United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-85/011
March 1985
Superfund
Record of Decision:
Heleva Landfill Site, PA
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HELEVA LANDFILL, PA
Record of De~ision
Abstract
The Heleva Landfill site consists of a 20-acre landfill located
on a 93-acre ~ract of land in Lehigh County, Pennsylvania. The site
is surrounded primarily by farm and pasturelands, with the village of
Ormrod (population approximately 100) and town of Ironton (population
150) located approximately one quarter mile away. The site began oper-
ations as a sanitary landfill in 1967, accepting 250-350 tons/day of
mixed refuse including paper, wood, and orchard wastes. In addition,
industrial wastes with high levels of trichloroethylene (200 micrograms/
li ter) were sent to the site as early as 1967. The 'si te was. closed in
May of 1981 by the Pennsylvania Department of Environmental Resources
because of operational deficiencies.
The selected remedy for the Heleva Landfill site consists of exten-
ding an existing water main from Ormrod to Ironton, capping the entire
20-acre landfill according to RCRA standards, constructing surface water
diversion and gas venting systems, conducting a pre-design study to fully
delineate the source of contamination and determine sinkhole activity,
constructing a treatment facility on-site, pumping and treating highly
contaminated ground water, monitoring and sampling existing wells and
surface water, and conducting operations and maintenance for a period of
at least two years. The total capital cost of the selected remedial
alternative is estimated to be $7,253,000.
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RECORD OF DECISION
REMEDIAL ALTE~~ATIVESELECTION
Site:
Heleva Landfill Site, North Whitehall Township, 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
Heleva Landfill site:
"Remedial Investigation Report and Feasibility Study of Alternative" Heleva
Landfill Site, Lehigh County, Pennsylvania (NUS Corp. January 1985)
"Site Investigation, Heleva Landfill, West Ormrod, Pennsylvania" (Environmental
Monitoring Systems Laboratory, November 1983)
"-
Staff summaries and recommendations
Recommendation by the Pennsylvania Department of Env~~onmental Resources.
Description of Selected Remedy:
- Provide and install an alternate water supply by extending an existing
12- water main approximately I mile from Ormrod to Ironton.
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~
- Install a cap on the 20 acre landfill that meets all the requirements of
the Resource Conservation and Re~overy Act (RCIA).
- Construction of a surface vater diversion systea.
- Construction of a gas venting systea with monitoring and possible
treat_ent.
- A pre-desiga study which viII involve test borings to .,re fully delineate
the location and magnitude of the source of conta81nation and to deteraine if "
collection of this 80urce will be effective in reducing the contaaiaat1on over
the extent ofeha contaainated area. The pre-desip study viII also deteraine
the existence and aagn1tude of sinkhole activity in the a~a.
- Based on the finding. of the pre-design study, a 80urce reduction program
involving PU8ptDg aDd treating of highly coataadnated ground vater fro. the
landfill viII be i8ple8eDted." "
- A treat_nt fadltty viII be COD8tru~ted onsite aDd viII treat the
vastevater down to approved ~centration level. before dis~harge tnto Coplay
Creek.
" \
- A ImDitorio, program during and subsequent to the re_dial a~tiOD. This
includes 8Onito~ing in ~o8Plian~e with RCIA regulaUons, 8Onitoring of e,dsting
8Onitoring veIls and periodi~ saapling and analysis of potentially afleeted
surface vater in the area." "
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- Operation and maintenance will be implemented by the State of Pennsylvania
on the landfill cap, gas venting system. surface water diversion system and
monitoring program six months after construction of these systems. The source
reduction and treatment system will be operated as a remedial action for a
period of at le~st tWo years and will be eligible for Trust Fund monies.
Declarations
Consistent with the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA). and the National Contingency Plan (40 C.F.R.
Part 300), I have determined that the remedial actions described above together
with proper operation and maintenance. is a cost effective remedy and provides
adequate protection to public health, welfare and the environment. The remedial
action provides for an alternate water supply to affected households and
minimizes the threat of further contamination of the environment. The remedial
action does not affect or violate any floodplain or wetland areas. Three key
elements of the remedial action include the temporary institutional constraints
which will prohibit the withdrawl of groundwater fro. a designated area near-
the site, the pre-design study which will asaist in designing the source reduction
program and to detena1ne the potential for stnkhole activity in this area, ana..
after the source reduction program is implemented, the Regional Administrator
will make a decision after two years of remedial action, determining if further
remedial action is needed or if a closeout sequence on the pU8ping and treating
should begin. The State of Pennsylvania haa been consulted and agrees with
the approved remedy. .
I have deter.!ned that the action being taken i8 appropriate ~hen ~lanced
against the availability of Trust Fund 80nies for use at other sites. In addition,
the selected alternative i8 the !m8t cost effective remedy that _ets all relevant
and applicable enviroU8e0tal standard8, and 18neces8ary to protect public health
aod the environment. .
. y~ ~V'.!"
Date
~~-L~'
Stanl L. LaakoW8k1
Acttog legional Ad8dntstrator
ErA Region .111
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Summary of Remedial \lternat1ve Selection
HelevaLandfill S1 te
Site Location and Description
The Heleva Landfill Site consists of a 20 acre landfill located on a 93-
acre tract of land in North Whitehall Township, Lehigh County, Pennsylvania.
The area within a three mile radius of the site is primarily rural in nature,
with a high density of farm and pasturelands. Although agricultural activities
are important, much of the employment for the area residents is 1n industry or
mining. . A large percentage of the population lives in small single-family
residential communities which pocket the area surrounding the site. .
Ormrod, a village of approximately 35 families, is located about 1/4 mile
southeast of the site (Pigure 1). Irontown, located approximately 1/4 miles
west of the landfill has a population of about 150 residents. The Ironton
Elementary School is located within 1,500 feet south of the site.
Several abandoned quarries l1e near the site, including Todd Lake to the
west, Ranger Lake and the abandoned Whitehall Cement quarry to the south.
Coplay Creek is south of the site and runs easterly eventually~discharging into
the Lehigh R1 ver. . . .
Site History
.. .
The site began operations as a san1tary landfill in 1967 and accepted
between 250-350 tons/day of general mixed refuse, paper. wood. and orchard
wastes from.the Allentown area. .In aCicliUon to fn«f municipal wastes. industrial
wastes were reported" to have been sent to the s1 te as eady as 1967." State.
inspection reports from the early 1970's indicate that the landIill accepted
high volumes of TCE liquid wastes from several industries in the area. In
1977 the West Ormrod Water Association well located southeast of the landfill
detected high levels of trichloroethylene in their well in 1977 which ultimately
led to the closing of the well and the construction of a water main from the
. Northhampton Water Company to those affected residents in Ormrod and Ironton.
The landfill was closed in 1981. and the owner covered the fi11 with a
layer of soil taken fro. borrow pits located south of the site. Attempts to
seed the covered areas have not been effective due to the low fertility of the.
cover material. The site continued operation until its closure by Pennsylvania
Department of Environ_ntal Resources (PA DO) on May 1. 1981 because of opera":'
tional deficiencies. As part of the closure procedures, the corporation vas
required to cover the landfill with two feet of topsoil and then revegetate
it.
The site was listed as potentially hazardous 011 November 15. 1979 by
PA DEI and ErA un4fer the tCIA 7003 Dumpsite progra.. A Site Inspection Report
under this program ranked the site's apparent seriousness as high. A Hazard.
Ranking Model was first generated on August 4. .1982, and updated on September
2. 1982. Heleva received an aggregate HIS score of 50.22 resulting in the
placement of the Heleva site on the National Priorities List (NPL).
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Current Site Status
The entire site is covered by a clayey soil obtained from an adjacent
borrow area. Due to low fertility, there is no significant vegetation onsite.
Consequently, the cap has eroded, paris of the landfill are becoming exposed
and precipitation percolates into the landfill. . The top of the fill is about
500 feet above mean sea level and the land slopes to the southeast corner of
the site.
There is a pond onsite that acts as the main collection basin for surface.
water run-off and leachate, however, during high rain periods, smaller ponds are
formed in low lying areas on and around the site. Also, during heavy rain
periods, surface water run-off and leachate flow offsite into nearby fields and
into Todd Lake. (This run-off has been sampled and determined to have no
appreciable amounts of toxic substances). The only buildings onsite are
garages and storage barns associated with the past landfill operation. Mr.
Heleva still operates an automobile workshop onsite but adjacent to the actual
fill area.
A Remedial Investigation of the site and surrounding area, under the
sponsorship of the EPA (Superfund) was conducted from February, 1984 to December,
1984 to supplement previous data and to provide information to \perform a
Feasibility StudY. \
~
Geophysical surveys were conducted at the Heleva Landfill Site to aid in
determining subsurface conditions and to provide correlations with monitoring
well data. A. seismic refraction survey was conducted to delineate the top
surface of the bedrock. Porosity of the bedrock surface was then calculated.
Porosity of the unconsolidated zone,from the surface to bedrock was also
determined so that tbe velocity of ground water flow through both areas could be .
calculated. The ground water is moving at a very slow rate througb the unconsolidated
deposits (.07 ft!yr). However, when ground water reaches bedrock fractures tne
flow velocity is increased by several orders of magnitude to approximately 500
feet per year. Bedrock fractures occur in unpredictable patterns, therefore, the
exact routes of subsurface contaminant migration are unknown and unpredictable.
One tbeory suggests tbat ground water may be mOving very quickJy through
old filled-in mine tunnels Wbichwere once used for deep mining of iron ore.
Old maps indicate a mine tunnel running from the present area to the southeast
toward Ormrod Village. Exact tunnel locations will have to be determined
tbrougb geopbysics in tbe pre-design study (see Recommended Alternative section
of tbis document).
Contamination of tbree dOllestic wells by site-assoelated chemicals due to..
ground water transport is indicated by the data in Table 1. Sample locations
are sbown on Figure 2. Tbe Heleva and Cincilla wells are located adjacent to
. tbe site to tbe east, and the Horw1thWell is located approximately 600 feet.
northeast of tbe site boundary. Contamination in tbe Beleva and Cinellla .
Wells was very lo~ in February 1984 (TCE4 uS!1 and 3ug/I, respectively).
However, when res&Jllpled and analyzed in September 1984, the levels of
contamination had increased substantially (TCE 180 ug/l and 200 ug/l, respec-
tively). A reason for the increased contaminant levels in the Beleva and
Cincilla wells over the seven montb period between sampling episodes bas not
been determined. In addition, 1,2-trans-dichlorethylene (a site-assoelated
contaminant) was observed in botb wells in September, 1984(26 ug/l, and 31
ug!l, respectively). .
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TABLE
1
DRINKING WATER CONTAMINATION
HElEVA LANDFill SITE
Februarv 1984 SeDtember'1984
1,2 Trans 1,2 Trans
Location Dichloroethvlene TCE Dichloroethvlene TCE
Lakeview Mobile Not Observed Not Observed Not. Sampled. Not Sampled
Home Park
Horwith Not Observed Not Observed 9 ~g/I 5 ~g/l
(Before Softener)
Horwith Not Observed Not Observed Not Observed \ Not Observed-
(After Softener)
Fronheiser Not Observed Not Observed. Not Observed. Not .Observed
Sterner Not Observed . Not Observed Not Observed NOt Observed.
Taylor Not Observed NOt Observed Not Observed Not Observed
Mutz Not Observed Not Observed Not .Observed NOt Observed
Heleva Not Observed 4 ~g/I 28 ~g/I . 180 ~g/l
29~g/l 170 ~g/l
Cineilla Not Observed 3 ~g/l 31 ~g/I "200 ~g/l
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.1
fiGURE -Z
MONITORING 8 RESIDENTIAL W~LL LOCATIONS
tt~L-~VA LANDFILL. SITE. ~~ WtfITEHALL- TWP.. PA
,~.. :.: 1 ,.,-. ~ .
400 0
r-.---....-.
~':JJ:--: JC '],7';1j'
,jOO
J
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Site associated contaminants were observed in the Horwith water supply in
the. September, 1984 sampling (TCE: 5 ug.'l, 1, 2-trans-d1chloroethylene: 5 ug/l)
when sampled on~he inlet side of the water softener. However, the contaminants
were absent on the discharge side of the water softener.
Monitoring wells were Installed at various locations around the site,
concentrating on the southern periphery in the pathway of the regional ground water
flow from the site. Monitoring well locations are shown in Figure 2. In
addition to providing information required for characterizing the site geology,
the monitoring wells provided a means for sampling the ground water and .
determining the nature and extent of ground water contamination. Where possible,
two wells were installed at each monitoring location to detect and monitor
contaminants at different depths. One well, designated the "An well, was
installed to the top of the bedrock at a depth ranging from 30-50 feet. The.
second well , the "B" or deep well, was generally set into the bedrock at depths
ranging from 55-120 feet. An upgradient residential well (Taylor Well ) was
. used to determine background levels. .
Based on the occurrence of TCE and 1;2-trans-dichloroethylene, the data
presented in Table 2 indicate tbat the ground water was contaminated in 10 out
of 20 NUS wells (monitoring wells 4B, 7B, 9A, 9B, lOB, 11A, lIB, 12B, 13A and
13B), and in the two of the three wells previously installed by. the landfill o~er
(monitoring wells B-7 and B-8). Contamination was generally mare prevalent
(observed more often) in the deep wells.
~
With the exception of monitoring wells 13A and 13B, all of the contaminated
wells are located on the soutbeast perimeter of the site in the pathway of the
suspected hypothesized regional ground water flow~ This observation indicates
that chemicals have migrated from the site and that they are being transported
through the subsurface along the path of the ground water flow. Ground water
samples taken from monitoring wells south and west of the site (U, 2B, 3B,
5B, 6A, 6B, 8A, and 8B) did not contain contaminants. This indicates that
contaminants are not migrating toward these locations.
Ambient ai.r contaminants were collected at strategic locations (Figure 3) on
and around the landfill to determine if hydrocarbon chemicals were volatilizing
from so11s and surface waters to the air. Airborne contamnants were collected
using a Tenax sorbent tube method and analyzed by Gas Chromatography/Mass
Spectrometry (GC/MS). Table 3 sUllll8rizesthe data fro.. the air sampling survey.
An evaluation of the air sa8Pling data indicates that most of the contami-
nants (e.g. benzene, 0.8 ppb, toluene, 1.3ppb) at the observed concentrations
are typical of ambient air. However, some results (TCE, l,2-traaa-dichloroethylene,
tetrachloroethylene) are also typical of the site contaminants and ..y be .
indicative of low level volatilization with airborne transport to the atl8Osphere.
With the exception of one TCE and one xylene observation, airborne organic
contaminant levels are slightly higher than those observed in a 8i8ilar mid-
Atlantic rural area (Batsto, R.J), and generally below those observed in an .
urban mid-Atlanti,region (Rutherford, NJ). .
Volatilization of xylene, tetrachloroethylene, and trichloroethylene ...y be
occurring at the site, in particular from the TCE spill area. Maximum concen-
. trations of these contamfnants were observed at one meter above tbe ground
surface within the TCE spill area. !hi 8 location included the only detection3
of xylene (36.6 ug/..3), the maxitIIWI tetrachloroethylene observation (3.8 ug/m ),
and the obviously high maximum TCE observation (533 ug/..3). .
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TABLE 2.
SELECTED GROUNDWATER CONTAMINATION
OBSERVATIONS 1
HELEVA LANDALl SITE
Total Average Maximum Standard No. Wells
Chemical Observations Concentration Concentration Deviation Contaminated
1.2 Trans-
Oichloroethylene 15 173.7 ~g/l 730 ~g/l 182.4 9
Trichloroethylene 18 97.9 ~gll 410 ~gll 131. 1 9
Vinyl Chloride 7 9.29 ~gll 5.700 ~g/I 2112.6 5
Tetra-
chloroethylene 3 14.5 16 2 ....
1
Other observations Include' benzene (1). MEK (1). 1.1 dichloroethene (3).
1.1.1 trichloroethane (2). chlorofonn (2). 1.1.2.2 tetrachloroethane (1). toluene (2).
. and ethylbenzene (1). These observations were either detected below the contract .
detection limit or not conflnned by follow up sampling Ind Inalviis. .
".
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/
./
SURFACE WATER. SEDIMENT AN) SOIL SAMPLE LOCAT IONS
HELEVA LANDfiLL SITE. NORTH WtffEHALL TWP.. PA
SCALI' ('.400'
fiGURE 3
4~
.1
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TABLE ~
. SELECTED CONTAMINANTS IN AIR OBSERVATIONS
HElEVA . lANDFill SITE
.,
Downwind 0'
TCE Spill Area Batsto Village Rutherford
Upwind TCE Spill August 3 New Jersey New Jersey
ContamInant Sample. Area Sample Observations (Rural) (1) (Urb8n~ ( 1 ~
Benlene 0.75 ~9/rn3 1.58 ~9/m3 1.06 ~g/m3 1.6 ~g/m3 8.5 ~9/m3
(0.2 ppb) (0.4 ppb) (0.3 ppb) . (0.6 ppb) (3.2 ppb)
Toluene 3.3 ~9/m3 11.7 ~9/m3 6.4 ~9/m3 2.1 l-Ig/m3 30.1 ~9/.o3
(0.8 ppb) (3.2 ppb) ( 1. 5 ppb) (0.6 ppb) (8.6 ppb)
Xylene (0) Not De.tectld 36.7 119/83 Not Detected 0.6 l-Ig/m3 5.5 pg/m3
(8.4 ppb) (0.1 PI.b) (0.9 ppb)
Tetrachloroethylene Not Dltlcted . 3.83 119/83 1.7 IIg/m3 0.4 pg/m3 11.8 ~g/m3
(0.8 ppb). (0.4 ppb) (0.1 ppb) . (3 ppb)
Trichloroethylene Not Detected' 633.3 .119113 . 0.7 IIg/m3. 0.4 l-Ig/m3 6.2 ~9/m3
. (88 ppb) (0.1 ppb) . (0.06 ppb) (2 ppb)
.-
(1) Kebbeku., B.B.. 801,.111, J.W. 1883. (EPA-800163-83-022)
. Trichloroethylene w.. detected In one 0' the three downwind 88mplel.
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Shallow soil samples (composites vi 8-10 inches in depth) were taken at
two locations o~ the site. One sample. taken at the north" edge of the landfill,
was of a gray-colored surface material, which was uncharacteristic of the rest
of the site. The second sample was taken at the southern edge of the site
along the main southerly drainage route and" was intended to characterize any
materials that might have been transported by erosion. The contaminant di-n-
butyl phthalate was detected in both samples at 700 ug/kg. Sample locations
are shown on Figure 3. The observation of this contaminant at the low level
cited is not unusual and not felt to represent a significant impact on the site
assessment. The one in a million carcinogenic risk level for this compound is
set at 34,000 parts per billion. "
Sampling and analysis of surface water and sediment both onsite and off-
site was conducted to determine if the contaminants disposed at the site were
being transported by surface water mechanisms to other locations onsite and
offsite. Sampling locations included onsite ponded surface water bodies,
flowing surface leachate and run off streams. and offsite surface water bodies.
When sediment samples were taken in conjunction with a water sample, the shallow
sediment directly below the water sampling point was sampled.
Contamination of surface waters by site-associated chemic~s was observed -
onsite and offsite. Onsite surface water contaminants include\a mixture of
halogenated aliphatics, monocyclic aro~tics, and 2-butanone (methyl ethyl
ketone [MEK). The offsite contaminants were comprised mainly of halogenated
aliphatics. Table 4 lists the major surface water contaminants and their
frequency of detection and distribution, as determined by the first and second
sampling episodes. Sampling locations are shown on Figure 3.
~
Organic chemicals indicative of the site contaminants were observed in off-
" site surface waters south of the site. Table 5 details the contaminant" " ""
observations in the offsite surface waters from the April and September sampling
surveys. TCE and trans l,2-dichloroethylene were the predominant chemicals
observed in the offsite surface waters in bOth sampling episodes. The data
indicate that the offsite surface water contaminant concentrations, at least
over the period of observation (four months) did not differ markedly.
Endangerment Assessment
The major contaminant transport path, causing potential exposure to human
receptors to the landfill contaBdnants, 1s the ground water flow in the bedrock
beneath the site. The source of this contamination is bel1eved to be from TCE
contaminated ground water 1n the unconsolidated deposits below the landfll1
surface. This contaminated ground water moves very slow vertically until it
reaches the fractured bedrock, where it is then carried away downgradlent to
surface water discharge points.
There are also .everal minor routes of transport of contaminants. Volatil-
ization of organ~ contaminants to ambient air, and surface water runoff,
mtnglingwith contaminatedleachates emanating fro. the deposited wastes, may
affect the environment in drainage receptor areas.
Potential receptors include nearby users of groundwater for drinking
"pUrposes, nearby users of ground water for all other purposes, persons using
nearby surface waters for recreational purposes. They also include persons"
consuming aquatic biota in affected surfaces. Only those individuals using
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TABLE 'too
SElECTED SURFACE WATER
CONTAMINA TJON OBSERVATJONS
HElEVA LANDFill SITE
(BASED ON 23 SAMPLES FROM APRil 1984)
Chemical Observations Average Maximum
Contaminant Total Onsite Offsite Concentration Concentration
2-Butanone 4 4 0 2.259 J,1g/L 8,030 1J9/L
1,2,-Trans Di-
chloroethylene 6 2 4 21.4 J,1glL 40.8 1Jgll
Ethylb8nzene 3 3 0 4.7 \.lgIL 7.6 \.lgIL
Toluene 6 8 0 56 \.lglL 282 \.lglL
Trichloroethylene 7 3 4 11 \.lg/l 41 \.lgIL
Vinyl Chloride ~ --1 ....A 9.0 \.lglL 9.6 \.lgIL
Total 29 21 8
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TABU I .
8MJ08 OffIlJE "Am WATER COIOAlllNAHJSI
HlUVA LAf8IfILL IRE
ADrII 1184 S.D18mb8' 1884
....... 1.2-T'I'" Sam,.. 1.2-T'I".
SamDllrla sal. Number DIcNor...lhvl.... TCE Number Dlchtoro.lhvl.n. TCE
Qu.ry IIckpauncl CHL-IW-G08) 7.0 11811 ..7 11811 (HL-IW-I") . Not Ob..N.d NOl Ob..Nld
.
Ouary Sprtne CHi. -IW-OOI) 40.' 11811 41 11811 ""-8W-I03) 7 11,11 6 ...811
Coplay Creek ,CHL-IW-aae) 13.0 11811 I.' 11811 (&-IW-102) 48 11811 21 ...0/1
(Dow".t'.....)
Ran,. Lab Iti. -1W-007) ... 11811 7.1 11811 (HL-SW.,10i) 24 ...,11 20 ...011
Lak. EI.t of lit. --- Not ........... Not Sampled 1&-'W-I01) 18 11811 11 "'011
I
Like NoRh8...
0' "t. No. 'ampl'" Not ...... (HL-'W-I01) Not Ob..N.d NOI Ob..N.d
Lake ............
of "t. . Not Sampled Hot .......... (HL-1W-118 2.0 11811 NOl Ob..rvld
-liMa .,.a. ,
. .
1 CbIorOtonn......... once II I 11811 (L8II8 Iou"'.." of III.)
Avel.ge
1.2-11.nl
Dlchloloe'hylene
23.8 ...0/1
31 "'0/1
18.4 ...0/1
Average
TCE
23 110/1
13.8 Ilg/l
13.6 119/1
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water from contaminated residential wells have been directly exposed to site
contaminants.
The concentration of TCE found in the two affected residential wells are
at or near the lO-day Health Advisory Level of 200 ugll and well above the
long-term Health Advisory Level of 80 ug/l. The Centers for Disease Control
review of, the residential well data concluded that', "continued consumption presents
an undue health risk and that the affected residences should be immediately
provided a water supply that is safe for human and animal consumption." Through a
consent order bottled water i,s now being supplied to these homes by a potentially
responsible party.
Of the chemicals detected in samples collected during pre~ious investigations
and the RI, vinyl chloride; trichloroethylene (TCE); toluene; 1,2-trans-
dichloroethylene; 1,I,I-trichloroethane; and tetrachlorethylene (PCE) were
selected as the critical contaminants found at and around the Heleva Landfill
Site. The major potential exposure to TCE at Heleva Landfill is via the
ingestion of contaminated drinking water. Minor exposure to TOE can occur to
persons using surface water for recreational purposes and ingesting contaminated
surface water or aquatic organhms. Levels observed in offsitesurface water'
are below the 10-6 carcinogenic risk level for consumption of aquatic o~ganisms,
of 81 ppb. In addition. there is a slight potential for exposure to TCE vapors
at extremely low levels in ambient air. \
Individuals at risk for exposure to vinyl chloride would include remedial ~
investigation workers or persons trespassing on the site. who may encounter
vaporous vinyl chloride emanating from the leachate streams. However. because
of the dilution factors in ambient air. this exposure would be of a low concen-
tration and brief duration. Ingestion of vinyl chloride in contaminated drinking
water, has not been identified. but if the migration of vinyl chloride continues.
the potential increases. The 10-6 carcinogenic risk level for vinyl chloride has
been set at .015 ug/l.
, '
At the Releva Landfill Site~ ingestion of contaminated drinking water is
the primary exposureforl~2-trans-dichloroethylene. Inhalation and dermal
contact are also potential routes of exposure. Because of the low levels of
l,2-trans-dichloroethylene detected at the site and the contaDdnant's low
toxicity character, adverse health effects fro. 1,2-trans-dichloroethylene a~e
unlikely at the Releva Landfill Site.
The toxic effect of TeE and 1.2-trans-dichloroethylene on aquatic flora
and fauna would be unlikely because of the low levels of the contaminants
detected. in surface waters.
Table 6 lists the critical contaminants and their maximum concentration at
Releva compared with environmental criteria relevant to different media.
Enforcement
On JUly 8, 1~77, the PA DEI denied Beleva Landfill a permit to expand
their landfill operation, and subsequently issued an Order requiring them to
cease operation. On July 23, ~977, Beleva appealed the decision ofPA DEI to
the Pennsylvania Bearing Board. As a result. a Consent Order was signed on
, May 19; 1980 by PA DEI and Beleva Landfill which required the owners/operators
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CRITICAL CONTAl8WfTI-£IMRONMEHTAL CRITERIA
TABlE 1
lna..,lon 'W.,."
USEPA IIUc
USUA 1814..
USEPA .,l84d
PNlad8lplala A1111-
Do.. not con."'" e.reInOl.nelly .nd eaclud8. eonl""ulion. ',om a" and '00d
S.a R.....III. '01 ..a,'. '01 ADI. .
P,.UmllWy Prolacllon Concanllallon Umh.. (PPCLI) "a.ad on unh canc., rtak
PPCLS ba.ed on ADI. .
Recomm8ftd8d Malllmum
Conlamlnanl Le".I. and
Crtllcal Ob8arv.d. (PPOLI) CI) 13)
Conlamlnanl Me.. Cgnc. ilalL
1. Trlchloroal""" (TCE) 11.000 IIIIL 0 (1.1)+
CAS No. 78-01-1 moD. w..
Z. T.llachloro8l"8ft8 (PeE) 'I 1Ig/L 0 (1.0)+
CAS No. '27"18-4 moD. w.U
3.. Vlnvl ChIortd8 1.700 888IL .. (2.0)+
CAS No. 71-01-4 mono waU
... .. .. . - Trlclalor08''''''' 1,10088811. .. (21.7)+
CAS No~ 7.-11-1 moD. W8I
5. Toluene :182 1Ig/L - "1.000)"
CAS No. 108-88-3 lUll. w""
I. 1.2- Trans-OIcIalOlO8I1a8n8 7.- II8IL
CAS No. 127-18-4 mon. wall
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.
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.
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Daly "'lIk.s
&la/da" '2.
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&lall
zao
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34000"
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.'1
Inh,'aCion
Recommended Amblen.
AI' Quall.y Quldellne.
&101m3 fppma
a.65z (1.200)
8.268 (1.200)
8.24 (2.4)
Rem.rks
ADI based on
.81 chronic or.'
10lel (reproduct.
e"8cII)
ADI based 011
'.1 ch.onlc 0'81
10881
-------
-6-
to: control erosion to Todd Lake; control leachate; li~it dumping; and cease
dumping in presently filled areas. . In ~dditlon, Heleva initiated a biostimulation
project which was designed to reduce theTCE contamination in ground water.
The results of the biostimulation pilot project were not satisfactory
to the PA DER and the landfill was ordered closed in 1981 because of operational
deficiencies. The operators were required to cover the landfill with two feet
of soil and revegetate. .
Subsequent to the landfill's inclusion on the National Priorities List, a
responsible party investigation was conducted and several 104(e) letters were
sent. . After the review of Heleva Landfill's record books, the Enforcement Branch
. in Region III sent out 182 104(e) letters to companies which used the. landfill.
While most of these firms were small operations, some evidence was received
confirming that the American Telegraph and Telephone Company (AT&T) disposed of
several hundred thousand gallons of bulk liquid mixed solvents at the landfill.
Other potential responsible parties are expected to be found in the near future.
In January 1985, EPA issued verbal notice to AT&T, Stephen and Lois Heleva and
the HelevaLandfill Inc. (through Heleva's attorney) that they planned to take
action to supply alternate water to affected households with contaminated wells
in the area.. An Action Memorandum approving CERCLA funds was signed on February
15, 1985. Meetings were held with each of the responsible parties to see if
they would agree to sign and implement a Consent Order for the \al ternate .
water supply and related activities. On February 27, 1985 the EPA issued a cons"!nt
order to and with AT&T. An Administrative Order was issued to.the Helevas
and Heleva Inc. on February 27, 1985.
~
Compliance with all three of these Orders is currently being monitored by
!PA's Enforcement Branch in Region III.
. CERCLA 1104(a) "Notice Letters" for remedial action at Heleva were sent to
the three responsible parties on February 15, 1985. The Helevas and Heleva
Landfill Inc. have declined to perform the remedial respouse. AT&T has until
March 26, 1985 to respond to the notice letters. If AT&T agrees to perform the
remedial response we will negotiate a consent order with them for a 60 day
period after the ROD is signed. .
Conclusions
The following conclusions are based on the Remedial Investigation (RI)
(January 1985):
- The primary source of ground wate.r contamination in the area is believed
to be from TCE contamination in the landfill.
- The prilD8ry aaodes of environmental contaminant transport is the ground water
flow through the bedrock fractures and possibly through old mining tunnels
from past iron ore operations.
\ .
- Data from the monitoring wells onsite indicates that the highest levels
of contamination are found in the ground water. Ground water moves south-southeast
and eventually discharges into Coplay Creek, Ranger Lake and the old Whitehall
Cement Quarry. .
- TWo residential wells have been contaminated near or at the EPA Office of
j
-------
-7-
Drinking Water lO-day Health Advisory (200 ug/l) for TCE.
- TCE Contamination has been detected in offsite surface waters (Coplay Creek,
Ranger Lake and the Whitehall Cement Quarry) below the Water Quality Criteria.
- TCE Contamination above ambient air levels have been recorded onsite. Due
to dispersion, these levels were reduced to background downwind and just offsite.
Alternatives Evaluation
The technologies remaining after the initial screening will be combined
to develop the alternatives that would meet the site-specific remedial action
objectives and the criteria for evaluation of alternatives. The combined
technologies were screened with respect to the remedial objectives, as outlined
below:
- To maintain
- To maintain
- To maintain
of contaminants
- To ensure technical feasibility, public acceptability, and cost-
effectiveness of the remedial actions.
public health and safety
the quality of local surface water
the local land use by decreasing the risk of the migration
In addition, the following were used to eliminate ~ny of the permutations
obtained from the combining of the technologies.
- Based upon the results of the Remedial Inveseigation, potential movement
of contaminated ground water is a problem at this site.
- Alternate water supply must be included in the selected remedy.
.,
- Controlling the flow of the surface water across the site is a universal
re~uirement of the remediation in order to control erosion and protect the
integrity of the cap systea. Therefore, diversion of surface water will
be included in . chosen alternative. .
- Decreasing the amount of erosion of surface ..ter!als, through grading
and revegetation of the site, is a requirement of the remediation and will be
included in a chosen aleernaUve. . . .'
TheNCP specifies that remedial alternatives should be classified either
as source control (40 Cla 300.68(e)(2) or offsite (..nagement of migration) .
remedial actions (40 CPR 3oo.68(e)(3». Source control remedial actions address
sf tuations in' which hazardous substances rell81n at or near the areas in which
. they were originally located and are not adequately contained to prevent.
:migration into the environment. Management of migracion remedial actions-
address situations in which ehe hazardous substances have largely migraeed from
their original locations. Alternatives developed may fall solely in either
classification or ..y involve a co.bination of source control and aanagement of
migration measures, as deterudned by the specific site problems addressed.
. The cost-effective alternative is defined as the lowest cost alternative
o
that Is technologically feasible and reliable, effectively aitigates or minimizes
damage, and provides adequate protection of public health, welfare, and the
environment (40 crR 300.68 (j». Alternatives were developed by applying the
technologies to the site singly or in combination, based on the previously
developed remedial objectives.
-------
-8-
Numerous remedial technologies are available for use at the Heleva site.
Although many options are applicable, it is apparent that a number of technologies
can be removed from consideration. The rationale for eliminating various
alternatives is presented in Table 7. This screening was.based on the data and
informacion obtained in the remedial investigation.
Those technologies that have passed the technology screening process are
used to form remedial alternatives for the Heleva Landfill site. Remedial.
alte.rnatives are developed using best engineering judgement to select a technology
or groups of technologies that best address the problems existing at the site
in order to protect public health and the environment.
. In order to study a range of responses, site remediation alternatives that
fall into one of five different categories are developed. These categories are
described below.
- No action:
No-action alternatives could include monitoring activities.
- Alternatives that meet the CERCLA goals of preventing or minimizing
present or future migration of hazardous substances and protect human health.
and the environment, but do not attain all of the applicable or relevant
standards. (This category may include an alternative that closely approaches
but does not meet the level of protection provided by the applicable or relevant
standards.) .
~
- Alternatives that meet tERCLA goals and attain all applicable or relevant
Federal public health and environmental standards, guidance, and advisories.
- Alternatives that exceed all applicable or relevant Federal public health
and environmental standards, guidance, and advisories.
. .
- Alternatives specifying offsite storage, destruction, treatment, or
secure disposal of hazardous substances at a facility approved under the Resource
Conservation and Recovery Act (RCIA). Such a facility must also be in compliance
with all other applicable Environmental Protection Agency (EPA) standards.
The evaluation criteria selected were: techDical feasibility, ~blic
health, environment, institutional evaluation, and .cosc effectiveness.
Particular emphasis was placed on: .
- Technical Feasibility
. - Performance
- Implementability
- Reliability
- Public Health Evaluation
. Reduction of Heal tb impacts
EnvironmentAl Evaluation.
. Reduction of environmental impacts
- Institutional Evaluation
. Legal requirements, institutional requirements
. Community Impacts
-------
-9-
- Cost effectiveness.
. Capital Costs
. Operation and M4intenance
. Present Worth Values
. Sensitivity Analysis
. Cost Variations
Costs
The technologies remaining after initial screening were combined in logical
groups in order to fit into the five different categories mentioned above. The
seven alternatives developed were: .
- No Action with Monitoring
- Alternate Water Supply and Monitoring
- Alternate Water Supply,. Landfill Cap, Monitoring
- Alternate Water Supply, Landfill Cap, Source Reduction, Monitoring
- Alternate Water Supply, Excavation, Disposal in an Onsite RCRA Landfill
.and Monitoring. . .
- Alternate Water Supply, Excavation, Incineration of Waste and Monitoring
- Alternate Water Supply, Excavation and Removal to an Offsite RCRA
Landfill and Monitoring
I
Description of Remedial Alternatives
A.
No Action Alternative
1.
No Action with Monitoring
. Under a no action alternative, additional remedial activities would not
be performed. However, a long-term monitoring. program would be established to
provide information on contaminant migration that could cause further adverse
exposure to humans, sensitive and important aquatic species, and the environment.
Through the use of a comprehensive monitoring program, future environmental
impacts and health risks could be observed and then addressed.
. . ~. "v
The three sources of water samples at the Heleva Landfill Site are
residential wells, monitoring wells, and surface water points. Monitoring of
the residential wells would be essential since the ~ter is used for human
consumption.. Those residential veIls previously identified as 'contaminated, as
well as those which could b8COM contalll:1nated would be sampled.
Since fractures in the geologic formations provide a pathway for migra- .
tion of contaminanted ground water it is necessary to monitor the ground water.
Monitoring wells constructed in the aI phase of this study could be used for
monitoring migrating conta8inants downgradient fro. the site. Due to the high
degree of bedrock fractures the possibility exsistthat migration of contaminants
could be missed. '
, Surface ~ters are potential receptors for leachate that seeps from the
deposited wastes.' Also, ground water 1II&Y be contaainating some of the nearby'
surface waters. Surface waters may be used for bathing, irrigation, lawn
watering, and recreational uses, as well as providing a habitat for aquatic
organisms which potentially could be consullll8ed by humans. All onsite ponds and
affsite surface water receptors will need to be monitored.
-------
Groundwater Barriers
1. Slurry walls
Grout curtain
Sheet piling
Gel injection
Alternate Water Supply
TABLE 7
RATIONALE FOR ELIMINATING
VARIOUS TECHNOLOGIES
1. Upgradient wells with storage
and distribution system
2. Provide bottled water
3. Individual treatment unit8
. .
Surface capping
1. Sprayed bituminous membrane
2. Polyurethane fOall
3. Resins
Leachate Collection.
1. Prench drain
2. TUe drain
\
Rationale for Elimination
-all: Not effective due to
highly fractured bedrock.
-Little excess capacity;
continuous 8Onitoring required
. -Short t.ra 8olution only
-EKtensive 8Onitoring requ~ed
-Su8ceptable to cracking
-Hot fully de80DBtrated
-Hot fully de80nstrated
-to. hydraultc conductivity
-Su8ceptable to clogging
aDd crusbi ng
-------
EXTENDED 12 WATER
BASE MAP IS A PORTION OF THE U.S.O.S. CEMENTON.PA OUADRANOLE (7.9 MINUTE SERIES, 1964, PHOTOREVISION 19?2, CONTOUR INTERVAL 10)
FIGURE H
ALTERNATE WATER SUPPLY
EXTEND EXISTING 12-INCH WATER LINE
HELEVA LANDFILL SITE. NORTH WHITEHALL TWR. PA
SCALE 'l"= 1000'
-------
-10-
Due to seasonal variations, sampling and analyses should be conducted
once per quarter, at a minimum. For cOwting purposes, it is assumed that this
program will con~inue for thirty years.
B.
Alternatives that Meet the Objectives of CERCLA
1 .
Alternate Water Supply and Monitoring
This alternative involves extending the existing public water supply
lines along Hill Street and portions of Main Street in Ironton to 15 homes.
The water supply is being extended to these homes because they lie in the
expected downgradient movement of ground water and, due to their proximity,
are in danger of becoming contaminated in the near future. Rights f~r providing
water supply services in the vicinity of the Heleva Landfill Site are held by
the Northampton Municipal Water Authority. Figure 4 shows the location of the
existing public water lines along Main Street in the Village of Ormrod, as
well as the proposed extension. -
In addition, the monitoring program described above will be implemented
for all monitoring points except the residential wells. Some residential wells
may be included in future monitoring activities.
2.
Alternate Water Supply, Landfill Cap, Monitoring
This alternative includes the alternate vater supply and monitoring
program previously described. In addition, an impermeable cap which meets
standards listed in the RCRA regulations will be placed over the entire landfill..
The landfill boundar!es were determined through data received in the geophysical
and hydrogeological investigations. The cap will stop the erosion of the
cover material .which is now Gn the landfill, and will th~s prevent release of
. matedals in the landfill. Levels of up to 15,000 ug/l of TCE have been found
in the landfill during the investigation. It will also stop the generation of
rain induced leachate by preventing rainwater infiltration into the landfill.
At the Heleva Landfill site, rain-induced leachate stops within a week after a
rainfall event ends. Ground vater is at least 30 feet under the land surface.
Installation of the cap should be done during dry weather, so there will be no
residual leachate seeping out after installation of the cap. Consequently, no
leachate collection is being provided. Installation of a cap will also require
installation of a gas collection and venting systes so that the methane generated
in the landfill does not bu1ld up high pressures or sigrate into the basements
of adjacent homes. Surface vater will be diverted around the landfill.
C.
Alternatives that Sati8fy All Applicable Standards
1.
Alternate Water Supply, Landfill Cap, Source Reduction and Monitoring
All remedial activities discussed in the previous alternative (1.2) a180
apply here. In addition, a source reduction process would be iaplesented
subsequent to the ~re-design study.Thi8 pre-design study will be carried out
on the southern portion of the landfill to delineate the extent of the contaadnated
area within and near the landfill so that design specifications can be developed
that will be accurate for bidding purposes. Tbe study will also identify
optimum locations and nusber of recovery wells necessary for the program and
determine if the source reduction process will be effective in reducing conta8in-
ation over the extent of the contaminated area. .
-------
-11-
The source reduction process will consist of a number of wells drilled to
the bottom of the landfill in order to ~ump out .contaminated wastewater. The
wastewater will then be treated and. subsequently discharged into Coplay Creek.
This remedial action will continue for a period of at least two years (unless
contamination level targets are reached in less time). .
Several major treatment unit processes or operations were considered to
treat the contaminants in the wastewater so that technical requirements with
permit limits for Coplay Creek can be met. Major unit processes/operations.
such as air stripping, activated sludge. carbon adsorption. aeration, flow
equalization, lime addition and mixing~ and sedimentation were considered.
L1me 1s added to raise the pH value of the wastewater and enhance the precipitation
of heavy metal contaminants. The settling basin is used to remove the suspended
solids or the precipitate of the metal ions. Air stripping will remove dissolved
or entrained gases with TCE removal being the major objective of this process.
The activated sludge process is used to remove dissolved organics by the
growth of microorganisms and the subsequent re~oval of the cellular mass. BOD
and NR3 reduction is the goal of this process. Since the characteristics of
the contaminants in the pumped water are currently unknown, results of analyses
performed on other leachates were used to develop an estimate of the raw waste
characteristics. . .
\
Further discussion on applicable and relevant standards i8 8et forth in
the discussion of "Consistency with Environmental Laws-.
D.
Alternativestbat Exceed.AlI Applicable Standards
I. Alternate Water Supply, Excavation of Wastes, Disposal in an Onsite
RCR! Approved Landfill, Monitoring
Below tbe Releva Landfi~l are two former ponds wbicb botb ext,nd to an
estimated depth of 30 feet. These ponds are'assumed to bave been filled witb
wastes during tbe disposal period of tbe landfill. Based on tbe assumption
that the side slopes of the fill and both ponds are two units horizontal to
one uait vertical the volume of tbe landfill is estimated at 750,000 cubic
yards. .
Co~lete excavation of this quantity of material involves excavation and
hauling of waste material fro. the landfill to a nev onsite RCIA-approved
landfil~. Contaalnants would be released fro. the disturbed fill through
volatilization, Which would lead to posstble air pollution. Specialized con-
struction techniques would have to be developed to ~nimize the a.aunt of air
pollution. The techniques under consideration are the use of a te.porary
. liner over excavated portions of the laadfUl and of covered truw during any
. type of transportation. bc:avatioa and hauling would take place 16 bours each
day to minimize the length of ti- the _terial is ezposed.
\ . .
A preliminary design of an onaite landfill was done for the excavated
waste. The landfUl location was selected because of its pronatty to the
waste excavation area and its accessibility for post-clo8ure ..inteDance and
monitoring. The existing landfill was not used as the site for the nev landfill
because of the difficulty of constructing part of the nev landfill, and then
fUBng it with uterial that is being excavated to _ke r008 for construction
of addi Cional parts of the new landfill. A plan viev of the location of the
-------
-12-
landfill is shown 1n Figure 5.
The landfill incorporates a two-liner design with both leachate collection
and "leak detection zones. A synthetic membrane placed on a 2 foot layer of
clay will compose the double layer for the base and sides. A double layer cap
is used consisting of a PVC membrane and a 2 foot thick clay layer beneath a
seepage flow zone. Additional soil with a vegetative cover is placed on top of
the flow zone. " "
If all contamination can be successfully excavated and properly disposed or
treated, then this alternative should exceed the design targets set forth in
this document.
2.
Alternate Water Supply, Excavation, Incineration of Wastes and Monitoring
This alternative is similar to the option described above (D.l) except
that incineration will be used to destroy the excavated material, rather than
placing it in a RCRA approved onsite landfill. .
This alternative involves the excavation of the entire landfill, the
total amount of contaminated materials above and below the water table.
Since excavation rates and incineration rates are not the sa~, a temporary
storage facility will be needed for excess excavated material: The maximum
amount "that will be stored at anyone time is a~proximately 12,000 cubic yards. ~
A covered storage building will be used. Decontaminated materials could be
redisposed on site, while the fly ash produced would be considered hazardous
due to the presence of heavy metals, unless testing proves otherwise, and
would be disposed of in an approved hazardous waste facility.
" Only one type of incineration process is recommended for use at the.Heleva
Landfill site. This incineration process is the rotary kiln, the process
currently used by all of the commercial solid waste destruction facilities.
The rotary kiln has proven to be a very flexible unit, one that can withstand"
the rigorous conditions experienced during destruction of the heterogeneous
waste typically found in landfills. Rotary kilns have been used" extensively
for the treatment of troublesome, variable, solid wastes.
Since offsite ErA approved hazardous waste incinerators are ~urrently limited
in number and capacity, design and construction of onsite units dedicated
strictly to the landfill waste is proposed. Por Beleva such a facility would
include three incinerators eacb with a capacity of seven tons per hour. The
entire volume of landfilled waste could be incinerated by this facil~ty within
three years.
Alternatives Which Specify Offsite Disposal
1. Alternative Water Supply, Excavation and Re80valto an Off8ite ICRA"
Approve, Landfill and Monitoring
This alternative ia identical to the onea above except that the excavated
waste would be di8posed in an off8ite ICIA approved landfUI. Thi8 would be
done after excavation of the contaminated wastes. The ..terial would be
transported fro. the Releva Landfill site to a facility which meets all currently
applicable RCRA requirements. The trucks used Would have a 20 cubic yard.
capacity and would also be equipped with tarps to prevent spillage and minimize
volatilization of the contaminants. In addition to the removal and disposal of
E.
-------
MELEVA LANDFILL SITE. NORTH WHITEHALL TWR. PA
KALf>l**400'
W/KT
FIGURE s
-------
-13-
contaminated material, water lines would be extended to
and monitoring would continue at the eXLSting wells and
Transportation and disposal permits must be secured and
must be met.
the residential homes
surface water points.
all RCRA requirements
Costs
The costs of each alternative have been estimated based on construction
rates and treatment prices characteristic of the area. In addition, estimated
operation and maintenance costs per year, as well as the present worth costs
have been calculated. Present worth costs in the amount of investment needed
today to finance operation and maintenance necessary for each alternative. These
costs, as well as comparisons of each alternative public health, environmental,
technical and institutional considerations can be found in the alternatives matrix
(Table 8). .
Community Relations
. The Draft Remedial Investigation and Feasibility Study (RI/FS) was made
available for public comment between February 6, 1985 and Karch 6, 1985. Copies
of the document were placed in repositories in the North Whitehall/Allentown
area. The EPA Office of Public Affairs contacted the local media 88 to the
availability of the RIfFS report for public review and to annouDce that a
puol1c meeting would take place on February 19,1985. .
~
On February 13, 1985, a joint EPA and PA DER Fact Sheet was submitted to
the repositories which announced the regulatory agencies preferred alternative
for the Releva site. This fact sheet emphasized that this option was not a
final decision and that all comments would be welcome on any alternative until
Karch 6th. .
Tbe public meeting was held at the North Whitehall TOVDship Building in
Ironton, PA and was attended by representatives of ErA, PA DEI, the NUS .
Corporation, the Nortb Whitehall TOVDship Comadssioners, members of the local
media and approximately 50 concerned citizens.
No major concerns or complaints arose during the public meeting. There
were many good questions on the presentation given and on ErA and ~ER policies
a!.., they apply to the Superfund. Host of the concern expressed was over property
values in the area. One inquiry vas _de as to. possible rei.bursement of IIOney
expended by local citizens to tie into tbe vater line in 1980. Specific comments
and responses can be found in the attached Responsivenes8 Summary.
Recommended Alternative
. Section 300.68(j) of the Rational Conting~ncy Plaa (HCP) [47 FI 31180;
July 16, 1982J states that the appropriate extent of remedy shall be deteraiDed
by the lead ageDcfts seiectioD of the. remedial. alternative which the agency
determines is c08~-effective (i.e. the lowest cost alternative that i8 techDically
feasible aDd reliable) and which effectively 81tigates and 81ni81ze8 damage to
and provides adequate protection ofpub~ic health, welfare and tbe enVirOD8eDt.
In selecting a remedial alternative EPA consults other environmental laws that
are applicable and relevant. Based on the evaluation of the c08t-effectiveness
of each of the proposed alternatives, the comments received fro. the public,
information fro. the Feasibility Study and iDfor88tion from the Pennsylvania
Department of EDvironmental Resources, we recommend tbat the -Alternate Water
-------
-14-
Supply, Landfill Cap, Source Reduction pnd Monitoring" alternative be implemented.
This alternative includes supplying alternate water by extension of the
existing water main, capping the landfill with gas venting and possible treatment,
source reduction through recovery wells in the landfill and monitoring of
ground water through sampling and analysis of RCRA approved monitoring wells
as well as surface water targets downgradient of the site. Prior to remedial
work at the landfill a pre-design study will be undertaken to further define the
extent and source location of the TCE contamination and to determine if the area
is prone to sinkhole activity. This option will meet the CERCLA goals of
minimizing present and future migration of hazardous substances and protect
human health and the environment, while als~ attaining all applicable and
relevant Federal public health and environmental standards, guidances and
advisories. .
The recommended alternative is the least cost alternative that is
technically feasible and reliable, and which effectively mitigates and
minimizes damage to, and provides adequate protection of the public health, .
welfare and the environment. This option will also satisfy all the objectives
developed for the Heleva project. This alternative will (1) maintain the
public health and safety by providing an alternate water supply to local populations
which currently or potentially are affected by contaminated groundwater, (2) .
reduce or eliminate the source of contamination which is currently migrating
to area .surface waters, (3) maintain the local health, welfare and environment
by decreasing the risk of migration of contaminants through a RCRA approved
landfill cap, (4) and be both technically feasible and cost effective.
The alternate water supply extension of the 12- water main approximately 1
mile on Hill Street from Ormrod to Ironton, was chosen over three other
alternative water scenarios (new well and distribution, bottled water and
. individual well treatment) because it was the most complete and reliable of
those considered that will effectively remove any chance of human exposure to
ground water contamination. Table 7 offers the technical screening of. the
alternate water supplies.
The technology used to provide the alternate water supply is well established
and in cOlllllOn use. In addition, it can be implemented quickly to provide
remediation of the existing health. threat. There are no problems in implementation
of this alternative. Con8truction of the vater line viII disrupt traffic in
the area for a short time, otherwise, implementation will have little impact.
The design and construction of the water line can take place on a fast-track
schedule so that provision of water is not delayed by tbe pre-de8ign study
slated for onaite re..dlal action. .
An impermeable cap whicb meet8 the standards li8ted in the tCIA regulations
will be placed over tbe entire landfill. The cap viII stop tbe er08ion of the
cover material whicb i8 now on the landfill. It viiI also. stop the generation
of rain induced l.chate by preventing rainfall iufl1tration into tbe landfill.
Installadon of the cap sbould be done in dry weather so tbat there will. be no
residual leachate seeping out after installation. If constructed properly, the
cap should preclude any leachate coming fro. the landfill. However, if determined
necessary, a leachate collection systea viII be constructed and that leachate
viII be treated in the tre~tment systea to be constructed.
A clay layer will be used for the impermeable cap.
The existing cover
-------
-15-
material would be graded to eliminate punding. cracking and erosion channels
and then be rolled to compact the cover. Two feet of a compacted clay would be
placed across the surface of the entire landfill. This clay should have a
permeability of less than 1 x 10-7 cm/second. A 12 inch thick drainage layer
will then be placed over the clay. The drainage layer will be coverd with a .
geotextlle. to keep fine material from clogging the drainage layer. A minimum of
48 inches of soil will then be placed over the clay to provide. a root growth
area. This could be composed of 42 inches of onsite soils and 6 inches of
topsoil.
There is a concern that. due to the geologic formations in the area.
sinkhole activity may occur and threaten the integrity of the cap. Nomajor
solution cavities or sinkholes were evident during the geophysical investigation.
Since maximum karst topography takes a very long time to develop. the possibility
of karst features occurring in this area is very slim. In .order to support our
conclusions that settlement should not occur in this area. further geophysical
work needs to be done in the area. This work will be undertaken in the pre-
design study. If it is determined that some settlement may occur. the landfill
cap can then be specifically designed to withstand that amount of settlement.
The study will also include geophysical activity in order to locate the old
filled-in mine tunnels that may be acting as a conduit for movement of contaminated
ground water. If the tunnels are located, the possibilities o~ sinking a .
recovery well in the tunnel to intercept a large volume of the contaminated
ground water will be explored. .
~
Installing an impermeable cap4ver the 23 acre site requires installation
of a gas venting and migration control system (Figure 6) to abate the methane
gases formed from anaerobic decomposition of biodegradable organics. This
passive gas venting and migration control system will prevenC--meOtnarii-and- 0
other gases from developing extreme internal pressures within the landfill
site. The vertical pipe vents will be sealed at the juncture of each pipe and
the impermeable cap. The emissions fro. the gas collection vents should be
monitored to determine if treatment will be needed. Monitoring would involve
the use of organic vapor analyzers and laboratory analyses of air samples
taken at the vents and at the site boundaries. The results would be evaluated
to determine the need for treatment.
A source reduction program needs to be implemented since cont88ination is
leaving the landfill and threatens surface water and ground water supplies.
This source reduction process involves thesinktng of several wells to the
bottom of the landfill, puaping the contaminated water out, treating the water
and discharging it into Coplay Creek. This source reduction process will be
implemented subsequent to the pre-design study which vtll be ai.ad at determining
the optimum nuaber and locations of recovery wells, the extent and exact location
of the concentrated source and the effect the pumping operation will have on
reducing contamination over the extent of the contaadnated area.
The pumping aad treating will continue as a re..dJal action for at least
two years (woess contaminant targets are reached in l.s8 ti..) vtth the
target for trichloroethylene set at S-SO ug/1 and the target for vinyl chloride
set at laboratory detectable limits. The TCElim1t i8 ba8ed on the present
assessment of the potential cancer risk against the feasibility for. treatment
and has been used by ErA since May 1983. The 10-6 carcinogenic risk level 0
for vinyl chloride Is set at .01S ug/l. Since current laboratory detection
limits are only 10 ug/l the design target for vinyl chloride will be at its
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-16-
detectable limit.
If the contaminant targets are not reached after two years of pumping and
treating, the Regional Administrator will make a decision on the technical
feasibility of reaching these targets. If it is determined that the targets
can be reached, pumping and treating will continue as a remedial action and are
still eligible for Trust Fund monies. If original.contaminant target levels are
determined to be technically infeasible to obtain, the targets may need to be
adjusted; if doing so is not cost prohibitive. .
If the pre-design study determines that a relatively short pumping and
treating period will be needed (ie. one year or less) then placement of the cap
will occur subsequent to the source reducton process. However if the study
deems it necessary to pump on a long term basis, or if well recovery times
preclude high volume pumping, then the cap will be constructed prior to the
commencement of source reduction. If the cap is in place during the source
reduction program,. the pumpi ng rates will be low enough to ensure that no
significant settlement, due to radical 'changes in ground water pressures, will
occur.
It is proposed to treat and discharge the waste water to Coplay Creek. .
S1nce the wells will be pumping from the bott08 of the landftll, it was assumed
that the waste water will have the characteristic similar to leachate, along.
. ~
with the TCE and associated compound contamination. Several major treatment.
processes or operations were considered to treat the cOGtaminants in the waste.
water so that substantive requirements for discharge to Coplay Creek can be
met. Major unit processes/operation, such as air stripping, activated sludge,
carbon adsorption, aeration, flow equalization,li.- addition and mixing, and
sedimentation will be considered. Since the characteristics of the contaminants
in the pumped water are currently unknown, exact characteristica of the vater
at the base of the landfill will have to be obtained. A treatability study'
will be needed to complete the design of the vaste vater treatment plaDt.
The anticipated treatment train for the source reduction waste water is shown
in Figure 1. The use of activated sludge, Ii.. mixing, and settling/sedimentation
1s optional depending on the characteristics of the raw waste and the effluent
limits imposed on the discharge. .
Monitoring of several points in the area will. be necessary during and.
subsequent to re..dial activities to ensure that contaadnation is not increasing
and, in ti.-, the source reduction progra. is working. 'The prt_ry contaainants
found at the Beleva site are all volatile organics and it is believed that
this will be the only fraction necessary for analysis. A s"ll percentage of
the IIOnitortag points will be analyzed for full inorganic and organic Hazardous
Substance List (BSL) c01lpOunds. .
The three sources of vater samples in the area are residential wells,
monitoring well~ and surface vater points. Monitoring of the residential
wells will be periodic until the alternate water supply line is constructed and
operational. Monitoring well. conatructed in the II phase will be sampled
periodically to develop a pattern of down gradient conta8dnation fluctuations.
Surface waters are potential receptors for discharge of contaadnated ground
water. Surface waters will be sampled and analyzed once per quarter year,
at a minimum, to ensure that site related contaminants are not adversely
affecting aquatic life. .
-------
;#
"
NOTE' TOP 0' LANDFILL ILEVATI~N 800.0'
FIGURE (. .
. GAS VENT SYSTEM . .
HE . ~VA LANDFILL SITE. NORTH WHITEHALL TWP., PA
,.' SCALE ," = 200' . ..' '.' .
,.,-' ,
". c' ~,l ~~,~ ,>
-------
. "
FROM RECOVERY
WEW 10,..
LIME fEED
" -rl,H ADJUSTMENT
------.,.. 8-10
I
" I
I
MIX
T ANI(
CLARIfiER
ACID fEED
"t10.
-- - - -Q pH A~~STMENT
I
I
ACTIVATED
CARlON.
fiLTRATION.
GROUNDWATER TREATMENT PLANT FLOW 9'AGRAM
HELEVA LANDFILLSITE.NORTH.~HITEHALL TWP.. PA
NOT TO SCALE .::
0" 8_S
\."
WCT HEATER
. .t~'II"
PACKAGE IIOLOGICAL
TREATMENT UNIT
TO DISCHARGE
FIGURE 7
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-17-
In addition to the above, a RCRA approved monitoring program will be
implemented during source reduction. Lbis involves drilling one upgradient
well (from the source of contamination) and at least 5.downgradient wells,
three in bedrock and two in the uncohsol1dated deposits.
Cost of Recommended Alternative
The base capital cost of the recommended alternative is $7,253,000 with a
low-high range from $6.26 million - $8.15 million. The Corps of Engineers cost
for oversight on construction work is $95,000. Cost of actual design, including
the pre-design study is estimated to be $443,000. Therefore, the total design
and construction for the recommended alternat1ve 1s $7,79l,000~
Consistency with Environmental Laws
Envitonmental laws which may be applicable or relevant to remedial activity
are: .
- National Environmental Policy Act (NEPA)
- Clean Air Act (CAA)
- Clean Water Act (CWA) .
- Safe Drinking Water Act (SDWA)
Resource Conservation and Recovery Act (RCRA)
- Pennsylvania Clean Streams Act
~
This alternative meets NEPA functional equivalency exception because the
necessary and appropriate investigation and analysis of environmental factors
a8 they specifically relate to Heleva and the recommended alternative were
considered and evaluated in the Remedial Investigation and Peasibility Study.
In addition, a meaningful opportunity for public .comment.on environmental
iS8ues was provided before tbe final selection of tbe remedial alternative was
made. .
No floodplains or wetlands will be affected by tbe recommended altemative.
Compliance witb all applicable substantive requirements of the CWA and CAA as
well as the Pennsylvania Clean Strea.. Act will be built into the design of
the remedial alternatives. ADy discharge into the atmosphere of gaa fro. the
venting operation will be monitored and treated as necessary. All state permits
for discharge of treated waste water will be acquired and complied with as
necessary.
The alternate water supply will pipe in potable water under the supervision
of the Northampton Water Autbority whicb are subject to tbe requirements of the
SDWA. including monitoring. In easence. all ground water targets (potentially
affected residential wells) will be eliainated, thus r..oving the present
health risk of drinking water fro. this aquifer. A temporary institutional
restriction on ..11 drilling for potable water purposes will be requested of
the local government until source reduction is successfully coapleted.
\ . . .
This recommended alternative meets the require..nts as needed for site
closure under the Resource Conservation and Recovery Act with one exception.
Contaminated ground water aigratingfro. the facility (landfill) and moving
downgradient cannot be captured, collected or intercepted 88 called for under
RCRA. The contamination is III1grating very quickly in regional bedrock which is
highly fractured and faulted and structuall; comples. The possibility of
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-18-
. .
capturing the ground water in an effic~ent and cost-effective manner would be
small due to the. numerous fractures that are not inter-connected. The success
of constructing collection wells would be low due to the difficulty of intersecting
open rock fractures in the zones where the TCE may be migrating. Some ground water
recovery may be accomplished by placing a well in the old mine tunnels
southeast of the landfill. However, due to the highly fractured nature of the
bedrock, the complete interception or total collection of ground water from
downgradient bedrock is judged not practical, effective or technically feasible.
All other components of the recommended alternative meet the regulatory
intent of RCRA. A monitoring system will be constructed at the waste manage-
ment boundary. The landfill cap will be constructed to meet the requirements
of Section 264 of RCRA. The caps integrity will be assured through design
specifications to prevent settlement due to area geology or from pumping from the
source reduction process. The source reduction program, will significantly
reduce or eliminate the contamination of the ground water. . .
Operation and Maintenance
The components of the recommended alternative that may require operation
and maintenance are:
- Landfill Cap
- Treatment Plant Operation
- Recovery Well Pumping-Operation
- Surface Water Diversion Sys~em
- Gas Venting and Possible Treatment
- Monitoring
The landfill cap, gas venting, surface water diversion and monitoring -
program viII be considered normal operation ~nd ..intenence and viII be the
responsibility of the State of Pennsylvania six 80nths su~sequent to completion
of construction.
- The source reduction and trestment process will be considered part of the
approved remedy for a period of at least two years, unless contamination
reduction targets are accomplished in less time. If the targets are not reached
after two years of remedial activity the legional Administrator viII dete~ne
if it is technically feasible to reach those targets. If further pumping and
treatment is required this will also be considered as part of the approved
remedy and e11gi ble for Trust Pund 8Onies. -
If contamination reduction targets are reached and the remedial activity
is closed out, the State of Pennsylvania will then begin operation and aa1ntenence
on this portion of the project. U for any reason after cl08eout the ground water
contamination levels rise in the monitoring wells, the State of Pennsylvania
will restart the pumping and treating process until the ground water contaadnation
is once again reduced to close-out levels.
No Action Alternative
This alternative assumes that no remedial activities will be taken at the
Beleva Landfill site. If this vas the ch08en alternative it i8 believed that
The identified contamination in the ground vater viII continue and possibly
increase in concentration. Per80na u8ing ground water for drinking water
supply viII continue to beat a health risk due to TCE contamination. Puture
potential ground vater u8erswould p08sibly not be able to U8e the aquifer a8
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-19-
a potable water supply. Surface water contamination may increase due to con-
taminated ground water discharge and threaten the aquatic life in Coplay Creek,
Ranger Lake and the abandoned quarry. Contamination of the food chain would
be a real possibility if surface water contaminant levels increased significantly.
Public health would then be at risk by consumption of aquatic organisms from.
these surface waters. The landfill cover will continue to erode, leading to
increase exposure of waste to the air, soil and surface waters (Todd Lake).
Due to the above public health and environmental threat and because this alter-
native would not satisfy CERCLA goals or Federal public health and environmental
standards, the No-Action alternative was removed from consideration.
Alternatives Not Recommended
In conducting Superfund remedial actions EPA attempts to select the
remedial alternative which best mitigates the public health and env1ronment.~1
threat while attaining all relevant and applicable environmental standards,
regulatioDS and procedures. We feel tbat tbe reco~nded alternative is the
. best option to meet these policy goals.
The NO-Action alternative is discussed in the preceedlng section. Continued
monitoring along with the No-Action alternative can provide U8 information on
the severity of tbe ongoing contamination of tbe environment, and attempt to
give us advanced indication of a potentially damaging release to the environment~
However migration of a contaminant may go undetected due to the fractured .
nature of .the bedrock. . .
The Alternate Water Supply option alone will remove present targets of
ground water contamination but does not address future use of the aquifer as a
potable water supply. Contamination of the surface water would concinue to occur.
The exsisting landfill cap will.contlnue to erode causing leachate to runoff'
the site to local surface water (Todd Lake) and nearby fields with potential
increased air contamination through volatilization of organic compounds.
The third alternative involves capping of the landfill with a ICRA approved
cap. Although the cap will prevent erosion, tnftltration and leachate flow, it
does not address contaaination that is currently migrating to the bedrock and
eventually discharging to the local surface water. This alternative, as in the
previous option, does not address future use of the area ground water.
In the fifth alternative, excavation of waste is coabined with disposal in a
RCRA landfill constructed just south of the site. Although this may meet
CERCLA and other envlroD8ental goals, there is a greater risk ..sociated with
this option. Excavation of vaste could cause exposure of unknown quantities
and concentrations of volatile organics .to the atmosphere. Because of the
geology of the area (liaestone-doloadte) immediate recontamination of the.
enviroDlllent would occur if the liner sy.tea would fa11. AD e_rgency contingency
plan would need \0 be developed due to the uncertainty factors involved when.
excavating hazardous waste landfills. This alternative would have difficulties
meettng the substantive requirements of RCRA through siting issues and monitoring
require_nU.
In the next option excavation of the landfill is combined witb incineration
as its method. of ultimate disposal. Due to ltaited capacity of offsite RCRA
. approved hazardous waste incinerators, only the onsite incineration option was
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-20-
fully considered. This alternative call~d for the design and construction of
three, RCRA approvable, hazardous waste incinerators that would be operated at the
site. The incineration would need to take place on a 24 hour, 7 'day a week
basis for three straight years to fully destroy the anticipated volume of waste
at Heleva. Health risks cause by the increase of air pollution from the'
incinerators is a possibility. Disposal of the contaminated flyash would have
to be done at an approved offsite facility. In addition all the risks of
excavation would also apply to this option.
The last alternative evaluated was excavation coupled with disposal at an
offsite facility that was in compliance with RCRA regulations. Once again the
high risk to the local popoulation from site excavation of hazardous materials
1s a drawback for this and all excavation options. , In addition, human and
environmental exposure is possible if a spill or accident should occur during
transit. Offsite RCRA landfill capacity is currently limited and may not be
available to handle the waste volume at this site. '!be total'capital cost,of
this alternative ($97 million) may be prohibitive under the Fund-balancing
requirements.
Proposed Action
We request your approval of the recommended remedial altetnatlve as
described above. This action will complete construction for the Releva Superfund
Project. Tbe estimated total cost of design and construction for this federal
lead project is $7,791,000. '
-- - --- ~- -- ..-- ---- . - .
-------
RESPONSIVENESS SUMMARY
HELEVA LANDFILL SITE
NORTH WHITEHALL TOWNSHIP, PENNSYLVANIA
This responsiveness summary is broken into two sections: I. Verbal questions,
comments and EPA responses during two February 19 meetings with the public.
I I. Written questions and comments received during the comment per.1od,
February 6 - March 6, and EPA responses. Concerns raised during the
course of the RIfFS were few, and are covered in the comments which follow.
I.' The U.S. EPA and PaDER held two meetings February 19, 1985 to outline the
RIfFS to the public and to elicit comments on the FS and EPA's preferred
alternative. Bill Hagel, Ray Germann, and Francisco Barbe of EPA, and Gil
Meyer, Ann Cardinal and Steve Pederson of NUS met with Township Supervisors
Ronald Sechler, Paul Kuhns and Emory Minnich at 5 p.m. at the North
Whitehall Township Building and briefed them before the public, meeting.
The 7 p.m. public meeting at the same location was attended by those.
previously mentioned, Dave Crownover, of DER, approximate Ii 30 residents,
and other interested parties including AT&T representatives, quarry
owners, two newspaper reporters, one radio reporter and one TV reporter. 'lbe
following is a sUllmary of the points raised during those meetings and
other verbal discussions before and ,during the comment period.
...
: Site Responsibility
Concern:
Response: .
Concern:
Response:
Superfund money is used when the owner cannot or will not pay
for the cleanup. Into which category does this site fall?
At this point we have gone ahead wi th the study while the legal
staff is looking into financial liability of the landfill owner.
Af ter the record of decision (ROD) is signed, ErA will begin
negotiations with the landfill owner and any other potentially
responsible parties (PIPs) to determine the financial capability
of the PIPs and if any want to do any part of the cleanup of the
site.. . .
lsn' tthere SOlIe liability under the law for the generators ,
transporters, and disposers?
Generators, transporters, and disposers are all potentially
liable for the problema. During investigation of this site,
inquiry letters were sent to 184 potentially responsible
pa~ties. Th1s does not iaply that all or any of these were
responsible for the problem but rather these letters help
detena1ne what,how much, and when mat~rial .y have been
deposited on the site. Usually aost do not ult1aately have a
direct interest in the site problem. .
-------
Concern:
Response:
Concern:
Response:
Concern:
Response:
Concern:
Response:
Concern:
Response:
Concern:
Response:
Concern:
Response:
Concern:
Response:
2
I heard somewhere chat, al.. this site, some major companies are
involved and that EPA has taken some legal action against some?
That is true. . As a matter of fact, one company has agreed to
provide bottled water to some home owners that had contaminated
wells. As work at this site progresses, we expect more PRPs to
be named and to negotiate wi th them for help in the cleanup.
You talk about options as though there are no restrictions, but.
you don't have title to any of the land. Are you restricted in
any way by who owns the land? If you remove everything that was .
put into the landfill, does Heleva still own the land?
Yes, Heleva would still own the land. We are bound by law to
pick the most cost effective alternative that will correct the
environmental degradation. We would have the authority to go to
the court to obtain the necessary access to do whatever work is
needed. .
Do you have emi nent domain powe r?
No.
Only the power to clean up the land -- not take the land.
Have you had to go to court here to get onto this land?
No.
Not so far.
If you cap and vent the site but you do not have eminent domain,
how do you keep the owner from developing th~ area for personal
gain?
This 1s generally handled as part of the deed.
for use is carried in the deed.
The restriction.
If the well has 200 ppb TCE, isn't the home owuer's property
value affected?
Often the value is affected until the.problea is corrected. In
this case the alternate water supply will remedy the situation.
Does the state. pay for any of this work?
operation and maintenance of this site? .
Who pays for the
The state must pay 10 percent of the cleanup costs if the work is
done as part of ~uperfund.The state theuhas total financial
responsibility for the operation and maintenance cost.
What happens if the progr- doesn't work in five years?
We believe strongly that this progr- will work at this site. If,
however, we determine through monitoring that further remedies are
needed, - will cOIle back and perfot'll the work. .
-------
Concern:
Response:
Co nce rn:
Response:
Concern:
Response:
3
Hooker Chemical paid the people of Love Canal $20 million. Why
can't we sue someone for this problem? And would EPA support the
citizens if we filed a class action sui t? .
The federal law does not prevent any citizen from sueingany
responsible party over damage. The Superfund law does not contain
a "victims compensation" clause, so citizens can only sue private
companies and responsible individuals. EPA has the authority to
recover the cost of cleaning up the site. EPA can not, however,
actively participate in citizen suits.
Is there any protection from this kind of problem happening again?
Yes. Congress has passed the Resource Conservation and Recovery
" Act (RCRA), which gover~s the siting of all landfills, as well as
tracks hazardous chemicals from the generator through the disposer.
Is all the work done at this site available to the public?
Yes, all reports are available at the local Township building, the
local FaDER office, as well as in the EPA Region III office.
Groundwater Impacts
Concern:
Response:
Concern:
Response:
. ~
There was a study done initially and testimony given to DER, which"
determined that "the groundwater could not possibly be flowing to
the south and southeast. Your study seems to disagree with these
findings; was the other study wrong? .
We are aware that there were some studies done by a Lehigh
University professor. we cannot comment on the findings or the
detail of those studies; however, our extensive investigation
reveals that the groundwater can and does flow south and southeast.
, .
Initially you found no contamination in.residential wells east of
the landfill, now you 'have. What is the likelihood of the.
cout8l1natiou increasing or continuing to IIOve to the east, and
what is to keep the contall1nation from moving to the . Dorth'l
If the plume does 80ve to the north, it will not sustain this
northward IIOvement. Weknov it is IIOving to the east and southeast.
Because of the different readings we found from April to September,
we are aware of the seasonal fluctuation of the flow or slugs of
containation frOl8 the site. We now know we will get varying
concentrations of pollutants in various wells. Thi8 1s a ..jor
reason why the alternative we have chosen includes providing
these people witb an alterate Yater supply. .
\
-------
Concern:
Response:
Concern:
Response:
Note:
Concern:
Res pons e :
Concern:
Response:
Water Supply
Co ncern.:
Response: .
Co ncern:
4
Are the monitorin~ wells north of the Quar~'area all at one level
or at various levels?
We're monitoring at the water table level. The information on
these monitoring wells is in the appendix to the RIfFS report.
You say the groundwater flows east. There are
this area.. Two shafts supposedly were used to
The Bureau of Mines should have information on
open from 1905 - 1917. Are you aware of this?
mine shafts in
dispose. of TCE.
this. They were
We know there was some mining in the area.
you have would be helpful.
Any further information
EPA has investigated these comments through discussions with the
speaker, and by examining maps and historical data from the
local library. EPA will be examining mine shaft patterns in the
design phase.
How loog wi 11 it take
to implement the plan you have now?
. I
line in the spring'-- 2-3 months.
phase will most likely not begin
We hope to extend the water
The design and construction
until the fall of 1985. .
Will the wells to the southeast and Ranger Lake be monitored?
Yes.
Will you continue to monitor all wells that are east of the site?
Yes. 'lbere will be a study done in the next two to three weeks
to identify and sample all the wells using groundwater as a
potable water supply. 'lb08e wells found to be contaadnated above
the health risk level will be taken out of usage and bottled .
water will be provided until a water line to an alternate supply
can be installed.
Will you tie in all the hOlIes on the hill" or ju'st the veIls
affected?
. Response:. All those holies will be given an alternate supply.
Environmental and Health 1l1su
\ . . . .
'DIe Ranger Lake Fish Club _mbersare concerned about the fish in
Ranger Lake -- nov and in the future -- due to cont8ll1nation from
the landfill. Are the fish there . now , containated? Or, viII
the people who eat these fish become sick?
Concern:
-------
Response:
Other Issues
Concern:
Response:
5
We did som~ research on the effect of the contaminant levels
. found in Ranger Lake on tt.e fish and also on people who might eat
the. fish. We found the numbers in Ranger Lake (24-40 ppb) were
not close to the levels that could cause a fish kill (45,000 ppb).
The long term health risk to .people eating the fish is also very
low. The levels found in Ranger Lake are far below the levels that
would cause a concern for health of people. This does not mean,
however, that we will ignore the TCE levels in the lake. We intend
to monitor the lake and all other surface water to make sure that
the levels of contaminants are not increasing toward a dangerous
level. . If they do, there are procedures we can take immediately to
correct the situation.
!bring the last meeting you had here, I talked to someone about
some offsite dumping I knew about, did anyone check into this?
No one ever got back to me on it. .
Duting our investigation we did check several areas, especially
south of the site, but we found no evidence of extraneous dumping.
We did appreciate your information, and I am sorr~ no one got
back. to you on the findings. . . .
Surface Water Impacts
~
Concern:.
Response:
Concern:
Response:
Concern:
Response:
.You didn't mention Todd Lake, did you find evidence of any
leaching into it?
There was a high water period in Karch, 1984, during which there
was some leachate discharging into Todd Lake. We did sample the
lake and the leachate and found no contaminant levels high enough
to be a concern. We did issue a temporary warning on fishing
until the results were obtained but the results indicated no real
problem there. .
Did you check around Grouse Ball Pond?
No, because it is south-southwest of the site.
samples froa the IIOnitoring vells in that area
groundwater flow in that direction; therefore,.
there is no 8ite-related proble. in this lake.
'lbe results of
indicated no
we feel certai n
'lbe 'ICE in the quarry background is 4.7 ppb vbile the quarry
spriag is 41 ppb. Is it possible the percent in the quarry
backgrouad is lower because of dilution? .
It is likely due to dilution and volatilization of the TCE.
is also po8sible that the quarry is filling with water not
contaad.nated by TCE.
It
-------
6
Feasibility Study Alternatives
Co ncern:
Res pons e:
Concern:
Response:
Concern:
Response:
Concern:
Response:
Note:
Is there a chance to eliminate the problem with source reduction?
We feel we can eliminate most if not all of the problem through
source reduction. As. a precaution,' though, we will provide an
alternate water supply.
Do you feel that excavation of the landfill will solve the
problem?
If all the problem material were removed it would solve the
problem. But excavating this large a landfill wo~d cause
extensive side affects that must be dealt with.
During source reduction, what would you do with the water that
still had TCE In it?
We would pump this contaminated waste water to a treatment plant
and then into Coplay Creek.
Could you not cause a cone of depression in the landfill area
during this pumping that could cause the leachate to go back
into the landfill?
The amount of water that would be pumped would not be that great
to cause this to happen. Also, we would be pumping on.l¥.tte.- -- -
contaminated leachate rather than the groundwater.
The overall tone of both meetings was supportive of the preferred
alternative. The Township Supervisors have indicated a willingness to
cooperate in site operations.
II. Several written cOllUllents were received by EPA between February 6 and
Harch6. A sUllDllary of those CQ1lments and EPA's responses follows.
Site Responsibility
Concern:
Response:
HallY local hOlleowners already have hooked up to theaunicipal
water systa at their OWD expense because they feared _11
containation frOli the landfill. EPA should reillburse these
home~wners for expenses incurred 8S 8 result of cont88ination
at the' landfill (also mentioned during meeting).
Currently, there 1s no provision for victims compensation in
Superfund. .
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7
Groundwater Impacts
Concern:
Response:
Concern:
Response:
Concern:
Response:
Drinking well water sampling should be continued for threatened
homeowners.
Under EPA' s overview, a po tentially responsible party (PRP)
is currently sampling local wells. Those that show contamination
or potential for contamination will be incorporated into
EPA's planned water line expansion. After this is complete,
residential well sampling will no longer be necessary. . .
All contaminated liquids should be removed from the landfill
and disposed of off site.
EPA considers source reduction and treatment to be the most
feasible solution to groundwater contamination because it will
eliminate the threat to human health and the environment.
without the prohibitive cost or secondary risks of off site disposal.
There is no actual evidence in the RI/FS which indicates a
presence of a pool or reservoir of liquid waste in the landfill.
EPA is basing this assumption on the geological ~d hydrogeological
data from the RI. Groundwater'movement through the. unconsolidated
deposits is very slow (estimated to be .07 ft/year). If the TCE
disposal began in 1967 (as per DER inspection reports) the
contamination would have only migrated less than 1.5 feet from
the point of discharge. Since TCE is heavier than water the
contamination would sink to the bottaa of the fill area. This
. .
would account for the high levels of TCE found in on-site wells.
m any case the pre-des1gn study will be aimed at further defining
the extent and location of concentrated contamination within the
landfill. ..
Feasibility Study Alternatives
Concern:
Response:
A PRP questioned the rationale for the pumping/treating and RCRA.
landfill cap proposed for the site. and claimed that such activity
would be premature without proof of the existence .of a reservoir
of contaminated ground water.
The cap will be designed not only to stop infiltration of water
through the fill. but also to control erosion that.is causing
nuaerous leachate seeps and flows OD the landfill surface.
These flows are carried by surface drainage to affected targets
such as Todd Lake. Puaplng and Treating will be !.IIpl emented
to reduce the source of contaadnation co8ing fro. ehe landfill
in order to protect human health. welfare and the envirouaent.
A p~e-design study will give us design calculations on extent
of contamination. volume and anticipated pumping rates.
-------
8
RIfFS Methodology
Concern:
Re s po ns e :
Concern:
Response:
Concern:
Response:
Note:
Concern:
Response:
Concern:
Response:
Note:
A PRP stated that the Nassaux-Hemsley report was not included
in the RI Report as an appendix.
The Nassaux-Hemsley information was too voluminous to include
in an appendix. Copies of the Nassaux-Hemsley information can
be requested from EPA. .
A PRP stated there is no discussion of the performance testing
techniques utilized by the RIfFS authors.
Testing techniques are generally discussed in the text of the
RIfFS report. . Specific and detailed testing techniques can be
reviewed in the Quality Assurance Project Plan .and the Sampling
and Analysis Plan available at EPA. . .
A PRP questioned the hydrogeological study performed in the
RIfFS specific to fractured bedrock and contaminant travel
times. . .
While some geological points can be debated. EP~ feels that the
issues raised do not have any affect on how or why we chose our
seiected remedial alternative. .
~
EPA will give detailed answers to the PRP's concerns in a separate;
direct response. QUestions raised in the PRP's written evaluation
of the RI/FS are too complex to be properly addressed in this
responsiveness S\ID-ry.
A PRP suggested that 'EPA failed to 8ddress potential alternate
sources of contamination in the RI/FS.
'!be mining tunnels are referenced in the Record of Decision
and will be investigated further in the pre-design _tudy.
'!bere are no other known industrial or caamercial potential
sources between the landfill. and the affected wells.. Domestic
sources were investigated as part of the sampling effort by .
EPA's Te~hnical Assistance Te.. (TAT) in December 1984 and
dismissed as a Potential source of contamination to the affected
residential wells. . .
A PIP states that although referenced no aerial photograph
.. included with RI/FS.
Aerial photographs are not usually IUde part of the RI report.
Aerial photographs are available for review at the EPA office
in fhUadelphia or can be acquired through an FOIA request for
a research and copy fee. . .
. .
'lbe RAMP/Work Plan is being sent to the PilP.
-------
Ocher Issues
Conc.ern:
Response: .
Note:
,
A secure fence should be constructed around che entlre site.
The ~eed for a fence will be evaluaced during the design phase.
of the project.
In addition, EPA received two letters signed by a total of six
residents supporting the preferred alternative. A total of five
written responses were received during the comment period.
\
-------
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