UM
MlM MJM MM* HIM
IIM IIM
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lata*B» «. »a4a 1. alllllav
IMa4 flllar Ia4al Illlw la««4 'HIM
U • 4» • M • 4ff t I* •
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4.M. 4MM ^ »M. M.M I..M.
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«. •ucltlxf *•* injii*!** ^jal 11 *i i ••! r •«»«*" '«»""». "^«*»»» atlxlnl HI luld «««!/»>< lab blank* •> •<•'!•< !••«!
% Qualllifl MJ" n«l*4«l«
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H
FIGURE 4 GROUND WATER CONT^_VNATION CONCENTRATIONS
-------
3
5 SOU. SAMIM.1NC POINTS
* •/
53=' - *
i
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TAlil.E 6
14MMI W>ll iMMJMIt fcW* I tit •*•»
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• IM*«A I* w»ly «f*Mw«i*«l«
Is., ul lull." l»4*
-------
TABLE 6
Umittt Mil UBUMK MM I til Ml*
Mil* •UIMIII «• • I1MUM/IIMIII
•tMHI IM*
I
III
IItCIt
I l«Uklian
M I
M 4
t« I
||
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4 •
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4 i
it •
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M •
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•
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it •
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41
41
M
t I
IM
IM
IM
IM
IM
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IM
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MlltlU
TJ
o
oo
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00
Ml
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Il MNBII* I*
M« Mil
>«< '•< >*• lull M|
••• IM^IOK* wrac
i«»» i*
llaM* t**u4l*
IMll Mllilt MM lltll* MM*
-------
TAIil.K /
•JfUMJ Mill! II
MiU *UM*UI I
bi lilt Ml*
I/IM4II* IMMIII
•* I
M I
Illlv |M*4
•M I
1*4*1 IIIIM 1*4*1 IIIK
•M * «U I
III.** 1*1*1 III.M I.I.
4 •
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4 •
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Ml Ml M • i
U* t M* « IM 1 M* 4 If* I «•» 4 IM J IM t II* » W* i IM I /•• 4 4k* I IM I
til 141 I I « l*< I 4 » • » J
•M* VM* MM *VM MM MM IJM* KM* IIM* IIM* ItIM HIM I«IM KIM
M*« M*< M • < *••< M • i M « < IMi I««J M*4 IMi l**l ••<
• I
•••••I
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IIM !«*• Ur» ||
rm /n»
1 •
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I Ml «xl«* «^« ••
IM WHf MII1U Mt Hill*
o
00
:D 33
OO
-------
MlU
TABLE 7
in ••UHMC MM nit MI*
MUt M» •IMMI/»MMUI I
t •
^
•»
.1.1 Ifl4*l««
Ml ml f» 1 fk»4 Wt M« Ml •<• M U Wit MM IIIIWMI UirWMBi
,.
1 • IN • 11 • i* •
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n
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n
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M 11(11 Ml HIM*
l«l l« ll«l« •<«« !
olailw I.— I
08
oo
d
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TAHI.K ;
MM** IMBUMK MM Mil MI4
MtU *UM*.M4 Hm • !•»•*«/ SIM It* l
MkMltM
I*L*IMB
M • M II M II ft* U M 11 MM
llll«f l»4»4 HUM l*«>4 IIIIW l«4»4 HUM 1*4.1 Illl*. l*0l llll*l I.Ill
M MM
«• » 4 • 41*
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UM««|I» M M M M M
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t*W * • I • « I • J » I « II, 111 « t i M
• i>.ii>«^ M 44IM 4MM MM IM» «M* »4\M 4M* tVM MJM 4M M
• ma ..... M MM « UM « N» < M>4 M*J It • * M«4
•wttay • t 4 • /
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r^*Ml>« M 4UM MM* Ml* IU« tM »M tM •»• HIM UM*
4 •
1 • /t* 41 It !•• . II*
llm M M«« M • J M V* • j M • 4 4**J M*4 M*i I**J * • i /••< «• •
•Ull I *tl MiUlt MM* II* !• k«/l
«M>« •n«l>l«d IIM IIM lu«l i»~»«^n» IM !•• t MIKII MM Illll* MMWI
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o
oo
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oo
-------
TABLE 7
UIIMII IWMJMU MM lilt Ml*
Mil* ••••III •• »ll»g»«l /H«4»ll I
t*»
• MCIM*
IM4I
4«
• 4
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TAHI.K 1
— f auuitll Ml*
MJ I Mf « MJf tot t Hf I fMf *» »
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-------
Some organic compounds were detected in surface water samples
and sediment samples from the western wetlands at low
concentrations (6 ppb to 190 ppb in water, 12 ppb to 48 ppb in
sediment). Organic compounds were not detected at the outlet of
the western wetlands where the western wetlands flow into the
Little Juniata River in either water or sediment samples.
Six organic compounds were detected in surface water samples
from the western wetlands (1,1-dichloroethene, 1,1 dichloroethane,
1,2-dichloroethene, 1,1,1-trichloroethane, trichloroethene, and
tetrachloroethene). All concentrations were more than 10 times
lower than the Fresh Water Acute Water Quality Criteria for aquatic
life (25 Pa. Code §16.51. Table 1) of the six compounds detected,
only tetrachloroethene has a chronic limit established (840 ppb) .
The concentrations of tetrachloroethene measured (range 7 ppb to
20 ppb) are well below the chronic limit for tetrachloroethene.
Sample results are shown in Table 7.
IV. Summary of Site Risks
A. Human Health Effects of Site Contamination
A Baseline Public Health Evaluation and a risk assessment were
conducted to estimate the human health and environmental problems
that could result if no further response action is taken at the
Site. Contaminants of concern were selected and associated risks
calculated for the different media and potential exposure routes
at the Site.
The following compounds were selected as contaminants of
concern because of their presence in the contaminated media at the
Site and because of their potential chronic health affects: vinyl
chloride, 1,1-dichloroethane, 1,2-dichloroethene, chloroform, 1,2-
dichloroethane, TCE, tetrachloroethene and manganese.
Although not identified as a contaminant of concern as part
of the evaluation, nickel was found in the ground water at levels
above the proposed health-based maximum concentration level (MCL)
of 100 ppb.
Exposure Analysis
Exposure pathways considered for the purpose of evaluating
site risks include: (1) incidental ingestion and dermal absorption
from direct contact with contaminated surface soils, surface
waters, and sediments; (2) future consumption of contaminated
ground water which may be utilized as a potable supply; and (3)
future inhalation of vapor phase chemicals from daily showering
-------
with potentially contaminated household water. Other potential"
pathways of exposure such as inhalation of dusts and uptake oj
contaminants into garden vegetables were judged to be insignificant.
relative to exposures resulting from direct contact with
contaminated soils.
The next step in the exposure analysis process involved
quantification of the magnitude, frequency, and duration for the
populations and exposure pathways selected for evaluation.
Generally, exposure point concentrations of chemicals were based
not upon the arithmetic average concentrations of chemicals in a
particular medium, but rather upon the 95 percent upper confidence
limit of the average, so as to produce an estimate of the
reasonable maximum exposure. Intake factors (e.g., amount of soil
ingestion, rate of derraal contact, exposure frequency, and
duration) were selected in accordance with EPA risk assessment
guidance so that the combination of all variables conservatively
results in the maximum exposure that can reasonably be expected to
occur at a site. The assumptions used to estimate the projected
human intake factors are set forth in Table 8.
Toxicity and Risk Characterization
Projected intakes for each risk scenario and each chemical
were then compared to acceptable intake levels for carcinogenic
and noncarcinogenic effects. With respect to projected intake
levels for noncarcinogenic compounds, a comparison was made to risk
reference doses (RfDs) . RfDs have been developed by EPA for
chronic (e.g. lifetime) and/or subchronic (less than lifetime
exposure) to chemicals based on an estimate that is likely to be
without an appreciable risk of deleterious effects. The chronic
RfD for a chemical is an estimate of a lifetime daily exposure
level for the human population, including sensitive subpopulations,
that is likely to be without an appreciable risk of deleterious
effects. The potential for non-cancer health effects is evaluated
by comparing an exposure level over a specified time period with
the RfD derived by the EPA for a similar exposure period. This
ratio of exposure to toxicity is called the hazard quotient.
The non-cancer hazard quotient assumes that there is a
threshold level of exposure (i.e., RfD) below which it is unlikely
for even the most sensitive populations to experience adverse
health effects. If the exposure level exceeds the threshold (i.e..
the hazard quotient exceeds a value greater than 1.0) there may be
concern for potential non-cancer effects. The more the value of
the hazard quotient or hazard index exceeds one, the greater the
level of concern for potential health impacts.
To assess the overall potential for non-cancer effects posed
by multiple chemicals, a hazard index (HI) is derived by summing
the individual hazard quotients. This approach assumes additivity
of critical effects of multiple chemicals. This is appropriate
10
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only for compounds that induce the same effect by the same
mechanism of action. EPA considers any Hazard Index exceeding one
to be an unacceptable risk to human health.
For carcinogens, risks are estimated as the incremental
probability of an individual developing cancer over a lifetime as
a result of exposure to a potential human carcinogen. The EPA's
Carcinogen Assessment Group has developed carcinogen potency
factors (CPFs) for suspected and known human carcinogens which are
used to convert daily intakes averaged over a lifetime of exposure
directly to incremental risk. The CPF is generally expressed in
units of risk per milligram chemical per kilogram body weight per
day of exposure (i.e., risk units per mg/kg/day) . The CPF or slope
factor is the upper 95th percentile upper confidence limit of the
extrapolation (slope) from high-dosed animal data to very much
lower doses in humans. The use of the upper limit produces a risk
estimate that has a 95 percent probability of exceeding the actual
risk, which may actually be zero. For exposures to multiple
carcinogens the upper limits of cancer risk are summed to derive
a total cancer risk. Cancer risks beyond the generally acceptable
risk range of 1 x 10"4 to 1 x 10"6 are considered an unacceptable
risk to human health.
Ground Water Risks
Tables 9 and 10 present a summary of the hazard indices and
upper-bound lifetime cancer risks resulting from exposure to the
chemicals of potential concern in ground water via ingestion and
inhalation, respectively. As these tables indicate, the potential
risk associated with exposure to ground water (through ingestion
and inhalation of vapor phase chemicals during showering) is 0.8
based on the hazard index and therefore is acceptable. As
described below, the carginogenic risk which is driven by the
potential future use of ground water drawn from the aquifer is
beyond 1.0 x 10'4 and therefore unacceptable.
The cancer risk to persons currently living in the vicinity
of the site is within the acceptable risk range. As noted
earlier, no existing residential wells have evidenced any
indication of Site-related contamination. Indeed, all but a few
of the home wells situated around the site are upgradient of the
entire former fill area. Estimates of the current risk to nearby
residents based upon analysis of home well samples are less than
1 x 10-6 .
Alternately, transport modeling was used to predict
contaminant concentrations downgradient of specific monitoring
wells within the study area which revealed the greatest
contamination. This analysis predicts the exposure that existing
residents may face as the contaminated ground water migrates to
their wells.
11
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TA3LE 9
SO1MAAY OF HAZARD INDICES AND CA.NCZR REX ESTIMATES TOR THE INHALATION OF VAPOR P
CHEMICALS VTA DAILY SHOWERING FOJl FLTtRS RESIDENTS AT THE
DELTA QUARRIES AND DISPOSAL, STOTLER LANDFILL IN ALTOONA, ?A
Cuaais j
COM VniiinM _ C?p«r»a«ua4 VUsnuai Awtif* CiaewXi.
DOM l
Cilona. 0.010 3.6 x Iff* 5 x iff* • 7.2 x iff4 Z.35 x iff' i.5 x 1Q- .1.4 x :;
l.iOicalorowtao* 0.022 7.5 x Iff* 1.0 x Iff* (i) 7.6 x 10° ND
lew 0.065 1.1 x iff4 2.3 x iff1 (o) 5-5 x Iff1 NA NA
Qlorotorm 0.012 2.1 x Iff* 1.0 x Iff* (o) 2.1 x iff* 3.1 x Iff* (i) 1.3 x Iff4 1.5 x iff
1.2-DicalonxrtfamM 0.005 9.1 x iff4 0.19 (of 4.3 x iff* 9.1 x iff4 (I) 7.3 x iff1 7.1 x iO-
0.031 5.4 x Iff- 7.4 x Iff* (o/ 7.3 x Iff* 1.7 x Iff* (if 4.6 x Iff* 7.3 x iff-
O.OG6 1.1 x iff* 1.0 X lff*(o) 1.1 x Iff* 1.3 x lff*(i) 3.7 x Iff* 1.6 x 10"
1.767* 0 NA 0 .VA
Tooi 2 x iff4
t&t fhf*oift iahalaaoii R/D or ifl.^^ft>'nfli CPF *t* baaad oa orai *r)"7itTifflTri (nvift) ia toiaaJs, ia ibtorpcon f fcr «Aiorn
-------
TABLE 10 SUMMARY OF IUZARD INDICES AND CArtCKR RISK ESTIMATES
IX)R TUB INGESTION OF COMPOUNDS OF CONCERN IN DOWNCRAD1KNT MONITORING WELLS
FOR FUTURE RESIDENTS AT THE DELTA QUARRIES AND D1SPOSAL/STOTLER LANDFILL IN ALTOONA, PA
Chemical of Concern
Vinyl Chloride
1,1-Dtchloiuethane
1.2 DicfaJaroetheae
Chloroform
1,2-Dicblofoetliane
IVichloroetlieBA
rctracbloroctbon
kfangaaese
Upper 95 Percent
MoBilofinftWelli
(ns/f)
0.010
0.022
0.065
0.012
0.005
0.031
0.006
1.767-
Reasonable
Maxinum
Chronic Daily
Intake Chronic Oral Rfl) Hazard Uj>per-Bound Oral
(mf /kf /day) (mf/lcg/day) Quotient CPH (ing/kg/day) '
2.2 X IO4 1.3 X 10 » 0.169 1.9
4.7 x IO4 IX 10' 0.005 ND
1.4 x 10' 2.0 x I01 0.07 NA
2.6 x 10* 1.0 x 10 2 0.026 6.1 X 10»
1.1 X IO4 0.19 0.001 9.1 X 101
6.7 x IO4 7.4 x 10' 0.091 I.I x |02
1.3 X IO4 1.0 X * 0.013 5.1 X I02
3.8 X IO1 O.I X 10' 0.38 NA
Total 0.8
Reasonable Upper-Bound
Maximum Aveiago Cancer Ribk
Lifbtiroe Daily Intake Adjusted foi 31
(n^g/kg/day) Year Expo«u«.
9.5 X 10* 1.8 X IO4
,
NA
1.1 X IO4 6.7 X 10'
4.9 x 10s 4.5 X 10*
2.9 X IO4 3.2 x 10*
5.4 X IOJ 2.8 X 10*
NA
2 X 10*
Based oa filtered resulta only.
Group C carcinogen: only limited and equivocal evidence of carcinogenicily in animals and no evidence in bumans.
"D
O
OO
OO
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Based on the ground water gradient and transport model, the
only wells that could potentially exhibit elevated* concentrations
of VOCs in ground water are the existing ones downgradient of
Monitoring Well 6-85, which revealed 1,1-dichloroethene at 15
micrograms per liter (?pb) and chloroform at 39 ppb. The total
upper-bound cancer risk for household use of this water is
estimated to be about 1 x 10-5 , assuming concentrations of these
suspected human carcinogens remain constant in water used as a
household supply over several decades. However, according to the
EPA guidelines, even though no vinyl chloride was detected in this
monitoring well sample, at least one-half the sample method
detection limit of 1.3 ppb must be assumed as present. Under an
assumption of steady-state conditions (i.e.. the concentration
remains constant over time and the center plume eventually migrates
to the receptor point) , and further assuming a concentration of
10.4 ppb of vinyl chloride was present in household water, the
theoretical upper limit of risk would correspond to an upper limit
of about 2.0 X 10"5 risk of cancer.
The estimates of potential future risk are based on the
assumption that future residents may someday be located directly
downgradient of the fill area at the site boundary. Exposure point
concentrations were determined, in accordance with EPA's recent
Human Health Evaluation guideline (EPA, 1989) , by calculating the
95th percentile confidence limit on the current average
concentrations in monitoring wells and conservatively assuming
steady-state conditions. The 95 percentile upper confidence limit
represents a 95 percent probability that the average concentrations
are less than the upper limit calculated. Where chemicals detected
at least once in ground water were not detected in other samples,
a concentration equivalent to one-half the method detection limit
was assumed for the chemical in that sample, in accordance with the
EPA Human Health Evaluation guidelines (EPA, 1989). Calculations
of those exposure concentratons include monitoring Well 10A-88
which is the only well sampled during the Remedial Investigation
which revealed detectable levels of vinyl chloride. This well was
subsequently resampled. No vinyl chloride was detected during the
additional sampling. However, concentrations of TCE and PCE which
are precursors to vinyl chloride formation were found at levels
exeeding their respective MCLs. In addition, vinyl chloride was
found previously twice in another well prior to the Remedial
Investigation. Therefore the vinyl chloride was still considered
in the risk analysis.
For potential future conditions, Table 11 presents a summary
of the combined upper bound cancer risks and hazard indices
utilizing the upper 95 percentile confidence limits of the mean
concentrations in all downgradient wells of the compounds of
concern to future residents downgradient of the former landfill.
As shown in the table, the combined cancer risk for future
residents at the Site is 3.0 x 10-4 which exceeds the CERCLA
acceptable.'range of 1.0 x 10-6 to 1.0 x 10-4 . (This risk value
12
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TABLE 11
SUMMARY OF COMBINED GANGES RISKS AND HAZARD INDICES
-FOR FUTURE RESIDENTS AT THE
DELTA QUARRIES AND DISPOSAL/STOTLER LANDFILL IN ALTOONA, PA
Upper 95 Parent
of the M«
Applictbla
of Coacfirn
Vinyl Chloride
w*»~+.
Ci/oro/onn
!,2-DtciiJoro«a*w
Tetncoloroetheae
MtafBieH
Dowagndiacu
Mceuoriaf
WfliLi (u»/L)
10.3S
• 22.07
» .. . 65.24
12.21
» 5.31
31.31
5.39
1767.3d»
Water Criteria
Public \V«xer
Su&viitiii fuz/L)
2
70-100
(100)
5
5
5
AllAR
MCL
PropcjedMCL
NIPDWR'
MCL
MO.
Proposed MCL
Combined Upper
Lumt of
< (B2)
1.1 x iff' (peadiafj
3 x 10* (peodiaf)
VA
Total
0.241
0.013
0.125
0.047
0.001
0AM
0.024
TottJ
3 x
0.995
Zntunn Pdoavy DriaJanf Watar B«folaiiaai.
Thi« 017 ao< quaii/y u aa AJtAX for caloro/brm pr»«ni ia nw
Fflterod muJa only.
POOR QUALITY
ORIGINAL
-------
shown represents a change from the risk value previously listed in
the proposed plan. This change occurred as the result of"
recalculation of the risJc based on revised EPA risk assessment
guidance.) Also included in this table are some of the
preliminarily identified Applicable or Relevant and Appropriate
Requirements (ARARs), where available, for these compounds of
concern in ground water. MCLs are enforceable standards
promulgated under the Safe Drinking Water Act and are designed for
the protection of public health. MCLs represent chemical-specific
ARARs and provide the basis for defining preliminary remediation
goals. The 95th percentile upper confidence limits of some of the
compounds of concern exceed the MCL.
Surface Water and Sediment Risks
Based on the results of the sampling and analysis of the
surface water and sediment, there is no apparent current risk to
the human health or the environment, caused by any contaminant
migrating from the Site into the adjacent wetlands, Sandy Run Creek
or the Little Juniata River.
Surficial Soil Risks
Due to the existing 4 foot soil cap placed over the landfill,
no risk to human health or the environment is currently present nor
should any future risk occur as long as the cap integrity is
maintained.
Accordingly, the potentially carcinogenic chemicals found in
ground water represent the compounds of major potential concern,
and the future use of the affected ground water poses the only
unacceptable risk of interest at the Site.
B. Environmental Impact of Site Contamination
The ecological investigation of the Site consisted of a
wetlands delineation and an aquatic and terrestrial life study.
A summary of the investigation results are presented below. The
complete investigation reports for both the wetlands delineation
and the aquatic and terrestrial life study were submitted as a
separate report in March 1990.
Wetlands Investigation
Two wetland areas adjacent to the Site were delineated as
shown in Figure 6. The wetlands surveyed encompassed a total of
8.7 acres of which 8 acres is situated on the southwestern edge of
the landfill and .7 acre is situated on the northeastern edge of
the landfill. The survey included a determination of the
transition lines between wetland and upland vegetation with
13
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VV Junil^iafiSS
*OU»TC. UHNISlHtAt I
AM) Wl HANDS SIUIH
liHIA CH1AHH1*'-. AMD OtSPOSAt/
SIOIUN (AHi»*\
HI AIM LOUNfr. PINNSYIVANIA
-------
emphasis on that portion of the wetlands vegetation dominated by
emergent aquatic vegetation.
Surface Water and Sediment Impacts
The surface water and sediment data review concluded that
there was no observable negative impact from the western wetland
outflow on the surface water quality of the Little Juniata River.
There was no indication that Sandy Run has been affected by any
chemical compounds emanating from the landfill via the East Flow.
The findings of the ecological study also indicate that there
may be other potential sources of contamination upgradient from the
City of Altoona Wastewater Treatment•Plant, as several VOCs were
detected in an upstream control point sample above the influence
of the landfill drainage and the treatment plant.
There are no special or endangered species at the Site or in
the area of the Little Juniata or Sandy Run Creek drainage basin.
There is no evidence of impacts to biota in either tributary from
activities at the landfill.
C. Conclusion
Actual or threatened releases of hazardous substances froir
this Site, if not addressed by implementing the response actio.
selected in the Record of Decision, may present an imminent and
substantial endangerment to the public health, welfare, or the
environment.
V. 8COPB AND ROLB 07 THIS REMEDIAL ACTION
The scope and role of this remedial action is to address the
principal threat at the landfill which is the contaminated ground
water. The source materials within the existing landfill are
considered to be a low-level threat due to the existing soil cap
which provides protection from direct contact or ingestion and also
minimizes infiltration of rainwater into the landfill which in turn
minimizes leachate generation which could further contaminate the
ground water. The installation of gas venting along with continued
cap maintenance will ensure that the cap will continue to function
as intended. The purpose of the groundwater remediation is to
return the groundwater to its full Leneficial use.
VI. COMMUNITY RELATIONS SUMMARY
In accordance with Sections 113 and 117 of CERCLA, 42 U.S.C.
Sections 9613 and 9617, EPA, in conjunction with the PADER, issued
a Proposed Plan to present the preferred remedial alternative. The
Proposed Plan and the RI/FS reports were made available to the
14
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public in the copies of the administrative record maintained at the
EPA Region III offices and at the information repository listed
below:
Altoona Public Library
1600 5th Avenue
Altoona, Pennsylvania 16602
EPA instituted a public comment period from February 15, 1991 to
March 17, 1991 for the purpose of soliciting public participation
in the decision process. As part of the public comment period, a
public meeting was held on March 4, 1991 to present information
and to accept oral and written comments and to answer questions
from the public regarding the Site and remedial alternatives. A
transcript of the meeting was maintained in accordance with Section
117(a)(2) of CERCLA, 42 U.S.C. Section 9617(a)(2). Responses to
the oral and written comments received during the public comment
period are included in the attached Responsiveness Summary.
An announcement of the public meeting, the comment period,
and the availability of the RI/FS reports was published in the
Altoona Mirror, on February 15, 1991.
All documents considered or relied upon in reaching the remedy
selection decisions contained in this Record of Decision are
included in the Administrative Record for this Site and can be
reviewed at the information repositories.
VII. DOCUMENTATION OP SIGNIFICANT CHANGES FROM PROPOSED PLAN
The Proposed Plan for the Site was released for comment in
February 1991. The Proposed Plan described the alternatives
studied in detail in the Feasibility Study and identified
Alternative E as the Preferred Alternative. 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 presented in
the Proposed Plan were necessary.
VIII. DESCRIPTION OF ALTERNATIVES
The objective of the Feasibility Study performed at this Site
was to identify alternatives to address contaminant source control
and contaminated ground water remediation. Contaminant source
control is expected to maintain the reduction in the rate of
release of contaminants into the aquifer achieved upon closure of
the landfill. Contaminated ground water remediation will minimize
potential exposure of ground water contaminants to the public and
the environment and make future well water supplies available.
15
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CERCLA requires that the remedial alternative for a site be
protective of human health and the environment, cost effective,
and in accordance with statutory requirements.
Permanent solutions to contamination are to be achieved
whenever possible. In addition, emphasis is placed on treating
wastes on-site, wherever possible, to reduce the toxicity,
mobility, or volume of Site related contaminants, and on applying
alternative or innovative treatment technologies.
Potential technologies for implementation of these objectives
were evaluated to determine whether the technologies could meet
health-based and other environmental standards including applicable
or relevant and appropriate requirements of Federal and State law.
These technologies were also evaluated against operational,
institutional, cost and other factors affecting implementation.
The technologies evaluated in the Feasibility Study were combined
into remedial alternatives to address the Site.
The alternatives evaluated in the FS Report are summarized
below. The estimated costs reported for implementing each
alternative represent both the preliminary estimates of initial
capital outlay and the estimates of continuing operation and
maintenance. Costs are reported as present worth figure calculated
with a' discount rate of 10%. Costs of the alternatives are
compared in Table 12.
ALTERNATIVE A: NO ACTION
This alternative is included in the FS Report for comparison
with the other alternatives under investigation. It would only be
selected if the Site posed little or no risk to the public health
or the environment. Under this alternative, no additional measures
would be undertaken to remedy contaminant sources or their
migration pathways, and risks from the Site would remain and could
potentially increase with time. Because hazardous substances
would remain on the Site, five year effectiveness reviews would be
conducted.
Except for the costs involved with the five year review, no
capital or operation and maintenance (O&M) costs would be incurred
for this alternative, and no time expended beyond the costs and
time presently expended to maintain the existing landfill cap and
ground water monitoring. The estimated cost for this alternative
is $109,672.
ALTERNATIVE Bt DEED AND ACCE88 RESTRICTIONS, MONITORING AND CAP
MAINTENANCE
As part of this measure the current owners of the land
comprising the Site would be restricted from any future actions
16
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which would disturb the landfill surface and wastes, including
construction of roads, underground utilities, or wells. Deed
restrictions recorded by the owners would provide notice to any
future property owners of potential hazards and likewise restrict
the use of the relevant property.
i
Access restrictions would offer a physical barrier for
inhibiting direct contact of humans and wildlife with the landfill
wastes. A six-foot high, high tensile-strength fence would be
installed around the perimeter of the landfill. The fence would
have locking gates to control entrance of construction vehicles
used for Site maintenance. If necessary, barbed wire along the
top of the fence would also be installed.
Long-term ground water and surface monitoring would
incorporate periodic sampling and analysis at pre-determined
locations which would adequately track migration of impacted
contaminated ground water and sediments and surface water within
the adjacent wetlands. The sampling parameters will be determined
during the Remedial Design.
Gas vents would be installed to ensure the integrity of the
existing cap to complete the approved landfill closure plan
requirements. The existing soil cap would be repaired where
necessary. This would include minor re-regrading and backfilling
of areas where substantial soil erosion has occurred and reseeding
of bare areas. The existing drainage and erosion control measures
would be repaired and upgraded. They include the existing benches,
diversion ditches, and riprapped downchutes. In addition, a new
diversion ditch along the western edge of the flat central area
would minimize the erosion over the steeper western slopes.
Assuming no unexpected sampling results are obtained during
the sampling and analysis program, the following wells would be
sampled at the following frequency, with the sampling parameters
determined during the Remedial Design.
o From the upgradient side of the landfill, wells (4-88
and 18-88) would be sampled semi-annually for years 1
through 3, annually for years 4 through 30;
o Downgradient wells (6-85, 8-85, 10A-88, 20-88, new well
23-88, and Mi-Lined), cross-gradient well M2-Area IV,
and the outfall from the western wetland would be sampled
semi-annually for years l through 3, then annually for
years 4 through 30.
o Surface water and sediment samples would be taken from
FAM spring and several points within the western
wetland.
17
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Semi-annual sampling would be performed at different seasons
from year to year in order to assess seasonal fluctuations in water"
quality. After five years, the sampling frequency, location, an'
parameters would be reviewed and, if appropriate, modified. Foi
cost-estimating purposes, it is assumed that the monitoring
frequency described above would be followed for 30 years.
Long-term monitoring of Site ground water would effectively
mitigate the only unacceptable risk associated with the site:
future ingestion of Site ground water (risk value of 3.0 x 10-"4 )
by allowing protective action to be taken if organic chemicals are
detected in monitoring wells .upgradient of residential wells.
Because hazardous substances would remain on Site, five year
effectiveness reviews would be conducted. The estimated cost for
this alternative is $750,134. This alternative could be
implemented within 6 months.
ALTERNATIVE Ct HOOK-OP DOWKGRADIBNT RESIDENCES TO PUBLIC WATER
SUPPLY SYSTEM, DOWNGRADIBNT WELL CLOSURE, DEED AND ACCESS
RESTRICTIONS. LIMITED MONITORING AND CAP MAINTENANCE.
This alternative is identical to Alternative B except that an
alternate water supply source to downgradient residents would be
provided by a connection to the public water supply system. This
alternative would provide the total water supply (drinking,
cooking, and washing) to downgradient receptors, and would provide
for closure of the downgradient residential wells. Monitoring would
be done but less extensively due to the public water supply. Deed
and access restrictions, periodic Site reviews, and cap maintenance
will be provided as described in Alternative B.
Hook-up of the five downgradient residents to the nearest
public water supply main would require the installation of
approximately 5,400 linear feet (LF) of a water main along Sixth
Avenue. Installation of an additional 100 LF of 2-inch water main
along Sixth Avenue, and installation of an additional 100 LF of 2-
inch header pipe would be required to connect each resident to the
new water main.
Well closure is the abandonment of currently existing wells.
Each of the five downgradient residential wells would be pressure
grouted with cement until the entire well casing is filled. The
estimated cost of this alternative is $1,085,403. This alternative
could be implemented within 12 months.
ALTERNATIVE D; MULTILAYER CAP, DEED AND ACCESS RESTRICTIONS.
MONITORING AND CAP MAINTENANCE
Alternative D includes a full containment alternative
consisting of a multilayer cap over the entire landfill area. Deed
and access,.-restrict ions, ground water and surface water monitoring,
18
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cap maintenance and periodic site reviews are also provided as
described in Alternative B. The multilayer cap is intended to
isolate the waste from rainwater infiltration. The specific
components of this alternative include the following:
o Stripping of the existing cap material and regrading to
provide a smooth subgrade to install a multilayer cap
and to achieve a surface grade adequate for surface water
drainage;
o Installation of a multilayer cap (meeting the current
performance standards of PADER solid waste regulations)
over approximately 57 acres to cover the entire waste
disposal area;
o Placement of a soil cover which will be vegetated with
grass;
o Implementation of surface water control features such as
diversion ditches and benches along steep slopes.
The multilayer cap would further minimize the infiltration of
precipitation through the landfill. The vegetated surface and
benched slope would effectively control soil erosion. This
alternative would not directly address the only unacceptable risk
associated with the Site: future ingestion of already contaminated
ground water. The estimated cost of this alternative is
$6,766,864. This alternative could be implemented in 18 months.
ALTERNATIVE E: GROUTTO WATER EXTRACTION AND TREATMENT VIA AIR
STRIPPING. DEED AMD ACCESS RESTRICTIONS, MONITORING & MAINTENANCE
OF CAP
Alternative E consists of ground water extraction and
treatment via air stripping, with effluent discharge to the Little
Juniata River. Ground water and surface water monitoring, deed and
access restrictions, cap maintenance including gas venting, and
periodic Site reviews as described in Alternative B also would be
implemented as part of this alternative.
Ground water would be pumped at a rate of approximately 80
gallons per minute (gpm) from 8 downgradient wells. Ground water
would then be treated via stripping in an on-site facility.
Expected influent concentrations were estimated from the
average measured concentrations from wells Mi-Lined, 10A-88, 6-
19
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35, and' 3-35. The measured concentrations from well M2-Area itf
were not included in the averaging process since this well is nr
downgradient from the landfill and does not reflect potentia
contamination from the landfill. The expected average
concentrations in the extracted ground water are as follows:
Vinyl Chloride 7.0 parts per billion (ppb)
Chloroethane 6.2 ppb
Acetone 32.0 ppb
1,1-Dichloroethane 19.6 ppb
1,2-Dichloroethene(total) 33.3 ppb
1,1,1-Trichloroethane 9.6 ppb
Trichlorcethene 12.0 ppb
Tetrachloroethene 12.0 ppb
Chlorobenzene 1.3 ppb
It is also expected that other contaminants identified in the
ground water will be present in the extracted ground water. As of
the date of this Record of Decision, the expected concentrations
of the other contaminants in the extracted ground water has not
been calculated.
Eighty gpm was calculated to be the required pumping rate to
intercept all ground water flowing across the western edge of the
landfill in the top 50 feet of ground water. The precise pumping
rate will be determined as a part of the remedial design. The
resulting drawdown at the proposed extraction wells would be
approximately 6.4 feet. The resulting drawdown at downgradient
residential wells would be approximately 3.7 feet. Ground water
would still flow in the general area toward the Little Juniata
River. At 80 gpm, the total mass of VOCs extracted from the ground
water would be approximately 0.14 pounds per day (0.33 pounds per
day if the highest concentration well alone were used). Air from
the stripping tower would pass through activated carbon canisters
to minimize the release of VOCs to the atmosphere. For purposes
of the air emissions controls design, the maximum concentration
from downgradient monitor wells of 340 ppb of total VOCs was used.
During the remedial design, fugitive emissions disperson modeling
will be done to determine the extent and assess the risks created
by any fugitive emissions from the air stripping operation. The
treatment effluent stream would meet the PADER National Pollutant
Discharge Elimination System Requirements (NPDES).
Based upon the average concentrations of iron and manganese
measured in the ground water, pretreatment equipment for the
removal of iron, manganese, and suspended solids was considered to
be unnecessary. Precipitation of iron and manganese in the air
stripping tower could be handled by routine maintenance of the
treatment equipment. Such maintenance has been considered in the
cost estimate associated with this alternative. Treatability tests
would be conducted to confirm this assumption. Pretreatment
equipment would be added if treatability tests indicated that such
20
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equipment would make the treatment equipment operate more
efficiently and economically. The sperit carbon from the
airstripping operation will either be destroyed or regenerated at
a RCRA approved facility. The sludges produced during operation
will be managed in accordance with State hazardous waste
requirements and Federal land disposal restrictions.
Based on current estimates, it is anticipated that the ground
water extraction and air stripping operation will take
approximately 4 1/2 years to effectively clean up the contaminated
ground water to the cleanup levels set forth in Section X below.
Operation and maintenance of the cap, and monitoring of the ground
and surface water will occur for a minimum of 30 years. As waste
will be left on site, 5 years reviews of the site will take place.
The estimated cost for this alternative is $2,333,549. However,
this treatment period will be reevaluated as it progresses and the
remediation period may be adjusted based on the field results.
This alternative could be implemented within 12 months.
ALTERNATIVE ?t EXCAVATION OP LANDFILL SOURCE MATERIAL
SOLIDIFICATION AND DISPOSAL OP INCINERATOR ASH ONSITB . MULTILAYER
CAP, DEED AND ACCESS RESTRICTIONS, MONITORING AND MAINTENANCE OF
CAP
This alternative involves the excavation and thermal
destruction of all landfill materials constituting sources of site
contamination. Based on the estimated 6,700 cubic yards of
industrial wastes reportedly placed in the landfill, it is assumed
that 10 times this volume (i.e., other wastes and soils impacted
by the source areas) would require incineration. Materials which
are excavated and do not require incineration will be stockpiled
separately for use as backfill on-site. Ground water and surface
water monitoring, deed and access restrictions, cap maintenance,
periodic site inspections and five-year reviews as described in
Alternative B also would be implemented as part of this
alternative.
This alternative would consist of the following remedial
actions:
o Site preparation for installation of a mobile
incinerator;
o Excavation of all landfill waste (approximately 2,700,000
cy) and segregation of approximately 67,000 cy of wastes
requiring incineration;
o Incineration of segregated wastes;
o Stabilization and proper disposal of incinerator
residuals on site.
21
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A mobile rotary kiln incinerator, rated at eight tons per
hour, would be used at the Site. The incinerator may require a
secondary combustion unit (afterburner) operated at temperature?
adequate to completely oxidize any products of incomplete
combustion (PICs) heaving the primary combustion unit. A test burn
would be required to determine the optimum incinerator operating
conditions, and to identify any specific emission control
requirements. Pollution control devices (i.e., scrubbers) would
be required to capture fly ash and acid gases prior to discharge
from the stack.
For purposes of cost estimation, it is assumed the
incinerator ash and other facility residuals (e.g. scrubber
sludges) will be hazardous waste under the Resource Conservation
and Recovery Act (RCRA). The cost estimates assume that the ash
must be disposed of and treated in accordance with PADER hazardous
waste regulations.
A final cover meeting the current state solid waste standards
would be placed over the stabilized materials and the entire
landfill area. The cover area would be vegetated to prevent
erosion of the topsoil. Post-closure maintenance and monitoring
would also be performed. The cost estimate for this alternative
is $72,603,397. This alternative would take 48 months to implement
and 120 -months of operation.
IX. COMPARATIVE ANALY3I3 OF ALTERNATIVES
Each of the six remedial alternatives has been evaluated with
respect to the nine evaluation criteria set forth in the NCP, 40
C.F.R. Section 300.430(e)(9). These nine criteria can be
categorized into three groups: threshold criteria, primary
balancing criteria, and modifying criteria.
Threshold Critaria
1. Overall Protection of Human Health and the Environment
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Primary Balancing Criteria
3. Reduction of Toxicity, Mobility, or Volume through
Treatment
4. Implementability
5. Short-term Effectiveness
6. Long-term Effectiveness
7. Cost
Modifying Criteria
8. Community Acceptance
22
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9. State Acceptance
These evaluation criteria relate directly to requirements in
Section 121 of CERCLA, 42 U.S.C. Section 9621, which measure the
overall feasibility and acceptability of the alternatives.
Threshold criteria must be satisfied in order for an alternative
to be eligible for selection. Primary balancing criteria are used
to evaluate the performance of each of the alternatives relative
to the others. State and community acceptance are the modifying
criteria formally taken into account after public comment is
received on the Proposed Plan. The evaluations are as follows:
1. Overall Protection of Human Health and the Environment
A primary requirement of CERCLA is that the selected remedial
alternative be protective of human health and the environment. A
remedy is protective if it reduces current and potential risks to
acceptable levels under the established risk range posed by each
exposure pathway at the Site.
Environmental risks were not evaluated for the alternatives
as no unacceptable risk to any environmental receptor was identifed
during the RI. However, implementation of any of the alternatives
would provide protection to the environment by their
implementation.
Alternative A does not reduce risk to human health from future
use of ground water, because it does not address the risk posed
through exposure to the contaminated ground water; therefore
Alternative A will not be evaluated any further.
Alternatives B through F provide protection of human health
in the sense that the monitoring of existing wells between the
possible receptors' wells and the known contaminated ground water
would likely warn possible receptors of potential exposure to
contaminants in the ground water prior to actual exposure. The
deed and access restrictions in Alternatives B through F would
protect any receptors from any possible direct contact with any
contaminants still in the landfill. Alternative C would provide
additional overall protection to human health by providing
alternate water supply. Alternative D would be protective of human
health by further marginally reducing any new contaminants from
entering the ground water from the landfill. Alternative E would
be further protective of human health by extracting and treating
the ground water to the clean up levels listed in Section X.
Alternative F would be protective of human health by removing the
source of contamination, although it would not directly reduce the
threat of exposure to already contaminated ground water.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
23
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Under Section 121(d) of CERCLA, 42 U.S.C. Section 9621(d),
and EPA guidance, remedial actions at CERCLA sites must attain
legally applicable or relevant and appropriate Federal and
promulgated State environmental standards, requirements, criteria
and limitations which are collectively referred to as "ARARs",
unless such ARARs may be waived under CERCLA Section 121(d)(4), 42
U.S.C. Section 9621(d)(4). Applicable requirements are those
substantive environmental standards, requirements, criteria, or
limitations promulgated under Federal or State law that are legally
applicable to the remedial action to be implemented at the Site.
Relevant and appropriate requirements are those substantive
environmental protection requirements, criteria, or limitations
promulgated under Federal or State law which, while not being
directly applicable to the remedial action, do address problems or
situations sufficiently similar to those encountered at the Site
such that their use is well suited to the Site. ARARs may relate
to the substances addressed by the remedial action (chemical-
specific) , to the location of the Site (location-specific), or to
the manner in which the remedial action is implemented (action-
specific) . There are no location-specific ARARs for this site.
Alternatives B, C, and D do not include ground water
remediation as- a component of the remedies; therefore no chemical-
specific ARARs for ground water clean up exist for these remedies.
Accordingly these alternatives would not meet the chemical specific
ARARs relating to ground water remediation and treatment. The
alternatives would meet all action-specific ARARs relating to the
actions required under the respective remedies.
Alternative E, which includes ground water remediation, would
meet the chemical-specific ARARs (as set forth in Section XI of
this ROD) relating to ground water remediation and treatment. In
addition, Alternative E would meet all action-specific ARARs
relating to activities performed as part of the remedy, including
RCRA treatment, storage and disposal requirements, NPDES discharge
and design requirements, and Federal and State emissions
requirements.
Alternative F, which does not include ground water remediation
and treatment, would meet all action-specific ARARs relating to the
remedy, including RCRA requirements regarding construction,
operation and closure of hazardous waste incinerators, disposal
requirements, and air emissions requirements.
3. Reduction of Toxicitv. Mobility, or Volume through Treatment
This evaluation criterion addresses the degree to which a
technology or remedial alternative reduces toxicity, mobility, or
volume of hazardous substances at the Site. Section 121(b) of
CERCLA, 42 U.S.C. Section 9621(b), establishes a preference for
remedial actions which include treatment that permanently and
24
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significantly reduces the toxicity, mobility, or volume as a
principal element over remedial actions which do not.
Alternatives B, C and D do not employ a treatment process and
therefore do not satisfy the CERCLA statutory preference for
treatment.
Alternatives E and F will result in the reduction of toxicity,
mobility and volume of Site contaminants through various means of
treatment. In Alternative E, the ground water treatment
technology, air stripping, provides reduction of ground water
toxicity and the reduction of the mass or volume of ground water
constituents, but does not directly reduce the source of
contamination. The compounds extracted during the air stripping
phase of Alternative E, are expected to be absorbed onto carbon
and later incinerated at an off-Site facility during regeneration
of the carbon or treated in a biodegradation process. Alternative
F will reduce the volume and toxicity of contaminated materials in
the landfill through incineration, but will not address the primary
risk at the site, the existing contaminated ground water.
4. Implementability
This evaluation criterion addresses the difficulties and
unknowns associated with implementing technologies, the ability
and time necessary to obtain required permits and approvals, the
availability of services and materials, and the reliability and
effectiveness of monitoring.
For all of the remedial alternatives, the ability to monitor
effectiveness of each remedy exists. Over 21 ground water
monitoring wells are currently installed at the Site and nearby.
For Alternatives E and F, ground water monitoring and the use of
the early warning wells will give notice of failure of the action
before significant risk of exposure for downgradient ground water
users can occur. For Alternative E, periodic sampling and analysis
of ground water treatment system discharges would allow monitoring
of ARAR compliance. For Alternatives E and F, continuous and
automated sampling and monitoring of stack emissions would give the
ability to monitor ARAR compliance for air emissions.
For Alternative B, the monitoring wells and fencing would be
easily built. The waterline in Alternative C can be built using
existing lines and would require minimal O&M. The new cap in
Alternative D would be more difficult to build but would require
little maintenance. The groundwater recovery and treatment
facilities for Alternative E would be relatively easy to construct
and operate. The ground water treatment system requires some
operator attention. In Alternative F, the construction of the
hazardous waste incinerator is considered to be moderately
difficult and excavation of the landfill is considered to be
difficult.
25
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In terras of the availability of services and capacities
Alternative 3 requires few services and its implementation will
not affect any commercially available capacities. For Alternatives
C and D, services and capacities needed for implementation are
readily available. In addition to those services needed for
implementation of Alternative B, Alternative E has the need for air
stripper construction and ground water extraction facilities and
Site operating services, which are available. For Alternative F,
most of the services relating to excavating and incineration are
readily available but will take time to procure.
For all of the alternatives, equipment, specialists and
materials are readily available. The specified technologies needed
are available for all of the remaining alternatives. Alternative
E requires ground water treatment pilot testing and Alternative F
requires incineration treatability studies.
5. Short-Tern Effectiveness
Short-term effectiveness addresses the period of time needed
to achieve protection of human health and the environment and any
adverse impacts that may be posed during the construction and
operation period of the remedial alternative until cleanup levels
are achieved.
Alternative B does not present any short-term risk to the
community; potential releases of contaminants to the air from the
installation and operation of methane vents can easily be
controlled. The alternative however, could present a long-term
cancer risk by exposure to and ingestion of ground water, if the
monitoring fails to detect the movement of the contamination.
Alternative C does not pose any short-term risks to the community
and would provide no risks to receptors using the alternate water
supply. Alternative D does not present any substantial risk to
the community as the new cap would be installed in small
increments-thus reducing any possible short-term exposure to any
wastes below the existing cap. In addition, protective measures
would be implemented during construction to ensure that no new
infiltration would occurs during the recapping. Alternative E does
not present short term risks to the community because potential
releases of contaminants to the air from the installation and
operation of the air stripper and methane vents can easily be
controlled.
Excavation of the landfill and operation of an on-Site
incinerator in Alternative F will present a short-term risk to the
community of releases to the air and surface water runoff during
the operating period.
26
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There would be no significant short term risk to workers
resulting from the implementation of Alternatives B, C or D. For
Alternative E, there would be minor risks to workers with respect
to activities involving extraction well installation, construction
of the ground water treatment facility, and other related
construction. There would be significantly increased risks for
workers at the Site in Alternative F resulting from excavation of
the landfill. A substantially increased risk of worker exposure
to methane gas releases, as well as the risk of explosions
associated from possible methane gas pockets within the landfill
with this activity would be expected.
For Alternatives B, C, D and E there are no significant
detrimental environmental impacts. All air emissions, surface
water discharge and disposal of residuals would be conducted in
compliance with ARA£s. For Alternative F there would be increased
local pollutant loadings to the atmosphere from the on-Site
incinerator but will be controlled to the greatest extent possible.
In Alternatives B at least 75 years is the estimate for
natural attenuation and dissemination of ground water contamination
to reach background levels. For Alternative C, design and
construction of the alternate water supply could be implemented
within 12 months, however it would still take 75 years for the
ground water to be cleaned through natural attenuation.
For Alternative D, design and construction would take
approximately 18 months to implement. The ground water ground
water would then be cleansed faster as any current migration of
contaminants from the landfill to the ground water would be further
reduced from what the existing cap now allows, however, this rate
would be only marginally faster then with the existing cap.
Alternative E could be implemented within 12 months, however, the
actual extraction and operation is estimated to take approximately
4 1/2 years to reduce the concentration of VOCs to cleanup levels
set forth in Section X. Alternative F would take 4 years to
construct and approximately 10 years of operation to incinerate all
waste within the landfill. Even so,natural attenuation and
dissemination of ground water contaminants would require 75 years.
6. Lonq-Term Effectiveness and Permanence
Long-term effectiveness and permanence address the long-term
protection of human health and the environment provided after the
remedial action goals have been achieved. This comparison focuses
on the residual risk that will remain after completion of the
remedial action and the adequacy and reliability of controls used
to manage the untreated waste and treatment residuals.
There is virtually no residual risk -associated with direct
contact with soil or soil ingestion for any of the alternatives as
27
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long as the landfill cap is maintained and, in the case of
Alternatives B, C, D, E, and F, the site remains fenced. Fencing
the site along with deed restrictions will substantially eliminate
potential future exposure from unauthorized access or any
development on or within the landfill.
Alternative B would warn downgradient users prior to the
contamination of the drinking water supply; however, an additional
action would then subsequently be needed to alleviate the threat.
Alternative C would protect future users as long as they are
connected to the public water supply. Alternatives D and F reduce
the risk posed by any leachate generated within the landfill
through further containment and through the source reduction in
Alterative F, thus reducing the marginal risk of continuing release
of the ground water. Alternative E substantially eliminates any
risk posed by the ingestion of the ground water by extracting and
treating the ground water prior to migration to any receptor.
Due to the existing landfill cap and vegetative soil cover,
the adequacy and reliability of all the described alternatives is
sufficient to minimize leachate generation and prevent direct
exposure to soils. Controls for ground water recovery and
treatment under Alternative E are adequate and extremely reliable.
Additionally, early warning monitoring wells which will be part of
the ground water extraction and treatment system under Alternative
E provide backup performance monitoring. The source control
technology of Alternative F, incineration, has been demonstrated
as being effective in removing VOCs from soils. Field scale test
would be conducted to verify the effectiveness of incineration on
the landfill materials. The controls and monitoring technology for
incineration are well established and reliable. While removal of
the landfill and contaminated materials and treatment by
incineration does provide a good long-term solution for Site
remediation, the short-term implications of excavation of the
landfill are significant as described in paragraph 5 (Short-Term
Effectiveness) below.
For all of the remedial action alternatives, other than
Alternative F, a periodic review is needed to assure long-terra
effectiveness and permanence, as well as the protection of human
health.
7. Costa
CERCIA requires selection of a cost-effective remedy that
protects human health and the environment and meets the other
requirements of the Statute. The capital and the annual operation
and maintenance (O&M) costs for these alternatives, as calculated
on a present worth basis, vary significantly. Cost estimates have
been developed for direct and indirect capital costs and O&M costs.
The present worth of each alternative has been calculated for
comparative purposes. Direct Capital costs include the following:
23
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o Remedial action construction
o Equipment
o Building and services
o Waste disposal costs
Indirect capital costs include:
o Engineering expenses
o Environmental permit acquisition
o Startup and shakedown
o Contingency allowances
Annual O&M costs include the following:
o Operating and maintenance labor and material costs
o Maintenance materials and labor costs
o Chemicals, energy, and fuel
o Administrative costs and purchased services
o Monitoring costs
o Costs for periodic site review (every five years)
o Insurance, taxes, and license costs
The remedial action alternative cost estimates have an
accuracy of +50 percent to -30 percent. For the purpose of the
present worth calculations, all Alternatives have a performance
period of 30 years.
Alternative A involves no capital costs and no O&M. The.only
cost for Alternative A is the cost of $109,672 associated with the
five year effectiveness reviews, which are necessary in all of the
alternatives except Alternative F.
Alternative B has a present worth capital cost of $242,905
and a present worth operation and maintenance (O&M) cost of
$529,596 with a total $772,501 project cost. Alternative C has a
present worth capital cost of $831,155 and a present worth O&M cost
of $254,247 with a total of $1,085,402, project cost.
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Alternative D has a present worth capitol cost of $6,237,368
and a present worth O&M cost of $529,596 with a total of
$6,766,964, project cost.
Alternative E has a present worth capital cost of $1,167,592 and
a present worth O&M cost of $905,376 with a total project cost of
$2,344,531. Alternative F has a present worth capital cost of
$72,096,663 and a present worth O&M cost of $529,596 with a total
of $72,626,264 project cost. Alternative F is almost twelve times
greater in cost than any of the other considered alternatives.
Alternatives B, C, and E are all in the same order of cost range
with Alternative D being three tiaes the cost of Alternative E.
A summary of all costs are shown on Table 12.
3. State Acceptance
The Commonwealth of Pennsylvania has concurred with the
selection of Remedial Alternative E for implementation at the Site.
9. Community Acceptance
A public meeting on the Proposed Plan was held on March 4,
1991 in Altoona, Pennsylvania. Comments received at that meeting
and during the comment period are discussed in the Responsiveness
Summary attached to this Record of Decision.
X. SELECTED REMEDIAL ALTERNATIVE
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives and public comments, the
remedial alternative selected for implementation ("Selected
Remedy") at the Site is Alternative E, Groundvatar Extraction, and
Treatment of Ground water via an Air Stripper/ Deed and Access
Restrictions/ Monitoring and Maintenance of Cap.
Clean UP Levels
The clean up levels for the aquifer contaminants are, for each
contaminant, the lower of (1) the MCL listed below and (2) the
background level of that contaminant:
Contaminant Clean UP level (ua/11 Basis
1,2 Dichloroethane 5 MCL
cis 1,2 Dichloroethene 70 MCL
trans 1,2 Dichloroethene 100 MCL
Chloroform (total trihalomethanes) 100 MCL
Tetrachloroethane 5 MCL
Trichloroethene 5 MCL
Vinyl Chloride 2 MCL
30
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TABLE L2
COST ESTIMATES
Present
Alternative Capital
A S
3 $
C 3
D S
E 5
F $
9,
242.,
831,
6,237
1,167
72,096
Worth
Cost
312
905
L55
,368
,592
,668
Present Worth
O&M Cost
$
$
S
$
S
S
100
529
254
529
1,176
529
,360
,596
,247
,596
,989
,596
Total Project
Cost
S
S
S 1
S 6
S 2
S72
109
772
,085
,766
,344
,626
,672
,501
,403
,964
,581
,264
-------
Promulgated or relevant and appropriate health-based levels
for manganese do not exist. Because of the low hazard index for
manganese identified at this site, a site-specific health based
cleanup level is not necessary. Likewise, a promulgated or
relevant health-based level for 1,1 Dichloroethane (another
contaminant giving rise to relatively low risk at the site) does
not exist; and' therefore a site-specific health-based clean-up
level is not listed.
Background concentrations for the above contaminants will be
determined by complying with the procedures for ground water
monitoring as outlined in 25 ?A Code §264.97. In the event that
a contaminant is not detected in samples taken for background
calculations, the detection limit for the method of analysis
utilized with respect to that contaminant shall constitute the
"background" concentration of the contaminant. As of the date of
this Record of Decision, the appropriate methods and their
detection limits are as follows:
Contaminant Method Detection Limit _
Chloroform (total
trihalomethanes) 601/602' .05
1,2 Dichloreothane 601/602 .03
cis 1,2 Dichloroethane 524.22 .12
trans 1,2 Dichlorethene 601/602 .10
Tetrachloroethane 601/602 .03
Trichloroethene 601/602 .03
Vinyl Chloride 601/602 .18
'40 C.F.R. Part 136
240 C.F.R. Part 141
The discharge levels for contaminants in the treated ground
water effluent will be determined by EPA in consultation with PADER
as part of remedial design in accordance with the substantive
retirements of Pennsylvania's NPDES program.
If implementation of the selected remedy demonstrates, in
corroboration with hydrogeological and chemical evidence, that it
will be technically impracticable to achieve and maintain the
clean-np levels throughout the area of attainment (which will be
the edge of the landfill area where contamination is furthest
detected). EPA, in consultation with the Commonwealth of
Pennsylvania, intends to amend the ROD or issue an Explanation of
Significant Differences to inform the public of the selection of
alternative ground water clean up levels as appropriate.
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XI. STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
CERCLA sites is to undertake remedial actions that achieve adequate
protection of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences. One such requirement is that when
complete, the Selected Remedy implemented at the Site must comply
with applicable or relevant and appropriate environmental standards
established under federal and state environmental laws unless a
statutory waiver is justified. The Selected Remedy also must be
cost-effective and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. Finally, the statute includes a
preference for remedies that employ treatment as a principal
element to permanently and significantly reduce the volume,
toxicity, or mobility of hazardous waste. The following sections
discuss how the Selected Remedy meets these statutory requirements.
Protection of Human Health and the Environment
The Selected Remedial Alternative protects human health and
the environment in the long term by using ground water extraction
and treatment to halt the migration of the existing contamination
and to reduce the contamination in the groundwater to acceptable
levels. The current excess cancer risks associated with exposure
to contaminated ground water are 3.0 x 10-4. Implementation of
the Selected Remedial Alternative is expected to reduce this risk
to within the generally acceptable cancer risk range of l.o x 10-
4 to 1.0 x 10-6 .
The existing cap with installation of the gas vents along with
long term maintenance will continue to reduce the infiltration of
water into the landfill, which in turn reduces the migration of any
source contaminants into the ground water.
There are no short-term risks associated with the Selected
Remedy that cannot be readily controlled. In addition no adverse
cross media impacts are expected to result from implementation of
the Selected Remedy. The Selected Remedy will also provide
protection from exposure of contamination left on the site by the
installation of security fencing.
Compliance with Applicable or Relevant and Appropriate Requirement.
The Selected Remedy of ground water extraction and treatment
will comply with all applicable or relevant and appropriate
chemical-, location-, and action-specific ARARs. Those ARARs are
as follows:
1. Chemical-Specific ARARs
32
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a. Relevant and appropriate Maximum Contaminant Levels
(MCLs) promulgated under the Safe Drinking Watezi
Act, 42 U.S.C. § 300f to 300J-26, and set forth at?
40 C.F.R. §141.61(a) and 55 Fed. Reg. 30370 (July
25, 1990) are:
Contaminant
Concentration fug/liter)
1,2 Dichloroethane 5
cis-1,2 Dichloroethene 70
trans-1,2 Dichloroethene 100
Chloroform (Total Trihalomethanes)100
Tetrachloroethane 5
Trichloroethene 5
Vinyl Chloride 2
Nickel (proposed) 100
b. The Pennsylvania ARAR for ground water for hazardous
substances is that all ground water must be
remediated to "background" quality as specified by
25 Pa. Code Sections 264.90 - .100. The
Commonwealth of Pennsylvania also maintains that
the requirement to remediate to background is also
found in other legal authorities. The method by
which background levels will be determined is set
forth in Section X of this ROD (Selected Remedial
Alternative). Such background levels shall be
attained as part of the Selected Remedy, unless it
is demonstrated that attaining such levels is
infeasible, or otherwise waivable under CERCLA
Section 121(d), 42 U.S.C. Section 9621(d).
c. The National Emissions Standards for Hazardous Air
Pollutants (NESHAPs) set forth at 40 C.F.R.
§61.64(b) and promulgated under the Clean Air Act,
42 U.S.C. § 7401, contain an emission standard for
air stripping vinyl chloride manufacturing plants
which is relevant i.nd appropriate to the air
stripping. The vinyl chloride emission standard is
10 ppm (average for 3-hour period).
2. Location-Specific ARARs
f
No location specific ARARs with respect to this Site,
have been identified.
33
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3. Action-Specific ARARs
a. 25 Pa. Code Sections 123.1 and 123.2 are applicable
to the Selected Remedy, and require that dusts
generated by earthmoving activities be controlled
with water or other appropriate dust suppressants.
b. To the extent that new point source air emissions
result from the implementation of the remedial
alternative, 25 Pa. Code Section 127.i2(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.
c. Treatment and discharge of contaminated ground water
to The Little Juniata River will cause the
requirements of Pennsylvania's NPDES program to
apply. Those requirements, as set forth in 25' Pa.
Code Sections 93.1 through 93.9, include design,
discharge, and monitoring requirements which will
be met in implementing the Selected Remedy.
d. 25 Pa. Code Sections 102.1 through 102.24 contain
relevant and appropriate standards requiring the
development, implementation, and maintenance of
erosion and sedimentation control measures and
facilities which effectively minimize accelerated
erosion and sedimentation.
e. 25 Pa. Code Sections 105.291 through 105.314,
promulgated in part under the Pennsylvania Dam
Safety and Encroachments Act of 1978, set forth
applicable design requirements relating to the
ground water treatment discharge pipe/headwall
construction.
f. 25 Pa. Code Sections 264.111, 264.117, and
264.310(b), (i), (iv) and (v) contain relevant and
appropriate requirements with respect to maintenance
of the existing cap. These requirements preclude
any breaches of integrity of the existing landfill
cap except under certain circumstances, which
circumstances will be met by the Selected Remedy.
These provisions also will require adequate repair
of the landfill cap.
g. Portions of the Pennsylvania Municipal Waste
Regulations, 25 PA Code Article VIII, set forth
relevant and appropriate substantive requirements
34
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regarding the maintenance of the landfill cap
required under the Selected Remedy. Those portions
include are: 25 Pa. Code §§271.212 (relating to
access restrictions), 273.235 and 273.236 (relating
to revegetation of landfill cover), 273.241
(relating to prevention of water pollution) , 273.242
(relating to sedimentation and erosion control) , and
273.292 (relating to gas venting).
h. The ground water extraction and treatment operations
at the Site will constitute treatment of hazardous
waste (i.e., the ground water containing hazardous
waste), and will result in the generation of
hazardous wastes derived from the treatment of the
contaminated ground water (i.e.. spent carbon
filters from the air stripping operation). The
remedy will be implemented consistently with the
requirements of 25 Pa. Code Part 262 Subparts A
(relating to hazardous waste determination and
identification numbers), B (relating to manifesting
requirements for off-site shipments of spent carbon
or other hazardous wastes), and C (relating to
pretransport requirmentsr 25 Pa. Code Part 263
(relating to transporters of hazardous wastes) ; and
with respect to the operations at the site
generally, with the substantive requirements of 25
Pa. Code Part 264 Subparts B-E, F (in the event
hazardous waste generated as part of the Selected
Remedy is managed in a surface impoundment), G, I (in
the event that hazardous waste generated as part of
the Selected Remedy is managed in containers), J (in
the event hazardous waste generated as part of the
Selected Remedy is treated or stored in tanks), and
K (in the event hazardous waste generated as part
of the Selected Remedy is treated or stored in
surface impoundments).
i. The land disposal restrictions set forth at 40
C.F.R. Part 268 are applicable to the management
of hazardous wastes (including spent carbon filters
from the air stripping operation) generated as part
of the Selected Remedy.
j. 29 C,F.R. §1910.170 sets forth applicable
requirements regarding worker safety in the handling
of hazardous substances.
k. 49 C.F.R. §171.1-171.16 sets forth applicable
requirements regarding off-site transportation of
hazardous wastes.
35
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1. The requirements of Subpart AA (Air Emission
Standards for Process Vents) and BB (Air Emission
Standards for Equipment Leaks) of the federal RCRA
regulations, 40 C.F.R. Sections 1030 and 1050, are
relevant and appropriate (and, depending upon the
levels of organics in the extracted ground water
and treatment residuals) may be applicable to the
air stripping operations under the Selected Remedy.
These regulations require that total organic
emissions from the air stripping process vents must
be less than 1.4 kg/hr (3 Ib /hr) and 2.8 mg/yr (3.1
tons/yr.).
m. Revised Procedures for Planning and Implementing
Off-Site Response Actions (OSWER No. 9834.11
November 13, 1987), although not an ARAR, is a
guidance developed by EPA which is to be considered
in implementing the remedy.
Cost effectiveness
Alternative E is cost effective in remediating the site, when
compared to all other Alternatives. A detailed cost breakdown for
all components of the Alternative is shown below in Table 13
Table 13
Cost Estimate
Item Item Cost
Regrading $ 22,800
Fence 21,750
Well Construction and Development 184,549
PTA Treatment System 201,419
Plant Building 28,000
Indirect Construction Costs 114.630
Construction Total $ 573,148
Permits & Legal $ 120,000
Design Costs 205.OOP
Total Construction $ 898,148
Contingency 269.444
36
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Total Capital Costs $ 1,167,592
Present Worth O&M Costs 1. 176.989
Total Project Costs $ 2,344,581
Preference for Treatment as a Principal Element
The selected remedy satisfies the statutory preference for
remedies that employ treatment as a principal element to
permanently reduce the toxicity, mobility, or volume of hazardous
substances. The Selected Remedy addresses the risks posed by the
ground water associated with the Site through use of treatment
technologies.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
EPA has determined that the Selected Remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized while providing the best balance
amonung the other evaluation criteria. Of the alternatives that
are protective of human health and the environment, the selected
.remedy provides the best balance in terms of long-term and short-
term effectiveness and permanence; cost; iinplementability;
reduction in toxicity, mobility, or volume of hazardous substances
through treatment; state and community acceptance; and the
statutory preference for treatment,as a principal element.
The selected remedy utilizes the technology of ground water
extraction and treatment technology to reduce the volume and
toxicity of hazardous substances in the ground water. In the
short-term, the risks posed by direct contact with contaminated
materials present during remedial activates and afterwards and the
potential inges*-Jon of ground water will be avoided through the
installation of security fencing and deed restrictions. For the
long-term, the ground water extraction and treatment will return
the ground water to levels that meet federal and state criteria.
The treatment component of the selected remedy is easily
implemented. Removal of the source material within the landfill
is not practicable due to volume and nature of the landfill and the
excessive cost associated with the treatment method. Moreover,
existing containment measures, as maintained under the Selected
Remedy, significantly minimize the impact of the source material
on the ground water.
37
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RESPONSIVENESS SUMMARY
This community relations responsiveness summary is divided
into the following sections:
Section I Overview. A Discussion of EPA's Preferred
Alternative and the public's response to this
Alternative.
Section II Background of Community Involvement and Concerns.
A discussion of the history of community interest
and concerns raised during remedial planning
activities at the Delta Quarries Superfund Site.
Section III Summary of Major Comments Received During the
Public Comment Period and Agency Responses. A
summary of comments and responses categorized by
topic.
I. OVERVIEW
EPA's Preferred Alternative, Alternative E, outlined in the
Proposed Plan, involves access and deed restrictions on the
landfill portion of the site, long term maintenance of the
existing soil cap, installation of gas vents, monitoring of
ground and surface water, and the extraction of contaminated
ground water through a series of extraction wells with the ground
water being run through an on-Site ground water treatment system
and then discharged to the Little Juniata River.
During the public comment period, the community in general
supported the clean up of the Site, however, they questioned the
extent of the contamination and how the proposed plan will
guarantee the total remediation of the Site. Several residents
voiced their desire that EPA implement the proposed plan with the
addition of water supply lines to serve the community. Also of
concern to the community was a bacteria problem which they had
experienced in the drinking water supply during the previous few
years. Some residents believed these problems to be related to
the Site.
II. BACKGROUND O7 COMMUNITY INVOLVEMENT AND CONCERNS
Community interest in the Delta Quarries and Disposal Site
dates to 1979 when well water samples were taken from the homes
of four property owners living in the vicinity of the landfill.
Since that time general community interest has been minimal.
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EPA and PADER met with the Antis Township Action Committee
at the committee's request in May 1939. At the meeting EPA
discussed the ongoing RI/FS Investigation and the direction it
would be taking. The Antis Township Action Committee expressed
their concerns about their drinking water supply and requested
that a public water line be 'provided to bring water to the
Village of Pinecroft.
III. SUMMARY OP MAJOR COMMENTS DURING THE COMMENT PERIOD AND
AGENCY RESPONSES
Comments raised during the Delta Quarries and Disposal Site
public comment period on the proposed plan are summarized below.
The comment period was held from February 15, 1991 to March 17,
1991.
1. PADER supports EPA's choice of the preferred alternative
for the Delta Quarries and Disposal Site.
EPA RESPONSE: No response required.
2. One 'Resident asked, what is the vertical extent of the
ground water traveling from the landfill and what are the flow
paths and discharge zones for this groundwater regime?
EPA RESPONSE: To determine ground water flow directions,
the water levels of the monitoring wells at the Site were
measured. After the water level elevations were determined in
each well and plotted on a Site map, ground water contour lines
were drawn. These lines are similar to the contour lines of a
topographic map in that the lines indicate the elevation of a
surface (here the surface is the water table).
Realizing that water flows downhill, we can therefore
predict that ground water at the Site flows from areas of high
ground water table elevations to low ground water table
elevations. The ground water table at the Site is highest in the
eastern half and lowest in the western half near the Little
Juniata River, indicating that the ground water at the Site flows
from the landfill to the west northwest toward the river.
In th« northeast quadrant of the Site near monitoring well
#2, water table elevations indicated that ground water in this
location has the potential to flow north-northeast. However,
since ground water immediately west of this area flows toward the
west, and this area is east of the landfill, it is inferred that
contaminants from the Site will not be transported with the
north-northeast flow path. This is what is known as a ground
water divide.
Ground water at the Site is found in the pore spaces and in
the fracture zones of the bedrock. Since the pore spaces in the
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Site's bedrock are small, higher hydraulic conductivities are
found in the fractures.
The ground water that travels from the landfill discharges
to the Little Juniata River and will not travel under the river
to be carried to the opposite side from the landfill. Since
water table surfaces generally mirror the topographic surface of
an area, as observed at the landfill, the ground water table
elevations on the west side of the river would be lowest (nearest
the surface) at the river in the valley and the ground water
would tend to flow east toward the Little Juniata.
Therefore, ground water is flowing to the Little Juniata
River on both sides of the water body. Where the mirrored flow
gradients meet at the valley floor, there is an occurrence of an
upward rising of ground water flow and the ground water is
discharged into the river.
3. Residents questioned where the extraction wells would be
placed if the ground water contamination plume has not been well
defined.
EPA RESPONSE: The proposed plan contemplates the use of
eight extraction wells based on current information. During the
remedial design, additional ground water samples will be taken
from all downgradient wells to better define the ground water
contamination plume prior to the final selection of the number
and location of the extraction wells.
4. Residents questioned who was going to be financially
responsible for implementing the proposed plan.
EPA RESPONSE: EPA has done an investigation as to who,
under the Superfund Law, can be held liable for the costs of
cleaning up the Site. At some time after issuance of this Record
of Decision, EPA may issue special notice letters to those
potentially responsible parties (PRPs) whom EPA believes are
responsible for the performance of or payment for the clean up.
These letters will request that those PRPs enter into
negotiations with EPA to undertake the cleanup. If no party
wishes to negotiate or if negotiations are unsuccessful, then EPA
may either order the PRPs to undertake the cleanup or use
Superfund monies to undertake the cleanup. In the event EPA
performs the clean up, it is authorized to seek recovery of costs
incurred in the clean up from the PRPs.
5. One resident, who lives adjacent to the Site,
questioned why her children became ill after consuming their well
water and yet well tests done during the previous few years have
not shown any contamination.
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EPA RESPONSE: EPA has reviewed the well sampling'data from
the last several sampling rounds and finds that her well is no
longer showing any of those compounds which EPA looked for durim
a remedial investigation. It may be possible that the prior
contamination has degraded and no longer exists within her well
source. EPA, however, cannot explain why her children became ill
after consuming it. Based on the results of the recent and
previous well tests, there were no contaminants in the water
supply which was tested which could have caused an illness to
occur so rapidly after consumption.
5. Residents asked that since the source of contamination
will be left en the site, what assurances are there that the
problem will not reoccur after the ground water treatment process
is completed?
EPA RESPONSE: Under Superfund, if sources of contamination
are left on a site (as would occur under the proposed plan), EPA
is required to perform periodic reviews of the site at least
every five years after the remedial action is initiated. If
during any of these reviews or if during the normal ground water
monitoring which may take place as a part of the proposed
alternative, evidence demonstrates that conditions exist which
pose a threa.t to human health or the environment, EPA is required
to take appropiate action to address such conditions.
7. One resident questioned whether general trash haulers
could be held liable for clean up costs.
EPA RESPONSE: If a hauler disposed of only general
municipal trash not containing hazardous substances at the
Site, the hauler would not be considered liable under Superfund.
If the hauler disposed of hazardous substances at the Site and
the hauler was responsible for selecting Delta Quarries as the
disposal site, then the hauler may be a potentially responsible
party.
8. Several residents questioned the selection of
Alternative E only and recommended that Alternative E along with
Alternative C, a new public water supply be also implemented.
EPA RESPONSE: EPA evaluated Alternative C under the same
criteria as all alternatives, and while Alternative C would be
protective of human health, it does not address the cleanup of
the contaminated ground water. Although it is possible to
implement Alternative C concurrently with Alternative E, the
provision of alternate water supply is not appropriate given the
Site conditions and the protection provided under Alternative E.
No residential wells recently tested have shown any signs of
contamination associated with the Site, so at this time there is
no need to bring in an outside water supply to those residents
utilizing the ground water as their water supply. When
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Alternative E is implemented, the ground water extraction will be
designed to prevent any currently contaminated ground water from
migrating off-site to any drinking water supply well or any other
potential receptor. Furthermore, the continuous ground water and
surface water monitoring will ensure that no residential wells
are ever threatened during or after implementation of the ground
water extraction and treatment process.
9. Several residents from the Pinecroft area expressed
concern about their water supply in their area. Of particular
concern was high levels of bacteria which began appearing a few
years ago in their wells, which bacteria they feel may be coining
from the Delta Site.
EPA RESPONSE: During the Remedial Investigation, there was
no indication that any type of contamination from the Site could
have migrated to their residential area. Bacteria is generally
not considered a hazardous substance and therefore, EPA would not
sample for it during a Remedial Investigation nor attempt to
address it during a clean up. Nonetheless, given the fact that
no known Site contaminants have been detected in the wells in
question, it is unlikely that bacteria, even if it originated at
the Site, would have reached those wells.
Hydrogeological analysis demonstrates that contaminants have
not migrated to those wells. When a contaminant encounters the
water table at the Site, the horizontal hydraulic gradient
dictates the migration of that contaminant. This means
contaminants that are in the ground water are not as likely to be
transported downward as easily as they will be transported
horizontally. Therefore, the horizontal extent of the
contaminants is of much greater concern than the vertical extent.
However, the vertical extent is still important. A ground water
model was used to aid in extrapolating or determining the
vertical extent of the contamination which would be consistent
with the hydraulic properties and contaminant concentrations
observed during the investigation. Based on these analyses, it
appears that none of the Site contaminants have reached the wells
in question because ground water flow is not in the general
direction of these wells.
10. It was questioned that even if vinyl chloride was not
detected in some wells, could it be possible that the compound
was in fact near the well sampled, but not obtained during the
sample collection from that well.
EPA RESPONSE: If vinyl chloride was in the ground water,
near a well during sampling, it should have been detected during
sampling of that well. When a well is sampled three to five
volumes of water are purged or removed from the well prior to
sampling. This purging ensures that stagnant water is removed
from the well and that a representative sample of ground water is
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drawn into the well to be sampled. If vinyl chloride is in the
ground water near the well, it would be drawn into that well and
sampled. Vinyl chloride may be detected in a well in one sample,
but not in later samples because 1) the contaminant plume has
migrated or moved away from the well location to such a distance
from the well that the vinyl chloride can no longer be detected
in samples taken from that well, or 2) the concentration of vinyl
chloride has been diluted or the vinyl chloride has started to
degrade. When several consecutive sampling rounds indicate no
vinyl chloride at one well, there is some certainty that the
contaminant has moved or degraded and is no longer present near
that well.
11. One resident raised the question that if the wastes
were removed from the site would the contamination or po~. :ntial
for contamination be completely eliminated?
EPA RESPONSE: By eliminating the source, the potential for
future soil and ground water contamination from the site will be
eliminated. However, the soil and ground water that is already
contaminated by the landfill would still need to be addressed.
In addition, EPA policy is to not move sources of contamination
from one geographical location to another, but EPA prefers to
treat a source at a site and remove the source through its
treatment or extraction. Based on the factors set forth in the
decision summary, it was determined that removal of the landfill
materials would not be appropriate in this case.
12. The question was raised on why is there such a large
cost difference between Alternative E and Alternative F.
EPA RESPONSE: The difference in cost between Alternative E
and Alternative F involves the level of wor)c required.
Alternative E is a remedy which would involve pumping and
treating the ground water to remove contaminants. This remedy
would require some study to determine pumping rates and
construction of the actual pumping and treatment systems but is
expected to ultimately reach the remedial goal of cleaning or
restoring the aquifer.
Alternative F would involve a much larger scope of work,
specifically a very large construction/excavation project. This
project would involve the following components:
o A study to determine exactly where the buried wastes
are located.
o Excavation of all landfill wastes (approximately
2,700,000 cubic yards) and separation of approximately
67,000 cubic yards of waste for incineration.
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o Site preparation and installation of a mobile
incinerator.
o Incineration of some of the waste.
o Stabilization of incinerator residuals (i.e., treatment
of incinerator ash prior to disposal.
o Construction of a new landfill on-site. with liner and
multi-layer cap to hold incinerator ash.
o Monitoring and cap maintenance after the project is
complete.
13. It was questioned that if no records were maintained
describing or indicating what types of waste were being disposed
at the site, then what methods are used to determine the types of
buried waste.
EPA RESPONSE: Several methods are used to determine the
types of waste buried at the Site. Specifically this information
is determined by two methods: 1) using historical information
from landfill operators, waste haulers, and waste generating
companies, and 2) looking at substances actually detected in
environmental samples collected at the Site and determining the
types of wastes from which these substances would have come.
Even if the landfill owner or operator didn't keep records, waste
generators and haulers do so; therefore, through investigation
information can be tracked down concerning waste dumped at the
site. When no records are available, the knowledge of chemicals
found at the site gives a reasonably accurate idea of what was
disposed of at the site.
14. Residents asked what percentage of the contaminants
from the Site in the ground water can be removed by air
stripping?
EPA RESPONSE: EPA is proposing that the air stripping
device be designed to remove 99.9 percent of the concentrations
of volatile compounds that are in the ground water extracted from
the aquifer.
The extraction well or wells placed at the site will
intersect or be installed in zones of high hydraulic
conductivities I i.e.. fractures) so that a pump placed in the
wells could effectively remove the calculated ground water that
is contaminated from the aquifer (see response to question 2).
Packed towers (air stripper type) can achieve up to 99.9 percent
of some volatile compounds from ground water [EPA 540/2-
86/003(f), 1986]. Since vinyl chloride, the main contaminant of
concern, is highly volatile, it is expected that this compound
will effectively be removed.
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Post-treatment groundwater sampling will be part of the
alternative remedy to analyze the effectiveness of the air-
stripping program.
15. One resident asked why wells in Pinecroft, reported by
residents to be 230 and 240 feet deep, weren't included in the
sampling program for the RI?
EPA RESPONSE: The reason why wells in Pinecroft were not
sampled in twofold. The well nearest to Pinecroft which was
sampled was a residential well, approximately 1,400 feet north of
the Site. The analysis of this sample revealed no contaminants
associated with the Site. This indicates that contaminants have
not traveled in this direction. Also, due to the site hydraulic
characteristics, contaminants from the site should not be
transported by ground water to wells in Pinecroft. (See response
to question 9).
The EPA concluded that wells in Pinecroft have not and
should not be affected by contaminants from the Site, therefore
the wells were not sampled.
16. One resident suggested that wells be sampled on the
opposite side of the Little Juniata River from the landfill, and
some in Pinecroft.
EPA RESPONSE: EPA feels that based on the existing data the
ground water on the opposite side of the Little Juniata River
from the landfill and in Pinecroft will not be affected by
contaminants moving from the landfill. Therefore, these wells
were not included in the sampling program. This is based on our
review of all hydrogeological data available, based on water
level elevations observed in the monitoring and residential wells
sampled. Ground water on both sides of the Little Juniata River
are flowing towards the River. Therefore, EPA does not expect
contaminants to move to the other side of the river or towards
the village of Pinecroft.
17. One commenter stated that the ARAR requiring ground
water to b« remediated to background quality is not a
promulgated, legally enforceable requirement under Pennsylvania
law. The commenter also asserted that Pennsylvania has not
consistently applied, or demonstrated the intention to
consistently apply such a requirement at other remedial actions
within the Commonwealth.
EPA RESPONSE: In accordance with Section 121 of CERCLA, 42
U.S.C. §9621, and the NCP, Pennsylvania submitted to EPA a list
of state ARARs relating to the Site. As described in the
Decision Summary, the "background" ARAR is based upon promulgated
and legally enforceable provisions of Pennsylvania's hazardous
3
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waste management regulations, namely 25 PA Code §264.90 -
264.100. These provisions require ground water monitoring at
hazardous waste management facilities, and, in the event that
hazardous waste, hazardous constituents or decomposition by-
products are detected at levels above background, require
implementation of actions to abate the contamination. Abatement
under these provisions as interpreted by Pennsylvania requires
remediation of the ground water to background levels. Therefore,
the background ARAR is based upon a legally enforceable,
promulgated state environmental standard.
EPA is unaware of any action or pattern of activity by
Pennsylvania which would indicate that Pennsylvania, has not
consistently applied (or demonstrated the intention to
consistently apply) the background ARAR at other remedial actions
in the Commonwealth. Since Pennsylvania first identified the
relevant provisions as constituting an ARAR, it has consistently
asserted those provisions as ARARs at sites involving remediation
of contaminated ground water in the Commonwealth. Therefore,
based on the current facts known to EPA, it would not be
appropriate to invoke the waiver set forth in Section
121(d)(4)(E) of CERCLA with respect to this ARAR.
18. The owner of the Site has commented on the proposed
plan and has indicated it does not agree with the EPA's selection
of Alternative E. The owner recommends selection of Alternative
B based on the fact that there are no current receptors which are
threatened by the contaminated ground water, and that under
Alternative B, the ground water monitoring plan would alert any
potential receptors of possible contamination prior to it
reaching their water supply wells. In addition, the owner
disagrees with the risk analysis. It bases its disagreement on
the results of its resampling of well 10A-88, in January 1991.
This resampling did not show any vinyl chloride where as it had
been found previously once during the RI.
EPA RESPONSE: EPA does not agree with the commenter's
recommendation that Alternative B be implemented in lieu of
Alternative E for the following reasons: (1) Alternative B does
not address the EPA goal of returning the aquifer to its full
beneficial use; (2) Alternative B will not prevent the potential
migration of a contamination from the Site to current or future
potential receptors; and (3) Alternative E will provide the best
overall protection of human health and the environment.
EPA believes that the risk is not overstated. While well
10A-88 did not show any vinyl chloride during the resampling, in
January 1991, the resampling detected trichloroethene and
tetrachloroethene in the new sample. This is of concern to EPA
because both of these compounds are precusors to vinyl chloride
formation, through the natural degradation of both these
compounds. In addition, vinyl chloride has been detected twice
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before on the site in well 3-35 prior to the RI. In addition to
the vinyl chloride, there have been several instances where
various other volatile organic compounds have exceeded their
respective MCLs for safe drinking water standards and therefore
also represent potential risk. EPA's risk calculations are based
on reasonable maximum exposure assumptions and are not considered
overly conservative, therefore EPA believes that the risk value
of 3 x 10-4 is a reasonable expectation of risk for this Site.
10
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DELTA QUARRIES SITS
ADMINISTRATIVE RECORD FILE *
INDEX OF DOCUMENTS
SITE IDENTIFICATION
1. Report: Preliminary Assessment, Delta Quarries and
Disposal Inc. Landfill, 2/20/85.P. 100001-100047.
Administrative Record File available 1/3/91, updated
2/15/9U updated 3/18/91..
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II. REMEDIAL ENFORCEMENT PLANNING
1. Consent Order and Agreement In the Matter of: Delta
Excavating and Trucking Company, Inc., et al. v.
Pennsylvania Department of Environmental Resources
(PADER), Docket 181-080-M, signed by Mr. John P.
Niebauer, Jr., Delta Quarries and Disposal Inc., and
Mr. Edward Simmons and Mr. Donald Lazarchik, PADER,
10/17/34. ?. 200001-200036.
2. Report: Delta Altoona Landfill, "Old Stotler Site",
Hydrcgeolcgic Investigation, Antis and Logan Townships,
31air County, prepared by Meiser & Earl, Inc., 2/36.
?. 200037-200242.
3. Report: Delta Stotler Landfill, Closure Plan and Soil
Erosion and Sedimentation Plan, prepared by Martin and
Martin, Incorporated, 6/36. P. 200243-200333. A
transmittal letter is attached.
4. Administrative Order by Consent In the Matter of: Delta
Quarries and Disposal/Stotler Landfill, Docket #111-83-
01-DC, signed by Mr. John P. Niebauer, Jr., Delta
Quarries and Disposal Inc., and Mr. James M. Seif, U.51
EPA, 1.0/9/87. P. 200334-200349.
* 5. Attachment I (Part 1): Delta Quarries and Disposal,
Inc., Site-related Records, (undated). P. 200350-
200532.
• 6. Attachment I (Part 2): Delta Quarries and Dispoal,
Inc., Site-related Records, (undated). P. 200533-
200662.
* 7. Attachment II (Part 1): Delta Quarries and Disposal,
Inc., Title Documents, (undated). P. 200663-200836.
" 8. Attachment II (Part 2): Delta Quarries and Disposal,
Inc., Title Documents, (undated). P. 200837-201035.
Documents previously appearing at pages AR200350 through
AR201035 have been removed. These documents were not relied
upon or considered in selecting remedial alternatives for
the .• site and therefore placement of them in tht
administrative record file was erroneous. These documents
remain, in EPA Region III files and _ are subject to review
under the Freedom of Information Act, 5 U.S.C. Section 552.
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III. REMEDIAL RESPONSE PLANNING
1. Report: Worfc Plan, Remedial Investigation/Feasibility
Study (RI/FS), Delta Quarries and Disposal/SCotler
Landfill, Antis and Logan Townships, Blair County,
Pennsylvania, prepared by Meiser & Earl,Inc., 5/6/88.
P. 300001-300125.
2. Letter to Ms. Donna McCartney, U.S. EPA, from Ms.
Noreen Chamberlain, Bureau of Waste Management, re:
Concerns over investigation, 8/9/88. P. 300126-300127.
3. Report: Health and Safety Plan for the Delta Quarries
and Disposal/Stotler Landfill, Antis and Logan
Townships, Blair County, Pennsylvania, prepared by
Meiser & Earl, Inc., 8/29/88. P. 300128-300241.
4. Report: Quality Assurance Project Plan, Delta Quarries
and Disposal, Inc./Stotler Landfill, RI/FS, prepared by
Meiser & Earl, Inc., 8/29/88.P. 300242-300303.
5. Report: Quality Assurance Project Plan (Appendices),
Delta Quarries and Disposal, Inc./Stotler Landfill,
RI/FS, prepared by Meiser & Earl, Inc., 8/29/88.
P. 300304-300749.
6. Report: Remedial Investigation, Site Operations Plan,
Delta Quarries and Disposal/Stotler Landfill, Antis and
Logan Townships, Blair County, Pennsylvania, prepared
by Meiser 6 Earl, Inc., 8/29/88.P. 300750-300940.
7. Health Assessment for Delta Quarries/Stotler Landfill,
Antis/Logan Township, Blair County, Pennsylvania,
prepared by the Agency for Toxic Substances and Disease
Registry (ATSDR), 11/15/88. P. 300941-300944.
8. Organic Data Validation (Case 10702), prepared by
Weston, 1/18/89. P. 300945-301044. A transmittal
memorandum Is attached.
9. Inorganic Data Validation (Case 10702), prepared by
ff«ston, 1/19/89. P. 301045-301068. A transmittal
memorandum is attached.
10. Inorganic Data Validation (Case 10588), prepared by
Weston, 1/24/89. P. 301069-301087. A transmittal
memorandum is attached.
11. Organic Data Validation (Case 10588), prepared by
Weston, 3/31/89. P. 301088-301150. A.transmittal
memorandum is attached.
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12. Report: Statement of Qualifications, Delta Quarri
Remedial Investigation/Feasibility Study, prepared" _/
Canonie Environmental Services Corp., 5/19/89.
?. 301151-301206.
13. Report: Quality Assurance Review, the Delta Quarry
Project, prepared by Environmental Standards, Inc.,
9/20/39. P. 301207-301404.
14. Report: Quality Assurance Review, the Delta Quarry
Project, prepared by Environmental Standards, Inc.,
3/27/39. ?.'301405-301950.
15. Report: Quality Assurance Review, the Delta Quarry
Project, prepared by Environmental Standards, Inc.,
10/31/39. P. 301951-302296.
16. Inorganic Data Validation (Case 12544), prepared by
Weston, 11/10/89. P. 302297-302324. A transmittal
memorandum is attached.
17. Report: Quality Assurance Review, the Delta Quarry
Project, prepared by Environmental Standards, Inc.,
11/17/89. P. 302325-302704.
13. Letter to Ms. Donna McCartney, U.S. EPA, from Mr. 3ruce
Pluta, COM, re: Suspicion of test validity, 11/20/89.
P. 302705-302729. Information on dye tracers is
attached.
19. Report: Trip Report, Delta Quarries, RI/FS Oversight,
prepared by COM, 11/22/89.P. 302730-302819.The
transmittal letter is attached.
20. Letter to Ms. Donna McCartney, U.S. EPA, from Mr.
Arthur Pyron, re: Notification of geologic report and
comments on the Remedial Investigation, 11/25/89.
P. 302820-302823.
21. Inorganic Data Validation (Case 12735), prepared by
Weston, 11/30/89. P. 302824-302837. A transmittal
memorandum is attached.
22. Organic Data Validation (Case 12735), prepared by
Weston, 12/4/89. P. 302838-302915. A transmittal
memorandum is attached.
23. Organic Data Validation (Case 12544), prepared by
Weston, 12/7/89. P. 302916-303049. A transraittal
memorandum is attached.
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24. RI/FS Data Summary Tables transmittal letter to Ms.
Donna McCartney, U.S. EPA, from Mr. Joseph E. Mihm,
Canonie Environmental Services Corp., re: Completion
of RI/FS Data Summary Tables, 1/4/90. P. 303050-
303090. The tables are attached.
25. Report: Data Comparison Report, Delta Quarries Site/
prepared by COM, 4/3/90.P. 303091-303108.A
transmittal letter is attached.
26. Report: Summary of the Geology of the Delta Quarry
Superfund Site, and its Influence upon Site"
Hydrogeology, Logan and Antis Townships, Blair County/
Pennsylvania, prepared by Arthur J. Pyron, (undated).
P. 303109-303214.
27. Report: Wetlands Investigation and Phase II Surface
Water and Sediment Sampling Data Review, prepared by
Canonie Environmental, 3/90.P. 303215-303281.
V
28. Report: Draft Human Health Evaluation of the Delta
Quarries and Disposal/Stotler Landfill in Altoona,
Pennsylvania,prepared by Canonie Environmental,
4/24/90.PT 303282-303392.
29. Report: Final Draft Report, Remedial Investigation/
prepared by Canonie Environmental,11/14/90.
P. 303393-303978.
30. Report: Feasibility Study, prepared by Canonie
Environmental, 1/91.P7~T03989-304170.
31. Memorandum to Mr. Martin Kotsch, U.S. EPA, from Ms.
Nancy Rios, U.S. EPA, re: Report of analytical result
for MW 10A-88, 1/14/91. P. 304171-304172.
32. Letter to Mr. Martin Koch [sicj, U.S. EPA, from Mr.
Mike Morris, BrocJcway Analytical, Inc., re:
Transmittal of analytical data for monitoring well
IOA-88, 1/17/91. P. 304173-304188.
33. Proposed Remedial Action Plan, Delta Quarries and
Disposal Site, prepared by U.S. EPA, 2/15/91.
P. 304189-304203.
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V. COMMUNITY INVOLVSMENT/CCNGRgSSICNAL CORRESPONDENCE/
IMAGERY ! ' ' - ' — =—
Topographic map with directions, Delta Quarry Site and-*
surrounding area, U.S. Geological Survey, 1962
?. 500001-500002.
/
2. Topographic .-nap, Delta Quarry Site and surrounding
area, U.S. Geological Survey, 1962. ?. 500003-500004.
A legend indicating water line locations and number of
houses and people within two miles of the site is
attached.
3. General plan, Aitoona City Authority water system and
reservoirs, ~cbson & Foreman, Inc., 5/6/82. P. 500005-
500005.
4. Photographs from a site visit, Delta Quarries and
Disposal, 10/31/84. P. 500006-500010.
5. Contour map, Delta Quarries and Disposal, Inc., Aitoona
Disposal Sites, Meiser & Earl, Inc., 2/26/85.
P. 500011-500011.
6. Contour map (enlargement), Delta Quarries and Disposa^,
Inc., Aitoona Disposal Sites, Meiser 4 Earl, Inc.,
2/26/85. P. 500012-500012.
7. Contour map (enlargement) with handwritten additions to
the legend, Delta Quarries .and Disposal, Inc., Aitoona
Disposal Sites, Meiser & Earl, Inc., 2/26/85.
P. 500013-500013.
8. Contour map (full-size) with handwritten notations,
Delta Quarries and Disposal, Inc., Aitoona Disposal
Sites, Meiser & Earl, Inc., 2/26/85. P. 500014-500014.
9. Topographic map (Plate 1), Delta Quarries and
Disposal/Stotler Landfill, Antis and Logan Townships,
Blair County, PA, Meiser & Earl, Inc., 1/88.
P. 500015-500015.
10. Photographs from tvo site visits, Delta Quarries,
6/22/88 and S/15/88. ?. 500016-500032.
11 . Draft Report, Delta Quarries Site, Community Relations
Plan, prepared by 3ooz, Alien & Hamilton Inc., 8/4/38.
P. 500033-500052.
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12. Photographs from a site visit, including drilling
operations and testing procedures, 10/88. P. 500053-
500062.
13. Location map (Figure 1), Delta Quarries'and Disposal,
(undated). P. 500063-500063.
14. Assessment map (Figure 4), Delta Quarries Site,
TechLaw, Inc., (undated). P. 500064-500064.
15. Water system map, Altoona area, (undated).
P. 500065-500065.
16. Location map, Parshall Landfill, (undated).
P. 500066-500067. A topographic map showing the
Parshall Sanitary Landfill proposed site plan is
attached.
17. Transcript of Public Meeting, Delta Quarries, 3/4/91.
P. 500068-500158.
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i
SITE SPECIFIC GUI PANGS DOCUMENTS
Guidance for Conducting Remedial Investigations and
Feasibility Studies Under CERCLA, prepared by
CSWER/CERR, 10/1/33.
2 . Super fund Federal-Lead Remedial ?ro:ect Management
HandbocJc, prepared by CERR, 6/1/86.
3. Land Disposal Restrictions, prepared by H.L. Longest,
CERR. and G. Lucero, CWPE, 3/1/87. The following are
attached:
a) Su.Tjnary of Major LDR Provisions i California
List Prohibitions;
b) Other attachements cited are available in the
Federal Register.
4 . CERCLA Compliance with Other Environmental Statutes,
prepared by J.w. Porter, CSWER, 10/2/35.
5 . CERCLA Compliance with Other Laws Manual Draft
Guidance, prepared by GERR, 3/3/88.
6. ATSDR Health Assessments on NPL Sites, prepared by
Department of Health and Human Services/ATSDR, 6/16/6 .
7 . Guidelines for Carcinogen Risk Assessment ''(Federal
Register, September 24, 1986, P. 33992) ,\ prepared by
SPA, 9/24/86. ~~~~.
••••' '•
8 . Guidelines for Exposure Assessment (Federal Register,
September 24, 1986, P. 34042), prepared-by EPA,
9/24/36. •/,
. , '
9. Health Assessment Documents (53 Chemical Profiles)',/ ' ?
Volume 28-30, prepared by ORD/OHEA/ECAp and- OSWER/,OERR< .
9/1/84. -i ^ '••••" -V/'7' ;i- '/ . "- V
fi •> ! > ,. «'
10. Superfund Exposure Assessment" Manual-, ^.prepared By' OERR '•
and OSWER, 4/1/88. "'.../ /
' . 'i ' it; ' t
11. Superfund Public Health Evaluation Manual, prepared by
OERR and OSWER, 10/1/86.
12. Community Relations in Superfund: A Handbook (Interim
Version) , prepared by OERR, 6/1/88^.
13. Endangerment Assessment Guidance, prepared by J.w.
Porter, OSWER, 11/22/35.
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