United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/RO3-85/010
March 1985
Superfund
Record of Decision:
Lackawanna Refuse Site, PA
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IACKAWANNA REFUSE SITE, PA
Record of Decision
Abstract
'!he Lackawanna Refuse site is located along a section of the
north-south border between the Borough of Old Forge and Ransom Township,
in Lackawanna County, PA. Five strip mine pits of five to six acres each
were excavated in this area during the last century, and three were later
used for waste disposal iri the 1970's. One abandoned pit (pit 5)
. contains about 15,000 buried drums of hazardous waste as well as
municipal refuse. Pit 5 is approximately five acres and is estimated to
be 30-50 feet deep. '!he pit has only a thin cover of soil above the
waste. '!he contents of 20 drums were sampled and found to contain
various solvents, paints and thinners, sludges, organic acids, and toxic
metals. .
'!he selected remedial action includes: removal of all drums and
highly contaminated municipal refuse from Pit 5 for disposal at a
ECRA-regulated facility, clay capping (with gas venting systems) of Pits
2, 3, and 5, installation of surface water drainage diversion and
construction of a leachate collection and treatment system for all three
pits, removal and disposal of the top layer of contaminated soil from the
bore hole pit and the access road, reconstruction of the road with
appropriate drainage and sedimentation controls, and removal of the dried
paint and contaminated soil in the paint spill area for off-site disposal
of a ECRA-regulated facility. '!he estimated total project capital cost
for these remedial actions is $8,200,000.
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SITE:
Lackawanna Refuse Site, Old Forge, Lackawanna County, Pennsylvania
Documents Reviewed:
I am basing my decision principally on the following documents describing
the analysis of cost effectiveness and feasibility of remedial alternatives
for the Lackawanna Refuse Site:
"Remedial Investigation Report": Lackawanna Refuse Site, Lackawanna County,
Pennsylvania (NUS Corp. August 1984)
"Feasibility Study of Alternatives": Lackawanna Refuse Site, Lackawanna
County, Pennsylvania (NUS Corp. February 1985)
"Remedial Action Master Plan": Lackawanna Refuse Site, Lackawanna County,
Pennsylvania (NUS Corp. June 1983)
"Field Inspection Report-Lackawanna Refuse Removal Inc. "
Enforcement Investigation Center, October 2, 1980)
(EPA National
Staff Summaries and recommendations
Recommendations by the Pennsylvania Department of Environmental Resources
Description of the Selected Remedy:
Removal of all drums and highly contaminated municipal refuse from Pit 5 for
off-site disposal at a qualifying RCRA facility.
Construction of a clay cap over Pits 2, 3, and 5 to meet RCRA requirements.
Installation of surface water drainage diversion around all three pits and
construction of a leachate collection and treatment system for all three
pits.
Construction of a gas venting system through the caps of a~l three pits.
Removal of the top layer of contaminated soil from the borehole pit for
off-site disposal at ~ qualifying RCRA facility and returning to grade
with a soil cover.
Removal of the toP. layer of contaminated soil from the access road and
reconstruction of the road with appropriate drainage and sedimentation
controls.
Removal of the dried paint and contaminated soil in the paint spill area
for off-site disposal at a qualifying RCRA facility.
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Development of a monitoring program during the re>medial action, to include
monitoring the existing wells on-site, the gas venting system and the
leachate treatment system.
Operation and maintenance to be implemented by the Commonwealth of
Pennsylvania (the State). Quarterly inspections of the site will be
performed and any repairs necessary to the cap will be made. The
leachate collection and treatment system and any gas treatment
found to be necessary through the monitoring system will be operated
by the State.
Declarations
Consistent with the Comprehensive Environmental Respons~ and Compensation
and Liability Act of 1980 (CERCLA) (42 U.S.C. ~9601-96S7) and the National
Contingency Plan (40 CFR Part 300), and ~101(24) of CERCLA, 1 have determined
that the remedial action described above, together with proper operation
and maintenance constitute a cost-effective remedy which mitigates and
minimizes damage to public health, welfare, and the environment. The
remedial action provides for the removal of large quantities of drums
of hazardous waste and minimizes the threat of further contamination
of the environment. The remedial action does not affect or violate
any floodplain or wetland areas. The Commonwealth of Pennsylvania has
been consulted and agrees with the approved remedy. In addition, the.
action will require future operation and maintenance activities to
ensure the continued effectiveness of the remedies. These activities
will be considered part of the approved action and eligible for Trust
Fund monies for a period of six months following completion of construction.
I have determined that the action being taken is appropriate when
balanced against the availability of Trust Fund montes for use at other
site.
3~~/r;s
5;/qLc~.
DATE
Stanley L. Laskowski
Acting Regional Administrator
> EPA Region IIr
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SUMMARY OF REMEDIAL ALTERNATIVES SELECTION
LACKAWANNA REFUSE SUPERFUND SITE
SITE DESCRIPTION (See Figures 1, 2)
The Lackawanna Refuse site is located along a section of the north-south
border between the Borough of Old Forge and Ransom Township, in Lackawanna
o 0
County, Pennsylvania (at 41 22'35" N latitude and 75 44'55" W longitude).
The site is closely bordered by several houses to the east and by the Villa
Corporation Trailer Park to the south. Austin Heights, a residential sec-
tion of Old Forge Borough, is northeast of the site. The area west of the
site is forested steep hills. Approximately 9000 persons live within one
mile of the site. The local residents do not depend on groundwater as a .
source of drinking water, but obtain water through a public system derived
from reservoirs several miles to the north. .
The site is located above the floodplains of the St. Johns Creek and the
Lackawanna River. Several intermittent streams and drainage ditches, which
generally flow to the south and east toward St. Johns Creek, are located
on the site. The St. Johns Creek, flowing along the lower (eastern) edge
of the site, is an intermittent stream that is a tributary of the Lackawanna
River, which flows into the Susquehanna River. Although there are no
downstream users of surface water for drinking for more than three miles
from the site, the Lackawanna and Susquehanna Rivers are used for boating,
fishing, and recreation. Additionally, the St. Johns Creek flows by another
Superfund site (Taylor Borough) and several mine drainage areas before
passing the Lackawanna site.
Five strip mine pits of five to six acres each were excavated in this
area during the last century, and three were later used for waste disposal in
the 1970's. Two pits were used for the disposal of municipal and commercial
refuse. Two pits were never used and remain empty. The last pit (known
as Pit 5) contains about 15,000 buried drums of hazardous waste as well as
municipal refuse. Unknown quantities of bulk liquid wastes were reportedly
dumped or spilled from disposal vehicles onto the acceSs road to the pits
and into an adjacent depression, known as the "Borehole Pit." (See FIG. 2)
Pit 5 is approximately five acres and is estimated to be 30-50 feet deep.
The pit has only a thin cover of soil above che waste. In i979, the Pennsyl-
vania Department of Environmental Resources (PADER) .responded to complaints
by local ~esidents of trucks dumping hazardous substances in the open pit.
In September of 1980, following the State's investigation and sampling
effort, which revealed drums of solvent-like materials onsite, EPA's National
Enforcement Investigation Center (NEIC) conducted an assistance investigation,
and removed approximately 200 drums from six locations across the pits for
sampling. The contents of twenty drums were sampled and found to contain
various quantities and mixtures of hazardous waste. These consisted of
various solvents, paints and thinners, sludges, organic acids, and toxic
metals. A list of what was found includes cobalt, chromium, lead, titanium,
molybdinum, and zinc; as well as acetone, ethylbenzene, TCE, chloroform,
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methylene chloride, carbon tetrachloride, trichlorobenzene, MIBK, and
vinyl chloride. Concentrations in some samples measured 20-30%. No further
removal of drums was undertaken since the NEIC investigation.
SITE GEOLOGY
The Lackawanna Valley, a canoe-shaped trough extending both north and
south of the site, consists of sandstones and shales, along with numerous
deposits or seams of anthracite coal. The coalfield in this valley, known
as the Northern Anthracite Field, was mined from the early nineteenth
century until the mid-twentieth century. The valley is flanked by ridges
of rock. As a result of the folding of the uppermost of the rock units
(the Llewellyn Formation), a series of basins have been created with mine
pools below them. In the Scranton Wilkes-Barre region a vast series of
mine pools extends for miles beneath the Valley and forms the base level
for all groundwater flowing through the site. Groundwater collects within
a mine pool until it is higher than the structure enclosing it and overflows
into the next pool; eventually it is discharged into the Lackawanna River
south of the site. Flows from two outfalls about one mile south of the
site in the Lackawanna River have been measured at 20 and 40 million gallons
per day.
The area containing the pits consists of disturbed glacial till and mine
spoil, carbonaceous shale and coal fragments, sand, silt, gravel, cobbles,
and boulders. The area east (downgradient) of the site consists of decomposed
sandstone fragments overlain by sand and gravel with mine spoils above. .
Six seams of coal lie under the site. (See FIG. 3)
In addition to the strip mining, the six coal seams underlying the site
were extensively deep mined. Mine maps indicate that an additional seam,
the Checker, was originally present on parts of the site but was stripped
in Pits 1 and 5. It may be inferred that the interface between the spoil
and the rock at this location represents the base of the Checker coal (see
FIG. 4 for cross-section), since the drilling of Monitoring Well No. 10
required boring through 107 feet of mine spoil before hitting rock.
Subsidence studies and estimates prepared by the Appalachian Regional
Council indicate that this site is likely to subside three to twenty or
more feet. Because these studies covered a large region of which the Lacka-
wanna site was only a small part, this estimate is broad. According to
mine maps on file at .the Office of Surface Mining in Wilkes-Barre, four
mines were operated under the site, and approximately 50% of the coal was
left in place as pillars. We therefore expect future subsidence to range
only between three and seven feet. (See FIG. 4, which summarizes findings
obtained from the mine maps.)
HYDROGEOLOGY
Air shafts, boreholes, vents, mine shafts and other vertical conduits
created by the deep mining and fractured rock have precluded the formation
of a continuous groundwater aquifer under the site. It is likely that the
groundwater under the site flows to the east but is quickly transported
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through the underlying fractured rock to the mine pool. Although site
investigations revealed several areas of perched water within the garbage
layers and small areas of unconsolidated deposits of shallow water below
the site, no continuous system of groundwater was discovered.
The primary threat to the groundwater at the site comes from leachate
from the hazardous wastes deposited in Pit 5., This leachate is produced
from surface water and rainfall that percolate through the mine spoil and
soil cover into the waste. Shallow groundwater flows through the wastes
in Pits 2 and 3 and emerges in some areas as seeps, which flow offsitd
to the Villa Corporation Trailer Park. These seeps probably resulted from
groundwater flowing along pre-existing stream drainage areas. In addition,
there are smaller seeps in the north end of these two pits that probably
resulted from groundwater flowing along the shallow impermeable zones
within the old landfilled area. These watercourses emerge from the waste
downgradient along the edge of the pits and emanate as seeps which can
flow offsite during wet periods.
Much of the water also percolates through the waste into the perched
water zones and then through the lower formations into the mine pool.
Test pits dug into the waste verified the existence of confined, shallow
layers of water moving across the waste, and the monitoring well installed
at the eastern side of Pit 5 showed contamination in the groundwater
similar to that found in some of the leachate seeps at the site. Borings
drilled near the creek and the drainage ditch downslope of the pits encoun-
tered no groundwater that would discharge to the creek. Although a well
was placed in the minepool beneath the site, no contaminants from the site
were measured, probably due to the enormous volume of the pool diluting
small amounts of contaminants to below background level. Moreover, the
lack of a continuous groundwater system below the site precludes effective
monitoring of contaminants from the pits.
In sum, there is no continuous groundwater flow at the site. Shallow
groundwater passing through the waste carries contaminants across the site
as it emerges as seeps and leachate streams. The remainder of the groundwater
migrates down to the minepool beneath the site.
SITE HISTORY
The. Lackawanna Refuse site consists of five strip mine pits excavated
in the nineteenth century and used in the 1970's as a permitted-municipal
refuse landfill. In 1973 a State permit was issued for the disposal of solid
wastes with the condition that the leachate collection syt.em approved in
the permit application be installed within sixty days after receiving notifica-
tion from the PADER. In 1978 the permit was modified to allow disposal
of sludges. Pits 2 and 3 were used for the disposal of municipal refuse
alone; each of these pits is approximately six acres. After these two
pits were filled to capacity in 1976, Pit 5 was used for refuse disposal.
This pit, as well as Pits 2 and 3, were unlined. Boreholes, airshafts and
rock fractures allowed wastes to migrate via seeps and shallow groundwater
from the pits. The leachate collection system was never installed.
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In March 1979, the PADER issued an order suspending the solid waste
permit and requiring immediate cessation of the landfill after discovering
evidence of the dumping of industrial wastes and pollutants into Pit 5.
The order also required Lackawanna Refuse to dig up and dispose of buried
drums containing hazardous wastes and all contaminated soil. The PA DER
issued a second order in 1979 requiring the Company to construct and operate
a leachate collection system. The Company failed to comply with these
orders, and the owner, Peter Iacavazzi, Sr., was brought to trial in 1982
in the State court on criminal charges and found guilty of illegal dumping.
He was subsequently released after taking into account his advanced age and
poor physical condition. He also pleaded guilty to failing to notify EPA
that hazardous substances were disposed of and paid a $30,000 fine.
During pre-trial hearings, operators of trucking firms testified that
they brought drums of hazardous waste to the site and dumped. them into Pit
5. Estimates ranged between 10,000 - 20,000 drums, although one truck
driver estimated the quantity to be closer to 500,000. There were also
allegations that radioactive waste was disposed of at the site in heavy
drums that were lined with some tnick material. Other information gathered
during this time included allegations that bulk liquid wastes were disposed
of in a depression on the hillside known as the "borehole pit", and that
some amount of liquids were sprayed on the access road to the site for
dust control.'
In 1978, a cloud of white "vapor" was released from
truck driver allegedly dumped his load of waste into the
from this release moved down the mountainside and caused
and breathing difficulty in the residents of Old Fqrge.
area was evacuated by the local authorities during this
the potential for this kind of release that most alarms
and has created an active citizen group involved in the
remedy for this site.
the site when a
pits. The gases
eye irritation
The immediate
incident. It is
the local residents
selection of a
In 1979, the PADER investigated the conditions in Pit 5 by excavating
some of the area and drums. In 1980, the State requested EPA assistance
and the Region responded by coordinating with the National Enforcement
Investigation Center (NEIC) to conduct further excavation and analysis of
the drums in Pit 5. NEIC excavated seven test areas in Pit 5, uncovering
200 drums at depths of five to thirty f~~t below the surface of the
pit. Approximately 90% of the drums were found to be broken or crushed
when they were excavated.
Analysis was performed on twenty of the drums containing liquids or
sludges and the results showed high concentrations of solvents and paint
waste material with high metal and solvent contents. Metals found included
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cadmium, chromium, copper, lead, and mercury. Organics included benzene,
toluene, methylene chloride, carbon tetrachloride, ethylbenzene and trichlo-
roethylene (see FIG. 7). No evidence of the disposal of radioactive
waste was observed in these or any subsequent investigations at the site.
A site investigation by the Environmental Response Team (ERT) in 1982
revealed volatile organic vapors being released from Pit 5 at low levels.
These gases included vinyl chloride, a known carcinogen. Data collected
were used in applying the Hazard Ranking System to the site, which resulted
in an overall score of 36.57. A Remedial Action Master Plan (RAMP) was
prepared in June 1983, and the Remedial Investigation, Feasibility Study
(RIfFS) workplan was prepared in August 1983. Work on the RI began the same
month.
Removal activities were conducted at the site in September 1983 when
EPA installed a chainlink gate at the beginning of the access road to
control vehicular traffic, and a chainlink fence around all three pit
areas to prevent unauthorized access to the site.
CURRENT SITE STATUS
A RI was conducted by
to November 1984. A brief
they are grouped according
environmental concerns.
NUS Corporation during the period August 1983
summary of. the findings follows; for clarity,
to specific site locations and specific
A. Site Locations
PIT 5:
NEIC performed its excavation test of the site in 1980. At that
time they uncovered 200 drums from six locations across Pit 5 and from depths
of five to thirty feet below the pit. The contents of eighteen of these
drums were analyzed and found to contain high concentrations of solvents
and some heavy metals. No further excavation was performed in Pit 5 after
the NEIC report.
Magnetometer and vertical electrical soundings were conducted to
locate concentrations of drums buried in the pit. According to this data,
there are approximately 15,000 drums buried on the site, and they are not
confined to anyone area or "cell" of the fill (which is approximately
thirty to forty-five feet deep). According to the results of the NEIC studies
and testimony by former site operators, the majority of the drums are
crushed or broken. The waste material and garbage immediately surrounding
the broken drums are thought to be contaminated with the contents of the
drums. M~jor contaminants found during sampling were cadmium, chromium,
copper, lead, nickel, mercury, titanium, benzene, ethylbenzene, toluene,
methylene chloride, and TCE (see FIG. 7).
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The groundwater in the area of Pit 5 was monitored in Well No.4.
Although only several inorganic chemicals were found above background level,
many organic chemicals were detected at high levels. These include acetone,
2-butanone, 1,2-dichloroethane, methylene chloride, phenol and toluene.
The monitoring well in the mine pool was not able to detect any of these
compounds, but this may be because of dilution and/or the flushing action
of the pool water. Most other wells had little or no water and this water
showed little contamination. (See FIG. 6)
Leachate seeps from Pit 5 were sampled and found to contain some
low level inorganic contamination and higher levels of organics, including
2-butanone, 4-methylphenol, isopherone, and diethyl phthalate at concentrations
ranging up to 2,400 ppb. (See FIG. 7)
Air monitoring during site visits detected only one incident of a
measurable air release. This occurred as a transient photoionizer reading
near a leachate seep in Pit 5 on a hot day. No air sampling was done at
that time, and the release was not measureable a few yards away.
. PITS 2,3:
Magnetometer readings at these pits were similar to those obtained
over Pit 5, which is known to contain approximately 15,000 drums. A set of
exploratory excavations was performed in April 1984 and again in November
1984 using the magnetometer readings as guides. The first set consisted of
shallow excavations (less than 10 feet), and the second set consisted of
two excavations dug approximately thirty feet through the fill until clean
undisturbed soil was found for five to six feet. Because these excavations
turned up only several five-gallon pails and one thirty-gallon drum in the
several thousand cubic yards of material excavated, it may be inferred that
the municipal refuse in these pits contains the typical amount of commercial
or industrial waste (e.g., household solvents and cleaners and paint wastes
from non-commercial use). Leachate containing both organic and inorganic
contaminants leaves Pits 2 and 3 and migrates to the Villa Corporation
property south of the site. (See FIG. 7). No air releases were measured
at Pits 2 and 3.
BOREHOLE PIT:
Reportedly, bulk liquid wastes were dumped into this arca (about
4,000 to 5,000 square feet) during the operation of the site. It is likely
that any boreholes in the pit would have transmitted the waste-down to the
mine pool under the site. A thorough visual examination of the pit revealed
no sign of any boreholes, but they were probably filled in naturally through
erosion and sedimentation over the years.
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Sample analysis shows very low levels of contam1nants in the 50115
from the Borehole Pit. One soil sample from the surface (SO-26) showed
slightly elevated levels of cadmium, copper, nickel, tin and zinc. Only
tetrachloroethylene and toluene were measured in the soil and then only
at near the detection limits (NO - 3.5 ppb). It 1s suspected that the
contamination 15 confined to the upper layer of soil due to the known low
migration properties of the metals in soils. (See FIG. 8)
. ACCESS ROAD:
The local residents report that liquid hazardous wastes were
disposed of on the surface of the access road as a method of dust control.
Leachate from the area behind Pit 5 flows across the road and into the
surface drainage ditches or into the borehole pit. Analysis of the road
area soils reveals very low levels of contamination by either inorganics
or organics. Slightly elevated levels of cadmium, iron, manganese and
zinc were found, along with low concentrations of two phthalates at 1.5 and
1.6 ppm, and toluene at 5ppb. The source cannot be determined, however,
since contaminated runoff and leachate have probably flowed across the road
periodically since the operation of the facility. (See FIG. 8)
. Paint Spill:
A small area of dried paint (approximately 100 square feet) is
located along the side of the access road. Tests show that this paint is a
RCRA-defined hazardous waste, since it can leach toxic heavy metals (e.g.,
lead) .
B. Environmental Concerns
. OFF-SITE WELLS:
Three off-site wells are located in the' area near the site.
None of these wells are used for drinking water, but they were analyzed as
part of the RI. Dieldrin, a pesticide, was found in one well ( See FIG. 5).
Although the source of this contamination is unknown, there appears to be
no connection between the well and the groundwater or surface water that
flows from the site. Soil analysis at three homes near the site showed
only slightly elevat~d zinc le~e!e. which may be related to the composition
of soil native to that area. .
. LEACHATE:
Leachate has been observed emanaLl~g from Pits 2 and 3 and leaving
the site area to the south. This leachate contains both organic and inorganic
contaminants derived from the flow of shallow groundwater and infiltration
through the garbage in the pits.
Some leachate has also been identified with the Pit 5 area and
emanates from the spoil area east of the pit. Analyses were performed on
the leachate seeps which emanate from Pit 5. These seeps are known to
flow both to the Villa Corporation property south of the site, to the
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borehole pit, and to the intermittent drainage ditches flowing into the
St. John's creek. Once again, these analyses showed low concentrations of
metals and higher concentrations of organic contamination. The organic
contaminates include acetone, benzene, 2-butanone, 2-hexanone, toluene,
vinyl chloride and xylene. (See FIG. 7)
Surface water flowing across Pit 5 and out of the north end of
the pit was analyzed and also found to contain acetone, 2-butanone, 1,1
dichloroethane, 1,2 dichloroethane, methylene chloride, toluene and
xylenes, along with other organics. Analyses of other seeps oneite show
similar or higher contaminant levels. It is possible that, as a result of
the groundwater and infiltration percolating down to the mine pool, there
are fewer seeps near Pit 5 than there are near the other two pits. The
seeps near Pit 5 lie close to the surface, where insufficient soil cover
may have allowed contaminants to be flushed from the surface over the
years. In contrast to the seeps from Pits 2 and 3, which lie at the base
of the fill and can form shallow groundwater that flows through the garbage
in thin layers, the seeps near Pit 5 do not easily flow through layers,
because the pit area is depressed in relatiQn to the surrounding spoil area.
. SURFACE WATER:
The intermittent drainage ditches flowing across the site and to
the St. Johns Creek were sampled. The Creek was sampled both above and
below the confluence with the drainage from the Lackawanna site. Results
of the sampling showed that in the water column several contaminants,
including acetone, 2-butanone and 4-methyl-2-pentanone, increase downstream,
but that in the stream sediments, the amount of contaminant compounds
increases upstream of the site (See FIGS. 9, 10). The St. Johns Creek,
which flows past another Superfund site two miles upstream of this site,
probably receives drainage from other mined areas nearby, and this drainage
could affect sampling results.
The Old Forge outfall, one mile below the site in the Lackawanna
River, was also sampled, and no contaminants traceable to the site were
measured. Dilution in the mine pool, however, may have distorted the
samples.
WILDLIFE RELATED TO THE FOOD CHAIN:
Because the local residents hunt game in the area, in 1984 the
U.S. Fish and Wildlife Service conducte~ a study of wildlife living on or
near the pits. During this study, voles, mice, chipmunks, and rabbits
were trapped at the site. Eleven mice, five rabbits, along with ten fish
caught in the Lackawanna River, were examined by a veterinary pathologist,
and tissue samples from these animals were analyzed in a contract laboratory.
Results of the analyses show that these animals had measurable levels of
both organic and inorganic contaminants in their tissue. Most notably,
the level of nickel was high enough (1.8mg/kg) to make human consumption
of less than six grams of rabbit meat exceed the FDA's allowable daily
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intake for nickel. PCB (Arochlor 1260)- l_l,l-trichloroethylene- Dieldrin
and benzene were all found in the fish caught in the Lackawanna River at
levels that would warrant limiting intake of these fish. It should be
noted, however, that the Lackawanna River receives contaminants from many
sources other than the Lackawanna Refuse site and that the fish contamination
may not be site-related.
ALTERNATIVES EVALUATION
A. Objectives
The major objective of remedial action at the Lackawanna Refuse site
is to eliminate or at least mitigate environmental contamination: (1) in
Pits No.2, No. 3- and No.5, (2) in the borehole pit, (3) in the surface
soils and paint spill along portibns of the access road, (4) in leachate-
affected areas throughout the site, and (5) in the intermittent drainage
ditches adjacent to the site.
The overall strategy is to mitigate and minimize harm to the public
health and the environment. This should include minimizing further
groundwater contamination and the possibility of direct contact with the
waste. . Leachate control may be an integral part of the overall scheme in
order to eliminate the continuing migration of contaminants across the
site and off the site to the St. Johns Creek. Implementation of these
measures will benefit both the health of the local residents, as well as
the environment. Contamination of the food chain will be eliminated by
both the prevention of contact with the waste areas as well as the prevention
of leachate migration into the local watercourses.
Off-site concerns stem mainly from the leachate flows that migrate
from the site to the Villa Corporation property and along the access road
to the St. John's. Creek. A secondary concern is the potential for a large
air release of toxic vapors should one or more drums in Pit 5 rupture and
release their contents or react with other constituents in Pit 5. From
air tracer studies conducted during the Remedial Investigation, it is
known that prevailing winds could carry a release of harmful gases from
the pits directly over Old Forge. Although the potential for this sort of
occurrence is remote, the proposed action should nevertheless address the
possibility of this sort of release.
K-final site concern, raised by the U.S. Fish and Wildlife Service
(which'conducted the animal studies at the site), is that the animals in
the vicinity have accumulated chemical contaminants in their tissue.
There is a possibility of food chain accumulation in local predators, and
fish caught in the Lackawanna R~ver- downstream of the Old Forge mine
outfall, have contaminants which may have come from the site.
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The effect of the site on the outfall can be determined from a number
of facts. First, it is known that the outfall has a flow of thirty to
forty million gallons per day and drains the mine pool under the site.
Small amounts (less than one pint) of liquid leaking from buried drums and
entering the mine pool, assuming even dilution throughout the flow, could
exceed part-per-million levels in the discharge. For many organic compounds,
this will be in excess of water quality criteria or other limits recommended
by Federal and State agencies. .
The recommended remedial measures should focus on minimizing further
releases of contaminants from the drums buried in Pit 5 and the leachate
flows from all the pits. Additionally, the potential for further release
of contaminants through erosion of the access road and the borehole pit
should be mitigated.
o
Initial formulation and development of potential alternative actions
was based both on generic remedies and possible technologies. Initial
screening of technologies was based on: 1) the reliability and effectiveness
of the technology in protecting the population and the environment potentially
at risk from site contamination, 2) the engineering feasibility of the
technology for implementing the proposed remedies at the Lackawanna Refuse
site, and 3) costs involved in installing or implementing the technology.
The general response actions reviewed and the potential
retained following EPA's screening process are shown in FIG.
discussion of each of these alternatives follows (see also:
Alternatives, Fig. 13).
technologies
11. A detailed
Summary of
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B.
Analysis of Alternatives
PIT 5 REMEDIAL ALTERNATIVES
Alternative lA - No Action
This alternative involves no remedial action and leaves the site in
its existing state. Long-term monitoring and analyses of air, groundwater,
and surface water may be implemented, including the installation of a mon-
itoring well system. The site would continue to be a source of contamina-
tion. This landfill, in existence for about twelve years, is relati7ely
young. Therefore, it is likely to produce leachate that will, with time,
increase in strength. The possibility of the public coming into direct
contact with the hazardous substances or leachate would remain, and the
risk of toxic gaseous emissions would increase as the substances decompose.
Contamination of nearby surface waters would ~ontinue as leachate
flows unchecked off-site. The mine pool would continue to act as a "sink"
for any contaminated groundwater and would carry the contaminants to the
Lackawanna River. Subsidence or natural decay could rupture the buried
drums and release their hazardous wastes. Monitoring well data would be
unreliable due to the absence of a continuous groundwater flow under the
site, and releases would not necessarily be measured. Contamination of
the food chain would continue on site and may endanger local predators.
No additional protection to the public health or environment would be
provided under this alternative. "No-action" has been taken at many
hazardous waste sites prior to the implementation of a remedial action
and is.one reason why these sites continue to endanger the public.. There
would be no capital costs for this alternative.
Alternative 1B - Capping, Leachate Collection and Treatment On Site, Gas
Collection
The purpose of this alternative is to minimize the effect of the
contaminants in Pit 5 by reducing risks associated with direct contact and
by reducing contaminant migration via the intermittent surface water runoff.
A cap would be constructed over the existing wastes to minimize surface water
infiltration. Leachate from the waste would be less than the existing
amount, provided the cap 18 properly conatructed and maintained.
This alternative involves the construction of a clay cap (see Fig. 12)
over the pit. The drums and contaminated garbage would remain~n place
and be covered by the cap. Diversion ditches and berms would be installed
around the perimeter' of the ca~~ed area to minimize surface water runoff.
A leachate collection system to collect residual leachate would be installed
downgradient of Pit 5, and any leachate generated would be collected and
treated on site. A passive gas venting system would be integrated into
the capping system.
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(12)
The cap would be constructed to meet the requirements of RCRA in that
it would be less permeable than the bottom of the pit, and it would be
designed with the knowledge that some subsidence (three to seven feet) may
still occur in mines beneath the pits. Specific types of clay, moisture
content and placement would be determined during the design phase. The
small amount of total future subsidence predicted for the site would be
accommodated by the design. In addition, quarterly maintenance inspections
by the State should identify any subsidence, and repairs would be made to the
cap.
Any precipitation that percolates through the topsoil covering the cap
would be conveyed through the flow zone (along the top of the clay) and
then away from the pit area (see FIG. 12). Leachate collection pipe drains
(four inch diameter PVC perforated pipe) would be placed along the downgrad-
ient eastern edge of the pit, and leachate that currently emanates as seeps
would be collected by these drains. A drainage blanket of gravel or crushed
stone would also be placed on top of the waste, but below the clay portion
of the cap along the downgradient face of the fill, to facilitate leachate
collection.
Leachate treatment would be performed on site with the resulting residual
material being removed to a qualifying RCRA facility. Because of the contin-
uous nature of the leachate flows during wet weather and the expected volume,
transporting the leachate off-site for treatment was ruled out. Treated
effluent would be discharged under State permits to the St. Johns Creek or
to the Lower Lackawanna Valley Sewage Treatment Plant. It is anticipated
that the quantity of leachate will vary throughout the year and with weather
conditions, amounting to 10,000 - 20,000 gallons per day during the highest
flow periods. The installation of the cap and surface water diversion system
would slow the infiltration of water and subsequent leachate production; it
is thus expected that during the five years following construction of the cap,
the leachate production will drop substantially as the garbage dries out.
Operation and Maintenance would still be needed to observe the flows and
treat whatever leachate is produced after this time.
Although methane gas has not yet been detected near Pit 5, it is expected
that at some time the decomposing garbage in the landfill will start to
produce methane. Therefore, it would be necessary to provide for the venting
of this methane gas as well as other landfill gases. A passive collection
system composed of gravel channels, perforated pipe, and vent pipes is
propose4. to permit the normal landfill gases to migrate upward ~o the air
without causing pressure that could damage the cap. The gas venting system
would also require monitoring to determine if toxic organic vapors are being
released and to determine lhe need for treatment. Should mine subsidence or
consolidation of the landfill material become significant, the reliability
of these remedial measures may decrease.
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(13 )
As in ~lternative lA above, groundwater monitoring would not be totally
satisfactory, due to the absence of a continuous groundwater system. The
cap satisfies applicable criteria concerning design, as can be determined
from existing State and Federal policy advisories, and when properly con-
structed. would meet applicable and relevant performance standards. Permits.
other than local construction permits. or an NPDES permit for the leachate
discharge would not be required for implementation. Nevertheless. leaving
drums containing liquid hazardous wastes and solvents in the pit is incon-
sistent with those provisions of the Hazardous and Solid Waste Amendments
of 1984 that call for minimizing landfill disposal of containerized liquid
waste and call for the prohibition of landfill disposal of certain spent
solvents. This alternative would take approximately six months to complete.
and the capital costs are estimated to be $1.700.000.
Alternative lC - Partial Excavation. Capping, Incineration of Drums and
Contaminated Wastes Off-Site. Leachate Collection and Treatment On-Site.
Gas Collection
This alternative includes the installation of a clay cap (as described
under Alternative lB). installation of diversion ditches for surface water
runoff. a leachate collection and treatment system, and a passive gas
venting system. In addition. there would be "partial" excavation. This
excavation would remove all the buried drums and highly contaminated soils
and wastes but would leave non-contaminated and low-level contaminated
wastes in the pit. Prior to capping the site. all hazardous material that
was removed would be transported to an off-site. qualifying RCRA incinerator.
This excavation is being termed "partial" because it involves the removal
and incineration of all the drums and all the highly contaminated wastes;
however. those wastes determined to be equivalent to "normal" municipal
refuse would remain in the pit. This would be an effective means of
permanently reducing the source of contamination. In combination with a
cap. the overall performance of this option is also estimated to be very
effective in providing a barrier between the remaining wastes and the
environment and in minimizing damage to the public health.
Since this alternative would remove a major portion of the source of
hazardous contamination, along with providing the protection of a cap,
this would provide a higher degree of reliability in reducing off-site
migration of contaminants than Alternative lB. Subsidence or natural deter-
ioration would not allow the drums to release their contents into the pit.
The partial excavation would remove about 15.000 drums arid 4,260 cubic
yards of contaminated waste. This data is based on information obtained
during the Remedial Investigation phase of the Study. This alternative
would remove the hazardous wastes. and therefore. the primary source of
contamination from this area, although remaining nonhazardous wastes may
continue to generate leachate and gases. Although some wastes contaminated
at low levels would remain in place, the quantity is expected to be minimal.
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(14)
The cap portion of this alternative is easily constructed and thus
highly implementable. The partial excavation portion, however, would require
the establishment of guidelines to determine the degree of cleanup required.
The general approach that would be used to determine "action levels" for
excavation of contaminated material at Pit 5 involves: (1) designating
background levels of target compounds for the site and, (2) testing Pit 5
material for the extent of contamination relative to background levels. A
field screening program is proposed to do most of the required analyses on
site as excavation proceeds.
A sampling program would be established to obtain representative
samples for analysis that would establish background levels for target
compounds. Background levels for "clean" or uncontaminated garbage would
be determined from a statistically representative number of samples taken
from Pits 2 and 3, which contain "normal" municipal refuse. Background
levels for soil contamination would be determined from soil samples taken
from non-contaminated areas of the site. The target compounds to be analyzed
would be chosen based on compounds expected to be in the drums in Pit 5.
Complete analyses of these samples would be performed at a Contract Labor-
atory Program (CLP) laboratory.
Once the background levels for the compounds are designated, field
screening for the extent of contamination of the materials in Pit 5 could
begin. Samples for field screening analysis could be obtained from pre-set
increments of material being removed from Pit 5. This sampling/removal
approach would allow field action decisions to be made quickly and would thus
allow cleanup activities to proceed at a steady pace. Material found to
be "clean" will be left in or placed back into the pit, while all drums
(crushed or full) and all contaminated garbage is removed.
When contamination in the samples from Pit 5 reaches background levels,
either of "clean" garbage or soil, removal of materials will cease. At
this point samples from the pit boundaries (width and depth) will be taken
and analyzed at a CLP laboratory. This complete analysis would determine
whether or not removal of contaminants to background levels has been achieved.
As mentioned above, the only waste remaining in the pit would be the
municipal waste, which may contain low levels of contamination typical of
municipal refuse anywhere. Leachate would still be produced by the remaining
municipal waste, but the number and concentration of hazardous constituents
would be reduced significantly. The leachate collection and treatment system
proposed would eliminate the migration of leachate from the pits across the
site and to off-site areas. It would take approximately two years to excavate
and sort out the contaminated waste; capital costs are estimated to be
$8,200,000.
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(15)
Alternative lD - Partial Excavation, Capping, Incineration of Drums Off-
Site and Landfill Contaminated Waste Off-Site, Leachate Collection and
Treatment OnSite, Gas Collection
This alternative is similar to Alternative lC with regard to on site
remedial actions. The only difference between the two alternatives is that
the excavated contaminated bulk liquid wastes would be disposed of in a qual-
ifying RCRA hazardous waste landfill about 300 miles from Old Forge, Pennsyl-
vania, rather than be incinerated. The containerized liquid waste would
still be incinerated off-site. This would result in a slightly lower overall
cost than Alternative lC, since the cost of incineration is usually greater
than the cost of landfilling. The benefits of this alternative would be the
same at the site as those described for Alternative lC. The approximate time
to complete this remedy is two years; capital costs are estimated to be
$6,800,000.
Alternative IE - Total Excavation, Incineration of Drums Off-Site, Off-Site
Landfill Disposal of Other Wastes
This alternative represents the most comprehensive clean-up, since all
the waste material, hazardous and non-hazardous, would be removed from the
site. The drum contents would be incinerated and the remaining bulk liquid
would not be required. The excavation would be backfilled with clean, non-
leaching material, such as sand and gravel or crushed stone. This alternative
would also remove any possibility of direct contact with the waste or leach-
ate and would eliminate potential releases to the air or groundwater. It
would take two years to excavate the pit. Because the quantity of waste
landfi1led is greatly increased for this alternative, the cost of excavation
and disposal, estimated at $33 million, would also be much greater' than
for other alternatives.
PITS 2 and 3 REMEDIAL ALTERNATIVES
Alternative 2A - No Action
This alternative would involve no remedial action and would leave the
site in its existing state. The no-action alternative for Pits 2 and 3
would involve only the implementation of a long-term monitoring program.
This program would include monitoring of the air, surface water, and ground-
water in the vicinity of the pits. The monitoring should include sampling
and. testing of the air, water and stream sediments for the presence of
pollutants known to exist at the site, but would involve the same problems
described under lA.
Experience with this alternative at other hazardous waste sites has
demonstrated that these pits would continue to be a source of serious health
problems from direct contact with.the waste, surface water contamination,
and possible groundwater contamination. Without a cap, infiltration would
continue to produce leachate that would eventually convey pollutants into
nearby streams and watercourses. In its existing condition, the material
in Pits 2 and 3 is relatively accessible to the general public, and thus
direct contact with the waste or leachate is a concern. There would be no
capital costs.
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(16)
Alternative 2B - Capping, Leachate Collection and Treatment On Site, Gas
Collection
This alternative includes construction of a clay cap (See Fig. 12)
over the contents of Pits 2 and 3, collection of the surface leachate,
treatment of the leachate on site, and collection of and venting gas emanating
from the landfill. The risk to public health and the environment would be
minimized due to control of the migration of pollutants into the air, the
ground, and the groundwater.
Based on a review of the existing site conditions and the characteristics
of the landfilled wastes, this alternative can be considered an effective
method to control the migration of pollutants in the air, into the ground,
and in the groundwater.
The clay cap, which would be continuous with the cap constructed over
Pit 5 (assuming a cap alternative is chosen for Pit 5), would reduce the
amount of leachate, which is caused by infiltration of rainwater through
the landfill wastes. Lateral upgradient infiltration is not expected to
be a concern because of the low permeability of the soils in this area of
the site. Infiltration that passes through the two feet of soil would be
intercepted by the drainage layer and diverted from the landfill. Since
the quantity of infiltration would be reduced, groundwater contamination
should also decrease as the landfill stops serving as a source of migrating
pollutants. The only amount of leachate that would be generated after
capping would result from residual moisture in the waste and cap material
and from the minimal infiltration after cap installation. The cap would
also serve as a barrier between the wastes and the public, and thereby
decrease the risk of direct contact.
A passive gas collection system containing gravel 'channels, perforated
pipe, and vent pipes is proposed. Four-inch diameter PVC perforated pipe
will be installed as laterals under the cap to collect the landfill gases.
This venting and collecting system would be installed within the upper layers
of the wastes and vented through the cap. Although methane is not currently
being detected, at some time, the landfill wastes will start to produce
methane. Therefore, it would be necessary to provide for the venting of
the methane as well as other landfill gases.
Leachate generation would be controlled by the proposed leachate
collection system which would inhibit the leachate from flowing through
existing erosion gullies, ditches, and various seeps and thus from entering
surface waters. Currently, .the largest quantities of leachate are generated
from: (1) the seeps below Pit 3, (2) the sluice pipe seep, and (3) the
base of the ~;oil pile seep.
The discharge from each seep is directly related to previous rainfall.
Therefore, if the installation of a cap can reduce the infiltration, the
discharge from the seeps should also decrease. Surface waters would be
cleaner and would also decrease the possibility of public contact with the
leachate. It would take approximately six months to implement this alter-
native and capital costs are estimated to be $4,138,000.
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(17)
Alternative 2C - Total Excavation, Disposal Off Site
This alternative would require the complete removal of all wastes and
contaminated soils contained within Pits 2 and 3 and the backfilling of
the excavated area with an equal amount of clean sailor rock. The baseline
estimate for volume of excavation is 420,000 cubic yards. All wastes are
regarded as hazardous for the purpose of this evaluation and would be
transported and disposed of off-site at a qualifying RCRA facility. No
long-term monitoring would be required for total excavation, nor would
leachate or gas collection be required, since the source of both would be
removed.
Total excavation of contaminated waste is the most effective but also
the most expensive of the remedial alternatives. Since this area of the
site is the largest and contains the greatest volume of wastes, it may be
inferred that it will produce the greatest volume of contaminants subject
to migration. This contamination, however, may not be as toxic as that
from Pit 5, which contains the drums of hazardous substances.
This alternative would eliminate direct contact with the waste and
with the leachate seeps. It would take approximately two to three years
to excavate the pits, and capital costs are estimated to be $78,942,000.
BOREHOLE PIT REMEDIAL ALTERNATIVES
Alternative 3A - No Action
The no-action" alternative for this area would not involve monitoring,
analyses, nor soil removal activities; the site would remain in its existing
state. This alternative would not prevent or minimize risk to the public
health and to the environment, but this risk applies only to those few who
may come into direct contact with the exposed wastes and only to a very
limited degree. This alternative, therefore, could be used because the
relatively isolated location of this pit and the potential for limited
contamination would keep the degree of risk to the public very low.
Alternative 3B - Capping
This alternative includes the construction of a clay cap over the
borehole pit. Surface water flow over the cap would be diverted by dlverBion
ditches and/or berms placed along the upslope perimeter of the area. The
cap would reduce, but not eliminate, infiltration of the waste material.
Slight infiltration is acceptable, however, since the potential for contaminant
migration is relatively low even without a cap. This option would signi-
ficantly reduce any threats to the environment or public health that currently
exist. As a source control option, capping would minimize potential off-site
releases of contaminants and would prevent direct contact with the wastes.
It would take a~proximately three months to implement this alternative,
and the capital costs are egtimated to be $234,000.
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(18)
Alternative 3C - Excavation, Disposal Off-Site
This alternative includes the removal of
of contaminated soil in the borehole pit to a
the disposal of this material in a qualifying
approximatety 1,500 cubic yards
depth of about one foot and
RCRA facility.
Because the migration of metals in soils is
the contamination is in this top layer of soil.
would be used to insure reaching "clean" soil at
would take approximately four weeks to implement
capital costs are estimated to be $283,000.
slow, it is believed that
Sampling during excavation
background levels. It
this alternative, and the
ACCESS ROAD REMEDIAL ALTERNATIVES
Alternative 4A - No Action
This option would maintain the access road in its existing condition
and would not provide for environmental monitoring of surface or subsurface
hazardous substances.
Because the hazardous wastes were disposed on the surface of the road,
erosion and subsequent surface transport are primary concerns. Although
no off-site contamination has been discovered that can be directly attributed
to the access road, continued erosion is likely, and the contaminants on
the road would a180 be carried off-site into the St. Johns Creek. Therefore,
this alternative does not alleviate the existing threat of the spread of
contamination to the public and the environment. .
Alternative 4B - Excavation and Disposal Off-Site
This alternative would involve excavating the top twelve inches of
existing road material (consisting of dirt, gravel and mine spoil), instal-
ling sediment traps and culverts, and reconstructing a new roadway surface
along the 1,500 feet of the access road. The excavated material, approxi-
mately 1,650 cubic yards, would be transported and disposed of at a quali-
fying RCRA facility. Post-action monitoring along the access road is not
recommended, since excavation and off-site disposal of the excavated material
would provide a permanent remedial action (as long as the contaminated
water is kept off the roadway and the roadway is continuously maintained).
This option would reduce the possibility of future migration of contaminants
by remo~ing the contaminated material. Although it is believe~that most
of the contamination is in the top layer of soil, analysis during excavation
of deeper soils would allow excavation to "background" to be d~termined.
Construction related to implementation of this alternative would require
about three weeks to complete, and the benefits would be immediate. Capital
costs are estimated to be $284,000.
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(19)
Alternative 4C - Excavation, Disposal On Site
This alternative would involve the same remedial actions discussed under
Alternative 4B. This alternative differs in that the excavated roadway
material would be placed on top of the existing waste in Pits 2, 3, and 5.
This would be a technically feasible alternative, since the roadway is
coarse, aggregate material produced from the strip mining. This material
is not considered to be highly contaminated, and its disposal on the existing
landfill would therefore not significantly increase the threat to the
public health and environment. However, the amount of material to be excavated
will exceed the small quantity exclusion under RCRA (1000 kg); this would
preclude the disposal of the excavated material on-site. It would take
approximately three months to implement this alternative, and capital
costs are estimated to be $34,000.
PAINT SPILL REMEDIAL ALTERNATIVES
Alternative SA - No Action
The no-action alternative would not reduce the risk to public health,
because the contaminated material would remain in place. If the material
is left in place, it could be inadvertently excavated and used as backfill'
without knowledge of the soil contaminants. This has occurred at other
sites and could also happen at this site. There would be no capital costs.
Alternative SB - Excavation, Disposal Off-Site
Excavating the contaminated ground would be a highly effective method
of removing the spill. This is especially so since the paint waste is
clearly distinguishable and located within the top one foot of the ground.
An excavation of ten cubic yards would remove the paint from the soil and
would be backfilled to original grade.
Once the paint waste is excavated and the excav~tion backfilled,
the potential for this material being inadvertently taken by someone and
used would be eliminated. The estimated time to implement this alternative
is one week, and the capital costs are estimated to be $2,000.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
Alternatives were examined in light of relevant Federal, State and
local environmental program requirements for actions such as disturbances
of contaminated soils, and in light of all RCRA and CERCLA requirements
for the closure of hazardous waste landfills and for disposal of excavated
contaminants in off-site hazardous waste facilities, including landfills
and incinerators.
The remedial actions proposed will be coordinated with the State to
insure that any discharge of treated leachate will meet all permit require-
ments and that water and air quality will meet all applicable standards.
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(20)
RECOMMENDED ACTION
Section 300.68(j) of the National Contingency Plan (NCP) states that
the appropriate extent of remedy shall be determined by the lead agency's
selection of the remedial alternative which the agency determines is cost-
effective (i.e., the lowest cost alternative that is technologically
feasible and reliable) and which effectively mitigates and minimizes damage
to, and provides adequate protection of public health, welfare, or the
environment. Based on our evaluation of the cost-effectiveness of each of
the proposed alternatives, of the comments received from the public, and of
information received from the Pennsylvania Department of Environmental
Resources, we recommend:
Pit 5:
Alternative lC - Excavate all drums in the pit, along with all
contaminated garbage surrounding them. Uncontaminated waste will remain
in the pit. Excavated material would be incinerated if adequate capacity
is available at that time. If not, all liquids would be incinerated, but
the solid waste would be disposed of at a qualifying RCRA landfill in
compliance with EPA's current off-site disposal policy. The pit would
then be capped and a leachate collection and treatment system installed
in conjunction with the system at Pits 2 and 3.
The capping and leachate collection system would be necessary, since
the refuse remaining in place will leach hazardous substances contained
in the normal municipal waste disposed of in the pits. These contaminants
are found in the existing leachate and must be controlled. The cap and
collection system would control the flow of this leachate and eliminate
its migration off-site.
Pits 2 and 3:
Alternative 2B - Construct a clay cap over the pits and install
a leachate collection and treatment system on site. This cap and leachate
system would be continuous with the cap and leachate system constructed
for Pit 5. The treated leachate effluent flow would be via a permitted
discharge into the St. John's Creek or to a local sewage treatment system
capable of handling the flow.
Borehole Pit:
Alternative 3B - Excavate approximately the top one foot of
contaminated soil for disposal off-site at a qualifying RCRA facility.
The actual depth of excavation needed wouid be determined by sampling the
soil at intervals until background levels of contaminants are reached.
Due to the very low levels of contamination found in the Remedial Inves-
tigation, samples and the known low migration of metals through soil, it
is estimated that one foot would be sufficient.
In addition, to regrade the site and to further minimize contact
with the subsoils, a soil cover would be placed on the pit to a depth of
approximately two feet. This recommended alternative reflects comments
received during public review and therefore does not exactly reflect any
one alternative discussed above (from the Feasibility Study).
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(21)
The excavated material containing hazardous. substances would be
transported off-site to a qualifying RCRA facility. Disposal in the pits
on-site was ruled out because the purpose of the remedial action is to
remove hazardous waste from the pits, leaving only municipal refuse.
Access Road:
Alternative 48 - The top six to twelve inches of the access
road would be removed and disposed of off-site at a qualifying RCRA
facility. The road would then be regraded, drainage improved and a new
soil and gravel surface would be placed on top of the road. Disposal in the
pits on-site was ruled out, because the purpose of the remedial action is
to remove all hazardous waste from the pits, leaving only municipal refuse.
Paint Spill:
Alternative 58 - The paint spill area would be excavated and
disposed of off-site in a qualifying RCRA facility. Disposal in the pits
on-site of this RCRA hazardous waste was ruled out for the reasons given
above for the borehole pit and access road wastes.
In sum, EPA's recommended action includes those alternatives that
require excavation and off-site disposal of all drums and highly contaminated
fill material and wastes to a qualifying RCRA facility. These alternatives
were selected based on their reliability in eliminating the continued
generation and off-site migration of leachate from Pits 2 and 3 and the
continued contamination of the groundwater and mine pool beneath the site.
On-site disposal of the hazardous wastes was ruled out, because the borings
and hydrogeologic data indicate that the rock below the site is fractured
and contains numerous pathways for the contaminants and groundwater to
mix. Moreover, the absence of a continuous groundwater system would make
subsequent monitoring (a RCRA requirement) impossible, and the predicted
amount of subsidence (three to seven feet) can be accommodated by a properly
constructed clay cap.
To define excavation limits, background soil levels of inorganics
would be obtained from borings in "clean areas" away from the pits. This
data would be used to assess soil concentration background levels in the
borehole and access road areas. In Pit 5 organic contaminant levels would
be established by using background concentrations determined from a statis-
tical sampling from Pits 2 and 3, which contain typical municipal refuse
of approximately the same age as that in Pit 5. An ongoing contamination
detection program will be conducted during excavation to separate clean
material from contaminated waste.
Excavation of Pit 5 is expected to progress slowly (it will take at
least a year and a half) due to the need for frequent monitoring and sampling.
Continuous monitoring will be performed around the excavation to detect
any organic vapors being released by the excavation. Clean s011 or cover
will be readily available and could be rapidly placed by a bulldozer over
any material releasing harmful vapors. The selection of the hazardous
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( 22)
material to be excavated will be accomplished by a large-scale "sifting"
through the landfill waste. Only a small section of the pit would be open
at anyone time. and it is expected that excavation and removal of contam-
inated material will progress from one end of the pit to the other with
the excavated and "cleaned" area being closed as the next area to be worked
is opened.
To avoid creating a depression which would accumulate water and
accelerate the natural flushing of the waste. the excavated pits would be
backfilled and graded to prevent surface run-on and direct run-off. Site
reclamation after removal will include grading. capping and revegetation.
The fence and gates installed during the removal action will remain and
any repair necessary will be made.
Prior to commencing excavation. the following measures will be
implemented:
Decontamination and improvement of the access road to the
site to accommodate heavy equipment and truck tr~ffic. This is also the
chosen remedial alternative for the access road.
Formulation of an air monitoring plan and temporary
plan for protection of local residents. This will be similar to
~aken during the previous test pit excavations at the site.
evacuation
the measures
Transport and off-site disposal of all hazardous wastes will be con-
ducted in accordance with RCRA and Department of Transportation regulations.
Off-site incineration of excavated materials is the preferred method of
destroying hazardous substances. according to CERCLA Guidance. Should
incineration capacity be limited during the excavation period. however.
only the containerized liquid wastes would be sent to an incinerator. The
remainder of the hazardous wastes would go to a qualifying RCRA landfill.
Leachate Contaminated Soils
Small areas of soil along the bases of the pits and outside the existing
fence have been contaminated by leachate. Comments received during the
public review period asked that we address this problem. We plan to sample
these areas and excavate the contaminated soil down to background level.
Regrading to original contours would be made with clean topsoil. and the
area would be revegetated.
St. John's Creek
I
I .
The contaminants in the water of the Creek (see FIG. 9) should be
eliminated by the recommended remedial action. Leachate flow to the stream
would cease. and the low-level organic contaminants would no longer be
present. The low levels of organic contaminants in the stream sediments
are not a concern and. in fact. decrease downstream of the site.
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(23 )
Lackawanna River
Fish'caught in the River showed organic contaminants in their tissue.
These contaminants (pesticides and PCB's) were not directly attributable to
the site and most likely were from sources near the river. The recommended
remedial action at the Lackawanna site would eliminate any possible further
contribution of contaminants to the River from the site. The U.S. Fish and
Wildlife Service and the Pennsylvania Fish Commission will be given collected
data to determine what actions, if any, should be taken in the Lackawanna
River.
OPERATION AND MAINTENANCE
Post excavation activities will include the continued collection and
treatment of residual leachate and contaminted shallow groundwater. It is
expected that by removing the source of contamination the quality of leachate
and contaminated groundwater will gradually improve so that operation of
the treatment system will no longer be warranted. This time period is
estimated to be five years, according to the following schedule:
SCHEDULE
Approve Remedial Action (Sign ROD)
Amend Cooperative Agreement with COE for Design
Start Design
Complete Design
Amend Interagency Agreement for Construction
Start Construction
Complete Construction
3/31/85
3/31/85
June 1985
March 1986
March 1986
June 1986
September 1988
EVALUATION OF ALTERNATIVES NOT SELECTED
Pit 5:
Alternative lB, which allows capping, leachate collection and
treatment, and passive gas collection was not chosen due to the inability
of this alternative to remedy the continuing contamination of the groundwater
and the potential for further releases. Therefore, this alternative does not
adequately mitigate or minimize damage to public health and the environment.
It is known that the pit contains drums of liquid wastes which are flammable
and reactive. These drums are leaking and are mixed in with other Wastes.
Additionally, the site has been undermined and may be subject to subsidence.
As the drums deteriorate or subsidence occurs, it is likely that more drums
will be damaged and their contents released. This alternative also fails
to provide any monitoring for this kind of occurrence, since the contaminants
may flow directly into the mine pool. Additionally, the contents of the drums
could be released as toxic gases, and it is unlikely that periodic monitoring
would be able to identify a sudden release of the gas in sufficient time to
prevent harm to local residents.
-------
(24 )
Additionally, any releases would most likely require corrective
action. It would be difficult to define a plume of contamination under
emergency circumstances and impossible to try to control it without excavating
the leaking drums. This is what was already proposed in Alternatives
lC-E. Lastly, RCRA requirements under 40 C.F.R ~ 264 prohibit storage of
ignitable wastes under conditions existing in Pit 5 for the reasons listed
above.
Alternative lE, total excavation, was not chosen due to its
prohibitive expense ($3;3,500,000) and lack of clear advantages over "partial"
excavation, which is estimated to cost $8,200,000. Removal of all the
contaminated garbage and drums in Pit 5 under the recommended alternative
will still substantially reduce the risk of further releases; should any
mine subsidence occur, there will be no drums to rupture and release their
contents into the mine pool or into the air. The remaining waste is essen-
tially typical municipal waste and need not be excavated.
Pits 2 and 3:
Excavation of these pits was not chosen, since these pits do not
contain a large number of drums, as does Pit 5. Although these pits contain
mostly municipal refuse, it is possible that there are random drums of
industrial waste through the pits. Contaminants occur in the leachate
from these pits, but the selected alternative should address this problem..
Thus, there is no valid technical reason to excavate material from these
pits.
Borehole Pit:
While capping this pit, which has low levels of contamination,
would prevent direct contact with the material, there is still a potential
for further migration of the contaminents into the groundwater and mine pool
beneath the site. Excavation of the more highly contaminated top soil will
minimize this risk, however. Disposal of the hazardous soil into one of the
on-site pits was not chosen, since the purpose of our remedial action is to
remove hazardous materials off-site and to leave only municipal-type refuse.
The quantity of contaminated soil also exceeds the small quantity (less than
1000 kg) exclusion of RCRA; this precludes disposal of the excavated material
in Pits 2, 3 or 5.
Access Road:
Disposal of excavated material into the pits on-site was not
chosen, since it is the purpose of the remedial action to remove hazardous
wastes from the pits and to leave only municipal-type refuse. As with the
borehole pit, the quantities of contaminated soil will exceed the small
quantity exclusion of RCRA and must be transported off-site.
Paint Spill:
Disposal of the excavated material into the pits on-site was not
chosen for the same reasons as given above for the access road. The paint
spill is a RCRA-defined hazardous waste and the quantity expected to be
excavated will exceed the small quantity exclusion of RCRA. This is another
reason why the waste cannot be placed in Pits 2, 3 or 5.
-------
.,-- --
, .
.
.
.
LOCATION MAP
LACKAWANNA REFUSE SITE. OLD FORGE. PA
SCALE: I": 2000'
E1j~
C; A Halliburton Company
FIGURE 1
-------
"
\.. /')
TAYLOR~ /
BOROUGH I /
SITE J
/
( /,
'-./ 1/
PIT 3
OLD FORGE MINE
POOL OUTFALL
SUPERFUND SITE LOCATION MAP
LACKAWANNA REFUSE SITE. OLD FORGE. PA
II I
SCALE: I = 3000
TAYLOR
E1j~1!
o A Halliburton Company
FIGURE 2
-------
1100'
A SOUTHEAST
1000'
900'
800'
100'
600'
/'%j
H
C1
c:::
:::t'
t't1
l,.J
~; INFORMATION OBTAINED FROM DRILLING AND FROM MINE MAPS OF THE OLD FORGE COLLIERY
AT THE OFFICE OF SURFACE MINING, WILKES-BARRE,PA.
SECTION LINE .A-A' SHOWN ON FIGURES 3-10,3-11, a 3-12.
BOREHOLE PIT
EXISTING GRADE
CLARK COAL
UPPER RED ASH COAL HORIZON
MIDDLE RED ASH COAL
LOWER RED ASH COAL
--.---.
..--.--
~ALIZED CROSS SECTION
LACKAWANNA REFUSE SITE. OLD FORGE. PA
SCALE: 1":450' HORIZ.. I": IOO'VERT.
~~~
«) A Halliburton Company
-------
.
960
~
~
~
~
~
~
~
~
~
~
2~
2~
..l!!2--
680
~
M!L-
~
~
~
~
1140
NOT(. TI1f Pt:PTH MID T~SS 01 nc ~aa .TRATA INOoGATfO ON T...
CHOSS KCTIOII w[JI£ IitNUlAuUD'1IOM MID..IUIPtlUtD IIfTWUN IHf
TUT -...ciS '110M IQHIIICI DATA, '~LD OIIKIlVATIOIIS, AIItI UIOf'\.IiUII1tD
COAL - --- IIIfDIIMATIOII flUl.. DIU AT IHf LOCATIOII Of TlIf TUT
-..... AN) SUllSUlltIoU COHDITK»O IUWt:EH TUT ~ lIMY VARY
'110M THOSt: IHQICAUI). Pt:TAILW MRHG WGS - Pftllf"TUlIN AlftN-
... fi tIIOS' .'1I0Il LOCATIOHI AlIi SHf»M ON'XItJII( I-I.
~
/-..... ./-.....)
/ V . .
I~ /
I --~_/ ~ If'(JUI
.....
PIT 5
MICJOt.f NfD ASH COAL
--
&80
&601
I) 2:>0 :.00
~-...----,
HORIZONTAL .CALf IN r ffT
'"11
H
o
c::
:;d
tT1
po
.
"
.
960
~~Q .
9~O
-~
!!!!Q - -
_!!,?Q- -
!!'!Q
-'!!~Q n-
!!oo ---
/80
!!!Q
140
EQ --
- ~QQ
6110
"!~Q
640
610
._-- -.-
.~Qu
580
lll/I~Y~
: A II..UIIIUI II x\ CLK I ~)"IIV
.
-------
DOMESTIC WELLS - METALS AND ORGANICS (~g/I)
LACKAWANNA REFUSE SITE
SEPTEMBER 1983
Parameter
Domestic Wells
Concentration Ranqe
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Tin
Vanadium
Zinc
Acetone
Chloroform
Dieldrin
Methylene Chloride
<200 - 2000
<20
<10
<100 - 200
<5
<100
<1 - 4
<10
<50
<50
<50 - 500
<5 - 25
195 - 2300
<0.2
<40
<2
<10
<10
NO
<200
NO - 480 CF
NO - 25
NO
NO - 209"
NO
~g/i : - micrograms per liter (p p b)
NO not detected. not detected due to lab
blank"
CF corrected for field blank
< less than
Samples collected by NUS Corporation.
Table compiled from data in Tables 0-1 and 0-2.
blank. or not detected due to field
FIGURE 5
-------
SU~~Ry OF CONTAMINANTS
WELLS
UPGRADIENT
MWII4
OTHER WELLS
_-==C==:-"':;:::I
INORGANICS
concentrations in mg/l
( parts per million)
Ammonia <100 - 900 76,000 - 170,000 <100 - 800
Boron <100 3232 <100
Magnesium 3,800 - 30, 100 425,000 2,400 - 209,000
Manganese 75 - 1291 22,310 - 47,500 <10 - 7830
Nickel <40 46 - 80 <40 - 101
Zinc <10 - 36 10 - 60 <10 - 260
ORGANICS
concentrations in ug/l
( parts per billion)
Ammonia ND - <190 11 ,000 - 15,000
2-Butanone ND 26,000 29,000
1,2-Dichloroethane ND ND- 1500
Methylene Chloride ND - 65,000Q <500 - 1440
2 Methyl-2-pentanone ND 5,400 - 5,600
2 Methylphenol ND ND- <6,600
Toluene ND - <46 1,200 - 1,500
ND: Not De tec ted
Q: Questionable Data
ND
ND
ND
ND - 87
ND
ND
ND
Figure 6
-------
SUMMARY OF CONTA~INANTS
... ."".:::a',~ :c::8':S.-.~~:a.~...',,~
- .,.:&;.:8'~~~4:::8"':8--~~~:~~-:8~~' -~~.;=:"_.3.__.--=-~'-.z -....~..:a:~..~-~-:s=- ~-.::r.........=a.~--=--~"".--~=-.~..:::r.:8 ~~.~~~
PIT 5
Leachate and surface water
Other Seeps
Surface water
--:tr~~--~..s.----~~
-;S:.:8--
..-:313'..-.-
"._._~~ ~.&~=:8"':8.-::::.~~...::a:::8'~
INORGANICS concentrations 1n mg/kg (parts per million)
Iron 159 - 43,600 410 - 92,000 134 - 14,540
Magnesium 2,100 - 9,800 9,700 - 255,000 8,100 - 76,400
Nickel <25 - 50 <40 - 120 <40 - 163
ORGANICS
Concentrations in ug/kg
( parts per billion)
Ammonia 230 160,000 - 220,000 760 - 9,600
Acetone ND - <570 ND - 880 - ND - 1990
Benzoic Acid ND - 400 ND - 1,400 ND - 510
2-Butanone ND - 2,400 ND - 1,300 ND - 2,800
1,l-Dichloroethane ND ---8.2 ND - 33.1 ND
1,2-Dichloroethane ND - 5.8 ND - 1.3 ND
Diethyl phthalate ND - 87.5 ND - 27 ND
"Isophorone ND - 230. ND - 36 ND - <33
4-Methylphenol ND - 520 ND - 510 ND - 20
Toluene ND - 120 ND - 151 ND - <75
Xylenes ND - 180 ND - 180 ND
ND: Not detected
,04..
-------
SUMMARY OF CONT~~INANTS
...." ...~:a-..::IC"'8'~~""'~-
:: -=r :'S.~~~~ _:&=t~:=a-=r=-.~~-=-":2.s.s:r~~..~._~.--~-a>-:a:::=8~ -=--~~'..:a.'.~~.;S""" :a'=-:z::iI8~~-=:a:.=-=-~.=r.:8'~2 =--=-- =-~.s.~;:
ACCESS ROAD
BOREHOLE PIT
Typical Coal or Soil Range
~-~"=8.....-.:a..2-"~~~.~_.--=-::::a::=8~-..:::8'~---~_.. a~-w=:a.~....'-
:"::8':~_.~..D'~~_.=- -~'=~..:8 ~":&:::::IL.-=
INORGANICS concentrations in mg/kg (parts per million)
Cadmium <0.05 - 1.2 <0.05 - 1.2 0.01 - 0.7
Copper 6.0 - 32.5 3.85 - 1650 2 - 100
Manganese 97.5 - 13,100 190 - 345 11 - 850
Nickel 4 - < 20 4.3 - 324 7 - 40
Tin <1 <1 - 53 1 - 8
Zinc 10.5 - 435 17 - 640 11 - 50
ORGANICS
concentrations in ug/kg
( parts-per-billion )
Tetrachloroethylene
Toluene
ND
ND - 5.1
ND - (2.5
ND - 3.5
ND - <5
Bis(2-ethylhexyl)-
phthalate
Di-n-octylphthalate
ND-1,600
(10 - 1,500
ND
ND
ND
ND
ND: not detected
FT(~1TRF. R
-------
SUMMARY OF CONTAMINANTS
~ "~.:E"S.~'" ~ '::8..a ~ - =r':a -
=*-- 2=-:~ ~2:a.=8 ~........ ~..=-=:w--~ =- a''''''---'~''''.1a--=- =r'~ ~ -~~~:S a.._-
::;8'=-~~~--=-~.:a'~.'=11~:;.8
STREAMS FLOWING
OFF-SITE
ST. JOHNS CR.
ABOVE SITE
ST. JOHNS CR.
BELOW SITE
OLD FORGE
OUTFALL
. ::8"'~~c:I:"Ia =r-=-=a ~
-------
SUMMARY OF CONTAMINANTS
.~=--=
~~::r.::a.::-..-=-=--.~
SEDIMENTS
STREAMS FLOWING
OFF-SITE
ST. JOHNS CR.
ABOVE SITE
ST. JOHNS CR.
BELOW SITE
INORGANICS
concentrations in mg/kg
( parts per million)
Chromium 2.7 - 7 4.5 - 5.5 2.4 - 3.3
Cobalt 2.5 - 7.5 5.0 - 5.5 2.5 - 3.3
Copper 2.8 - 5 15 - 31 3 - 5
Iron 6,000 - 23,400 11 , 800 - 14,000 5,000 - 7,000
Lead 2.8 - 18 40 - 75 6 - 7
Nicke; 4.8 - 8 8.9 4 - 5
Zinc 12 - 64 43 - 60 11.5 - 19
ORGANICS
concentrations in ug/kg
( parts per billion)
Pyrene
Styrene
ND - 1,300
ND
ND - 720
NO - 6.2
NO
NO
NO
Flouranthene
Methylene Chloride
4-Methylphenol
ND
ND-2.6
ND-ll
ND - 730
ND
ND
ND
ND
ND: Not Detected
. l:'Tr.THH' 'n
-------
. LACKAWANNA REFUSE SITE
POTENTIAL REMEDIAL ACTION TECHNOLOGIES
TechnoloQV
Site Remediation:
No Remedial Action
Surface Capping
Surface Regrading and Revegetation
Surface Water Diversion
Contaminated Soil/Sediment Removal
Leachate Collection
Gas Collection
Groundwater Barriers
Excavation
Treatment an~ Disposal:
Filtration
Precipitation
Neutralization
Carbon Adsorption
Air Stripping'
Incineration
Offsite Disposal
Onsite Disposal
Retained For
Further Evaluation?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Comments
Passive only
Not applicable
Partial and total
Existing offsite
facility only
FIGURE 11
-------
"'1
H
CJ
c::
:xl
tt1
..-
N
.
GRADE TO DRAIN) 2%
18"
12"
24"
CAP DETAIL
LACKAWANNA REFUSE SITE, OLD FORGE, PA
NOT TO SCALE
I ..
.
FILTER FABRIC
PERFORATED
DRAINAGE PIPE
. .
.
. . #
-------
L
IH':'IEIIIo\1-
AI. n:RNATI VE
.--.. 4'- ---.- -- .--.- .--
!'IT r,
1,\
"" I\i; r I fiN
I~
';'II'I'IN':, I,EM:IIAn:
ClII.I.":':TlfI~ ASO
1"10.:,\ r~H:N 1'. ';I\S
':111.1.":': ('1'tN.
11:
~ F'1!J\',\ 1. OF A 1.1. nRIIHS
\~II C"~TA~INHEn CARRAr.E,
,:I\HJ.\i\t:I.:. CA.I'I' IN(: I
t.FA!;!'" ",.: f:tJl,I.":(:T ION
\~II TRI':A r"EN r. ':AS
(1II.I.foJ:rlflN.
'"Jl: I N")(,\ p.; AI.I. ~p.nv,,:u
'.IH":RIAI. flFF-SI n:
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,;\'1E AS I r., EXl:f:I'T
1.1')111 liS ARE I NC INf:RAn:n
M'III PI ,.: snl.' ItS .\RE
I,ANJI'" II.I,~:II.
I";
rllTAI. 1:~t:AVUlflN liNn
I1ISI'IISi\1. OF ALL "IT
ArEltl\I, IN "II\I.IFIEn
'!O~I\ F.o\CII,ITI":S.
CII P ITAI.
c:ns r
($A)
snono
$I~ql
$R204
$~~12
$ll,~"O
OM1
COST
($A)
PRES ENT
WO Rnl
($A)
TECHNICAL CONSIDERATIONS
C"1
.....
OTHER CONSIDERATIONS
~.
;:::J
c.:>
H
~
$4)
$40~
$88
$2~20
$88
$90n
$88
$7641
50
511, ~07
PUBLIC HF~LTH CONSIDERATIONS
There would be continuing off-
sIte migrstlon of contaminants
into air, Rroundwater and 8ur-
faCe.WBter. There would be a
possible risk of direct contact
with contamlnsted leschate.
There would be a continuing
risk of an air releaae from
drums rupturing below the cap.
Contaminated waste would remain
unconfined and would leach Into
the mlnepool below.
this method would remove the
major source of contamination:
would preclude further dl rect
contact. air Bnd surface
water re1eaaes. and would
minimize Rroundvater reteases.
~Ame 89 ahove
This method would eliminate
all pr~sent threats to the
publIc From contact or
potential releaseo to the
envIronment.
ENVIRONMENTAL CONSIDERATIONS
There would be continuing threat
to the environment by all routea
further contamination of wildlife
on-aite and the potential of con
tamlnatlon of off-alte wildlife
and flah.
There would be a continuing
threat to aquatic life in the
Lackawanna River from potential
releases Into the mlnepool.
this method would eliminate the
direct contact threat to wildlife
and the potential for off-site
migratIon via leachate, contam-
inated groundwater, and surface
vater runoff to local 8trea~R.
Same 88 above
thIs method would ellmlnBte all
present threats to the environ-
ment from releases or wildlife
contact.
The existing gate
are inadequate to
further misratlon
contaminant..
and fence
prevent
of
Thla method would not .llow the
prediction of air releaaea and
thus, there treatment before
release off-alte. Groundwater
monItoring Is not possible to
detect contaminanta.
Contaminants would be removed to
a safe background level. Low
levels of contaminants remaining
would not pose a serloua threat.
Continuous monitoring and aampl-
Ing required during construction.
Same as above
All material In the pit would be
removed. Liquids would be Incin-
erated and all' remalnln!! material
would be placed .In a qual I fylng
RCM facility.
There are known carcinogens
preaent In the leachate ond
In the tissue of anImals
found on-elte.
Thla method does not me~t
RCRA storage or closure
requl relllentB.
By removing drums of liquids
and contaminated garbage, the
requirements of RCRA would
be met with the cap and
leachate system. .
Same 88 above
this method exc~eds All
requirements under RCRA
-------
1J~':fl\l,
I \'F
1.---- --. --...-c----
" ~
.'A
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.'11
C,\I'I'INI:, I,F:Ar.lIAn:
j:"!'U':(,rlO~ ANfl
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f:'''.I.Ec:rloN.
?C
TlJr~1. EXCAVATIIIN ANI!
,II';l'il~"1. fJFf-~ ITE
.,1' .\:.1. "An:~IAI.S IN '!lIE
"I r';.
"'!;{~:!lfILF. I'IT
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111
1:,\1'1' I Nf;
"\1:
L'{l:I\VI\TI4IN ru: SI!~FI\CE
I\NIJ ,:.\1'1'1'1(:
CAPITAL
GIIST
($K)
$n0110
$'" 111
$78,942
$noon
$214
$2111
n,.M
COST
($K)
"RF:SF:NT
WOR11I
( $K)
$4)
$405
$Inl
$5090
$0
$78,942
$0
$0
$1
$24)
$0
$2111
PtJRLIC HEAL11I CONSIDERATIONS
There would be continuln!! off
site mtRration of contaminants
Into sir, Rroundwater, lurface
water, and a possible risk of
direct contact with contamin-
ated leachate.
Cappln!! would remove the major
source of contamination and
would preclude further direct
contact, air and surface vater
releases and would minimize
groundwater relesses.
All hazArdou. material and all
non-hAzardous waste would be
removed and all potential for
contact or relessea would be
eliminated.
The low potentlsl for the
public'. direct contsct wHh
the material would continue.
Release. throu!!h leachln!! of
contamtnantA Into groundwater
Is po..lble.
The potentlsl for direct
contAct would be eliminated
The pot ent Ia I for direct
contact would be eliminated
~ONKENTAL CONSIDERATIONS
There would be continuing
thrp.ats to the environment by
all routes and further
contamlnstlon of vlldllfe on-
site and potentially to off-
site wildlife snd fish.
Capping would eliminate the
direct contact threat to wild-
life and the potential for off-
alte mlgrstlon via leachate.
contaminated groundvater and
surface water runoff to local
stream..
Total ~acavatlon would elim-
Inate direct contact threat
and any releasea Into the
tocal environment.
The potential for release.
to lurface or groundwater
exist from runoff and perc-
olation through the upper
soil layer that Is contam-
Inated.
Relea8es to the environment
may be possible by small
amounts of water penetrating
the cap or enterlo!! from the
side Alope.
The potential for RroundwAter
rele3se would be eliminated,
TE~NICA~ CO~SIDeRATIONS
The existing fence and gate
are Inadequate to prevent
further migration of contam-
Inanta. Infiltration and
groundwatar .Inlliing of the
vaatea can still occur.
The cap viII be designed to
accomodate the expected sub-
sidence. The cap and leachate
.ystem viiI be conatructed to
be contlnuoua with t~e cap and
leachate collection syatem
of PH 5.
All excavated material would be
aent to a quallfyln!! RCRA
facility for disposal.
The exlstlnR fence and sccess
gate are Inadequate to prevent
scross the borehole
pit snd t prevent direct
contact.
+t'e.spo..S.5
Some contsmlnants may stilI
slowly leach Into the
Rroundwater or Into the
mlnepool beneath the pit.
Removal of relatively small
amounts of soil would minimize
the potentlsl for further
release..
Ot1lER CONSIDERA~'~'.
There are known c8rcl"o~en8
In the leschate and In the
t188ue of anlm.11g C:"II~ht
on-site,
~
p
L
f-
1-1
The acceas rosd wO\l1 d be moved
to the aide of the pit. durlny,
capping. The cap wollid comply
with RCRA solid vsste cloAure
requirements. ~tate inRp~ctfon~
and necessary maintenance witt
Inaure the csp Inte!!rlty.
No evidence of subAtanttAI
amounts of hB!SrdoU9 wagte dfA-
posal In these pit. ex..tA. HOAt
vaate Is eKpected to tip mllnlclp.::w1
refule.
Access to the pit srea IA limited
by steep slopes on the upper
.Ide. Surface water can be exrertpcl
to pond In this area And leAch
contaminant" Into the p;rollnrlw:tter.
-------
r.AI' ITAI. O~>I
HI"lI':1I1 "I. CoST ConS,.
Hn:~N".:rI_V.E.--. ---------_\..~~~- -(_~.!~L
"f:I:I'::;~ ~1J"1J
'1:\
N'l ,v: r IIIN
!i!\ ~:\~:I\\'.\rl'IN.
!11";1'11~;,\1. (IFF-SIP':
I,,: F'\I:AVo\TIIIN.
nl~~I'rl~,\1. tI~J -SITE
I',,,~r ~I'II.I. AKEA
...." .., . .,....
',1\ Nil M:rlI)N
'd\ I.'\I:V\TION,
"";I':I~:"1. fJFF-Sl"n:
$1111110
S2H/,
$)4
SI)f)on
$2
I'KESf.NT
WI1RTH
($1()
TECHNICAL CONSIDERATIONS
lI"\
......
OTHER CONSIDF.RATIONS
w
p::
~
C1
H
~
so
$0
Sf)
$2M
$0
$)4
$0
$0
$11
pURLIC HFALTH CONSIDERATIONS
Tho potont lal for furthor
roloa.oa to Rround and surface
waters would conttnue. Eroston
and runoff will carry soil
contAminants tnto the streams.
The potentlsl for release will
eliminated.
The potential for release viii
be minimized.
The potential for direct
contAct or the removal of
this materlsl by an Individual
for fIll wIll remain.
$2
All potential contAct with the
material or surroundlnR soil
wIll be ellmlnate~.
ENVIRONMENTAL CONSIDERATIONS
Further migration of ~ontam-
inanta into the air and streams
can be e~pected. Vehicular
traffic on the road will
hasten this migration by
eroding the aurface.
The migration of contaminants
into the environment viii
be eliminated.
The migration of contaminsnta
Into the environment viii be
minimized by the propoaed
cap and leachate collection.
The spill hinders the growth
of ground cover and Increases
eros~n potential which carries
othe,contamlnanta off-site. ~
Ground cover could be reestab-
lished and erosion controlled.
The present road Is Insdequate
to handle the conatructlon
traffic vlthout upgrading.
Serious eroaion could be
e~pected if no action vas
taken to improve the road.
Removal of our face 0011 would
minimize further releaoeo and
the road upgrading vould
minimize further erooion.
The ooil is not conaldered to
be hiRhly contaminated and
could be adequotely contained
In Pit 5 or Pits 213.
It is possible that locsl
citizens could Inadvertantly
excavate the paint If they try
to ohtaln fill from the srea.
The spl1l la very amall and
removal could be accnmpllahed
quickly by .tandard methods.
Surface vater control 88 veil JI
811 8011 erosion meAsureR vou1ti J 0(0
be needed to control further --- t]
dearedAtlonIof the rOAd And the-
"uoclsted release of 8011
contsmi nant a .
Diopooal would be In a quallfylnp,
RCRA facility. The upgraded road
would aloo have improved surface
vater and eroalon control mea.urea.
The pita sre not eaally monItored
for groundvater contamInation snd
adding more hazardous waste to them
increasea the rlak of releas..,
The poaalbllty of dIrect contact
and the accidental excavation of the
spill is likely alnce the spill la
in an eaally acceasshle area.
The spill 18 a RCRA hazardous waate
and ahould not he rlsced In tho rlta
which we WOtlld have eJ(cAv"ted
and removed RCRA wa.tea,
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Lackawanna Responsiveness Summary
The Lackawanna Refuse Superfund Site is located on the border of Old
Forge Boro and Ransom Township in Lackawanna County, Pennsylvania.
In the
Nineteenth Century the site was extensively strip mined, and during the
1970's it was used as a municipal and commercial disposal site.
Industrial
waste was also dumped at the site.
Wastes were buried in three former
mining pits, numbered 2,3 and 5.
The types of industrial and potentially.
hazardous wastes discovered at the site include toxic metal compounds,
various solvents, oils, paints and thinners, various sludges, organic
acids, rubber compounds, coolants, and other organic wastes.
Barrels of
industrial and hazardous waste are buried in Pit S.
The exact number of
barrels is unknown, but is estimated to be in the area of 15,000 drums.
The
two main environmental concerns associated with this site are:
detrimental
health effects from direct contact with substances disposed of on-site.
and contamination of air, surface water, sailor groundwater through
migration of hazardous substances.
The Bora of Old Forge is a middle class community of approximately
9500 residents.
Strong citizen interest in the Lackawanna Superfund site
developed early in the project.
EPA officials met with local officials
and toured the site in June of 1983.
Several state and federal-elected
officials have also visited the site, and have become involved in the
citizen's actions against the site.
A very influential citizens' group formed in Old Forge.
They have
been active through the Immediate Removal Measures, and throughout all
phases of the Remedial Investigation and Feasibility Study.
The Mayor
of Old Forge appointed the citizens group, known as the Old Forge Toxic
Waste Removal Committee, as the official representatives of the community.
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2
The Old Forge Boro Hall ..ln~ the COr.1l'1i ttpc? are two repositories for all EPA
official documents pertaining to the Lackawanna Site.
The citizen group
corresponds with EPA officials on a regular basis, and has made a point
of being a part of all activity at the site.
Through the Lackawanna
County budget, the Boro of Old Forge budget, private donations from
residents, and fund-raising activities, the Old Forge Toxic Waste Removal
Committee retained a consultant from Environ, Inc., an environmental
consulting firm located in Princeton, NJ.
This consultant, along with
the Committee, reviews EPA reports and comments to the Regional Office, in
Philadelphia.
An Immediate Removal action installed a fence around the site.
That measure was taken October-November of 1983.
Some citizens and
committee members assembled at the gate on the access road to the site.
They were concerned about possible air releases when the work was being
done.
They wanted the children to be evacuated from Old Forge as the
work continued.
Because of the nature of the work, evacuation was not
necessary.
The first public meeting to discuss the Lackawanna Workplan, was
held in August, 1983.
About 600 residents attended the meeting and
voiced strong concerns about the site.
Their main concerns centered on
how EPA's work at the Lackawanna site would affect them, their families,
and "their environment.
Health and safety concerns were most prevalent.
~e r~sidents asked questions about their groundwater, and about the
chances of leachate migrating into their water system.
Specific questions
concerning radiation, toxic gases, health effects, and air releases were
also raised.
Testing showed radiation at background levels, during all
work at the site.
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3
The community was told by EPA officials that health and safety plans
would be assured under the contingency plan.
Since the residents obtain
their drinking water through a public system derived from reservoirs
several miles to the north of the site, ground water contamination is
not an imminent health threat.
One month later, in September, 1983, a public meeting was held to
dispel rumors that began within the community regarding the EPA's next
course of action at the site.
That meeting went rather smoothly, and
about 250 residents were in attendance.
In April, 1984, EPA held a
meeting to discuss trenching that was to take place at the end of the
month.
The purpose of the trenching was to see if any drums were dumped
in pits 2 and 3, since we were aware that drums did exist in pit 5.
The
pits were trenched 10 feet deep, and no drums were found.
It was decided,
due to high citizen concern, that the work would take place over the
weekend when school was not in session.
During the on-site work, several
interested citizens and members of the citizens group met with EPA's
Public Affairs staff and other officials to discuss the progress of the
wo rk .
Press and media interest was very strong during the trenching, as
it had been from the beginning of the project.
The .local citizens group
took a very active role in relaying information to the residents of Old
Forge.
In May, 1984, EPA officials met at the home of the Chairman of
the citizens group.
We went through the draft Remedial Investigation
Report With the committee, and also discussed the Wildlife Study that
had been conducted at the site by the U.S. Fish and Wildlife Service.
This informal, small group gathering proved very helpful -- the committee
repeated their concerns about groundwater contamination, and future
health effects from site contamination.
Many of the Old Forge residents
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4
hunt deer near the site, and were pleased to see that a Wildlife Study
was being done.
The Committe~ traveled to Washington DC on July 12,
1984, to meet with Lee Thomas, who was EPA Assistant Administrator
for Solid Waste and Emergency Response, at the time.
The Old Forge
residents gave Mr. Thomas a list of 10 "demands".
Their concerns
were answered during the meeting. and a written copy of the response
was sent to the committee, and to EPA Region III.
The Regional Superfund Project Manager was asked to attend the
committee's regular Sunday night meeting on September 25, 1984.
The
meeting went well and most of the concerns centered on technical aspects
of the project.
They wanted to know how deep the next round of trenching
would be in Pits 2 & 3, and they asked questions pertaining to the health
and safety procedures that. were planned for the work.
In October, 1984. a public meeting was held to discuss the findings
in the Remedial Investigation Report, and additional trenching in Pits
2 & 3.
Approximately 75 residents attended the meeting.
The citizens
group made a statement before the close of the meeting requesting that
all barrels be removed from Pit 5.
At the end of October, into early November. Pits 2 & 3 were trenched
30 feet deep, and no drums were found.
The work began on a Wednesday and
lasted throu~h Sunday.
Due to high citizen concern about the safety of
their children, and a lack of enough school buses to evacuate schools in
the case of an emergency,. the local school board decided to clo-se school
Wednesday through Friday during the trenching.
The residents of Old Forge and EPA officials were in contact quite
often in the months leading to development of the Feasibility Study.
On
February 8, 1985, a small meeting was held in Philadelphia with 5 committee
members, EPA officials and a representative from DER.
Also in attendance
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5
was a representative from U.S. Senator John Heinz's Office.
The Feasibility
Study was distributed, and a representative from U.S. Fish and Wildlife
Service was present to discuss the Wildlife Study report.
At that time,
EPA also discussed the Regional recomm~ndation to remove all barrels from
Pi t 5.
After 5 hours. and quite a bit of discussion. the committee left.
pleased with our recommendations.
The final public meeting to discuss the Feasibility Study was held
February 28. 1985.
The committee distributed form letters for the residents
to sign, supporting the EPA' s recommended alternative.
Many residents
wrote their own comments on the back of the form letters.
We received
200 signed form letters from the residents of Old Forge.
Fi fteen of the
letters included written comments by each resident.
Six of those comments
concerned future ownership of the property once the cleanup is complete.
Five residents asked who would monitor and maintain the treatment system,
and three letters that we received showed great concern about the timeframe
of the project from start to finish.
Most prevalent among those comments
was the transportation of hazardous material.
Specifically, what route
would be taken and in what kind of vehicle the materials would be hauled.
Other concerns centered on health and safety precautions that would be
taken by EPA to assure residents' safety. and the residents were concerned
with continued monitoring and maintenance of the treatment system after
the work was complete.
These written concerns will be answered once the
design phase of the project is complete.
Included in the comments that
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6
we received were letters from a Pennsylvani~ State Senator, a Pennsylvania
I
St ate Re presentative, the Lacka~anna County Emergency Management Agency,
I
the Borough Council of Old Forge, and a formal statement f~om the Old
Forge Toxic Waste Removal Committee.
All of the letters were in favor
of the EPA's recommended cleanup alternatives for the Lackawanna Superfund
site.
Throughout the comment period, which ended on March 7, 1985, residents
were encouraged to contact EPA's Region III Offices with any questions
that they had pertaining to the Lackawanna site.
During the early and later phases of design EPA officials will meet
with the Old Forge Toxic Waste Removal Committee and their consultant from
Environ. Inc. to discuss ideas for both the design and construction phases
of the project.
EPA will also discuss with the Committee and their
consultant safety measures that will be taken during the project.
After the design stage is complete. a public meeting will be held
to discuss what will take ~lace during the construction stage.
At that
future meeting. we will be prepared to address the concerns of the residents
pertaining to the transport of hazardous materials throughout their
communi ty.
EPA Region III will continue to update the media and the residents
of Old Forge should any questions arise during the design stage of the
project.
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