United Statsa
Environmental Protection
Agency
Office of
Emergency end
Remediel Respons*
EPA/ROD/R03-85/012
June 1985
Superfund
Record of Decision
McAdoo Associates, PA
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C TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R03-85/0l2
4. TITLE AND SUBTITLE 6. REPORT DATE
SUPERFUND RECORD OF DECISION .Tn"':> ?R lqRc;
McAdoo Associates, PA 6. PERFORMING ORGANIZATION CODE
7. AUTHOR IS) 8. PERFORMING ORGANIZATION REPORT NO.
.. .
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
16. SUPPLEMENTARY NOTES
16. ABSTRACT
The McAdoo Associates site: is an eight acre track of land located in Schuylkill
County in northeastern Pennsylvania. It is situated approximately l~ miles south of
McAdoo Borough on U.S. Route 309. The site and adjacent area was once used ext~nsively
for deep and strip mining of anthracite coal. Mining activities started in 1884 and
continued periodically until 1962. After the site was acquired by McAdoo Associates
in January 1975, two rotary-kiln furnaces and a vertical liquid waste incinerator
were installed and operated as part of a metals reclaiming operation. A log maintained
by McAdoo Associates shows acceptance of a variety of wastes from January 1977 through
November 1978. These wastes include: paint sludges, spent solvents, metallic sludges,
acid and caustic liquids, toluene, waste oil/water, solid wastes and other miscel-
laneous residuals. None of the incoming waste streams received prior to January 1977
were logged into the facili ty.
The selected remedial action for the McAdoo site includes: removal of the tank
and debris; limited excavation of soils with off-site disposal in a RCRA facility;
capping; diversion of surface water and maintenance of surface water diversion ditches
and cover. In addition, a comprehensive mining study to determine appropriate cap
design and an evaluation of the dilution factor will be undertaken during the design
phase. The total capital cost for the selected remedial alternative is estimated
to be $2,360,000.
17. KEY WORDS AND DOCUMENT ANAL YSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group
Record of Decision
McAdoo Associates, PA
Contaminated Media: soil, gw, sw
Key contaminants: paint sludges, spent
solvents, metallic sludges, acid and
caustic liquids, toluene, waste oil/water
and solid wastes.
1B. DISTRIBUTION STATEMENT 19. SECURITY CLASS (Tltis Reporr) 21. NO. OF PAGES
t..l",...."" 71
20. SECURITY CLASS (TlJispage) 22. PRICE
None
EPA Form 2220-1 (Rn. 4-77)
PREVIOUS EDITION 15 DB$OL.ETE
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SITE:
McAdoo Associates Site, Schuylkill County, Pennsylvania
DOCUMENTS REVIEWED
I am basing my decision on the following documents describing
the analysis of cost-effectiveness of remedial alternatives for
the McAdoo Associates Site: .
- McAdoo Associates Remedial Investigation
- McAdoo Associates Feasibility Study
- Summary of Remedial Alternative Selection
- Responsiveness Summary
DESCRIPTION OF SELECTED REMEDY
- Removal of
soils with
accordance
capping to
water.
the tank and debris, limited excavation of
off-site disposal in a RCRA facility in
with current EPA off-site disposal guidance,
meet intent of RCRA, and diversion surface
- A comprehensive mining study to determine appropriate cap
design and an evaluation of the dilution factor will be
undertaken during the design phase. If the affectiveness
of the recommended remedy would change as a result of the
information from the study, an amendment to this Record
of Decision will be required.
- Maintenance of surface water diversion ditches and cover.
DECLARATIONS
Consistent with the Comprehensive Environmental Response
Compensation, and Liability Act of 1980 (CERCLA), and the National
Contingency Plan (40 CFR Part 300), I have determined that limited
excavation with off-site disposal in a RCRA facility, covering
in accordance with RCRA, 40 CFR 264.310(a) and Diversion of
Surface Water at the McAdoo Associates Site is a cost-effective
remedy and provides adequate protection of 'public health, welfare,
and the environment. The State of Pennsylvania has been consulted
and agrees with the approved remedy. They have suggested that
we include applying lime to the soil in the removal/cover remedy.
This will be considered in the design phase. In addition, the
action will require future operation and maintenance activities'
to ensure the continued effectiveness of the remedy. These
activities will be considered part of the approved action and
eligible for Trust Fund monies for a period of 12 months.
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- 2 -
I am deferring selection of Remedial Response Measures, if
any, for the mine pool and surface water. Additional evaluation
of these areas will continue.
I am delegating to the Regional Administrator the
responsibility for approving ROD amendments concerning
selection of the remedy for this"~perable unit for the
Site.
the
McAdoo
I have also determined that the action being taken is
appropriate when balanced against the availability of Trust
Fund monies for use at other sites. In addition, the off-site
transport and secure disposition is more cost-effective than
other remedial "actions, and is necessary to protect public
health, welfare or the environment.
~~.\,t!;
Date
"'~
Jack W. McGraw, Actin
Office of Solid Waste
J(., t1
Assistant Administrator
and Emergency Response
.~
",
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SUBJECT:
FROM:
TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
841 Chestnut Building
Philadelphia. Pennsylvania 19107
McAdoo Site - Record of Decision
Stanley L. Laskowski fA f"
\r'Deputy Regional Administrator (3RAOO)
Jack McGraw, Acting Assistant Administrator
Office of Solid Waste and Emergency Response
(WH-562-A)
DATE:
JUN 1 9 1985
I have reviewed the proposed action to be taken at the McAdoo
Superfund Site and recommend that the Agency fund the recommended
alternative as described in detail in the Record of Decision document.
The Pennsylvania Department of Environmental Resources concurs with
this recommendation.
The estimated capital cost of this Federal lead project is
approximately $2,360,000.
Please call me at 597-981.4 if you have any questions.
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CO't'10~WE:\L TH OF PE~~SYL \' A~IA
D[P ARTME~T OF E~VIRO:\'tE~T AL RESOLRCES
Post Office Box 2063
Harrisburg, Pennsylvania 17120 ~
April 29, 1985
\
, (717) 783-7816
u.s. Environmental Protection Agency
A ttn: Tom Voltaggio (3HW20)
Region III
841 Chestnut Street
Philade lphia, P A 19106
Re:
McAdoo Associates - Kline Township Site
ROD Review
Dear Mr. Voltaggio:
This is to provide comments on the third revision of the Record of
Decision (ROD) for the McAdoo Kline Township Site. We are pleased to inform
you that DER concurs with the goals set forth by the proposed remedial actions.
We feel that the current proposed removal of wastes and contaminated soils will
insure the protection of public health and the environment.
On March 25, 1985, our comments concerning the third revision were
provided to Mr. DiGiulio (EPA Project Officer), during a telephone conversation.
This letter confirms the discussion which was as follows:
1. We recommend that after the excavation of contaminated soils
and site grading, that lime be incorporated into the top twelve inches of the
top soil at the site, prior to construction of the cap. Site soils should be
adjusted to pH 6.5 or greater. This will reduce the mobility, availability,
and toxicity of any trace metal contamination which may remain at the site.
2. Since mine subsidence is a concern which has been discussed
repeatedly, we suggest that the remedial design of the cap include a provision
to allow for any future mine subsidence at the site. This may make future
cap maintenance much easier.
3. Soil excavation, site grading, and cap placement activities may
destroy or alter the integrity of monitQring wells currently on site. We
would suggest that an additional one or two monitoring wells be installed at
the southeast area off the site, in the vicinity of borings 118 and 1110 as part
of the last phase of remedial construction. To the extent possible, existing
wells should be maintained for future monitoring.
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u.s. Environmental Protection Agency
A ttn: Tom Voltaggio - 2 -
Apri129,1985'
Since the RIfFS has been completed for approximately nine mqnths
and these are comments on the third revision of the ROD, I am hopeful that this
will conclude our review of this remedial planning effort and that an expeditious
approval of the ROD wiU be forthcoming.
Do not hesitate to contact me if we can offer any additional assistance.
Very truly yours,
D~:£:~
Division of Operations
Bureau of SoUd Waste Management
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Summary of Remedial Alternative Selection
McAdoo Associates Site
Site Location and Description
The l'tAdoo Associates site is an eight acre track of land located in
Schuylkill County in northeastern Pennsylvania. It is situated approximately
1 1/2 miles south of l'tAdoo IDrm.gh on U. S. R:>ute 309. '!he property is
presently owned by First Valley Bank of 8ethlehan, Pennsylvania and the
Reading Canpany of Pennsylvania.
Coal refuse constitutes most of the site and surrounding area. '!he
site and adjacent area was once used extensively for deep and strip mining
of anthracite coal. Several rones are located within 1/4 mile north of
the site. Population is greater than 10,000 for McAdoo and the surroundirg
areas. An aquifer system known as the Mauch O1unk Formation supplies
drinkiDJ water for people liviDJ in the area who rely on ground water.
The shallow aquifer system underlying the site consists of mined out coal
seams and is collectively known as the mine pool. The mine pool drains
into the Little Schuylkill River, a stream significantly affected by acid
mine drainage. The site does not lie in a flood plain.
'!he site is presently enclosed by a chain link fence. Surface debris
such as 1NOOden pallets, concrete slabs and contcminated soils are located
throu:.Jhout the site. In addition, a 1-2 inch thick resin-like sheet resulting
from a spillover a one acre area and a 15,000 gallon tank containing
about 1300 gallons of hazardous liquid and sludge material lie in the
northern portion of the site.
Site History
The area was once used extensively for deep and strip mining of
anthracite coal. Minirg activities started in 1884 and continued periodically
until 1962. Coarse and fine rock refuse fram mining constitute most of
the site. After the site was acquired by McAdoo Associates in January
1975, two rotary-kiln furnaces and a vertical liquid waste incinerator
were installed and operated. These units were used for reclaiming metals
by burniDJ off im~rities on metal turnings and for drying high-metal content
slucges. Waste solvents were reportedly used as the fuel. These incinerators
were not used after 1977, due to nonccmpliance with Pennsylvania Department
of Envirormental Resources (PAlER) air ~ulations. The operator applied
to PAtER for a permit to operate a new rotary kiln incinerator in Janurary
1978, but the unit failed to meet canpliance requiranents and was abandoned
after August 1978. .
The operator submitted an application for a solid waste permit to the
PADER in January 1978 and was granted a conditional permit on May 18, 1978.
PADER repeatedly attempted to get l'tAdoo Associates to imp1anent requirements
attached to the permit. After all attanpts failed, the pennit was revoked
and the site operations subsequently closed on April 13, 1979.
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NOIfTH
SOUTH
W-AI
W-2
LEGEND
bk', WEll YN FORMATION
POTTS" lLE F('~MATION
--.
011
mID
..
(ill
D
FI'_L (MINING WASTE ROCK)
f\ES1OUAL SOIL
W~LL LOCATIONS ARE GRAPHIC ONLY TO SHOW MONITORED 10NES
ROCK
IDEALIZED CROSS SECTION
Ff!~CTURES
COAL SEAM
. 1
GENERALIZED GROUNDWATER FLOW PATHS
McADOO ASSOCIATES SITE. ~LINE TOWNSHIP. PA
NOT TO SCALE
FIGURE ,. ~
DRNUEi
LD~TO
o A Halliburton Compar
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A log mainta~ned by ~Adoo A<3sociates soows acceptance of a variety
of wastes fran January 1977 throu:.Jh Novenber 1978. The logged wastes
included: 12,560 druns of paint sludges, spent solvents, and metallic
slu:iges including cyanide, bery11il.rn, and sodiun wastes: 394,000 gallons
of bulk acidic and caustic liquids, toluene, aoo waste oil/water;: 13,226
tons of solid wastes inclu:iing griooing grit (11,821 tons), zinc wastes
(60 tons), lead silicate (20 tons), refractory brick (1085 tons), and
magnesllm sludge (20 tons): and other miscellaneous residuals. None of
the incaning waste streams received prior to January 1977 were logged
into the facility.
At the time of closure of operations in July 1979, the site contained
6,790 druns of hazardous waste aoo several 1S,000-gallon and 10,000-gallon
storage tanks of hazardous waste. In 1980, PAreR erected a chain-link
fence. In early 1981 throu:.Jh 1982, the p:>tentially resp:>nsible parties
disassembled and renoved the incinerator buildings, and ranoved the
drums and all but one of the lS,OOQ-gallon storage tanks.
Current Site Status
In May 19~3, EPA sponsored a Superfund Iemedial Investigation!
Feasibility Study (RI/FS) to supplanent previous findings and provide
sufficient data to plan cleanup strategies. The following sections
highlight the site work canpleted.
1.
Hydrogeologic Coooitions
Geologic structure in the vicinity of the site is very complicated.
The stratigraphy underneath and in the vicinity of the site, however, was
determined during the Reme<;:iial Investigation. The site is located within
a synclinal basin within 100 feet of a high angle reverse fault. Rock
strata in Kline TOwnship are tightly folded synclines and anticlines
interspersed with several faults. The three uppermost formations under-
lying the site border of occurence are the Llewellyn, Pottsville and Mauch
Chunk. The Mauch Chunk formation is canp:>sed of red shale, gray sand-
stone and siltstone. '!he red shale forms a productive aquifer used in
the area and tapped by local residential wells. The Pottsville formation
overlies the Mauch Clunk and is canpased of resistant, well-canented,
coarse grain sandstone and cOrY;Jlanerates. The Uewellyn formation overlies
the Pottsville fonnation, and is canposed chiefly of sandstone and the
Manmouth and Bu=k PtJuntain coal seams. The Buck PtJuntain seCl1\ outcrops
throlgh the northern end of the site while the Marmtouth seam outcrop;
within 50 feet of the southeastern eoo of the site. The Buck PtJuntain
seam was extensively deep-mined resulting in a labyrinth of underground,
interconnected mine shafts and rock tunnels in the saoostone bedrock.
These mine shafts and rock tunnels collectively form a bedrock aquifer
systan known as the mine p:>ol. The ground water in the mine pool is
tholght to vary in elevation as much as 20 feet during the year within the
Llewellyn bedrock but does not reach the residual soil or refuse at the site.
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The p::>ol is believed to have only one outlet, which is an old mine shaft
entrance known as the Silverbrook discharge. The discharge is located
approximately' 1500 feet south of the site af1(1 produces a strecrn known as
the Little Schuylkill River. Figure 1 illustrates the ground wa~er flow
paths to the mine p::>ol.
As docunented in the Remedial Investigation, elevated levels of metals
were detected in the mine p::>ol and site fill. In the mine pool, altmintm,
chraniun, bariun, beryllium, colbalt, copper, iron, nickel, manganese,
zinc, and arsenic were detected at 60,000, 30, 200, 12, 270, 350, 38,000,
240, 5,500, 920, and 50 ppb respectively. Seleniun and cyanide were rot
detected. In site fill, metals su:h as beryllium, nickel, chraniun, and
zinc were detected in higher concentrations in on-site fill than what
would oonnally be eXPected in fran coal refuse, as evidenced by Appendices
A and B. Levels of metals in on site soil fill are believed to be higher
than background because they are elevated when canpared to literature
values, and soil areas with high levels of metals correspond to locations
where druns of metallic sludges were stored. ~pendix A contains a 1984
report published by Pennsylvania State University entitled Variabilit¥
in the Inorganic Content of United States Coals - A Multivariate Statlstical
Study. Appendix B contains information obtained fran the Pennsylvania'
State Coal 1esearch Institute. Berylliun, nickel, chranium, and zinc
were detected in on-site fill at 28, 1720, 1370, and 48,000 ppm respectively.
Mean levels of these metals in anthracite coal fran the Appalachin Region
fran Appendix A are 2.2, 42.4, 49.0, and 20.7 ppm resPectively. Levels
of metal should be greater in coal than coal refuse so that Appendix A
represents a conservative estimate. Other inorganics such as caaniun,
lead, and cyanide were fouoo in on-site fill in higher concentrations
than are normally found in soil. 'r-b <'.lata was available on the normal
concentrations of .caaniun and lead in coal.' Cadmiun typically occurs at
0.2 ppm while lead typically occurs at about 14 ppm in United States
soils. Cyanide is not believed to occur naturally in coal but is a
product of ax aerobic coal canbustion or of industrial origin. Caanitm,
lead, and cyanide were detected in site fill at concentrations up to
137, 2,830, and 44 ppm, respectively.
Elevated levels of metals detected in the mine p::>ol might be caused
by a canbination of acid mine drainage and migration of metals fran site
fill. For exanple, berylliun was detected at 28 and 10 ppm in test pits
24 and 14 respectively. The mean concentration in the Buck r-t:>untain
Coal seam fran Appendix B is only 0.62 ppm. Also, test pits 24 and 14
correspond to locations where sludges were believed to have been stored.
Test pit 24 had strong. organic odors indicative of bulk disposal while
test pit 14 contained the highest concentrations of nickel aoo caaniun
detected on-site, 1720 and 137 ppm, resPectively. In addition, berylliun
was detected in the mine pool at 12 ppb, a level higher than normally
found in ground water. The present migration of metals fran the fill to
the mine pool cannot be conclusively deduced tOOlgh. EPA recently scrnpled
the Big Gorilla Quarry near the site which is considered an upgradient
part of the mine pool. A canparison of beryllium, cadmiun, chraniun, .
nickel, and zinc in the Big Gorilla (upgradient), mine p::>ol (site), and
Silverbrook Discharge (d0wrrJradient) yields, inconclusive results.
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Metal
Big Gorilla
Mine Pool
Silverbrook Discharge
beryllium
cacinit..rn
chranium
nickel
zinc
< 10
< 10 - 20
< 10
< 50 - 1230
210 - 270
12
not analyzed
30
240
920
< 5
1.1
< 10
89
340
All values are in ppb.
Beryllium, zinc, and possibly nickel may be leaching fran the site
fill and resultin;J in sanewhat higher than normal acid mine drain~e
metals levels in the mine pool. The levels of metals in the mine pool,
in general,'underlyin;J the site do not appear significantly higher
than levels of metals detected in the mine quarry. Further sampl ing ~uld
be required to substantiate any present releases of metals to the mine pool.
Metals could migrate fran site fill, thol.Qh, in significant concentra-
tions if site fill came into contact with mine pool water as in the case
of an incident of mine subsidence of sufficient magnitude. The pH of the
mine pool water fran the Big Gorilla Quarry is 3.5. At this low pH,
metals freely leach fran soils. PaDER has reported that mine subsidence
has occured in the area. The risk and magnitude of mine subsidence is
unknown at the Mch:loo site. In the absence of significant mine subsidence,
it is difficult to predict the mobility of metals in site fill. If
metals are not presently migrating to the mine pool, they could slowly
move downward in the unsaturated soil column fran ':"ainfall solubilization
and migrate to the mine pool sanetime in the future.
Mobility of organics present in site fill is a little easier to
predict. M::>st nonionic hydrorhobic (preferring organic phase to water
phase) organics remain adsorbed to soils regardless of pH levels so,the
effect of mine subsidence \oiOuld not be as severe as with metals. However,
soils containing organic canpounds under saturated conditions ~uld be
expected to leach organics at greater rates than under unsaturated soil
conditions currently present on-site. If significant subsidence occured,
soils containing organic canpounds \oiOuld cane into contact with mine
pool water and leaching of organics ~uld mostly depend on the adsorption
partition coefficients (Koc) of individual canpounds. h:lsorption partition
coefficents can be thol.Qht of as the ratio of the amount of chanical
adsorbed per unit \!/eight of organic carbon in the soil or sediment to the
concentration of the chanical dissolved, in solution at equilbrium. Koc
values may range fran 1 to 10,000,000. hhen laboratory observed Koc
values are not available, they can be calculated fran linear regression
equations using octanol-water coefficients (Kow). Kow is defined as the ,
ratio of a chemical's concen,tration in the octanel phase to its concentration
in the aqueous phase. It is an indication of a chemical's hydroP1obicity.
EkIuations using Kow values are preferable to equations utilizing other'
,physical properties such as water solubility because of higher correlation
coefficients (r2). ~ equations \!/ere used to calculate Koc fran
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which an avercrJe value was obtained. Equation 1 was derived fran Brown
et. ale [leg Koc = 0.937 leg Kow - 0.006], has a r2 value of 0.95 and was
derived fran aranatics, polynuclear aranatics, triazines, and dinitroaniline
herbicides. Equation 2 was derived fran Karichkoff [leg Koc = leg kow -
0.21], has a correlation value of 1.00 and was derived usio;;J mostly aranatic
or polynuclear aranatics. These equations were used because they were
derived fran the type of canpouros present on-site. The followio;;J is a
list of organic canpounds detected and their calculated Koc values. '!he
Koc values are presented to give an idea of the mobility of each contaminant
detected in site soils and will be used later on to develop safe soil .
levels for each contcrninant. All Kow values were obtained fran "Water-
Related Envirorunental Fate of 129 Priority Pollutants. \blLmes I and IIII-
EPA 440/4-79-029 a and b.
leg Kow leg Koc leg Koc Avg.
C;nT\t)Ol md eqn. 1 eqn. 2 log Koc
.~
phenol 1.46 1.36 1.26 1.32
4~ethylphenol 1.94 1.81 1.73 1.78
BaselNeutrals
bis(2-ethy1hexy1)phthalate 5.30* 4.96 5.09 5.03
butyl benzyl phthalate 5.80 5.43 5.59 5.52
di-n-butyl phthalate 5.20 4.87 5.00 4.93
diethyl phthalate 3.22 3.01 3.00 3.01
benzyl alcohol 1.50 1.40 1.29 1.34
isopoorone 1.70 1.59 1.49 1.54
flouranthene 5.53 5.18 5.32 5.26
naphthalene 3.36 3.14 3.15 3.15
phenanthrene 4.46 4.18" 4.25 4.22
chrysene 5.60 5.24 5.39 5.32
pyrene 5.30 4.96 5.09 5.03
benzo(a)anthracene 5.60 5.24 5.39 5.32
benzo(k)flouranthene 6.85 6.41 6.64 6.54
benzo(b)flouranthene 6.60 6.18 6.39 6.30
dibenzofuran 4.12 3.85 3.91 3.88
Volatiles
hexachloroethane 3.34 3.13 3.13 3.13
~
PCB-1248 6.11 5.72 5.90 5.82
PCB-l254 6.03 5.64 5.82 5.74
* Two values were given (8.73 & 5.3); the lower one was chosen.
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DJring the RI/FS study there was considerable concern about the possi-
bility of residential well contcrnination near the site. Residential wells
on Silverbrook !bad (1/4 mile oorth of the site) were sampled during the RI.
Silver was detected at 86 p~ in one well. The knbient EPA Water Quality
Criteria for silver is 50.0 ppb. The well was resampled several months later
and did oot show silver levels exceeding 50.0 ppb. The RI concluded
thoUJh that water enterirq the residential wells does not orig inate fran
the McAdoo Associates site because the upper fractured zone of the formation
is sloping downward to the south and west, and the cones of depression
created by these wells are insufficient to reverse the direction of
ground water flow.. .
Another concern was the possibility of residential well contamination of
of wells located adjacent to the Little SChuylkill River from ground water
recharge. This contamination also is very unlikely because the \to1ells in
question are topograhically upgradient of the river and are likely hydrol-
. ogically uwradient. under normal hydrological conditions the shallow flow
would discharge into the river while deeper flow would continue beneath the
river. Even under maxirntm ptmpirq capacities, danestic wells do not produce
eoou.Jh for the cone of depression to intersect the river itself. Also, the
Still Creek Reservoir is located in the same general area. N::>t only is the
reservoir uwradient, it would also be an additional hydraulic load on the
system. This effect would create higher gradients in the reservoir area
causing flow pataterns to be generated in the direction of the river.
2. SUrface water Conditions
As previously stated, the mine pool flows to an outfall called the
Silverbrook Discharge and .becanes the headwater for the Little SChuylkill
River, a stream significantly affected by acid mine drainage. As one
proceeds north of Tcmaqua (a town approximately 12 strecrn miles south of
the mine discharge point) towards the site, the stream becomes increasing
acidic and incapable of supporting a healthy community of aquatic life.
The WilkeS-Barre Regional Office of the Pennsylvania Deparement of
Envirortnental Resources (PADER) recently canpleted an extensive inorganic
analysis and a qualitative aquatic macroinvertebrate survey. The regional
office sampled many points and tributaries along the Little SChuylkill
River extending fran the mine outfall to an area several miles south of
Tamaqua fran CCtober 1 to CCtober 15, 1984. Relevent data are presented
on the next page for sampling points located in the river fran the outfall
to the PADER Water ~ality Station 1-19 located in Walker 'Ibwnship
(approximately four stream miles south of Tamaqua) ~
Data from pages 7 and 8 indicates that the stream begins to recover at
LSR4 and probably could sUPIX'rt same forms of aquatic life at LSRS. The
Wilkes Barre office is presently interpreting these results.
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Loca Hon
.
Paraneter LSRl LSR2 LSR3 LSR4 LSRS LSR6 LSR7
Flow(MGD) 0.07 2.26 3.04 7.69 9.76 27.14 29.08
pH 3.3 3.6 3.8 4.8 5.7 7.1 6.8
alkalinity(mg/l) 0 0 0 2 3 28 24
aciditY(ItYJ/l) 176 128 102 60 26 0 0
hardness (mg/l ) 204 93 62 45 32 678 468
sulfate(mg/l) 276 120 76 41 29 738 516
all.lt\im.m 11 , 000 6,000 4,800 .2,200 600 900 1000
arsenic 7.3 < 4 < 4 < 4 < 4 < 4 < 4
bery 11 i I.It\ < 10 < 10 < 10 < 10 < 10 < 10 < 10
cadnillTt 2.80 0.77 2.98 0.56 0.20 0.21 < 0.2
chrani\.ln < 70 < 70 < 70 < 70 < 70 < 70 < 70
copper < 80 < 80 < 80 < 80 < 80 < 80 < 80
iron 8,470 7,040 1,110 520 160 1,280 990
lead 16.6 4.1 6.8 < 4 < 4 < 4 < 4
maTXJanese 2,480 1,450 830 510 260 1,210 1,000
mercury < 2.0 < 2.0 < 2.0 < 2.0 < 2.0 < 2.0 < 2.0
nickel 150 < 140 < 140 < 140 < 140 < 140 < 140
seleniun < 6 < 6 < 6 < 6 < 6 < 6 < 6
thalli \.In < 120 < 120. < 120 < 120 < 120 < 120 < 120
zinc 390 280 160 90 70 70 80
Sampling Location Description
LSR1: Little Schuylkill River, 10 yards upstream of Silverbrook OUtfall
LSR2: Little Schuylkill River, 50 yards upstrecrn of n:cuth of Lofty Creek
(approxUnately 3/4 miles downstream of outfall)
LSR3: Little Schuylkill River at bridge in Village in Ginter (approxUnately
1 1/2 miles downstream of outfall)
LSR4: Little Schuylkill River at bridge on route 54 (approxUnately 7 miles
downstream of outfall)
LSRS: Little SChuylkill River at first highway downstream of Locust
Creek (approximately 10 miles downstream of outfall)
LSR6 :
Little SChuylkill River at route 309 bridge in Tarnaqua (approxUnately
12 miles downstream of outfall)
Little SChuylkill River at PAlER monitoring station in walker
Township (approximately 17 miles downstrean of outfall)
Water quality values are in parts per billion (ppb) unless otherwise noted.,
MGD refers to millions of gallons per day, aoo ppt\ refers to parts per million.
All metals are expressed as total concentrations (dissolved and suspeooed).
ISR7 :
-------
~
location
LSRl LSRl LSR3 LSR4 LSRS LSR6 LSR7
Species :
Nematoda (roundworms)
Oligochaeta (segmented worms)
Astacidae (crayfish)
Ephemeroptera (mayflies)
BacUs spl
B. sp2
:-..~udocloeon
Epheme rell a
Paraleptophlebia
Isonychia
Stenonema
Stenocron
Plecoptera (stone flies) x
Allonarcys proteus
Peltoperla
NellOura
hoperla
Acroneuria ca ro 11 nend s
A. abnomis
A. evoluta
A. unk. sp
Phasganophora capitata
Eccoptura xanthenes
Paragnetina immarginata
Coleoptera (beetles)
Elmidae
Psepheus
Tricoptera (caddis flies)
Hydropsyche spl
H. sp2
Cheumatopsyche
Diplectrona
Dolophl1odes
Polycentropus
Glossosoma
Rhyacophl1a x
Kegaloptera (hellgrammites, etc.)
Nigronia
Corydal us
Diptera (true flies)
Ch i ronomi dae
Hexatoma
Tipula
Atherix
Odonata (dragonflies)
Gomphus
Lanthus
Boyerla
Macromia
Calopteryx
Sphaerlum (clams)
Physa (snail)
Total Taxa 0 0 0 0 2 0 0
('X} Mto.f\c. ~{t~ +{t }O),;, ,',- i\ q ~Q" ~
-------
- 9 -
In t~ previous studies, DER had concluded that the Little Schuylkill
River was degraded fram acid mine drainage.
Also, in January of 1979, the Readirg office concluded that the main
stem (fram outfall of Tarnaqua) does not sur:.port a heal thy aquatic carmuni ty
and could not support a sport fishery.
EPA Region III learned fram a local, resident that the Little Schuylkill
River was beirg stocked with fish and contacted the Pennsylvania Fish
Ccmnission to validate this claim. The Ccmnission stated that the river
had been less acidic in the past few years and that the quality and
quantity of aquatic life was improving. The ccmnission began stOCking the
river with brook and brown trout at various locations between Locust and
Panther Creeks (directly north and south of Tamaqua) in 1983 and experienced
limited success. The brown trout seemed to have suffered from chronic
toxicity possibly fram low pH levels or elevated concentrations of metals
and sulfates. In 1984, the Ccmnission only stocked the river with brook
trout and was fairly successful. The Camtission also stated that the
Little Schuylkill River Conservation Club ( a local fishing club) had
been stocking the river with brook, brown, and rainbow trout, and bass
and catfish for the past 5 years at Owl Creek (a stream a few miles south
of Tamaqua). The club obtains its fish fram the Fish Ccmnission.
It is obvious that the river is severely affected by acid mine
drainage north of LSRS. At points south of LSRS tho~h, it appears that
a limited population of same macroinvenebrates and stocked fish can
survive. Since stocked fish are consumed by humans, it is possible that
a release of contaminants could affect not only aquatic like, but humans
who ingest aquatic life. Biological uptake of contaminants by fish
\«>uld depend on factors such as lipid content, uptake and depurgation 'rates,
differences in metabolism, organism behavior (i.e. bot tam dwellirg, lergth of
time in contaminated area), water temperature, dissolved oxygen level and the
salinity in the water.
3.
Surface Drainage Conditions
Since the mine spoil on-site is fairly permeable, most rainwater
percolates into the mine spoil rather than running off-site. Surface water
that does run-off generally fl~ fram rorth to south on-site. There is
severe erosional damage at the site as evidenced by several gulleys
cuttirg into the coal refuse. Of major concern is the off-si te migration
of contaninants via surface water run-off. In addition to the previously
listed organic arid inorganic contaminants detected at various depths in
soils on-site, a one acre resin sheet ,lies on the surface in the northern
part of the site. This resin sheet appears to be one or t\«> inches thick
and contains the following canpounds:
-------
styrene (tentatively identified)
alkane substituted benzenes (tentatively identified)
branched chain hydrocarbons (tentatively identified)
4-methyl-2-pentanone
trichloroethylene
l,l,l-trichloroethane
naphthalene (tentatively identified)
1,2-dichloropropane
methyl ethyl ketone
xylene (iscrner)
methyl ethyl benzene (isaner)
trimethyl benzene
decane
toluene
1,2-dichloroethane
benzene
tetrachloroethylene
ethyl be nzene
acetone
nonane
propyl benzene
Contaminant
* 1% = 10,000 ppm
- 10 -
Concentration
10 - 100% *
1 - 10%
1 - 10%
1 - 10%
2.8%
2.0%
1.3%
1.2%
0.1 - 1.0%
"
"
"
"
0.64%
0.63%
0.19%
0.12%
0.10%
0.01 - 0.10%
"
"
-------
-11-
4.
Air Conditions
Air monitori~ scans ~re performed over a 12-acre area on and near
the site duri~ the Renedial Investigation. l-bnitori~ was done :to
determine the presence of radioactive substances, oxygen levels, and
explosive and organic vapors. Results of these tests did not indicate
the presence of any of these contaminants at above background levels.
Ibwever, these findings particularly for organic vapors do not mean that
some contaminants are not volatilizing from the site soil or the resin
sheet since odors can be observed ananating fran .the site duri~ warm
sl.lTlT\er days. Air sampli~ was not conducted duri~ the sl.lTlT\er. Since vapors
can be observed during warm sUtrner months and IrUJt.agenic compounds ~re detected
in the resin sheet, it is possible that same low and undetermined health risk
could result from the inhalation of vapors o~site. Another concern is the
possibility that contaminants adsorbed to micron size soil particles could be
dispersed via wind erosion and inhaled or i~ested by pe~sons travelling on or
near the site. Particulate air sampling was not conducted during the Renedial
. Investigation, it is difficult to quantify this risk. Concern about ingestion
or inhalation of airborne soil particles is based upon the observation of
higher than background levels of organic and inorganic contcrninants in soil.
Many of these contaminants are suspected carcinogens and have cancer risk
factors in the low parts per billion ranJe. For excrnple, berylliun was detected
in surface soils at concentratiqns up to 28.0 ppm and is considered an industrial
substance suspect of carcinCX]enic potential by the A'nerican Conference of
Government Hygenists (ACGIH). The Time VEighted Averaqe (1WA) for berylliUTI is
2.0 ug/m3 in air. The alternative National Emission Standard in 40 C.F.R.
S61.32(b) for Hazardous Hazardous Air Pollutants lists a standard for beryllium
at 0.01 ug/m3. I:: is difficult to determine whether air at the McAdoo Site is
exceeding this limit or not.
5.
Existing Storaqe Tank waste
A presently secure 15,000 gallon storage tank containing approximately
1300 gallons of liquid and sludge hazardous was~e remains o~site. Region
Ill's Field Investigation Team (FIT) sampled the supernatant in June 1981 and
detected: methylene chloride (140 ppm), a xylene isomer (probably orthcrxylene
at 10 - 100 ppm), and unknown styrene (10 - 100 ppm), and bis( 2-ethylhexyl)
~thalate (450 ppm). Chanical waste Manaqanent (representi~ one or more of the
responsible parties) samppled the slooge during the same period and detected:
-------
- 12 -
C9 - C17 hydrocarbons (80,000 ppm), xylenes (40,000 ppm), ethylbenzenes (8,600
ppm), toluene (3,000 ppm), and Total Halogenated Organics (3,600 ppm). Elevated
vapor readin:Js were observed in the manhole at the top of the tank usinG ,-..
OVM-FID on a day when the ambient temperature exceeded 80°F. If the C8r~
tcminants listed above are inhaled, ingested, or cane in contact with
skin, liver dcmage, kidney dCl1\age or dysfunction, heart palpitations, or
central nervous system dClnaJe could result. If long-tenn exposure
occurs, these contaminants may cause cancer since sane of these canpounds
are suspected carcinogens.
. Remedial Action Alternatives Selection
Numerous remedial action alternatives were identified and evaluated
durin:J the Feasibility Study (FS) to address two site-specific remErliation
objectives. These objectives are:
°
Prevent direct contact with o~site wastes (supernatant and slu1ge
in the storage tank, and resin sheet) and contcminated soils.
Direct contact is defined here as skin contact, in:Jestion, and
inhalation of wastes and contcminated soils
°
Prevent off-site migration of wastes and contaminated soils through
surface water run-off, percolation to the mine pool, and wind dis-
persal.
Each alternative was studied and reviewed to determine its effective-
ness in mitigatin:J health or environmental concerns, technical feasibility,
consistency with the National Contingency Plan and other environmental laws
and oost. An initial screening of technologies was required to eliminate
infeasible or inappropriate technologies fran consideration.
The no action alternative for removal of tank content was rejected
because the tank contents are in concentrated form and direct or prolonged
contact with spilled wastes could cause acute, chronic, or IOn:J tenn heal th
effects. The tank is presently secure, but its security can not be assured in
the future. Rusting or vandalisn may result in a significant release.
In reviewing treatment and disposal alternatives for wastes and contam-
inated soils, chemical, biological, am activated carbon treatment were rejecteQ
alon:J with solidification of wastes and soils. O1emical treatment would involve
technologies such as chemical oxidation, neutralization, ion exch~e, and
chemical dechlorination of extracted contaminants. O1emical treatment was
removed fram further consideration because treacment systems are not applicable
to waste constituents o~site. Biological treatment involves seeding of a
waste material with microorganisns to obtain degradation. This process is
limited to contaminants which are biodegradable at a sufficient rate and soil
which is naturally aerated or where artificial aeration is possible (it is .
assuned that compounds on site which will biodegrade undergo aerobic degradation) .
-------
- 13 -
Biological treatment was removed fram further consideration because the the
lOrxJ-terrn effectiveness of this methoo is unknCM'l. Activated carbon tre"'e-~nt
was removed fram further consideration becaus~ the contaminants found or. 5.ite
are adsorbed to soil. Incineration and wet-air oxidation were removed fram
further 'consideration because they would have elbninated organics but concentrated
metal concentrations. On-site disposal in a RCRA landfill was removed fram
further consideration because the RCRA cap could provide sbniliar protection
since the ground water table does not normally came in contact with the soils.
The mechanism in which contaminants would came in contact with the ground water,
except for subsidence, would be through dCM'lward migration fram precipitation.
The location of the landfill would also be susceptible to subsidence and difficulty
in monitoring and would cost twice as much as a RCRA cap.
After campletion of the initial screening of technologies, a detailed
evaluation of alternatives was conducted in order to identify those alter-
natives which may best address the problems on-site in addition to ranov-
ing the ranaining 15,000 gallon tank. The chosen alternative should'
be the most cost-effective, technically feasible, and reliable solution
that effectively mitigates or minimizes damage to and provides adequate protection
of public health, welfare, and the envirorment. Alternatives were developed
by applying technologies considered individually or in combinations.
The alternatives ranaining after the initial screenirxJ process were
grouped into two catergories: .site related and disposal related acitivities.
The alternatives are listed below:
o Site Related:
- No remedial action
- Removal of debris
- Excavation and/or removal of wastes and most heavily contaminated soil
- Excavation of contaminated soil to background levels
- Capping which meets the standard of RCRA regulations 40 CFR Part 264
- Diversion of surface water
o Disposal-Related
- Off-site disposal in an appropriate RCRA facility
These technologies were then combined in remedial alternatives that
would be applicable to this site, and screened with respect to the remedial
objectives. The following is a detailed analysis of these alternatives.
-------
- 14 -
Alternative n - rb Action
The No Action alternative was rejected because it would fail to pre-
vent off-site migration of contaminants via wind dispersal, surface
water, and ground water. The rationale for limiting off-site migration
of contaminants via surface water and air dispersal were previously
explained and need not be repeated. The following is the rationale for
limiting migration of contaminants off-site via ground water flow:
As was previously mentioned, all rainwater or surface water run-on.
to the site which percolates through the site fill, follows the natural
contour of residual soil and bedrock, enters the mine pool, and eventually
discharges at the Silver Brook outfall. As was explained in the subsec-
tion on surface water conditions, the Little Schuylkill River is severely
affected by acid mine drain~e fran the outfall. fbwever, there are
indications that the aquatic life may revive. The river is virtually
devoid of aquatic life several miles downstream. The Pennsylvania Fish
Oammission and a local sporting club using fish fran the commission stocks the
river toough at lcx;:ations fran Locust to Owl Creek with sane success. EPA must
consider the effect that the site could have on these fish and any other aquatic
life which could eventually populate the river. If a pH adjusbment treatment
system were installed at the outfall, elevated levels of inorganics would
precipitate fran the acid mine drain~e and the effulent might be of adequate
quality to support a diverse community of aquatic life.
To determine the risk posed to present or future aquatic life in the
river from the site, levels.of contaminants in soils which could leach
harmful levels of contaminants to the mine pool and eventually to the
river must be calculated. (In other words, determining a safe level of
contaminants in soil and observing whether concentrations detected on
site exceed these levels.) This can be accomplished by first selecting
target locations, then setting ambient water criteria for each contami-
nant to protect aquatic life or hunan health thru the ingestion of
aquatic life, and finally calculating maximun levels of contaminants
. in soil which will not result in leaching of contaminants at levels
which exceed these criteria. Since the resulting soil criteria is
only a rOlgh approximation, it is important to be as conservative as
possible when establishing water criteria and using applicable calculations.
The Pennsylvania ~parbment of Environnental Resources has stated that
there is a possibility of mine subsidence at this site (see Appendix D). Mine
subsidence has occurred at other mined out areas in the region. Without an
extensive and canprehensive subsurface investigation, it is difficult to estimate
the potential and resulting severity of an incidence of mine subsidence. . .
Therefore, EPA will assune that an incident of significant mine subsidence is
possible, but not likely, and that much of the site soil could cane in contact
with the mine pool water if catastrophic subsidence occurred. To be conservative,
calculations were based on the worst-case scenario in order to protect the
-------
I .
- 15 -
environnent in the case of catastrophic subsidence. Hence, calculations
will ass\.lT\e that site soil is under saturated flow conditions. The target
location for inorganics is at LSRS near Locust Creek since this is the first
downstream location where fish are stocked in the river. The outfall was not
chosen as the target location because aquatic life will not survive there
unless the pH is adjusted. If a treabnent system is constructed and significant
subsidence occurs, most of the released metals should be precipitated out at
the treatment facility. The target lOcation for organics is at the outfall
since pH adjustment should not greatly affect the mobility of most organic
canpounds and it is ass\.lT\ed that saneday the outfall discharge will be treated
and enable aquatic life to survive near the outfall. latest Camtents fran the
State indicate, that the State will probably address the outfall after the
source of contanination fran the r-t:Adoo site is addressed.
Prnbient water quality criteria for inorganic and organic canpounds
were established using current EPA cr iteria doc\.lT\ents when available.
When no criteria were available, other toxicolcgical data were used to
derive criteria. When no criteria was available, aquatic toxicolcgical
data was used (See Appendix A). 'I11e next Table li~ts criteria established
to protect aquatic life and h\.lT\an health thrOllJh the protection of aquatic
life. The chosen water criteria was selected to be the lowest of the
two values. See Appendix C for references which are shown in parenthesis.
Fbr organics, the soil criteria was chosen using calculated water
partition coefficients (Koc) illustrated on page 5 and chosen water
criteria shown on the previous page. The t....o values were used in the
Freundlich equation shown below which decribes the ratio of organic can-
pounds expected in aqueous and soil media. An in depth discussion of
adsorption and use of the Freundlich equation is presented in the .
Handbook of Chemical Property Estimation Methods copyright 1982 by r-t:Graw
-- -r - - .
Hill Inc. The organlc carbon content was ass\.lT\ed to be 1.0%. SolIs
typically contain between 0.01 to 8% organic carbon. An organic carbon
content value had to be ass\.lT\ed since analysis was not performed for
this paraneter in the coal refuse or residual soil during the remed ial
investigation. The fill and underlying soil is not expected to have a
high concentration of organic carbon. A lOX dilution factor was added
to the equation since any contcminants leaching ....ould be diluted sanewhat
in the mine pool. No attempt was made to calculate a water dilution
factor throllJh water balance equations because the areal extent of the
-------
- 16 -
Canpound Protection of Protection of Chosen
Aquatic Life HlJ!Ian Health Water
thru Ingestioo Criteria
of Aquatic Life
ORGANICS
Acids
phenol 2540(a) NA 2540
4-methylphenol 541(j) NA 541
Base/Neutrals
Bis(2-ethylhexyl)phthalate < 3(b) SO,OOO(u) 3
butyl benzyl phthalate 220(c) NA 220
di-n-butyl phthalate 17.38(d) 154,000(u) 17
diethyl phthatlate l240.5(e) l,800,000(u) 1240
benzyl alCohol 580(k) NA 580
isophorone 43,333.33(f) 520,000(v) 43,333
fluoran thene ~,592(g) 54(w) 54
naphthalene NA 0.0311(x) 0.03
phenanthrene " II II
chrysene II II II
pyrene " II II
benzo(a) anthracene II II "
benzo(k) fluor an thene " II II
benzo(b)flouranthene u " II
dibenzofuran 12 (1) NA 12
Volatiles
hexachloroethane 540 ( i) .8.74(y) 8
PCBs
PCB-1248 0.014(z) 0.00079( z) 0.001
PCB-1254 II II "
IOORGANICS
berylliun 5. 3(m) 0.117(1) 0.12
cactnium 1.2(p) NA 1
chraniun( +6) 11 (n) II 11
chrani lI'I\ ( +3) 605.7(0) II 606
lead 13.9(q) II 14
nickel 775.9(r) II 776
zinc 124.8(s) . " 125
cyanide 22(t) II 22
NA - rot available
-------
- 17 -
mine pool is unknown. lOX is considered a conservative dilution .factor.
.
l/n
x/m = Koe x foe x C
(Freundl ich equation)
where:
x/m = maximum holding concentration of soil
KOc = soil adsorption coefficient
C = ambient water criteria
foc = fraction of organic carbon iry soil
= factor used in estimating curve for non linear isotherms
(note: when n =1, Freundlich isotherm becanes linear)
If it is assumed that n = 1, foe = 0.01, and a mine pool lOX dilution
factor then:
x/m = 0.1 Koc x C
n
The following is a list the organic canpounds detected on site,
their maximum calculated safe concentrations in the case of catastrophic
mine subsidence, and maximum levels detected in fill on-site.
Calculated Safe Levels of Contaminants in Soil(ppb) to
Protect Aquatic Life in the Stream
Canpdund Calculated safe Level Highest Level Detected OnSite
Acids
phenol 5,376 7,200
4-roethylphenol 3,260 1,200
Base/Neutrals
Bis(2-ethylhexyl) phthalate 32,146 960,000
butyl benzyl phthalate 7,230,652 104,000
di-n-butyl phthalate 145,000 3,400
diethyl phthaltate 127,100 1,063
benzyl alcoool 1,269 2,900
isopoorone 150,251 2,800
fluoranthene 971,876 4,000
napththalene 87,172 680
phenanthrene 51 1600
chrysene 656 1600
pyrene 334 3800
benzo(a)anthracene 656 1300
benzo(k)fluoranthene 10,689 2,600
benzp(b)fluoranthene 6,190 2,600
PCB-1254 55 870
diben2Dfuran 9,103 390
Volatiles
hexachloroethane 1,311 1,600
PCBs
PCB-1248 66 3,058
-------
- 18 -
Soil criteria for metals can not be derived as easily as for organics.
Metals will also adsorb to organic carbon (or to hllTlic acids which may
adsorb to organic carbon), but will also undergo other attenuati~ reac-
tions such as canplexation, precipitation, and cation exchange. Because
of lack of field data and experience utilizi~ equations deali~ with
these mechanisns, a more simplistic approach was purs\.ed in establishi~
soil criteria for inorganics. The highest levels of metals detected in
background mine pool water (Big Gorilla OJarry) 'Nere canpared with mean
concentrations of metals expected in ""anthracite coal. This direct propor-
tion relationship enables the calculation of the mean concentration of
metal needed in anthracite coal to exceed previously established ambient
criteria. A 15X dilution factor is then added (lOX for mine pool and 5X
for dilution fram outfall to LSR5 (9.76 MGD/2.26-o.07 MGD = 4.5). Where
inorganics 'Nere not detected in the quarry, the detection limit was used
for calculation. See the data below and accanpaning calculations.
Inorganic Highest Level Background Calculated Chosen Max iln1..rn
~tected in level in Soil Soil Concentration
Quarry ( ppb) fill (ppn) Criteria Criteria Detected on
(ppn) (ppn) Site (ppn)
beryllium < 10 2.2 0.4 2.2 28
cadmium 20 0.2 0.14 0.2 137
chrami um < 10 49.0 808.5 809 1370
nickel 1230 42.4 401. 2 401 1720
lead < 50 14 58.4 58 2830
zinc 270 20.7 143.5 144 48400
cyanide < 10 < 1 33 33 44
For example in beryllillTl: 2.2 = 10 x = 0.4 ppn which is less than
x 0.12(15)
background, therefore the chosen soil criteria should only be 2.2 ppn.
See page 3 for references referri~ to background levels of metal in fill.
Cyanide was listed as < 1 because it is not believed to occur naturally in
coal. '!be calculation for chramiun was based on Cr(+3).
This strategy is novel but reasonable and circllTlvents problems associated
with the employment of cation excha~e "capacity (CEC) caculations for
acidic conditions.
By comparing the calculated safe levels for inorganics and organics
and canpari~ than to the maximlln levels detected, 'Ne reject the No
Action alternative.
Alternative #2 - Removal of ~bris, Filling, Gradi~, ~vegetation, and
Diversion of Surface water
'Ibis alternative would involve removing about 500 yds of surface
-------
- 19 -
debris (ie: wooden pallets, and concrete slabs) to an appropriate landfill (if
the material is found to be contaminated it will be disposed of in an appropropriate
hazardous waste landfill) filling in depressions and erosional cuts with soil,
covering the site with soil capable of supporting vegetatiQn, revegetating,
and constructing surface water diversion ditches to avoild future erosion.
Off-site ranOl1al of debris is necessary to pro~rly grade the site. '!he depth
of cover soil should be a least six inches to avoid possible future direct
contact or migration of contaminants via surface water run-off or wind dispersal
should significant erosion occur at the site.
All aspects of this alternative involve well-established engineering
practices but lroOuld not prevent future migration of contcrninants to the
mine pool. '!he construction time involved would probably not exceed
tlroO months. Land use after action lroOuld need to be restricted to activities
which would rot disturb the soil and cause mine subsidence. h:1jacent
land use would probably not be affected. Capi tal costs would consist
of:
remOl1al of debris: 500 yd3 x $50 = $25,000
yd3
filling: 12907 yd3 x $10'.00 = $129,000 (assllTle depth of 1 foot over
yd3 entire 8 acre area)
grading: 12907 yd3 x $2.62 = $34,000
yd3
top soil: 6454 yd3 x $10.00 = $65,000
yd3
seeding: 8 acres x $600 = $5000
acre
(assllTle six inches)
1/2
diversion ditches: (8 acres x 4840 yd2) x 4 sides x 2 yd width x 1 yd depth
acre
x $9.90 = $16,000 (assllTle ditches
yd3 surround a square
site)
remOl1al of tank = $16,000
TOtal estimated capital cost = $290,000 (Cbst figures obtained fram
EPA Handbook for Evaluating lemedial Action 'Iechnolcqy plans EPA-600/
2-83-076)
This option would reduce the possibility of direct contact with wastes
and contcrninated soil and would prev~nt off-site migration of contcrninants
via surface water and wind dispersal. '!he option would rot reduce the.
percolation of run-on surface water aoo rain 'Miter throu.Jh site soil or
address the risk of releasing contaminants to the mine pool in the case
of catastrophic mine subsidence. The basis for considering mine subsidence
and corresponding safe levels of contaminants in soils was previously
established. !he risk of contaninants migrating to the mine pool fran
site fill fram surface water run-on and rain water percolation is more
-------
- 20 -
difficult to quantify. Site soils were shown to contain higher than
background levels' of organics and inorganics. However, data collected
during the Remedial Investigation is insufficient to dete~ine the present
mobility of contaminants in soil especially in regard to inorganics.
Samples taken in test pit areas where the highest concentrations of
metals were detected were shallow (less than 3 feet). of beryllitrn,
chranilm, and zinc detected in the mine pool seem elevated and may indicate
present leaching of sane contaminants. It is also possible that most
contaminants are presently situated in shallow soils and are slowly
migrating downward to the mine pool which could result in a future release
of contaminants to the mine pool.
Alternative # 3 - Removal and Disposal of Debris, Filling, Grading,
Capping, and Diversion of Surface water
This alternative involves the removal of approxbnately 500 cubic
yards of debris with disposal in an appropriate landfill, filling in
depressions and erosional cuts with soil, grading the entire site for
Capping, capping the site in accordance with current RCRA reauirements,
and constructing surface water diversion ditches to protect the cap.
The debris would be removed to assure proper construction of the cap
and avoid possible settling due to degradation of same debris. Since
the possibility of mine subsidence is a concern, the cap should be
designed to withstand minor subsidence. As in alternative #2, surface'
water diversion ditches would be constructed to avoid future erosional
problems.
. All aspects of this alternative are considered well established
engineering practices. The reliability of the cap should be maintained
except in the case of catastrophic subsidence. A mine subsidence study
would be necessary to better define cap design.
The principal disadvantage of leaving contaminated soils in place
under the cap involves of the possiblity of mine subsidence as previously
discussed and its likely effects on the cap (i.e. collapse, cracking).
Minor subsidence could probably be repaired, but EPA is considering the
possibility of significant mine subsidence which could cause unrepairable
. damage to the cap. The construction time involved in this alternative
would probably not exceed four months. Land use after action would need
to be restricted to non-soil disturbing activities and activities which
would not cause mine subsidence. Adjacent land use would probably not
be affected. Capital costs would consist of .sUnilar actions discribed
in alternative '2, except that an ~rmeQble clay cap would be installed
over the entire site: .
removal of debris:
filling:
grading:
seeding:
diversion ditches:
$25,000
$129,000
$34,000
$5,000
$16,000
$209,000
plus cap costs:
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- 21 -
(2 ft cover soil) x 4840 'so yds x (8 acres) x ~ x $10.00 = $258,000
acre 3 ft yd3
, (note:
Depth of soil cover required varies with the frost line.
For calculations, 2 feet is asSlJned)
(1 ft sand for drainage layer) x 4840 sq yds x (8acres) x lyd x $18.15
yd3
(2 ft clay) x 4840 sq yds x (8acres) x 1yd x $16.29
acre 3 ft yd3
= $234,000
$420,000 (if clay is
needed) ,
=
removal of tank = $16,000
Costs for a subsidence study including costs for drilling 5 borings $50,000
Therefore, total capital costs = $1,187,000.
Since the mine pool water does not came in contact with the site fill,
an irnpe~eable cap would hydraulically isolate the site and provide a high
degree of protection. H~ver, as stated, there is an unauantified or unknown
chance of catastrohpic mine subsidence which could provide a route for future
migration of contaminants to the mine pool. If a cap was constructed, a
comprehensive inspection and maintenance would have to be develoPed to ensure
that subsidence would be detected and any significant breaches repaired. Minor
subsidence would be difficult to detect, but depending on the swelling properties'
of the clay, may not result in a breach of the cap.
Since there is a possibility of subsidence, the cap alone may not
provide adequate protection. Long term operation and maintance would be required.
Alternative #4 - Excavation of Contaminated So~l Exceeding Criteria Devel-
oped in the No Action Alternative with off-site Disposal
in a RCRA Regulated Landfill
This option involves removing about 500 cubic yards of surface debris
with disposal in an appropriate landfill, excavating any contaminated soils or
wastes which exceed criteria developed in the No Action Alternative with
off-site disposal in a RCRA regulated landfill, filli~ with soil, grading,
covering with a layer of soil capable of support vegetation, and revegetating.
This alternative is considered technically feasible but may be difficult
to implement. Numeroos soil samples were taken from test pits during the
Remedial Investigation in an attempt to characterize and delineate the areal
extent and depth of contcrnination. The sample results indicated many areas of
-------
- 22 -
..
organic and inorganic soil contemination but. obviously could oot identify
contamination in every cubic yard on site. Even if all soils sampled in test
pits exceeding the previously established criteria for inorganics' and organics
were excavated there would still be a substantial amount of soil rot sampled
which may exceed criteria. 'Iherefore, either a substantial cm:>unt of further
sampling should be incorporated into this alternative to better identify
the location of conteminants or an alternative excavation strategy
should be prop:>sed. Since soil samples can cost over $1,000, it seems
prudent 'to prop:>se a strategy which will min~ize scrnpling and at the
same t~e remove most of . the contaminated soil exceeding the established
criteria. O1e strategy considered 'tr«)uld involve identifing test pit
locations and depths which contained soil exceeding criteria and excavat-
ing to that depth. Since the test pit semple is only an indication of
contamination which may exist in that entire area, excavation should extend
over sane area which will collect m:>st 'of the conteminated soil. One
. strategy might be to excavate over a 50' by 50' area at certain selected
depths and then sample at the edJe of each excavated pit to ensure that
remaining soils do not exceed criteria. 'Ihe exact methodology for exca-
vation will be defined during design, but it may be useful at this point
to rOLqhly est~ate the amount of soil that may be excavated so that a
rOlqh approx~tion of cost can be described. Also, it should be recognized
that the risk model used to develop safe soil levels and contaminants may
also be further refined during design. The next ~e contains a description
of contaminants detected on site in various test pits which exceed the
inorganic and organic criteria and an est~ate of soil removal.
All excavated soil 'tr«)uld have to be placed in a RCRA facility in accordance
with current EPA off-site disposal policy. lined landfill in accordance with
current EPA off-site disp:>sal policy. It is estimated that disposal in a
K:RA landfill could cost $200 per cubic yard. If it is assuned that 00 other
soils fail the criteria and only soils outlined in the next page will be removed
(5898 cu yds) then removal of waste and soil alone could cost $1,179,000. If
it is aSSlJ1\ed that at least 4 priority pollutants samples are taken near each
test pit marked for excavation (11 test pits) then sanpling alone could cost
$44,000. (Priority Pollutant samples cost approximately $1000.00 each)
Total costs for Alternative #4 are est~ted as follows:
excavation and removal of contaminated soils =
further sempling = $44,000
removal of debris = $25,000
grading = $34,000
seeding = $5,000
diversion ditches = $16,000
six inches of cover soil = $65,000
filling = $129,'000
removal of tank = $16,000
$1,179,000
Tbtal capital costs = $1,513,000.
-------
- 23 -.
Contaminant Test Pits. and Depth of Contamination (feet)
Test pits Numbers ~
Organics 3A 9 10 11 12 14 17 18 19 24 25 28 29 33
Hexachloroethane 10
PCB-1248 2.3 (Depth) 1.5
PCB-1254 3 2.5
phenol 2.5
phenanthrene 2 12 3
chrysene 3
pyrene 2
benzyl alcohol 1.5
Inorganics
beryllium 2.3 14
nickel 2.3 1.5
cadmium 4 4.5 0.5 2.3 2 2 3 14 7
chrClt\ium
zinc 4.5 2.3 2 12 1.5 3
lead 1 2.3 2 3 2.5 10
cyanide 4.5
Estimated 1.5 4.5 5 1 0 3 2.5 2.5 3.5 14 7.5 0 0 10
Depth of
Removal
(feet)
Estimated
volume of
Removal
(yd3) 139 417 463 93 0 278 231 231 324 1296 694 0 0 926
= 5,092 cu yds
resin sheet = 1 acre x 4840 yd2 x 112ft x 1yd = 806 cu yds
acre 3ft
IOtal est~ated removal of soil and waste based on test pits alone and assuning
no other soils fail criteria = 5898 cu yds
-------
- 24 -
Alternative #5 - Canbination of Alternatives #3 and #4
Alternative #5 involves ranoval and disposal of debris, excavation
of wastes aoo contaninated soil exceeding criteria, filling, gradiOJ,
constructing a R:RA cap, and diversion of surface water. A mine engineering
study ~uld be coooucted to determine the risk and m~nitude of mine subsidence
and assist in appropriate cap design. This alternative offers the greatest
protection to aquatic life in the Little Schuylkill River when compared to the
previously discussed alternatives. '!he placement of an impermeable cap ~uld
eliminate any present or future potential migration of contaninants from site
fill under coooitions other than catastroIi1ic mine subsidence, and if catastroIi1ic
subsidence occured, excavation of the highest concentrations of contaninatect
soil ~uld minimize any impact on the river. '!his alternative is viewed as
providiOJ an adequate protection aoo achieves the stated objective to mitigate
any present or future migration of contaminants from the site.
Capital costs for Alternative #5 are as follows:
ranoval of debris = $25,000'
further sanpling = $44,000
excavation and removal of contaminated
grading = $34,000
seeding = $5,000
diversion ditches = $16,000
filling = $129,000
ranoval of tank = $16,000
clay cap = $420,000
drainage layer = 234,000
2' cover soil = $258,000
mine subsidence study =,50,000
soils = $1,179,000
Capital costs = $2,410,000
Total costs could substantially increase if more than 5898 yd3 of
waste aoo soil are ranoved or if the cap sOOuld fail.
Alternative #6 - Excavation of Contaminated SOils to Background Levels
This alternative ~uld involve identifying all soils which contain
contaminants above background levels and ranoving these soils off-site to
an appropriate ~ facility. Identifying all contaninated soil ~uld
be difficult and involve taking hundreds of additional samples costing
several huoored thousaoo dollars. Excavating contaninated soil ~uld
involve standard reliable engineering practices. Since all contaminated
soil ~uld be ranoved, there ~uld be no future health or envirortnental
impacts risks posed by the site. f\.1ture use of land would only be re-
stricted to geological limitations posed from past deep mining.
The costs of this alternative ~uld be very high and ~uld not provide
significantly more hlJ'l\an health or envirormental protection as compared to
other alternatives. In calculating capital costs, it is assuned that only
one-half of site soil oontains contaninats above background levels in soil.
-------
- 25 -
The amount of contaminated soil on site may well be greater.
is an estllnate of 'capital costs involved in alternative #6.
no 0 $ M costs incurred at this site.
The following
There should be
removal of soil:
1/2 x 8 acres x 4840 yd2 x 8 ft avg. depth x ~ x $200 = $10,325,000
acre 3 ft yd3
additional sampling: (assume one sample per 20 yd3 - actual frequency
may change during design)
8 acres x 4840 yd2 x 8 ft x ~ x $1000 x 1/20 = $5,163,000
acre 3 ft sample
filling:
1/2 x 8 acres x 4840 yd2 x 8 ft x ~ x $2.00 = $103,000
acre
3 ft
yd3
plus:
removal of debris = $25,000
grading = $33,000
total costs = $15,649,000
Consistency With Other Envirormental Laws
The six alternatives presented in this ROD were evaluated to deter-
mine consistency with RCRA regulations, 40 CPR Part 264, as described.
Because consideration and selection of a remedial response regarding the
decision on ground water and possible off-site sedilnent contamination in
the Little Schuylkill River is being deferred, consistency with RCRA for
these two concerns Was not examined.
EPA examined the remedial alternative with respect to their consistency
with 40 CFR 264.310(a). In order to canply with the cover requirements of this
regulation, a final cover must be placed which is designed and constructed to: '
(1) Provide long-term minimization of migration of liauids
through the closed landfill:
(2)
Function with minimum maintenance:
-------
- 26 -
(3) Pranote drainage and minimize erosion or abrasion of tl1e
cover
( 4 ) Accanodate settling and subs idence so that the cover's
integrity is maintained; and
(5) Have a peIT!\eability less than or equal to the permeability
of any bottbm liner system or natural subsoils present.
The preferred alternative relies principally on the construction of a
cover that is consistent with EPA's engineering specifications for construction-
ing the RCRA cover required by 40 C.F.R. S264.310(a). The cover is EPA's
standard method of preventing the migration of pollutants to the ground water~
The preferred alternative will also involve excavation of soils exceeding the
established criteria to the extent described in the ROD to provide additional
protection. Residual soils remaining on-site will have a minimal impact on
human health and aquatic life if mine subsidence occurs. These measures will
provide long-term minimization of migration of liquids through the closed
landfill [40 C.F.R. S264.310 (a) (l)} and accamodate settling and minor subsidence
so that the cover's integrity is maintained [40 C.F.R. S264.310 (a) (4)].
The technical feasibility of ground water monitoring is in question, but
will be considered during the next operable unit since the decision concerning
remedial action for the ground water and. surface water have been deferred at
this tune.
Recammended Alternative
Section 300.68 (j) of the National Contingency Plan (NCP) [47 FR 31180,
July 16, 1982] states that the appropriate extent of remedy shall be determined
by the lead agency's selection of the remedial alternative which the agency
determines is cost-effective (i.e., the lowest cost alternative that is techno-
logically feasible and reliable and which effectively mitigates and minimizes
damage to and provides adequate protection of public health, welfare, and the
environment). Section 101(24) of CERCLA states that off-site transport of
hazardous substances is not appropriate unless it is "more cost-effective than
other remedial actions" or "necessary to protect public health or welfare or the
environment from a present or potential risk which may be created by further
exposure to the continued presence of such substances." Based on our evaluation
of the cost-effectiveness of each of the proposed alternatives, the crnrnents
received fran the public, and the state and information fran the Feasibility
Study, we recamtend that Alternative #5 be implemented. This alternative includes
removal of the on-site tank, debris and the resin-like material and contaminated
soils exceeding guidelines as discussed previously to an off-site RCPA regulated
facility. The site would then be filled, graded, and overlain with RCRA
cover. Diversion ditches would also be constructed around the site to divert
surface water run-on and prevent erosion. Operation and maintenance would be
-------
- 27 -
of the cap ard surface water ditches and samplirq of the monitoring
wells and Silverbrook mine di::iCharge p:>int. The State of Pennsylyania
requested that we add lime into soil for any ranedy other than total
excavation. This will be reviewed during the design phase to determine
if it soould be utilized to enhance the ranedy.
The No Action Alternative was rejected because Alternative U would
fail to prevent off-site migration of contaminants via surface water,
wind dispersal, and ground water. The No Action alternative 'oIOuld also
tail to address the protection of future adjacent lard users against
acute, chronic, and long term health effects. .
Alternative #5 was chosen instead of Alternative #2 because Alterna-
tive #2 would fail to prevent percolation of rain water throUJh the site
fill, and does not address the p:>ssibility of release of contaminants
in the event of catastrophic mine subsidence.
Alternative #5 was coosen instead of Alternative #3 because there may
be a p:>ssibility of future catastrophic mine subsidence that 'oIOuld allow
contaminants to migrate to the mine pool.
A canprehensive mining erqineering stLrly to determine appropriate cap
design takirq into account the risk.and magnitude of mine subsidence for this
site will be undertaken during the design stage. If the study shows that
subsidence sufficient to cause significant cap damage can not be reasonably
expected to occur at the r-k:Adoo site, then reevaluation of the remedy may be
cons idered . If the ranedy is charqed, a ROD crnendnent 'oIOuld be required.
Al ternative #5 was COOsell instead of alternative #4 because under
alternative #4, rainwater ard surface water run-on could still percolate
through lesser contaminated soils and cause possible future migration of
contcrninants to the mine pool. Also, sane soils exceedirq criteria may
remain after excavation.
Alternative #5 was chosen instead of alternative #6 because it
can achiel1e adequate levels of protection to public health and environnent
for substantially less expense.
Capital Cost
'n1e capital cost of Alternative #5 is estimated to be $2,360,000
Project Schedule
ApprOlle ~cord of Lecision
June, 1985
Start Lesign
Canplete Lesign
AUJust, 1985
/\pr il, 1986
-------
- 28 -
Approve State Superfund Contract
for Construction
May 1986
.
Start Construction
June, 1986
Oamplete Construction
D3cember, 1986
Future Actions
Decisions regarding remediating and monitoring ground water flowing
in the mine pool and sediment in the Little Schuylkill River have been
postponed pending further evaluation.
-------
Alternative
Alternative 11
Alternative 12
Alternative 13
Alternative i4
- Canponents _Cap. O&M Considerations Considertions Considerations Other
- -
~ Action -0- -0- Soil migrating offsite Soils migrating off- ~Jie Very unaccept-
via surface water runoff site via surface able to the
and wind dispersal may water runoff and public
cause a threat throlJ:]h ground water flow may
direct contact or inhal- further'degrade the
ation of harmful partic- Little Schuylkill
ulates. Ri vel' .
"
Fill irYJ, 290 * Will prevent direct will prevent offsite Based on well Unacceptable to
leg rad ing Contact and inhalation migration of soils and established publ ic . Accept-
Ievegeta- of hannful pollutants waste via surface run- erYJineering able to PRP's
tion and off but not prevent practices
Di version additional migration
of Surface of contaminants
Water to the mine pool.
Cap and 1,187 * Same as 2 will prevent offsite Same as 2 Probably not
Divert' Sur- migration of soils and acceptable to
face Water waste via surface water " publ ic.
runoff. will greatly land use 1 im i ted
reduce migration of after action.
contaminants to mine Unacceptable to
pool. Mine subsidence State.
might breach cap and Probably acceptable
cause release to mine to PRP's.
, pool.
Excavation 1,513 * Same as 2 Lesser contaminated Same as 2 Acceptable
with Offsite soil would remain on- to publ ic .
Disposal site and be exposed to ..
and Divert infiltrating rainwater land use limited
&lrface nd round water inflow after action.
Water I Probab~y not
f acceptable to PRP'.
-------
Alternative '5 Limited 2,410 * Same as 2 Same as 3 except that I Same as 2 Probably accept'
excavation the highest concentra- to public. Ian'
with Offsite tions of the most limited after a
Disposal, I mobile soil contamin- RP's probably w
Cappirq and ants ,would be removed accept.
Diversion of to provide protection
SUrface against mine sub-
Water sidence and migration
of contaminants to
the -!'line JIOOl.
Alternative '6 Excavation 15,649 -0- Protects public Protect env irorment Same as 2 Very acceptable
to back health Not acceptable
ground
levels
* 1b be detennined
-------
Community Relations Responsiveness Summary
McAdoo Associates Site
.
EPA, Region III, completed a Remedial Investigation (RI)
in May, and prepared a draft Feasibility Study (FS) in June, 1984
for the McAdoo Associates Site. The Region provided copies
of the RI/FS and notified the public through a press release
two weeks prior for a July 11, 1984 public meeting. The RI and
draft FS were distribute6 to three community repositories:
Kline Township Building, Kline Township.Fire Hall, and the
McAdoo-Kelayers Elementary School. The meeting was held at
the McAdoo-Kelayers Elementary School to elicit citizen views
about the findings of the Remedial Investigation and describe
cleanup alternatives developed during the FS.
During the public meeting, the region provided copies of
the FS free of. charge. The region informed the public of the
August 13th comment deadline and strongly encouraged the
submittal of written comments to the EPA regional community
relations coordinator. Several citizens gave speeches during
the three hour meeting expressing their concerns about the
adequacy of the RI and eventual choice of a FS option.
The region received many written comments during the public
comment period from citizens, local officials, and environmental
groups in addition to a petition containing approximately 3400
signatures. The following is a brief summary of all written
comments received during the public comment period and the
region's response.
1.
Comment:
State Senator Rhoades
Date of Letter:
7/27/84
"All contaminated materials, soils and storage tanks
(should be) removed from site and area.
Response:
~ The Region considered excavation of contamineated soil
to backgrond level but judged this alternative as being
unnecessary to protect public health and the environment.
The Region estimated that this option requires the excavation
and removal off-site to a RCRA regulated facility of approximately
103,253 yd3 probably costing over 30 million dollars. The
Region believes that several far less costly alternatives are
available which could provide adequate public health and
environmental protection.
Da te of Letter:
8/06/84
Requested meeting with EPA and Tamaqua Borough, Schuylkill
County, and McAdoo and Kline Township officials to discuss
the fingings of the RI/FS.
-------
-2-
Reponse:
The Region advised State Senator Rhoades that the July 11,
1984 public meeting was conducted to discuss findings in
the RI/FS. The Region encouraged Senator Rhoades to submit
further comments in writing to the Region's Community Relations
Coordinator.
Date of Letter:
8/2/84
Comment: Schuylkill County Board of Commissioners
2.
Wished to meet with EPA representatives to discuss site
cleanup.
Response:
The reg ion als.o encouraged the Board of Commissioners to
submit further comments in writing to the Region's
Community Relations Coordinator.
3.
Comment:
Borough of McAdoo
Date of Letter:
7/17/84
complained that:
o
Inadequate notice had been given for the public meeting
The RI/FS is not clear and concise
EPA did not consult with local workers previously employed
by the facilities
EPA and PADER paperwork is delaying the cleanup
EPA and PADER not acting in an honest manner
EPA and PADER personnel not qualified to conduct
environmental investigations
PADER caused situation by not properly monitoring
the site operations prior to closure
o
o
o
o
o
o
believes that chemicals were dumped or buried farther
off-site than investigated during the RI
wants "total excavation of the site... and that the
contaminated soils be removed out of state... as far away
from our area as possible".
Response:
The region notified the public of the July llth.meeting
through press releases two weeks prior to the meeting.
The Region's consultant attempted to contact local
miners when investigating mine tunnels.
Preliminary headspace analysis screening of soils adjacent
to the site gave no indication of significant volatile
contamination, however, elevated levels of metals may be
present. This will be investigated during implement ion
of the chosen remedial action.
-------
-3-
- Tbtal excavation comment previously discussed.
Date of Letter:
7/16/84
4 . Carrnent :
Cbncerned Citizens of Schuylkill Cbunty
- area not appropriate for construction of a landfill (referring
to on-site disp:>sal with ReRA landfill alternative) because
of extensive underground mining under site and in vicinity.
northern aoo rorthwestern section of site is intersected by
State highways (81 and 309) which required drilling and blasting
for construction. Therefore, rock strata are fractured in area.
(Probably referring to cemented sandstone Pottsville formation
. which prevents contaninated ground water fran migrati~ to deeper
aquifers).
- site is near three major surface water sources supplying
drinking water to the area. Still Creek Reservoir is 1 1/2
miles southeast of the si te, and supplies water for the towns
of Tanaqua and Hcrnetown. Quakake Creek lies several hundred
yards north of the site and empties into the Hudsondale dam,
a major water source for Hazleton. Also, the site is 1 1/2
miles south of the Honeybrook water Canpany well which may
have a oone of depression CNer 1 mile.
- wants" [remCNal of] all remaining toxic wastes, contaminated
soils and any other buried waste...to a... landfill out of
[ the] area. " .
Resp:>nse: .
- The RCRA LF was eliminated fran evaluation since it would
provide similiar protection as a OCRA cap for approximately
double the cost.
In regard to rock strata fractures from blasting, it is
unlikely such blasts could sufficiently fracture several
hundred feet of Pottsville sandstone to allow downward
migration of contaminants. Local fracturing, however, is
p:>ssible. EPA believes that no drin~ing water supply is
threatened by the site since all water percolati~ through
the site migrates to the mine pool which eventualJ.Y discharges
to the Little Schuylkill River. The Little Schuylkill River
is not used nor does it flow into any reservoirs which are
used for drinking water.
I:Bte of Letter:
8/9/84
5 . Ccmnent :
- Concerned Citizens of SChuykill County, Citizens against
Hazardous and Nuclear waste, 924 Citizen Ca'llnittee, aoo
the Little Schuykill Conservation Club.
-------
-4-
Submitted photocopied petition containing about 3400 signatures
demanding the following:
o
o
further investigation of the site
water samples taken from:
Big Gorilla (abandoned
Hollow Creek
Quakake Creek
Haddock Creek
Still Creek Reservoir'
Hudsondale Reservoir
homes in:
water filled mine quarry)
o
o
Ginter
Quakake
Hometown
Still Creek
Lofty
Tamaqua
Haddock
o
o
o
o
o
o
with split samples given to the committees
more monitoring wells installed at the site and other areas
previously specified
more soil samples taken from the site and other areas previously
. s pe c i fie d .
Constant testing of the McAdoo, Hudsondale, and Still Creek
Reservoirs .
with split samples provided to the committees
air monitors installed to check vapors coming from'site
health survey from McAdoo thru Tamaqua
o
o
o
o
Response:
The Region does not believe it necessary to sample the creeks,
reservoirs, or home areas listed, because as previously stated,
all water percolating through the site migrates to the mine
pool which eventually discharges to the Little Schuylkill
River which in not used or flowing into any reservoir used
for drinking. The Region will address the need for ground
water and surface water treatment in the future. The Region
is also confident that it has properly characterized the
subsurface geology and ground water flow patterns underneath
the site and surrounding area, and at this time additional
monitoring wells are not needed to characterize the site.
During implementation of the recommended cleanup alternative,
further soil sampling and air monitoring will be necessary.
The request for a health survey was referred to the Region's
Centers for Disease Control (CDC) representative.
-------
6.
-5-
Date of Letter:
7/24/84
Comment:
Mary Magda
wanted further investigation at the site and re-evaluation
of the Silverbrook wells
complained of acrid odors from site
stated that residents have a high incidence of cancer and
other illnesses
wanted removal of all contaminated soil and waste with
off-site disposal
Response:
7.
8.
9.
1.
The chosen remedial alternative should eliminate any odors
from the site.
2.
During excavation, odors may emanate. Air monitoring will
be conducted during implementation to assure that levels do
not exceed safe standards.
3.
Additional soil" sampling will be conducted during excavation
to determine excavdtion limits.
Date of Letters:
7/18/84
Comment:
Photocopied Letters from 32 Citizens
"want...all the contaminated soil and remaining chemicals
removed from area.
Response:
Comment previously addressed
Comment:
Letters form Two Other Citizens
Date of Letters:
7/14/85
wanted complete off-site disposal of all contaminated soil
and debris
Response:
Comment previously addressed
Comment:
Phone calls from Mrs. Clymer
(Resident of Silverbrook Road)
Throughout the comment period, the region received phone
calls from Mrs. Clymer who lives on Silverbrook Road which
is located a few hundred yards north of the site. She was
concerned about the possibility of the site causing
contaminat ion of her well on Silverbrook Road. . The Reg ional
-------
~6-
Project Manager explained that the RI had concluded that it is
very unlikely that water originating from the site could reach
residential wells on Silverbrook Road. However, sampiing of the
wells during the HI detected silver at 86ppb at a neighbor's
well and higher than normal levels (62 & 82ppb) of nickel in
her well. Also, a May 1982 PADER sampling of those wells detected
cyanide at 50 and 51ppb in each well. The well containing silver
was resampled by EPA in June 1984 forinorganics: silver was not
detected. The region does not believe ~hat the elevated levels
of inorganics detected in residential wells on Silverbrook road
are coming from the site. A preliminary assessment site and site
inspection will be conducted seperate from the McAdoo study to
investigate the situation.
Date of Letter:
8/13/84
10.
Comment:
David W. Marston, Attorney at Law
Requested that Potential Responsible Party (PRP) Committee
be afforded the opportunity to review and comment on the
proposed ROD prior to. its submission for adoption
Wants the site rescored (Hazard Ranking System) based on
findings of RI. Their consultant, Fred C. Hart Associates,
now score the site at 3.09 as compared to the original
score of 71.99.
Feasibility Study does not contain a rating of effectiveness
and cost.
F~ does not contain an analysis the cost-effectiveness of each
alternative
The RI concludes there is and has been on ground water
contamination from waste management activities at the site.
In the description of rotary kiln incineration alternative,
the FS states that residue will be considered nonhazardous.
Unless the residue is delisted it is presumed to be a
hazardous waste for purposes of ultimate disposal.
Rotary kiln incineration and wet-air oxidation are not cost-
effective and increased environmental risks associated with
excavation and handling of contaminated soil and waste .prior
to treatment, and the emissions and water discharges that
will result make these alternatives unacceptable.
The alternative describing the using of an on-site RCRA
landfill states that approximately 12,000 cubic yards of
debris would be landfilled while the non-RCRA landfill
alternative states that only 300-500 cubic yards of debris
would be landfilled.
-------
--
I
I
-7-
"The associated environmental consequences of on-site
landfilling such as reconcentrating the wastes and ;their added
handling would only exacerbate conditions at the site."
"With respect to the off-site disposal alternative, the FS
concludes that the most likely candidate for disposal is the
the CECOS International Site near Buffalo, New York, approxi-
mately 400 miles from the McAdoo site. No consideration is
given to other possible sites."
Off-site disposal runs counter to EPA's current policy
restricting the use of off-site land disposal facilities.
FS does not contain explanations of how cost estimates were
determined nor is there any consideration of the long term
costs and obligations associated with the alternatives
"Based on the NUS studies, the McAdoo site poses little or no
risk to public health or the environment."
They support remediation no more extensive than:
o
removal of the 1300 gallons of liquids and
to an approved disposal facility
provision of surface water run-off control
.filling, regrading and revegetating
surface debris
o
o
Response:
It is not current EPA policy to allow potential responsible
parties an opportunity to review and comment on the proposed
ROD prior to its submission for adoption. However, the PRP's'
comments on the RI/FS are taken into'account in EPA's selection
of the remedial alternative.
EPA scores sites for inclusion on the NPL based on hazards that
existed prior to any response actions. Scoring a site on the
basis of the latest conditions could encourage incomplete
solutions that might leave significant health or environmental
threats unaddressed.
The FS as suggested does not have a detailed breakdown of
costs for each remedial option which is a shortcoming of this
study. The study did provide an estimate of present worth long
term operation and maintenance costs. EPA, however, utilized
the Handbook for Evaluating Remedial Actions Technology Plans
to better define the costs in the ROD.
Evidence obtained from the RI suggests that there is a potential
for ground water contamination from waste management activities at
the site.
-------
-8-
- The Region agrees that incineration is not cost effective.
- As pointed out, there does sean to be a discrepancy in the
volLJne of soil to be excavated in the RCRA and Non-PCRA
alternative. The on-site RCRA landfill should involve the
excavation of approxnnately 12,000 yd3 of soil and 300-500
yd3 of debris.
- On-site landfillil'YJ of contaminated soils or waste -«>uld not
exacerbate conditions at the site if the wastes or soils were
properly isolated (air, direct contact, groundwater, surface
water) as could be provided in a RCRA "landfill if it could be
located effectively.
- During the Feasibility Study, other off-site disposal locations
were considered besides the CECOS International site but not
mentioned in the report.
- EPA does have a current policy which recarrnends that on site
treatment or disposal be considered in lieu of off site dis~
sal when technically feasible and cost-effective. The
proposed ranedy does not leave all the waste at the site due
to the possibility of catastrophic mine subsidence.
- As discussed in the roo, the Region disagrees with the
conclusion that the site poses no risk to public health or
the envirorrnent. The chosen ranedial alternative will rectify
this situation.
- The Region acknowledges the PRP Committee's recammendation
for ranedial action at the site and considered it with other
alternatives presented in the Feasibility Study.
11. Catment:
Joseph M. Polito, Attorney at Law
Date of Letter:
6/14/85
Submitted a voluminous package of comments mainly concerning
the risk and magnitude of mine subsidence and the validity of
EPA's crosen soil criteria for contaminants. The most important
camments are summarized as follows:
- mine subsidence is very improbable and even if subsidence
occurs, canplete saturation of the contaminated fill is
unlikely.
- the mine pool dilution factor should be approximately 400
instead of 10.
Response:
-------
-9-
As the ROD states "a comprehensive mining engineering study
to determine appropriate cap design, taking into account the
risk and magnitude of mine subisdence for this stu~y will be
undertaken during the design stage. The information submitted
will be evaluated in conjunction with information from the
State during the Design Phase. Collection of additional
intormation concerning the potential for mine subsidence may
be necessary. If the study, shows that subsidence sufficient
to cause significant cap damage cannot be reasonably expected
to occur at the McAdoo site,.. then reevaluation of the remedy
may be considered."
In reference to mine dilution factor, it should be recognized
that the risk model used to develop the safe SOil levels of
contaminants may be further refined as additional data is
collected during the design stage. If a dilution factor greater
than 10 is valid, then a higher value would be incorporated.
See Appendix E for additional comments and responses to PRP.
comments submitted June 15, 1985.
-------
I ~
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-------
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Final Report ~ Part 10
VARIABiliTY IN THE INORGANIC CONTENT
~. ;
OF UNITED STATES' COALS -
A MULTIVARIATE STATISTICAL STUDY
by
David C. Glick and Alan Dawis '
Coal Research Section
The Pennsylvania State, University
University Park, Pa. 16802
, ' PREPARED FOR
UNITED STATES DEPARTMENT OF ENERGY
Under Contract No. DE-AC22-80PC30013
-------
Table 6. Summary Statistics for Variables of Eastern Province Coals by Region -
N
(Whole-Coal 8a s is) 0
.'
~llcht.n Regton S..ples AIIthrlctt. Re,lOII SI.pI...
"tnl- MI_I- Stlnd.rd "Inl- MI_I- Stlnd.rd
V.,bbl. Value V.lue Me.n Devl.tlOft n. V.lue V.lue Me.. Devl.tlOft n*
51, I O. 390 8.218 2.918 1.827 146 1 . I 21 7.217 4.132 1.927 12
AI, I O. US 6. I I] 1.890 1.160 146 1.028 4.75] 2.743 1.259 12
TI, I 0.015 0.61] 0.1t 2 0.084 146 0.029 0.]51 0.208 0.106 12
Fe. I 0.090 11.408 1.168 1.543 146 0."8 1.217 0.453 0.]19 12
"9, , 0.010 0.201 0.062 0.044 146 0.010 0.101 0.052 - 0.025 12
CI, I 0.022 1.007 0.14] 0.129 146 0.014 0.091 0.052 0.02] 11
II., , . 0.009 0.140 0.0]] 0.021 146 0.001 0.102 0.038 0.026 12
It, I 0.003 1.211 0.230 0.Z04 146 0.080 0.652 0.]]8 0.110 12
P, I 0.001 0.229 0.02] 0.035 146 0.002 0.040 0.011 0.011 12
81. PP8 1.650 5J2.5J2 117.469 9S.ll] 146 43.699 196.821 113.521 48.015 12
8e, PP8 0.280 13:202 2.323 1.125 145 0.688 5.155 2.206 1.609 12
Cr. PP8 ].046 99.084 25.546 16.098 145 13. JOG 75.608 48.998 18.159 12
Cu. PP8 2.493 85.703 20.562 13.910 146 10.925 73.317 ~.521 16.307 12
61. PP8 0.954 26.445 . 6.580 4.218 82 4.674 27.494 12.105 7.]14 8
ll. PP8 1.658 29.113' 9.560 5.869 82 7.515 30.36] 21. 0 13 8.]15 8
"". PP8 2.1 J9 671.030 31.096 88.940 145 ]. 325 95.918 27 . 240 29.442 12
III. PP8 ].239 119.11] 21.134 19.176 145 10.925 1 Z6.8J5 42.425 30.860 12
RD. PP8 0.888 13.011 13.926 12.649 144 0.193 . 41.210 20.618 12.854 12
Sc, PP8 0.589 14.266 4.601 2.619 '82 4.281 16.807 9.278 4. Z02 8
Sr, PP8 8.9]4 621.621 113.4 JO 105.298 146 5.252 91.576 39.918 ]2.946 12
U, PP8 0.102 10. Z04 1.309 1. 134 142 0.604 5.221 2.026 1. 286 12
V, P" 4.547 99.084 30.471 19.356 146 15.615 142.052 51.558 36.012 12
" P" 2.487 27. 368 10.162 5.060 82 5.549 29.185 11.004 8.191 8
'''. PP8 0.264 ].091 1.4)0 0.6]5 82 0.113 ].Z08 1.894 0.93] 8
lll. P" 2.411 99.916 22.921 19.479 144 2.850 65.653 20.129 19.745 12
Zr. pplii 5.219 215.260 34.080 24.295 146 9.915 120.851 61.041 40.999 12
p,rltle 5, I 0.010 5.810 1.401 1.301 142 0.020 1.2)0 0.261 0.]]9 12
SuI fate S, , 0.000 0.490 0.071 0.104 146 0.000 0.010 0.019 0.024 12
Or9.nlc 5, I 0.080 2.430 0.818 0.414 142 0.450 0.920 0.559 0.146 12
MTA. I 2.0:1) 38.109 1].501 7.1]1 146 4.150 26.261 16.196 6.881 12
en . nUllber 0' v.lues ,v.ll.ble
-------
Appendix B
-------
SUBJECT:
FROM:
10:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ReQ'OtI III - elll .. .,;.""",, St..
PII.lade!DII.a. Pa. 19106
Phone Conversation with Professor
Pennsylvania State University
J)~,6l ~.'-'
Domi ni c Di Gi uli 0, McAdoo Pro j e ct
Site Response Section (3HW21)
File
Alan Davis,
DATE: SEP 2 4 1984
CO""l'C'dinaL.)r
I spoke to Professor Alan Davi.s, Pennsylvania State Un! versity Coal
Research Institute (814-865-3437) on Friday, September 7 to discuss the
trace element content of anthracite coal near McAdoo, Pennsylvania. He
provided the following information:
Element
Beryllium (Be)
Nickel (N!)
Chromium (Cr)
Zinc (Zn)
Concentration
.
,
2.2 ppm - Average concentration in
Anthracite Coal
0.6~ ppm - Average concentration in
Buck Mountain Coal Seam
7.8 p~~ - Average concentration in
Ash from Buck Mountain Coal Seam
127.0 pp~ - maximum concentration in
Anthraci te Coal
42.4 ~~~ - mean concentration in Anthracite
Coal
75.6 p~~ - maximum concentration in Anthracite
Coal
49.0 ppm - mean concentration in Anthracite
Coal
66.0 Pf~ - maximum concentration in Anthracite
Coal
21.0 ppm - mean concentration in Anthracite
Coal
He also stated that Beryllium is usually found in higher concentrations
in coal than coal refuse.
-------
Appendix C
-------
References
a.
chronic value for Fathead minnow, method ELS, Halcombe et." al., 1980
b.
chronic value for Daphnia magna, method LC, Hayer and Sanders, 1973
c.
chronic value for Fathead minnow, method ELS, u.S. EPA, 1978
d.
acute value for Bluegill (730 ppb), method S,U, Hayer and Sanders, 1973
divided by the acute chronic ratio for Daphnia magna for butyl benzl
phthalate (42), Gledhill et. al., 1980
e.
acute value for Daphnia magna (52,100 ppb), method S,U, u.S. EPA, 1978
divided by the acute chronic ratio for Daphnia magna for butyl benz1
phthalate (42), G1edhillet. al., 1980
f.
acute value for Daphnia magna (117,000 ppb), method S,U, u.S. EPA, 1978
divided by the acute chronic ratio for Sheepshead minnow (2.7-saltwater
species), method ELS, u.S. EPA, 1978
g.
acute value for Bluegill (3,980 ppb), method S,U, U.S. EPA, 1978 divided
by the acute-chronic ratio for Hysid shrimp (2.5-saltwater species),
u.S. EPA, 1978
h.
chronic value for Fathead minnow, method EL, DeGraeve, et. al., 1980
i.
Ambient Water Quality Criteria for hexachloroethane
j.
criteria derived from the equation:
water criteria= [LD(50) of chemical) / BCF of chemical] x (47 kg-ug/ mg-l).
The correction factor (47 kg-ug / mg-l) was derived using the phenol criteria:
2560 ug/l ~ [LD(50) of phenol (414 mg/kg) / BCF of phenol (7.6)] x (factor).
The BCF for phenol was calculated from the equation: log BCF= 0.76 log Kow-0.23.
Therefore the criteria for 4-methylphenol is calculated to be [LD(50) of
4-methylphenol (207 mg/kg) / calculated BCF for 4-methylphenol (18)] x 47
which equals 541 ug/l
k.
criteria derived from logic used in (j.). The LD(50) and calculated BCF
for benzl alcohol are 100mg/kg and 8.1 respectively
1.
criteria derived from logic used in (j.). The LD(50) and measured BCF for
dibenzofuran are 350 mg/kg and 1350 respectively
m.
chronic value for Daphnia magna (beryllium sulfate), method LC, 220,mg/l
hardness as CaC03, Kimbal manuscript
n.
Federal Register/ Vol. 49, No. 26/ Tuesday, Feb. 7, 1984
o.
maximum concentration not to exceed [0.819 In(hardness) + 3.568] obtained from
e
(n.). Hardness equals 32 mg/l as CaC03 obtained from lSR5, the target
location for metals
-------
:
p. maximum concentration not to exceed [1.16 1n(hardness) - 3.841] obtained
from (n.) e
maximum concentration .
q. not to exceed [1.34 In(hardness) - 2.014] obtai ned
from (n.) e
r. maximum concentration not to exceed [0.76 In(hardness) + 4.02] obtained
e
from the Ambient Water Quality Criteria for nickel, October 1980
s.
maximum concentration not to exceed
[0.83 In(hardness) + 1.95] obtained
e
from the Ambient Water Quality Criteria for zinc, October 1980
t. maximum concentration not to exceed 22 ppb obtained from (n.)
u. Ambient Water Quality Criteria for phthalate esters, October 1980
v. Ambient Water Quality Criteria for isophorone, October 1980
w. Ambient Water Quality Criteria for f1uoranthene, October 1980
x. Ambient Water Quality ~riteria for po1yaromatic hydrocarbons, October 1980
y. Ambient Water Quality Criteria for hexachloroethane, October 1980.
z. Ambient Water Quality Criteria for polychlorinated biphenyls, October 1980
1. Ambient Water Quality for beryllium October 1980
-------
Appendix D
. .
-------
ATTACHMENT A
Commonwealth of Pennsylvania
Environmental Resources
January 2, 198.5
787-7383
Subject:
McAdoo Mining Activity Summary/Conclusions
To:
Mike Steiner, Chief
Emergency and Remedial Response Section
Division of Operations
'./'
. ~~
'.
From:
Eugene W. Pine, Hydrogeologist £/<. It'
Emergency and Remedial Response Section
'. Division of Operations
Bureau of Solid Waste Management
Solid Waste Program Specialist J~
Through:
Recent investigations to determine the extent of underground mining activities at
the McAdoo Associates-Kline Township Site have yielded certain data upon which
. the following discussion and conclusions are based.
Deep mining in the Silverbrook Basin, a structural as well as topographic synclinal
basin of Pennsylvanian Age, began approximately 100 years ago. The prinicipal
coal of economic interest was the Buck Mountain seam, originally deep mined by
the Silverbrook Mining Company in the late 19th and early 20th Century. Later
(1925), the Haddock Mining Company began a pillar removal operation which lasted
until 1938, when all deep mining activities under the present site were termina ted.
The overlying Mammoth coal seam was originally deep mined late in the 19th
Century, then later surface mined, so records for this particular seam cannot be
considered very accurate. Two minor coal seams which exist between the
Mammoth and Buck Mountain seams, the Wharton and Gamma seams, were not
economically important and, consequently, were not mined in the area.
Groundwater conditions under the site are dictated by the mine pool network of
the basin, which so often characterizes the anthracite area. Also, the underlying
synclinal Pottsville formation forms a large "bowl" which essentially traps
groundwater in the mine void network. Groundwater from the mine pools exits
through the Silverbrook discharge, located approximately 1,500 feet south of the
McAdoo site, into the Little Schuylkill River.
It is interesting to note that the Silverbrook Mine (as it is known today) was one of
the few deep mines in the area in which water was actually pumped out of the
mine, not "dewatered" by the drainage tunnels which are normally found in an
anthracite operation in this area.
-------
Mike Steiner, Chief
- 2 -
January 2, 1985
The present McAdoo Associates site area represe'nts one of the earliest phases of
the mining operation. It was within and adjacent to this area tha t the coal
breaker/prep plant, associated shop and support buildings, and the Gordon
slope--a main entrance to the mine--were located. Today, the foundations for
some of these structures may still be observed on the site.
A review of the Silverbrook Mining maps from the 1920's and 1930's confirmed
that the Buck Mountain seam was extensively deep mined along the length of the
basin. In many areas, the Buck Mountain seam would split into a "main" seam and
an overlying "rider" seam. Where the rider seam was sufficiently thick, both
seams were mined separately on different levels. An exception to this would be
where an insufficient thickness 01 shales and/or sandstone existed between the
two seams. In this case, this rock was also removed with both coal seams and
removed a t the prep plant.
-,
Records and mining maps indicate that in many areas of the mine, the support
pillars were removed as mining activities in the area drew to a close. In some
areas, the pillars were left in place, either for continued support or because the
areas were considered "un mineable". While it is difficult to determine the extent
of pillar removal, it is certain tha t the area was deep mined and a mine void
network exists beneath the site. . .
I would conclude that, owing to the existence of an extensive mine void network,
part of which underlies the McAdoo site (as documented by existing maps and
some conversations with personnel with knowledge of the area), the potential for
mine subsidence exists in the area. This potential must be considered prior to
implementation of any remedial activities at the site. The effectiveness of
specific remedial measures, such as installation of a cap over certain areas of the
site, may be threatened by a, future subsidence event, the magnitude of which is
difficult to predict.
cc:
Mr. Worley
Mr. Pine
Mr. Kozlosky
File
Chron.
E P:rd
-------
APPENDIX E
-------
RESPONSES TO ADDITIONAL c:a.tMENrS FRCt-t PRPS
Comments on the Hydro-Terra Mine Subsidence Study:
The study canpleted by HydrcrTerra for the PRPs was reviewed by EPA.
The stuay was rot considered accurate since tW'J out of three assllnptions
upon which the report was based are in question. EPA has determined that
this information in conjunction with infomation fran the state will be
reviewed during the design phase to determine the appropriate cap design.
Hydro-Terra states in Section 4.5 of its report that the analysis of the
risk of magnitude of subsidence at the ~Adoo site is based on three assLl1\ptions:
(1) That the location of the mine W'Jrki~s shown on the "original mine map" are
accurate, as is the location of the workings in relation to the McAdoo site.
(2) The worki~s beneath the site have not totally collapsed or been backfilled.
(3) The pillars beneath the site have not been remCNed.
After reviewi~ parts of the McAdoo RI and a different but prd:>ably more
recent mine map, it appears that assLI1\ptions (1) and (3) are in error. The RI
states in section 2.4.2 that deep mini~ at the site commenced in 1884 with the
opening of the untain seams were
reported to have been deep mined until 1910. Active minil'¥J started again
between 1923 and 1926 and continued until 1938. DJring this latter period, it
was reported that pillars were remCNed and the entire si te area was canpletely
mined. PAlER prov ided EPA with a different map than that used by Hydro-Terra.
The PADER map shows that most of the site had been deep mined and that extensive
pillar robbing had occured in the western half of the site. It is believed
that PADER's map is more current than HydrO-Terra's map because PADER's map
shows more extensive deep mining and pillar robbing and because structures
such as the breaker facility are located in different areas of the site. The
PArER map shows a breaker located on the southern perimeter of the si te, and a
wash house in' the west central portion of the site while the Hydro-Terra mine
map shows the breaker located rorth of the si te wi th no wash house. The RI
states that at least three coal breakers were burned down or dEmolished and
reerected at different locations. M aerial P1oto taken by EPA in 1969 shows
a coal breaker south of the site with an old wash house onsite which ultimately
t>ecame part of the incinerator structure. It is also interesting that at
DOring location B3 and B3A, the boring logs do not correspond to what is
illustrated on HydrcrTerra' s map. According to HydrcrTerra' s map', there
should not be voids at borings B3 and B3A yet the boring logs show a 3.6
foot gob filled mine void (upper Buck mountain coal seam) at a depth of
27.4 feet in boring 3 and a 10 foot void (Buck nountain seam) in boring
B3A at a depth of 31 feet. According to HydrcrTerra, the Upper Buck
M::>untain coal seam was not even mined. Therefore, based on information
presented here, it appears that assLI1\ptions (1) and (3) are not valid
and thus the. accuracy of the ent ire report is very quest ionable.
-------
2
Hydro-Terra states repeatedly that there is a very low risk tor mine
subsidence whether it is sink hole or trough subsidence. In an interoffice
mauorandl.lY\, Gene Pine, a hydrogeo1cgist fran PArER stated that "owiNJ to the
existence of an extensive mine void net\liOrk, part of which underlies the r-tAdoo
site (as docl.IY\ented by existiNJ maps and sane conversations with personnel
with knowledge of the area) the potential for mine subsidence exists in this
area... the magnitude of which is difficult to predict." Potentially responsible
parties have also questioned the risk 6f subsidence at the t-t:POoo site and
requested docl.IY\entation to show that subsidence. has occured in the area. PAIER
has reported that actual subsidence has occured in the 54 square mile mining
area in which t-t:Adoo lies. l-t:>re conclusive proof of past subsidence though is
presently at the site itself. DJrin] test boriNJ drilliNJ, NUS noted that "all
of the rock strata in the Uewellyn Formation was intensely fractured, probably
. .as a result of subsidence caused by the miniNJ operat ions ." The test boriNJ
results not only provide evidence that past subsidence has already actually
occurred but describe the over1yin] bedrock above mine voids which consists
substantially of highly fractured weathered sandstone. DJring test pitting, 13
of the 36 test pits were excavated 0.5 to 4.2 feet into the bedrock. The
bedrock was weathered and broken(more than normally expected). In evaluating
the risk of subsidence, it \IiOu1d seem 1cgica1 to consider the streNJth of
overlying bedrock. Hydro-Terra did not ccrnrnent on this point and therefore
either uia not consiaer it or believed it unnecessary in their evaluation.
In referellce to trOllJh subsidence, Hydro-Terra, states that "Instantaneous
sUDsiaence shoula have occurr~ lon] ago and that Time-dependent subsidence
tellus to De .less than .lU percellt of total suosiaence... l-t:>st time-dependent sutr
sidence should have occurred over the past 85 years, and future area subsidence
should be less than six inches." Hydro-Terra also states that this type of
subsidence could cause differential settlement over a horizontal distance of
about 15 feet. In reference to sink hole subsidence, Hydro-Terra states that
the probability "is very low because subsidence probably \IiOuld have occurred
during the past 85 years," Hydro-Terra does not estimate the possible surface
vertical or differential settlement caused by sink hole subsidence except to
say that sink hole collapse should propagate 60 to 150 feet above the mine
~rkiNJs. In reference to the vertical settlement caused by sink hole subsidence
Hydro-'D3rra states earlier in the report that "the maximl.lY\ amount of surface
subsidence can be greater than the height of mine ~rkings because debris can
move into adjacent ~rkings where collapse has not occurred especially if the
~rkiNJs are steeply inclined." \>.by wasn't the vertical aoo horizontal settlement
estimated for sink hole subsidence? The Buck l-t:>lD1tain coal seam is steeply
inclined at the site (45 degrees) and mine voids were found durin] test boring
which may be susceptible to sink hole collapse. 'D3st boriNJ 3A had a 10 foot
void at a depth of only 31 feet. B3.sed on HydrO-'D3rra's previous statement
concerniNJ the vertical settlement mechanics of sink holes, i t ~uld seem
possible that vertical subsidence greater than 10 feet is possible at TB 3A.
Horizontal settlauent at this test boring is probably in excess of the void
area. If void areas extend 30 feet as sUJgested by records, then horizontal. .
settlauent could exceed 30 feet in width. HI analysis has not been made
concernin] if soils could drop into the mine pool based on the subsidence
potential. Expert assistance will be necessary to provide interpretation
in this area.
-------
3
Hydro-Terra bases much of their evaluation of the risk and magnitude of
mine subsidence on the m.rnber of years since miniDJ has begun. 1'tley repeatedly
use 85 years as the time period over which mine subsidence should have already
occurred. '!here is evidence at the site which does show that mine subsidence
has occurred, but this does not mean that it will not continue to occur in the
future since subsidence is a time-depeooent deformation of ground surface and
can always occur as long as mine voids exist. Eighty-five years seems to b€ an
inappropriate time period to estimate the potential of mine subsidence since
deep mining is reported to have ceased in 1938 and pillar robbing probably
occurred duriDJ this latter date. Forty-seven years is a more appropriate time
frame. Time dependent subsidence will continue to occur so void spaces becane
less and less. Future subsidence cannot be ruled out as long as void spaces
still exist even if subsidence has not occurred for 50 or 100 years.
Sane insight to the potential risk and magnitude of mine subsidence
incidents is provided by Richard Gray of GAl consultants in an article published
in the Northeastern Environmental Science in volume 2, number 2, 1983, titled
ItAlternative Measures in Undermined Areas.1t .
It.. . Subsidence is a time-dependent defcmation of the grouoo surface
resulting fran readjustment of the overburden above a mine. AlthoUJh
the vertical canp:ments of movanent are usually largest, horizontal
movements and the resulting strains and deplacements are often most
significant in causing surface damage. Sane movanents take place
duriDJ mining and same after depending on the type and extent of
mining, the thickness arrl character of the overburden aoo the mine
floor and alter details on the site. '!he movanents cover fran a
few square feet to many areas, and vertically fran a few inches to
several feet... In most cases the surface area affected by subsidence
exceeds the area of the seam extracted... sink holes generally
develop where the cover above a mine is less than 100 feet... [and] where
rock cover is weak... troUJhs aevelop where a pillar or pillars fall by
crushing or punching into the mine floor or roof... subsidence tends to
reduce with increased internal above mine level. Sites located 60 or
more feet above mine level avoided the majority of sinkholes. Sinkholes
oonstituted 95% of all reported incident [however] a substantial
thickness of overDurden does not necessarily ensure safety fran
subsidence. .. Subsidence over abarxioned mines may occur many years
after mining...A study of the Prittsky coal seam showed subsidence
has occurred as early as a decade af~er mining and as late as a
century. .. more than half the subsidence incidents took place 50 or
IOOre years after miniDJ.... The time of occurrence of subsidence is
undoubtedly governed by the rate of deterioration of the rock state
am coal pillars, and by other factors which sanetimes include
mostly of pillars of small operators years after initial miniDJ.
This represents a camplex interaction of phenomenon that ~rohibit
convenient prediction of the time of subsidence... SCmet:une after
miniDJ canplete collapse of abarrloned entries and roans is to be
expected as a resul t of natural causes and acti vi ties of man...
[subsidence will occur by increasiDJ numbers of incidents for an
extended period of time as progressive deterioration and failure of
the rock surrounaing the openiDJs becanes more prooounced: And
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4
later a deminishing number of incidents as the void spaces ~t the
mine level became fewer arrl fewer... This implies that the p=>ssibili ty
of future subsidence at a site cannot be ruled out merely because
subsidence has not been recognized in the first 50 or 100 years after
mining. If abandoned mine openings beneath a site have not been
designed for long term stability, the p=>tential or subsidence remains
until the openings colla~se or until they are stabilized by backfilling,
grout columns, or sane other means... Even after subsidence has taken
place at a particular site, the possibility of future subsidence may..
remain...
This article points out the difficulty in estimating the potential risk
and magnituae of subsiaence aTX1 the time span in which subsidence will occur.
Based on these limitations and Hydro-Terra's previously stated assLlT\ptions (2
of which appear invalid) it does not seem that HydrcrTerra has substantial
justification to state that the 'risk of subsidence at the site is very low,
extranely low or improbable for different parts of the site.
Another point of contention is the nLlT\erical analysis presented in Section
, five. HydrcrTerra states tha,!: if sink hole subsiaence were to occur, each case
of subsidence should only affect less than 0.1 percent of the potentially
contaninated soils at the site. This is an area which will require assistaoce
from a mine subsidence expert for evaluation.
In the report, Hydro-Terra does make one very important point. That is
.. if subsidence were to occur, it is unlikely that contaminated soils fran
the site woula becane sutmerged in the mine pool." The model which was
usee to aevelop maximLlT\ safe contaminant levels in soils assLlT\ed saturated
flow throl.lJh the site fill if subsidence occurred to simulate a worst
case scenario. DJring design of the cover, EPA will initiate a mine
subsidence study of its own to attempt to evaluate the risk and magnitude
of subsidence. If the study shows that the assLlT\ption of saturated flow
corrlitions is erroneous, the soils model would need to be reevaluated.
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5
The Approach to Capping the Site
Fred Hart Associates stated that "a need can only be establlshed to place
a soil layer with vegetative cover over the eight-acre site." Their statement
is based on:
The organic contaminants are stable and nnmobile.
Inorganic contcrninants are not present. at higher than background levels.
None of the contaminanats onsite violate RCRA EP Toxicity criteria.
As stated in the "Establishing Background Levels of Heavy Metals at the
McAdoo Site" section, the levels of metals detected in soils onsite are above
background. The site Sllt1t\ary sutJnitted to the PRPs described why high
concentrations of organic contaminants are not stable at the site and why
removal to predetemined soil criteria is necessary. The point that organic
contaminants found at the site are nnmobile is frequently made by Hart Associates
in the carments and forms part of the basis for the recarmendation not to cover
or remove soils at the site. Therefore, it is appropriate to discuss this
point in greater detail.
The Remedial Investigation states that "significant soil contamination is
limited to upper horizon shallow soils. Migration of pollutants to the deeper
soils and ground water has not occured. rEHP (Bis 2-ethyl hexyl phthalate),
the- most critical soil contcrninant was not detected in any onsite grourd water."
The RI states later on that since the contaminants are Unmobile, migration to
the ground water will not occur.
Statements in the RI referring to the migration of organic contaminants
are unjustified because of the lack of longitudinal sampling data, lack of
consideration of the potential risk and magnitude of mine subsidence, and
Unproper assumptions regarding transport mechanisms of organic contaminants.
NUS did not consider the migration of inorganic contaminants because they
believed them to be at background levels. EPA disagrees with this interpretation
of the inorganic sampling data and thus considered migration of inorganics.
O1ly test pits 24, JA, 33, and 25 have sufficient longitudinal sampling
points. Sampling results seem to conflict with the RI's findings of significant
soil contanination being limited to the upper soil hori zone In test pit 24,
basel neutral canpounds 'Nere detected at 12 feet. In test pit 33, hexachloroethane
was detected at 1.4 ppn at 10 feet. In test pit 25, base neutrals 'Nere detected
at 5 and 7 feet. Other test pits eSPecially those containing high levels of
metals 'Nere rot sanpled at sufficient depths to detemine migration. For
example, test pi t 14 contained high levels of beryllium, nickel, zinc, caanium
and lead but was only sampled once at a depth of 2.3 feet. Test pit 14
is located in an area where metallic sludges 'Nere believed to have been
. stored. DEHP was alSO found in test pi t 14 at high levels. '!he highest
level of rEHP found onsi te was in test pi t 9 at 960 ppn at 4 feet. Samples
'Nere only taken at 1.5' and 4 feet so the migration of DEHP into deeper soil
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6
2Dnes is unknown at this location. Therefore, as illustrated with these
sample 'results, a conclusive detennination cannot be made as to ihe past
migration of contaminants in site fill.
It is also bel ieved that assunptions in the RI/FS were inaccurate
in regard to the transport of nonionic organics in both the unsaturatoo
and saturated zones. '!he site fill presently exists under unsaturated
conditions but could becane at least partly saturated by an incidence of
significant mine subsidence. ~nionic organic contaminants traveling in
the dissolved phase absorb to organic carbon in soil or sediment with an
affinity corresponding to their organic carbon partition coefficient
(Koc). The more organic carbon in the soil and the higher the Koc value,
the greater the ratio of an organic contaminants in soil to its concentration
in the aqueous phase. If it is assuned that adsorption is canpletely
reversible (researchers have shown that this is the case with many compounds)
then it must be assuned that contaminant will eventually leach fran site soils
if the site is not hydraulically isolated. '!he question is not so much the
ability of a canpound to migrate, but the time or rate of migration and the
eventual concentration in ground water. Since desorption depends on the
washing out of soil by uncontaminated water, desorption rates will be greatest
under saturated conditions and thus the resulting ground water concentration
is highest under saturated conditions.
W"len attempting to establish safe soil levels for contaminants, desorption
must be taken into account to predict the highest concentration in ground
water res'ulting fran contaminated soil. With the use of an appropriate ground
water mooel or ailution factors, an estimation can be made to detennine if
contaminant levels in soil will affect public health or environmental targets.
A mcxlel using dilution factors was applied at McAdoo to protect present and
possible future aquatic life and hunans who ingest aquatic life. '!he mcxlel
assumes saturated fill conditions since there is an unknown possibility of mine.
subsidence. Mine subsidence could enable hydrophobic contaminations to reach
the saturated zone in minutes in what could otherwise take hundreds of years.
As pointed out in the Hydro-Terra mine subsidence report though, the
assunption of saturated flow conditions may not be valid. This ccmnent will be
reevaluated during design of the cover.
E.Ven in the absence of mine subsidence though, contamination \o,Ould eventually
migrate to the mine pool in a shg like. fonn and result in a similar type of
release to the mine pool water except the release \o,Ould occur over a longer
pericxl of time and maximun concentrations realized in the mine pool 'llUuld prooably
be less than that which 'llUuld occur under saturated conditions. ~sorption
can occur over a very long pericxl of time and concentrations of contaminants'
coula increase in deeper soil until eventual release is obtained. At this
time maximun release will be obtained and greatest impact to aquatic life
Will occur ~
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7
If soils are ranewed according to criteria established by EI?A, a ReM
cover w:>uld be acceptable for site closure. The cOller must be designed arrl
constructed to:
(1) PrOllide long-te~ minimization of migration of liquias.
(2) Function with minimLm maintenance.
(3) Pranote drainage and minimize erosion or abrasion of the cover.
(4) Accanodate settling and subsidence so that the cover's integrity is
maintained .
(5) Have a pa~eability less than or equal to the pe~eability of residual
soils at the site.
Therefore, if all soils containing levels of contaminants exceeding EPA
criteria are ranoved, only a cOller having pe~ability equal to or less than
residual soils present at the site w:>uld be required.
The comment concerning coRtaminants not failing the EP toxicity criteria
is not valid since soils are not routinely tested for EP toxicity during the RIfFS.
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8
Dilution in the Mine Pool:
Fred Hart Associates believes that the lOX dilution factor ~ed by
EPA in the soil model is "far too conservative to appropriately reflect the
situation at the site". Hart Associates estUnated a dilution factor of
approxnnately 400X based on:
o potential residual contamination covering site area of 8 acres
o potential net annual infiltration of 12 inches
o annual mine pool discharge of 824 million gallons based on October
1984's flow rate . . .
o Correction factor of 1.2 to 1.5 to account for:
- rainfall runoff
- residual contamination covering only 4 acres instead of 8 acres
- October discharge probably lower than the average daily discharge
The correction factor may not be appropriate because inorganic anu oryanlc
levels in soils were found at greater than backgrouna l.evels 1n cwuOSt: t::very
. test pit sampled during the RI. Data in the RI indicates that soil contamina-
tion on the site is extensive so the calculation should be based on 8 acres
instead 4 acres. Also, the RI states that coal refuse is very permeable material
so surface water will mostly percclate into the mine spoil rather than running
off-site.
'!he other mmbers appear reasonable and will be further evaluated during
design to deteDmine whether a dilution factor greater than 10 is valid.
If any change in the dilution factor changes the affectiveness of the remedy
selection, then a ROD amendment will be required.
The Pathways:
'ttlis section uses m.merous excerpts fran the RI and FS reports to
substantiate the lack of pathways at the site. It is not necessary to
cat1t\ent on individual excerpts fran the RI and FS made in this sectlon
since ~~AS technical. position regaraing tnese points is outl.ined in deta11. 1n
the slte summary submitted to the PRPs.
Source of Contamination:
'!his section states that the remaining contamination presents an
extremely low residua! risK anu uses nunerous excerpts fran the t(J. ana
FS reports reports to substantiate this statement. It is not necessary to
carment on il'X1iviaual points made in this section because the site Sl.lm\ary
SUDmlttea to the PRPs summarizes EPA's technical poSition on every
point. EPA re-evaluated the analysis of the data in the RI and FS in the
ROD and justification is provided in the SUmmary of Alternatives section.
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9
Receptors and Removal of Contaminated Soil:
Fred Hart Associates provides nl.rnerous excerpts fran a 1973 A.W. Martin
Assoc1ates report ana various PaDER manorandams to describe the current water
quality conditions in the Little Schuylkill River. EPA itself used the same
sources when evaluating the river and thus accepted most of the conclusions
presented. However, there is one conc.lUS10n which EPA does not agree with:
that the Little Schuylkill River is so badly degraueu tnat 1t 1S oeyona recovery.
IDes this mean that the river will never recover? It is doubtful whether anyone
~o~a present aata to sUDstiatiate this claim.
'.u~ I-"'r' ::.tates that "Jerneaia.1 actions are those responses to releases
that are consistent with a pennanent remedy to prevent or minimize the release
of hazardous substances of pollutants or contaminants so that they do not
m1grate to cause sUustantia.l aaI'kder tu present or future public health, welfare,
or the envirorment.'"
A risk exists to future aquatic life and humans who ingest aquatic
. ufe. PeSt or the organic contcrninants 1n s1te fill are hydrophobic ana
thus aasoro str0I'kdJ.Y to Oryan1C caroon In SOl1 or fiB. Adsorption is
Leversio.le through ana thus even very hyOrophobic organics may be eventually
IoJt:! LeJ.easeu to the m111e POU.1.. J.llt:: lrnportant quest10n 1S not whether these
organic contaminants will migrate, but when, and what will the maximum
concentration in the mine pool be. HydroP'lobic organics move much more
Slow.LY through soi.1 than hydrotX'lilic organics. A release could take
hundreds of years. EPA assl.rned that recovery of the stream is possible
within this time-frame, especially since the State intends to address the
acid mine drainage point once the source of contamination at the McAdoo Site
is ranediated. .
Another point which was ignored by Fred Hart Associates is' that the river
is presently being stocked with fish near Tcrnaqua, and stocking has been mooerately
successful. Many of the stocked fish are probably consl.rned by humans. These
fish were not considered as receptors by Hart Associates.
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! .
10
Bulk Disposal:
The NUS RI states that:
"Topographic conditions aId subsurface features observed
in TP-9, 10, and 24 (all in Zone 1) strongly suggest that
bulk wastes were dunped onto the ground, in the the vicinty
of the buried coal mine entry. Likewise, subsurface coroi tions
observed in TP-25 (Zone 3) strongly suggest that liquid wastes
were dumped onto the ground (or into the coal slurry pond)".
Since bulk liquids were handled on site, if the site operators
wanted to disr;ose of bulk liquids, they ~uld likely choose a very
permeable location such as the G:>rdon slope entry. The fact that
,liquid wastes were disposed of directly or indirectly into the G:>rdon
Slope is documented in the RI:
"with regard to the crxylene and styrene found in the soils,
the pattern and distribution of the crxylene and styrene ~uld
indicate that the resin-like sheet covering the area is releasing
these contaminants. It also confirms at the time of release, the'
contaminants moved over the soils. and into the mine oPening which
acted as a sump. The canbined factors; location of the storage
tanks, presence of the resin-like sheet and its spill pattern,
, presence of the congealed resin in the ceiling of the slope entry
... and the chemical analytical c.ata, are evidence that bulk liquid
spillage took place in this particular area." .
Further evidence of bulk disposal is docLl11ented 'in the test
pit l~s:
o Strong organic odors were detected while digging in many test pits
o Test pit of TP-3 had sharp organic chanical odors which caused
skin, eye, and nasal irritation at 2 to 5 feet.
o Strong organic chanical and acid like odors are present in
fill over the mine entry.
o TP - 25A contained strong organic'chemical and acid odors which
caused skin, eye, and nasal irri tat ion. Red and green paint sl udJe
was also present.
o TP - 26A contained an oily waste seep at 2'.
, 0 TP - 33 had strong organic odors, and oily seep~e water.
o TP - 35 had oily .seepage water.
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11
Since water or liquids on the site eventually percolate thro~h the
site fill and enter the mine pool, and since the mine pool water enters
the Little Schuylkill River, it is reasonable to assume that bulk liquids
in a diluted foen could have reached the river and may still be present
in the sediment.
SUrface Run-off ,Fran the Resin Sheet:
Fred Hart Associates questions whether there is any direct evidence that
the resin sheet is contributing to surface run-off. The RI states on
page 5-9 that "the pattern of distribution of the o-xylene and styrene
would indicate that the resin-like sheet coveriNJ the area is releasir¥J
these cootcrninants" o-xylene detected in soils underneath the resin
sheet could release same contaminants via water solubilization or through
sorption on micron size particles passiNJ through course coal refuse.
. Since it is possible for o-xylene to migrate in soil, it is also possible
for it to flow off-site via surface water run-off. The environmental
impact of this run-off and concentrations of contaminants in off-site
soils fran run-of f are unknown.
Fred Hart Associates also states that "given that the contaminants
are stable, there is serious question as to whether ranoval would not in
fact increase the environmental risks" but gives no explantion of how
ranoval \'IOuld present an environmental risk or whethe-:r the risk leaving
the resin sheet on site out-weighs the risk of ranoval.
The Use of the MEGS Model at the McAdoo Site:
The Mult~edia Environmental Goals (MEGS) Model was developed by
EPA in 1977 to establish goals for canpounds in air, water, and soil.
There is currently no EPA policy regarding its use. The goals set by
the mooel were not used for sane of the sane reasons the PRPs do not find
them acceptable. The soil model assumes two liters of water can leach
100% of all contiminants fran 1 kg of soil. As mentioned by Fred Hart
Associates, this is an extreme assumption. Hart associates also mentions
that the gOalS for metalS in soil are so conservative that they are
below backgrouna levels for many regions which is true. For these reasons,
the MEGS model goals were not deaned appropriate for the McMoo site.
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12
Establishing Background Levels of Heavy Metals at the McAdoo Site:
Fred Hart Associates states that the Glick and Davis study is statistically
flawed because of S'!\al1 sample size aoo large standard deviations for the
metals of concern. They state that "natural levels of metals in anthracite
coal may actually be higher than the study irdicates... [and that] usin;;j
metals concentrations of coal to determine background values provides
only a crude estimate for soils on site ... [and] actual sampling of
soils on site or adjacent to the site 'IoOuld be necessary to detemine
what background levels are for the McAdoo soils."
The summary statistics for whole anthracite coal from the Glick and
Davis Penn state stooy are listed below. All values are given ppn.
minimun maximun Std
metal value value mean Dev n
- - - - - - - - --
Be 0.618 5.755 2.206 1.609 '12
Cr 13.300 75.608 48.998 18.159 12
Ni 10.925 126.835 42.425 30.860 12
Zn 2.850 65.653 20.729 19.745 12
In the Buck M::>untain Coal Seam, berylliun is found at a mean concentration
of 0.62 ppn (Davis, September, 1984).
It is of course possible that in some locations natural levels of metals
in anthracite coal may be higher than the maximun value indicated by
Glick and Davis, but at the same time it is equally possible that in
some locations natural metals values may be less than the minimun values
reported by Glick and Davis. The variation in the range of values reported
for these four metals is not significant when compared to the concentrations
of metals detected at "hot SfX)ts" in site soil. For instance, the range
for zinc is reported as 2.850 to 65.653 ppm in anthracite coal while
78,406 ppn of zinc was detected (dry weight) in test pit 25. The rarYJe
for nickel is reported as 10.925 to 126.835 ppn while 2,012.4 ppn
was detected in test pit 14.
Also, EPA does not believe that it is coincidence that the highest concentrations
of metals detected in on site soils coincides with the areas where metallic
sludges were reported to have stored ana where bulk disfX)sal of liquidS
took place. .
EPA did take 3 off-site fill samples while test boring in areas which
should rot have been affected by the site. The results for metals of
concern are ilJ.ustrated as foHOWS: All values are pptt.
"
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13
Metal 8-8 8-9 8-10
Cr 4.9 3.3 5.2
Be ND 0.3 NO
Ni 4.7 3.6 2.7
Zn 5.1 6.0 7.9
Cd NO NO NO
Pb 8.8 1.1 7.4
Cyanide NO NO. NO
The concentrations of metals in the borings are obviously below levels
expected fram anthracite coal as is expected since coal typically contains
higher levels of metals than coal refuse.
EPA did not select offsi te boring sample results for background metals
because the site overlies the Buck Mountain Goal seam which intersects
the mine p:x>l. Establishing background levels for metals below those
nonna.Uy fourd in anthracite coal could theoretically (and in this case
,unreaSOnaDiY) involve significantly greater need for remedial action at
the si te . '
For the reasons previously discussed and the fact that 12,56U druns of
wastes, (many containing metallic sludges); 20 tons of lead silicate;
and 60 tons of zinc waste' were stored on site (it seems unrealistic to
asStlt)e that none of these wastes were purposely or accidentially spilled
onto the ground), it is obvious that metals are present in site soils at
higher than background levels.
Biological treatment was removed fram futher consideration because the
lo~-tenn effectiveness of this method is unknown. Activated carbon,
treatment was removed fram further consideration because the contaminants
found on site are adsorbed to soil. Incineration and wet-air oxidation
were removed fram further consideration because they would have elllTIinated
organics but concentrated metal ooncentrations. On-si te disposal in a
ReM landfill was removed fram further consideration because the RCM
cap would provide similiar protection since the ground water table does
rot normally cane in contact with the soils. '!he only chance that
contcminants would cane in oontact wi th the ground water would be thro~h
downward migration fran precipitation. The location of the, landfill
would also be susceptible to subsidence ,~ difficulty in monitoring
and would cost twice as much as a RCM cap.
After canpletion of the initial screeninJ of technologies, as detailed
evaluation of alternatives was conducted in order to identify those alter-
natives which may best address the problEl'l\S on-site in addition to ranoving
the ranaining 15,000 gallon tank. '!he coosen alternative should be the
most cost-effective, technically feasible, 'and reliable solution that
effectively mitigates or minllTIizes damage to and provides adequate
protection of public health, welfare, and the envirorrnent. Alternatives
were developed by applying technologies considered individually or in
canbinations.
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14
The alternatives remaining after the initial screening process were grouped
into two catergories: site related and disposal related activitj.es. The
alternatives are listed below:
o
Site Related:
- No remedial action
- RemO\1al of debris
Excavation and/or remO\1al of wastes and most heavily contaminated
soil
Excavation of contaminated soil to background levels
- Capping which meets the standard of ICRA regulations 40 CFR Part
264 throughout the entire site
Diversion of surface water
o
Disposal-Related
- Off-site disposal in a RCRA permitted facility
These technologies were then combined in remedial alternatives that
would be applicab.le to this site, and screened with respect to the remedial
objectives. The following is a detailed analysis of these alternatives.
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