United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-85/013
June 1985
Superfund
Record of Decision:
Taylor Borough, PA
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~,
,. REPORT NO.
EPA/ROD/R03-85/013
4. TITLE AND SUBTITLE
SUPERFUND RECORD_OF DECISION
Taylor Borough, PA
TECHNICAL REPORT DATA
(Please read InstrUctions on the reverse be/ore completing)
3. RECIPIENT'S ACCESSION NO.
12.
5. REPORT DATE
June 28, 1985
6. PERFORMING ORGANIZATION CODE
7. AUTHORISI
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
1,. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
Agency
13. TYPE OF REPORT AND PERIOD COVERED
Finril Rnn
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. A8STRACT
The Taylor Borough site is located at the toe of Bald Mountain, approxi~~ly
three' miles south of the City of Scranton. The population within a one mile :radius .
of the site is estimated to be 1,007 persons with approximately 265 residentiaL'
dwellings. The site is situated within a tract of land that was previously coal
mined and left unreclaimed with numerous open and surface mine ~poil pits. Subse-
quent to the mining activities, unreclaimed portions of the l25-acre site were used
for a-municipallandfillqoperation by the City of Scranton. Municipal waste was
disposed. in the pits and the mine spoil material was used as a cove~ material. As
a result of the landfill operation, which ceased in 1968, the topography of the site
consists. of relatively rolling terrain between steep slopes of mine spoil piles and
unreclaimed pits. In addition, after the landfill operation ceased, drummed indus-
trial wastes were. found on the surface of the site.
The selected remedial action includes: removal and off-site disposal of
approximately 125 crushed and intact drums and remnants to a qualifying RCRA facility;
collec~ion and treatment of contaminated surface water; excavation of contaminated
soils and wastes from the former drum storage areas for off-site disposal to a
qualified RCRA facility; proper backfilling and placement of a 24-inch soil cover
over the former drum storage areas and installation of a chain link fence around the
perimeter of both soil covered areas. 'T'n~~l "'~T''; ~~1 ,..n..~ ;.., " ...~ '"'~ ~d '17 nnn
.
17.
~.
DESCRIPTORS
KEY WORDS AND DOCUMENT ANAL YSIS
b.IDENTIFIERS/OPEN ENDED TERMS
c. CDSATI Field/Group
Record of Decision
Taylor Borough, PA
Contaminat~d Media: soil, sw, air
Key contaminants: Benzene, toluene, phtalab
acid esters, polycyclic aromatic hydrocar'ons,
trichloroethylene, chloroform and other
organic chemicals
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (Tllis Rrpo't)
None
20. SECURITY CLASS (Tllis page)
21. NO. OF PAGES
~.d
22. PRICE
None
EPA FOIIII 2220-1 fR... 4-77)
PREVIOUS EDITION'I 08S0L.ETE
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site:
Taylor __Bor.ough Site, Lackawanna County, Pennsylvania
Documents Reviewed:
I am basing .y decision principally on the following documents
describing the analysis of cost effectiveness and feasibility of remedial
alternatives for the Taylor Borough Site. Unless otherwise specified,
the underlying technical infonaation is included- in theee rsporta:
"Feasibility Study Report". (Draft). Taylor Boro~gh Site, Lackawanna
County. Pennsylvania. (NUS Corp. Kay. 1985)
"Remedial Investigation Report-. (Draft). Taylor Borough Site,
Lackawanna County. Pennsylvania, (NUS Corp. Kay, 1985)
"Work Plan". Remedial -Investigation/Feasibility Study of Alternatives.
Taylor Borough Site (NUS Corp. February. 1984)
"Remedial Action Master Plan". Taylor Borough Site, (NUS Corp./Phoenix
Safety Association LTD. S~ptember. 1983)
Summary of Remedial Alternative Selection
Recommendations by the Pennsylvania Department of Environmental
Resources
Staff summaries and recommendations, including these attached
Description of the Selected Remedy:
Removal and off-site disposal to a qualifying facility under the
Resource Conservation and Recovery Act (RCRA) 40 C.F.R. Part 264.
Subpart N of approximately 125 crushed and intact drums and remnants
remaining on the surface or partially buried.
Collection and treatment of contaminated surface water in Ponds 1 and 2.
Excavation of contaminated soils and wastes from former Drum Storage
Areas Nos. 1 and 2 and sediments in POnda Nos. 1 and 2 for off-site
disposal to a qualified RCRA facility.
Proper backfilling and placement of a 24 inch 80i1 cover over: (a)-
former drum 8torage areas 3 and 6 and the entire area in between. and
(b) former drum storage area 4. lostallation of a chain link fence
around the perimeter of both soil covered areas. -
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Declarations
Consistent with the Comprehensive Environmental Response, Compensation
and Liability Act of 1980 (CERCLA) and the National Contingency Plan (40
C.F.R. Part 300), I have determined that the remedial actions described
above together with proper operation and maintenance constitute a cost-
effective remedy which mitigates and minimizes damage to public health,
welfare, and the environment. The remedial action will be designed to
minimize the risk of potential evacuation and temporary inconveniences to
the local environment during the excavation and transportation phases.
The State of Pennsylvania has been consulted and agrees with the
approved remedy. Following placement and installation of the soil cover
and fence at the locations identified in the "Summary of Remedial
Alternative Selection," operation and maintenance activities will be
required to ensure the continued effectiveness and level of protection
of the remedy. These activities will be considered part of the approved
action and eligible for Trust Fund monies for a period of one year.
Land use restrictions may also be necessary to ensure the effectiveness of
the remedy.
In addition, the off-site disposal of contamined soil, sediment, and
wastes to a secure hazardous waste facility is necessary to protect public
health, welfare and the environment.
I am deferring selection of remedial response measures, if
groundwater contamination. Further assessment of the nature of
contamination and the appropriate RCRA measures to address such
will be performed.
any, for
detected
contamination
I have determined that the action being taken is appropriate when
. balanced against the availability of Trust Fund monies for use at other
sites.
Date
<' p. --:::;.../ /
----~ ~,~/'-:~~>!..
James M. Self
~egional Administrator
EPA Region III
~L<~ ..'7/Z. .
t'/Jb!~..-
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Summary of Remedial Alternative Selection
Taylor Borough Site
Site Location and Description
The Taylor Borough Site is aligned in a northeast-southwest direction
in Taylor B2rough, Lackawanna County, Pennsylvania (figure 1). It is
situated at the toe of Bald Mountain about 3 miles south of the City of
Scranton. The Northeast Extension of the Pennsylvania Turnpike is the
Northwest limit of the site. A recreational area, McDade Park, and a County
maintenance building and property bound the site on the northeast. Abandoned
strip mine operations, waterfilled depressions, and spoil piles bound .the
site on the southeast. A new residential development and the inactive
Bichler municipal landfill bound the site on the southwest (figure 2).
The Taylor Borough site is situated within a tract of land previously
mined (both underground and strip). The strip mine operations, which
extended beyond the limits of the site, left the area unreclaimed with
numerous open pits and surface mine spoil piles. Subsequent to the mining
activities, unreclaimed portions of the 125 acre site were used for a
municipal landfill operation by the City of Scranton. Municipal waste was
disposed in the pits and the mine spoil material was used as a minimal (0-2
feet) cover material. As a result of the landfill operation, which ceased
in 1968, the topography of the site consists of relatively rolling terrain
.between steep slopes of mine spoil piles and unreclaimed pits.
Based on the 1980 census, approximately 75 percent of the populations
of Scranton (88,117) and Old Forge (9,304), and all of the population of
Tayl6r Borough (7,246) live within a five mile rad1us of the site. The
population within a one mile radius of the site is about 1,007 persons with -
approximately 265 re~idential dwellings. With the exception of the new
residential development located at the southeastern border of the site,
there has been no residential or commercial development within 1,400 feet
of the identified site limits. Onsite observations indicate the site has
been used particularly by children as a place to play, bike ride, walk
through to McDade Park, and as a target practice area for hunters or other
gun owners.
St. John's Creek, with head waters on Bald Mountain, is an intermittent
stream which flows through the site and eventually discharges into the
Lackawanna River. During the strip mine operations, the creek bed had been
relocated within the site limits onto strip mine spoil fill. As a result,
the flow frequently disappears into the creek bed at certain points and
reappears at other points during relatively low flow periods.
As a result of the mining and landfill operations, subsidence and
settlement have developed depressions on the surface which act as seasonal
ponds. Precipitation and surface runoff collect in these areas and depen-
ding on the type of cover (soil and rock matrix) present, the water either
ponds or infiltrates into the subsurface. Several small ponds which store
water throughout the year are located approximately 100 feet east of the
site. These ponds have been used by the adjacent property owner for recrea-
tional purposes.' Due to the present surface grading, these ponds do not
receive surface runoff from the site. .
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FIGURE 1
LOCATION AND VICINITY MAPS
TAYLOR BOROUGH SITE. TAYLOR BOROUGH. PA
SCALE: 1.= 2000'
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, ',.., FIGURE 2
TAYLOR
EXISTING CONDITIONS
BOROUGH SITE, TAYLOR BOROUGH, p~
SCALE AS SHOWN
400 0
~---
SCALE IN FEET
400
,
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2
Potable water for the Scranton-Wilkes Barre area is provided by a
municipal surface water reservoir system. Neither the Campbell Lodge Reser-
voir (approximately 5 miles southwest of the site) or Lake Scranton (approx-
imately 4.5 miles southeast of the site) receive surface water runoff from
the site. ~~ere is no reported use of ground water for drinking purposes
within one mile- of the site. .
Due to the extensive mining in Lackawanna County (strip and underground),
the ground water aquifers closest to the surface in the valley have been
significantly affected' both in quality and yield. Bedrock beneath the site
has naturally-occurring fractures; however, 'resultant mine voids have caused
further rock fracturing and subsidence which has impacted ground water flow
patterns. Unconsolidated soil deposits have been disturbed through surface
mining operations. As a result, the hydrologic characteristics of the
surface area, particularly the recharge of ground water aquifers has been
substantially altered.
Site History
. The Lackawanna Valley has historically been extensively mined for
anthracite coal. Following the mining operations, the City of Scranton
used the unreclaimed strip mine pits as a municipal landfill at least
from 1967 through 1968. Records rrom the Pennsylvania Department of
Environmental Resources (PADER) also document the disposal of industrial
wastes. After the landfill operation ceased, drummed industrial wastes
were found on the surface of the site.
Beginning in 1981', Environmental Protection Agency (EPA) and the
PADER conducted various field inspections of the site. The majority of
the surface drums were concentrated in six areas (figure 3). Most of
the drums were open and the contents may have spilled during the dumping.
Many had also been punctured by bullet holes. Air sampling close to the
drums identified the presence of volatile organics. Drum and drum spill
samples were analyzed in 1982 and found to contain benzene, toluene and
other substituted benzenes, phthalate acid esters, polycyclic aromatic
hydrocarbons, trichloroethylene, chloroform and other organic chemicals.
On September 11 through 12, 1983, a fire occurred on the surface
of the landfill. It appears mine spoil was pushed over burning areas
to extinguish the fire. As a result, some drums were partially buried.
Since the fire had engulfed seNeral drums, it prompted EPA to institute
an Immediate Removal. During September through November of 1983, approxi-
mately 1,200 drums were removed from the site.
The initial Hazard Ranking System (HRS) score for the site 27.32.
After additional documentation from the PAD~R indicating larger quantities
of potentially hazardous substances had been dumped at the site, the HRS
score was revised. The incorporation of this additional information resulted
in a revised score of 30.94. After the site had been proposed for placement
on the National Priorities List, authoriz~tion to proceed with a Remedial
Investigation/Feasibility Study was approved in November, 1983. A work
plan was developed which identified the following data needs:
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~~~:IJ t ','..,.,: ~:,~}[~:\ :" ~ l':' :,~tll ,r' C"'(~?,:j '7" -'",\''' : '~,:':~~:-:""'~'~[;1/.~; t~ ;~:' .",~' -
" ''\ , '" ,if'\. /. ' 1 ' .. : " ",,,', ' ',' , " ',,' "\ ~";:-.1J
" \ -i-, \ I,-,J) :", ' , ,-- "l..' / ..,,-"=,=", : ';','''' '," ',1.' '
. il- ;>.,"'t"..,~..:: : .' "'.." ,h-- ~--01\~ >-,: '-,0 <"''c' ,~:'>J: ii (':"'\'; ,,'
1'9EAIL:::::MATE LIMITS OF ~:'~.'- "~ ?Jk:,.)~-t'~ L.>i ., ;\~':. ,)t~yt:-'~~~:-j";-~"'<:";! ~"~~D';'::'~'~~':' \; "'~,~"s:;~.'~c::~ ,
KNOWN SURFACE DRUM <: .._:~! I - " " --..." - .;, i 'n ., ';.. '. 'L.:..:.:-r~-'i?"" .. :. ",. '---:""~ '0', -:. ::
I,' STORAGE AREAS ,\1:: 'I :".., !' - I',";' ,- :\ ,,', ( '~" ( ,~'. '-r-:.""" ,-..-r. ,- '''''';''''~:~ -- ,.,....-.
,'~~ .. '. ,,~", ,':. ,-;,,:. \,,-'" , "".> , -- ',c ',;",u--A ~~ _. '-'''11!;' '," .
I ' " , ~J..." '" ,,-, -', ..' , ~'.- .' _. U ,- ,,,. . .-..' -.., . . .'.'.- --'-- ~- ..' ,. ....
FIGURE
....~.
,.'
3
TAYLOR
SURFACE DRUMS STORAGE AREAS
BOROUGH SITE. TAYLOR BOROUGH. PA
SCAl E AS SHOWN
",DO °
1"""""\0..--
SCALE IN FEET
",DO
,
-------
3
o Drummed wastes were spilled on the surface of the site' as indicated
by previous sampling. Surface soil sampling was required to determine
. the nature and extent of contamination remaining in areas where field
observations indicated the presence of isolated, crushed. surface drums.
o .
No ground water data was available. Monitoring wells were needed to
determine the" p~esence and migration of possible bulk or drummed wastes
buried within the landfill operations which might be affecting the ground
water regime. .
o Surface waters on and off site needed to be sampled to determine the
nature and extent of contamination and to monitor possible migration of'
contaminants.
A Remedial Investigation/Feasibility Study was funded at a total
cost of $606,625 and field work began March, . 1984.
Current Site Status
Geophysical surveys were conducted during the Remedial Investigation
to aid in determining the limits of the strip mine pits and the possible
occurrence of buried drums. An Electromagnetic Conductivity (EM) Survey
coupled with a review of a~ailable mining information identified the strip
mine pits (figure 4). The EM Survey also estimated that trash and debris
is extensive and occurs to depths of up to 25 feet in the pits. Below the
trash and debris is a layer of mine spoil fill ranging from 25 to 75 feet
from the bottom of the trash and debris to the base of the strip pits.
A Magnetometer Survey was performed to delineate areas underlain by
ferromagnetic material. Results from this survey indicated significant
amounts of buried ferromagnetic materials. In an effort to determine the
type of material buried, nine test pits were.excavated to a depth of nine
feet in a large grid area which exhibited extensive anomalies (above
background levels of buried ferromagnetic materials). No drums were
encountered, only typical municipal landfill metal objects.Other smaller
grid areas exhibited similar anomalies. Due to the possible interference
of crushed barrels and other ferromagnetic debris on the surface of these
areas coupled with the results of the first test pit program, it was
decided not to expand the test pit program for the purpose of identify-
ing other site anomalies.
Beneath the site, at least eight underground coal seams exist in the
bedrock and have been extensively mined (figure 5). Based on subsurface
investigations performed during the RI, the following coal seams and average
thicknesses have been identified:
Coal Seam
Average Thickness (feet)
Diamond
Rock
Big
New County
5
6
11
4
-------
'.
. -
. '
'-'-!"'Jo..~~,':'::,;;~ '.." "c: ';----""
..; t~-.....! ~;-"'-'.'------,::, ,,-...:s=;~~,2",---c.:-"'\- ,-~-'
- -- . .--. ~ . ---- --- - ".."\..~ ..~.
:' , '.- ~:',:'~'--:,;.:5, .,<\" J/ -~-. -"';~,i, . ~~'~.\-~' r:''':~~:-g:''''
"", . '0'.",. ~~~<' ,'NEW" CQ,U N. T Y ~-,
,.~... ~.COAt:-SEAM :-;,'-. 1:---' ~.'; -~ ',.." ~ ,,0.
--'~\j~" -:t::):~:~~.:~~;. ~_.:,' ~~:~:> f" . (r-'~ .
:--. ""'::~~- L - ;:-
~~ '.'
'-'- - - ,,:~"~~'~;;;,-C:, ~
e
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,
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.~:"'"
'-,
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- -- -----
"
'. .:.
[-',
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0";. .
/. ':---.::.7...-...-~
-- -=- " '\ ,-., Co ''''''
MW-TD . -E'!"'~'-' g.' ", AL,' iD
"', MW'~ii""- '" -- ,.J~~, ~. ,." / 'i
-, "'" .' - , 'M\V'2c'4,,'2 IC ;5' A\ ,v.I',/. ,SEAMs
MW-U MW'~~ ',1 ,,",,, ','.
, C / ' ,:;' '7"'~:~~-MW-4C
." \"", ,~":~~t~~~~-" :-::~~,s~i.£::~l~~"
-=---:..-:~... ,- ,~ . (INT£RMITTE?f-T Mw-IlA,E~IO "':--,:-'" (~'-:-
-- , '- , Q~-IOA .'" \'::
"'-::-:'~_-:::-=-:_o STRIPPING,' .
/ '\' M~.'B .
.- '" ",,, \..;? ,~~i' \,
!' MW-3C (' ,-,'
FOUR FOOT, 'J" ..-.
COAL SEAM \
MW,5I
"
..-:
A.,
l'
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.\.,
..
, '
"
~
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,-
. -'"
1_."
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,
, \
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~
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J'
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"~,,J , , :"r"
, "
r
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- -
"n.., -, ',' " '..' ',\"""~,, .
!I. FOR DETAILED DESCRIPTION OF SUBSURFACE CONDITION'. SEE BORING' . \~ ',' '...,.,.,'1 ,;Y-' ..,.' '"
,~, :r, ;.G:O~HY;I::::;~~.::~D:::.~:~~~:? ~*,~¥:~:~~~~~~;~~~: --~
AT THE OHICE OF SURFACE MINING, WILKES-BARRE, PA.
:l
:
"
..~---_.- -
-----, .0-- j
.... ------ ~.
,~
LEGEND
O\IMW.SA,E-6 MONITORING WELL 8 EXPLORATION BORING
.f-I EXPLORATION BORING
() APPROXIMATE LIMIT OF FORMER STRIP PIT
OF ASSOCIATED COALSEAM
;; ..
-'
: .~~ '.
, ,
"
"'MW-'
A
MONITORING WELL
A' CROSS SECTION LOCATION
-.
..
""rE' INFORMAT'ON CONCERNING LOCATION OF STRIP PITS TAKEN FROM MINE MAPS ON FILE
,I
FIGURE 4
STRIP MINE PITS,
MONITORING WELL LOCATIONS/CROSS SECTIONS, A-A' THROUGH D-D'
TAYLOR BOROUGH SITE. TAYLOR BOROUGH. PA
SCALE AS SHOWN
.00 0
~--
SCALl IN FEET
.eGO
.
.....
-------
.
APPROXIMATE LIMITS OF
TAYLOR BOROUGH SITE
NEW COUNTY COAL
STRIP PIT
BIG COAL
STRIP PIT
DIAMOND AND ROCK COAL
STRIP PIT
.-
1&.1
1&.1
....
Z
o
t:
~
1&.1
...J
1&.1
1000
500
400
300
LEGEND
- APPROXIMATE LOCATION
OF COAL SEAM
000
900
FOUR fOOT
---
DIAMOND
800
ROCK 700
81G
NEW COUNTY
600
. CLARK
500
NO.1 DUNMORE
NO.2 DUNMORE 400
NO.3 DuNMORE
300
THIS CROSS SECTION ADAPTED fROM MINE
MAP INfORMATION ON fiLE AT THE OffiCE
Of SURfACE MINING,WILKES-SARRE, PA.
FIGURE 5
GENERALIZED GEOLOGIC CROSS SECTION
TAYLOR BOROUGH SITE. TAYLOR BOROUGH. PA
SCALE: I"; 200'
-------
4
Coal Seam
Average Thickness (Feet)
.Clark
Dunmore No.1
D~~~ore No.2
Dunmore No.3
3
3
3
4
These seams have had at least 50 percent of the coal mined (Singer 1975).
Bedrock stratigraphy as determined from drilling and borehole geo-
physics is summarized in figure 6. Naturally existing fractures and
fracturing due to the mining operation have had a substantial impact on
the ground water hydrology. Major aquifers that may have existed prior
to mining have been de~atered. Perched water zones exist within the
shallow unconsolidated deposits in the site area, however, yields are
generally less than 1 gallon per minute. The water in these zones is
controlled by (a) the presence of low-permeability till deposits and (b)
the uncontrolled deposit of strip mine spoil that contains varying
quantities of clay and silt materials. Based on the above, no continuous
ground water level is present across the site.
Structural geology and subsurface drilling information has indicated at
least five distinct water-bearing zones that were monitored in the bedrock.
These zones are perched on unfractured shale units. Water in these zones
flows to a vast mine pool either by vertically migrating through fractured
rock and mine openings (air shafts, slope openings, unsealed boreholes)
or by following geologic structure and intercepting the mine pool at an
elevation of approximately 600 feet above mean sea level. Within the
vicinity of the site, vertical distance from the site surface to the
mine pool ranges between 300 and 350 feet.
e
The mine pool water is not a potential source of drinking water.
Based on the Ground Water Protection Strategy categories, the mine pool
is considered a Class 3 aquifer due to contamination from mine drainage.
Laboratory analyses indicate its quality as having high levels o~ dissolved
metals and ionic constituents (Feasibility Study Report, Lackawanna Site,
February, 1985).
The site is an abandoned municipal landfill located in a reclaimed
strip mine operation. Certain waste characteristics identified could be
reflective of either of these activities as weil as unpermitted disposal.
In an attempt to segregate these contaminations from the contaminants
related to the industrial waste disposal, a literature search was
performed to identify documented data relating to typical landfill
and anthracite coal/spoil characteristics. A detailed discussion of
the remedial investigation sampling results is described below.
-------
NOTE' THIS COLUMN COMPILED FROM LOGS OF TEST BORINGS, MONITORING WELLS AND BOREHOLE GEOPHYSICS.
LITHOLOGIES AND DESCRIPTIONS ARE A SUMMARY OF THE SEOUENCES ENCOUNTERED AND ARE AVERAGED
WHERE NECESSARY.
DIAMOND COAL AND MINE VOID. THICKNESS VARIES-7.5' TO 10'.
SHALE, DARK GRAY TOBLACK,COMMONLY HIGHLY FRACTURED OR
- , SUBSIDED. SANDY LENSES FREQUENT. THICKNESS VARIES
:_:'~ 4' TO 12'.
20 ~II~~
30 ~I~~~
40 ::~::::
~:~:~:~:~
50 j))~~~~~~
60 ~j!~!!!j!
70 {{j
80 ?L:'
90 ':'.':',',
~~~{
....
UJ
UJ
I.L.
r
....
a..
UJ
o
~z 120
..Jo
-'
~ 2: 130
1&J!5
jll.
150
160 ----
\t~\
170 }I~~
180. ~~f:
190 j~~~j~~
240 .
250
GROUND SURFACE
SHALE, GRAY , OCCASIONALLY SANDY.
FOUR FOOT COAL, 2.5' GRAY SHALE PARTING.
SHALE,GRAY, OCCASIONALLY SANDY,
SANDSTONE, MEDIUM GRAY, MEDIUM TO COARSE GRAINED, MICACEOUS,
PREDOMINANTLY MASSIVE, VERTICAL AND DIAGONAL FRACTURES
FREQUENT. SHALEY LENSES FREQUENT. THICKNESS VARIES-SO' TO 66'.
FRACTURE (TYPICAL)
SHALE, GRAy TO DARK GRAY, VERTICAL AND HIGH ANGLE FRACTURES
COMMON INCREASING DOWNWARD. SANDY LENSES OCCASIONAL.
THICKNESS VARIES 21' TO 32'. .
ROCK COAL AND MINE VOID. THICKNESS VARIES -3' TO 7' ,
SHALE,DARK GRAY TO BLACK, COMMONLY ABSENT OF FRACTURES.
THICKNESS RANGES 4' TO 8',
SANDSTONE, MEDIUM GRAY, MEDIUM TO COARSE GRAINED MICACEOUS,
PREDOMINANTLY MASSIVE, SHALEY LENSES OCCASIONAL,
SPARSE FRACTURES.
SHALE, GRAY TO DARK GRAY, WITH OCCASIONAL SANDY LENSES,
LOWER HALF VERY BROKEN AND FRACTURED.
BIG COAL AND MINE VOID.
SHALE,GRAY, FREQUENTLY SANDY.
-------
5
Air surveys. using direct-reading volatile hydrocarbon detectors. were
conducted during all field activities to detect volatile hydrocarbons. Each
area where drums had been located was inspected and scanned. There were
no readings above background in any of the areas. At various times during
field visits to the site. a sweet chemical-like aroma would be detected in
the vicin~ty_~f Pond No.1. The occurrence of the aroma was transient "and
seemed to be emanating from the surface soils. water. or mud adjacent to
the pond. This organic vapor could not be detected on the direct reading
instrumentation. Based on its persistence. EPA decided to perform a second
test pit program in an effort to identify the source and extent of contam-
ination. .
Eleven test pits were excavated adjacent to Ponds 1 and 2 and soil
samples at different depths were screened by gas chromatography for a
selection of samples to be sent to the Contract Laboratory Program for
Hazardous Substances List analysis. The screening showed tetrachloroethy-
lene and/or toluene in eight out of thirteen samples and methylene chloride
in all thirteen samples. Full analyses also indicated the presence of
methylene chloride in all samples. One test pit sample contained several
other commonly used industrial solvents including ethylbenzene, toluene,
xylene and 4-methyl-2-pentanone. Bis(2-ethyl hexyl) phthalate and PCB-1254
were also present. Another test pit sample contained numerous polynuclear
aromatic hydrocarbons as well as PCB-1254 (see Table 1).
A comparison of test pit inorganic results with background surface soil
samples shows one test pit to have elevated levels of chronium, copper, lead,
mercury, tin and zinc. Other test pit samples showed isolated instances of
higher than background surface soil metal concentrations, but no test pit
(other than TP20) had more than one metal above background (reference pg.
]-18 versus pg. 3-22'of "Remedial Investigation Report". Taylor Borough
Site, NUS Corp., May, 1985).
A total of 17 surface water and sediment samples were collected and
analyzed. Inorganic surface water results from onsite and offsite ponds
and St. John's creek were within EPA Primary Drinking Water Standards.
Concentrations of metals in all sediment samples (including downstream
samples) were similar when compared to a background (upstream) sample
in St. John's Creek.
Organic contamination of surface water and sediment samples was found
to be localized in Pond 1 and 2. Samples taken from these two ponds
showed similar organic constituents when compared to the test pit samples
(12D and 13E) from the adjacent former drum storage area. These ponds and
sediment are probably receiving runoff and occasional leachate from the.
former drum storage areas during periods of high rainfall.
-------
TABLE 1
TEST PIT ORGANIC RESULTS - MARCH 1985
TAYlOR BOROUGH SITE
~ CAS' Parameter
(38V) 100-41-4 ethylbenzene
(44V) 75-09-2 melhylene chloride
(86V) 108-88-3 toluene
108-10-1 4-methyl-2-pentanone
1330-20-7 total xylene
(39B) 206-44-0 fluoranthene
(668) 117-81-7 bls (2-ethylhexyl) phthalate
(728) 56-55-3 benzo (a)anthracene
(73B) 50-32-8 benzo (a)pyrene
(748) 205-99-2 benzo (b)fluorenthene
(768) 218-01-9 chrysene
(81B) 85-01-8 phenanthrene
~84B) 129-00-0 pyrene
(65A) 108-95-2 phenol
(91P) 57-74-9 chlorodane
(107P) 11097-69-1 PC8-1254
T8-TP TB-TP
12D 18E
C9680 ~
42
140 160
110
89
480
3,500
200
1.700
.Tolal of benzo(a) and benzo(k)fluoranthene'
Results are given In !lglleg,
Complete analysis for HSL organics was performed; only those compounds detected are shown.
Dash Indicates the parameter was not present above the detection limit,
The test pits presented here are localed adjacent to Ponds 1 and 2.
Sample Identification Number
TO-TP 'TO-TP TO-TP
17C 17D 20
Tra"lc Report Number
C9682 ~
~
110
66
180
40
TO-TP TO-TP
13E 19E
~ CA600
140 120
14,000
2,600
2,900
5.500.
5,400
6,000
2,000
45
-------
7
Table 2
Sample Means *
(mg/kg)
Background
Depression 2
Depression 3
Arsenic 7.3
Lead 20.2
* (Pg. 6-18 of Remedial Investigation)
17.2
77.7
7.3
370.
Conclusions
o Severely fractured rock is present beneath the site. The rock for-
mation has naturally-occuring fractures; however, as a result of the exten-
sive underground coal mining (8 seams), the fracturing is more extensive
than expected.
o Limited ground water flow enters the Diamond and Rock Coal strip mine
pit that was used in the landfill operation.
o Ground water flow is controlled by fractures, joints, abandoned
underground mine workings, and other mining related openings (for example»
boreholes, shafts, strip pits).
o A continuous ground water level is not present across the site.
Perched (localized pockets of water) water tables are present and have
developed from the extensive rehandling of the soil materials and rock
during the mining and landfill operations.
o Surface soils analysis indicated the presence of heavy metals in
Depressions No.2 and 3.
o Surface water analysis indicates the presence of limited volatile
organics and pesticides. These contaminants are primarily in Pond No.1.
o Sediment analysis indicated the presence of volatile organics and
PCBs primarily in Pond No.1.
o The area between Depressions No.2 and 3 still has crushed drums and
remnants that are on the surface and/or partially buried.
o Areas adjacent to Ponds Nos. 1 and 2 have drums protruding from the
slopes.
-------
8
Endangerment Assesment
The primary mechanisms for exposure to surface water and sediment-
bound contaminants is by direct skin contact which may occur with
occasional_~ccidental contact with contaminants by site trespassers. .
Ingestion of contaminated surface water or sediments although unlikely
is also a viable pathway. Toluene and carbon disulfide (detected in
Pond No.1) both have demonstrated mutagenic and reproductive. effects in
animal studies.
A discernable odor of volatile organic vapors persists within the
boundaries and adjacent to former drum storage areas Nos. 1 and 2. These
emmissions could constitute an inhalation threat to site trespassers.
Although the organic contaminants mentioned in the ground water have
toxic biological health effects associated with them (suspected human
and animal carcinogens with long term exposure), the risk of deleterious
health effects to any individual in the vicinity of the site from consump-
tion of the water is very minimal. Because of the general poor quality
of the ground water in the Lackawanna Valley from acid mine drainage and
hardness, which are distinct from any influence of the Taylor Borough
site, ground water is not used for consumption in the area. Consequently,
there is no known groundwater exposure pathway for the contaminants, nor
are there likely to be any in the future. The most likely pathway of
concern would be the discharge of the mine pool into the Lackawanna
River which is located four miles downstream from the site.
The major contaminant pathway of concern with surface soil contami-
nants would be direct contact to site trespassers and wildlife. There
was no indication of high arsenic and lead levels in ground water,
surface waters, and sediments. This would suggest that there is no signi~
ficant migration concern. Inhalation of dusts bearing lead at appreciable
. exposure levels also has a low probability of occurrence because of the
high degree of vegetative cover on the site which tends to minimize dust
generation.
Alternatives Evaluation
The major objectives for remedial action to be taken at the Taylor
Borough site is to mitigate or eliminate environmental contamination
through inhalation of organic vapors and direct contact with or ingestion
of contaminated soils, sediments, and surface water. The decision whether
remedial action is necessary for groundwater contamination (found in
well 3C) will be deferred pending further investigation, in order to
fully assess the nature of detected contamination.
-------
9
It is important to note that any remedial alternative proposed onsite
must consider the potential of subsidence. Mine subsidence, which resulted
from the underground mining of numerous coal seams, is evidenced by docu-
mented gradual and catastrophic changes to surface topography and structural
damage to buildings, roads, and utilities. A comprehensive study performed
by H.R.B. Singer (1975) classified the site to be within a "precautionary
area." This classification implies that future subsidence is probable {f
it has not yet progressed to completion. The report also predicted that
subsidences in the vicinity of the site could vary from 1.3 to 16.3 feet
from the pre-mining elevations.
In addition to mine subsidence, the site may incur other surface
disturbance problems because of the settlement of the municipal refuse.
Settlement will occur as a result of (1) physical changes to the fill caused
by biological and chemical action; (2) water percolating through the wastes;
and (3) the loading caused by the weight of subsequent layering of refuse
or cover material. Although all of these factors are time-dependent and
there is no information as to the amount of settlement and/or subsidence
which has occurred, it is safe to assume that the site will settle if a
site-specific remedial alternative requires additional fill material
placement.
The NCP specifies that remedial alternatives should be classified
either as source control (40 CFR 300.68(e)(2» or offsite (management of
migration) remedial actions (40 CFR 300.68(e)(3». Source control remedial
actions address situations in which hazardous substances remain at or near
the areas in which they were originally located and are not adequately
contained to prevent migration into the environment. Management of migration
remedial actions address situations in which the hazardous substances have
largely migrated from their original locations. Alternatives developed may
fall solely in either" classification or may involve a combination of source
control and management of migration. measures, as determined by the specific
site problems addressed.
In an effort to determine remedial alternatives for the subject site,
feasible technologies were identifed for consideration in each response
action (source "control and management of migration). Available "technologies
'were then scre~ned to eliminate ~ll but the most defiqitive and implementab1e
alternatives. This screening included: technical (site conditions or waste
characteristics), environmental and public health, institutional, performance
and cost criteria.
Certain response actions and technologies were not associated with any
specific remedial obejctive or feasible technology for the site. These
technologies and response actions and the rationale for not including them
are listed on Table 3. Further detail of this initial screening is included
in Section 2 of the Feasibility Study.
Those technologies that have passed the technology screening process
were used to form remedial alternatives. Remedial alternatives were devel-
oped using best engineering judgement to select a technology or groups of
technologies that best address the problems existing at the site to protect
public health and the environment.
-------
TABLE 3
Rationale for Eliminating
Various Technologies
Surface Water Controls
Rationale for Elimination
1. ditches
grading
dikes
- all, not directly associated
with a response action
Leachate/Ground Water Controls
1. Leachate Collection
2. Containment Barriers
3. Ground Water Pumping
- no visible leachate seeps
- limited lateral GW flow
- extensive fracturing of
bedrock
- pumping of mine pool may
increase subsidence
4. Subsurface Collection Drains
Direct Waste Treatment
3. Biological Treatment Methods
- did not exceed background
- low organic content in soils,
further disposal of inorganics
required, low levels of
organics in surface water,
need auxiliary fuel
- not useful for inorganic
destruction in soils
- Technologies are waste
specific-a sOil/garbage
matrix would be difficult
to treat.
1. Gaseous Waste Treatm~nt
2. Incineration of solids/liquids
4. Chemical Treatment Methods
-------
10
In order to study a range of responses, site remediation alternatives
that fall into one of five different categories are developed. These
categories are described below.
o No action:
No-action alternatives could include monitoring activities.
o Alternatives that meet the CERCLA goals of preventing or minimizing
present or future migration of hazardous substances and protecting human health
and the environment, but which do not attain all of the applicable or relevant
standards. (This category may include an alternative that closely approaches,
but does not meet) the level of protection provided by the applicable or '
relevant standards.)
o Alternatives that meet CERCLA goals and attain all applicable or
relevant Federal public health and environmental standards, guidance, and
advisories.
o Alternatives that exceed all applicable or relevant Federal public
health and environmental standards, guidance, and advisories.
o Alternatives specifying offsite storage, destruction, treatment, or
secure disposal of hazardous substances at a facility approved under the
Resource Conservation and Recovery Act (RCRA). Such a facility must also
be in compliance with all other applicable Environmental Protection Agency
(EPA) standards.
The evaluation criteria selected were: technical feasibility, public
health, environment, institutional evaluation, and cost effectiveness.
Particular emphasis was placed on:
- Technical Feasibility
- Performance
- Implementability
- Reliability
- Public Health Evaluation
o Reduction of Health Impacts
- Environmental Evaluation
o Reduction of environmental impacts
o Protection of Natural Resources
-------
11
- Institutional Evaluation
o Legal requirementst institutional requirements
o Community Impacts
- Cost Effectiveness
~ 0 Capital Costs
0- Operation and Maintenance
o Present Worth Values
o Sensitivity Analyses
Costs
Technologies remaining after the initial screening were combined in
logical groups called components in order to fit into the five different
categories mentioned above. These components were then combined to form
various remedial alternatives. These associated alternatives are listed
in Table 4 with associated costs.
Description of Remedial Alternatives
A.
No Action Alternative
Alternative No.1 -
No Action with Monitoring
Under the no action alternative, additional remedial activities would
not be performed. However, a long-term monitoring program would be esta-
blished to provide information on contaminant concentrations remaining
-and extent of potential migration. The monitoring program would include
ground water, surface water, sediment sampling, and respective analysis.
Ground water samples analyzed during the RI indicated that contamina-
tion was present in isolated wells at varying depths during one sampling
series. Analytical results from the second sampling series did not detect
the same contamination or sampling was not performed for specific wells
because of a lack of sufficient water volume in the wells. Existing and
two planned monitoring wells can be monitored to measure possible future
migration of contaminants resulting from either the mining operation,
landfill activities, or disposal of industrial wastes. Should significant
increases in concentration, contaminants detected and/or number of wells
indicating contamination occur, the site could be re-evaluated and remedial
actions could be implemented if necessary.
Surface waters and sediments from Pond Nos. 1 and 2 were found to be
contaminated and could pose a public health and environmental concern.
Sampling and analysis at both locations would identify any change to the
known contamination. .
Due to seasonal variations sampling and analysis should be conducted
on a quarterly basis for a period of 30 years. During this period, portions
of the program c~n be revised and eliminated based on new data. It is
recommended that ground water sampling not be eliminated.
-------
TABLE
4
CAPITAL AND PRESENT WORTH COSTS
REMEDIAL ACTION ALTERNATIVES
TAYLOR BOROUGH SITE
Costs
Present
Remedial Action Alternative Capital(1) Worth
1. No Action with Monitoring $ 16,000 . $1 ,402,000
*2. Partially Remove Contaminated 1 ,418 ,000 3,341,000
Materials, Dispose On Site, and Cover
with a Soil Cap
3. Same as NO.2 with Waste Stabilization 1,681,000 3,604,000
prior to disposal.
4. Same as No.2, Except Completely Remove 1 ,4 80, 000 3,403,000
Contamianted Materials
5. Same as No.4, with Waste Stabilization 2,002,000 3,925,000
prior to disposal
6. Partially Remove Contaminated Materials 1,835,000 3.758,000
Dispose On Site, and Cover with
Clay Cap
7. Same as No.6, except Completely Remove 1,897,000 3,820,000
Contaminated Materials
8. Cover Individual Contaminated Areas with 2,343,000 6,051,000
Clay Cap
9. Completely Remove Contaminated Material 12, 185, 000 14,296,000
and Dispose On Site in RCRA-Approved
Landfill
10. Drain and Treat Surface Waters, Backfill 47,029,000 48,594,000
Depression, and Cover Entire Site with
Clay Cap
-------
- - ----------=----- - - - - - i------------U--
TABLE 4
CAPITAl AND PRESENT WORTH COSTS
REMEDIAL ACTION ALTERNATIVES
TAYLOR BOROUGH SITE
PAGE TWO
Costs
Present
Remedial Action Alternative Capital(1) Worth
11. Partially Remove Contaminated Materials 5,612,000 6,998,000
and Dispose Offsite at RCRA-approved.
HWMF
12. Same as No.8 except Completely Remove 9,793,000 11 , 179 ,000
Contaminated Materials
13. Cover Area Bound by' Drum Storage Areas 4,237.000 5,764 ,000
3 and 6, Inclusive and Drum Storage
Area 4 with a Soil Cover
(1)
Costs presented are rounded to nearest $ 1 000 for comparison purposes.
Detailed cost breakdown is presented in Appendix B of Feasibility Study.
Alternatives 2 through 12 all include draining and treating collected waters
from Ponds No.1 and 2.
*
-------
12
Site monitoring (described above), the remediation of Ponds 1 and 2
and adjacent former surface drum storage areas (which is described below)
and removal of surface wastes (i.e., remnants and crushed drums) are
three components that are common to most of the following alternatives
unless specifically mentioned. Therefore, these components will not be
described 1~ detail with each alternative. .
- COMMON TO ALL ALTERNATIVES -
Drums Storage Areas 1 and 2, Including Ponds 1 and 2 (Figure 7)
Pond Nos. 1 and 2 are depressions or poorly drained areas that collect
water and act as seasonal ponds with fluctuating water levels. Pond No.2
was observed to dry up in the summer while Pond No.1 varies from 1 to 3
feet of water, depending on the season. The estimated volume of water to
be collected and eventually treated is approximately 191,200 gallons.
The amount of water that needs to be treated can be reduced by minimizing
surface water run-on and implementing this component of the remedial
alternative during dry periods of the year. The water will either be
pumped into an onsite activated carbon treatment system for subsequent
discharge into St. John's Creek or into a 5,000-gallon tank truck using
conventional pumps and transported to an offsite treatment facility.
The use of a mobile treatment unit onsite would require approximately 10
days of treatment of 40 gpm. The offsite treatment would require approxi-
mately 39 truck trips to dispose of the contaminated water.
Once the ponds are drained, the sediments will be excavated to
background levels from Pond Nos. 1 and 2 by conventional excavation
practices (bulldozer and loader). The ponds receive runoff from a five
acre vegetated/wooded area of the site. This results in low-sediment-
bearing runoff. Therefore, sediments will be removed to an estimated
dep~h of 2 feet, which totals about 1,100 cubic yards.
The materials (soils and wastes) in former Drum Storage Areas 1
and 2 would be excavated to background levels. The estimated areal and
vertical extent of contamination was confirmed by test pits and soil
sampling completed in March 1985. Quantity of materials to be excavated
was estimated to a depth of approximately 8 feet within an approxi-
mate 0.3 acre area (about 13,500 square feet) which would result in 4,000
cubic yards of material.
Ultimate disposal of all excavated materials (sediments, soils and
wastes) is described under each alternative. Following excavation of
these areas and the ponds, the areas will be backfilled and regraded to
promote proper surface runoff drainage. Depending on future use of the
area or need for the access road that separates Pond Nos. 1 and 2, the
area could be regraded with or without a culvert. In this alternative,
a culvert is assumed to be installed and the access road reconstructed.
This will prevent the future ponding of water in the area of Pond No. 1.
-------
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VEGETATED
LEGEND
rt9J.~)l.~K EXCAVATE SEDIMENT
WIIIIIIII/, BACKFILLED SOIL
_.',
PROPOSED DRAINAGE AND GRADING PLAN FOR POND Nos. I AND 2 AND ADJACENT AREAS
TAYLOR BOROUGH SITE, TAYLOR BOROUGH. PA
100 0
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SCAI,E IN FEET
,
100
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FIGURE 7
-------
13
Covering former drum storage areas Nos. 1 and 2 with soil was not
evaluated since this remedy would not be an effective source control
measure. Volatile organics in these areas would continue to emanate
through a permeable cover. These compounds also exhibit high soil
migration mobility in~ices (i.e. 4-methyl-2-pentanone and toluene
are considered to be very mobile while methylene chloride is extremely
mobile).
Capping these areas with clay was considered to be a reliable remedial
technology since it would reduce the potential for air emmissions as well
as infiltration of precipitation through contaminated materials. For the
clay cap to be effective. its integrity must be maintained. Therefore.
grouting of the mine voids beneath this area would be required to prevent
subsidence. Compliance with RCRA closure and post closure regulations
would also be required since above background levels of contamination
would be left on site. Based on the higher cost of implementing this
remedy and the fact that it does not substantially provide greater public
health or environmental protection. this remedy was not considered for
further detailed evaluation.
B. Alternatives that meet the objectives of CERCLA
Alternative No.2 - Partially Remove Contaminated Materials. Dispose On-
Site in Storage Area 6. and Cover. with a Soil Cap
In addition to excavated materials from former Drum Storage areas 1
and 2 and sediments from Ponds 1 and 2. the surface soils in an area
located southwest of former Drum Storage 6 will be excavated to a depth
of 2 feet. These soils were found to have the highest levels (370 ppm ave.)
of lead found during the RI surface soil sampling program. The excavation
depth is associated to the depth of the landfill cover placed over the
landfill wastes. Beneath this depth. landfill waste and/or a landfill/
soil matrix exist. The estimated excavation volume is 8.900 cubic yards.
Vertical excavation of surface soils (landfill cover) down to the
municipal waste interface may not constitute removal to background levels.
Migration of hazardous waste into the garbage would require removal of the
garbage. Should surface soil contamination due to unpermitted surface
disposal (i.e. leaking drums) be similar to contamination commonly found
in municipal waste. a distinct separation of RCRA Subtitle C (Hazardous)
and Subtitle D (Municipal) waste would be difficult to ascertain.
All of the excavated materials. approximately 14.000 cubic yards.
total, would be disposed in former Drum Storage Area 6. Excavated areas
and exposed garbage would be backfilled with local soils and mine spoil
to provide a cover for revegetation and minimize adverse environmental
concerns related to landfills.
A soil cap will be placed over the excavated material after it has
been deposited into former Prum Storage Area 6. The cap will consist of
a minimum of 24 inches of soil and/or mine spoil. Post closure maintenance
of the soil cover will be required. The objective of this cap is to
provide protection from direc~ contact exposure to the excavated material.
-------
14
Alternative No.3 - Partially Remove Contaminated Materials, Stabilize the
Materials, Dispose Onsite in Storage Area 6, and Cover with a S01l Cap.
This alternative is similar to Alternative No.2 with the addition of
stabilizing.Jhe sediments and waste materials. A binding agent, such as
cement, could.~e used to bind contaminated material in a stable, solid
mass. Furthermore, the wastes are rendered virtually.nonleachable. Based
on the available site data, approximately one cubic yard of cement would
be mixed with every 3 cubic yards of waste materials. This mixing could be
accomplished by pre-manufactured soil blenders, farm discs, or earth moving
equipment. For the partial removal alternative, the estimated volume of
stabilized waste material to be disposed would be 22,400 cubic yards; an
increase of approximately 5,600 cubic yards over non-stabilized partial
removal. The combined mixture would then be disposed and soil capped in
former Drum Area 6.
Alternative No.4 - Completely Remove Contaminated Materials, Dispose
Onsite in Storage Area 6, and Cover with a Soil Cap.
Complete removal includes all of the excavation described in Alter-
native No.2 with the addition of approximately 2 feet of cover material
being excavated from the former Drum Storage Areas 3 and 4, and the Removal
Staging Area. These additional areas were included based on being former
drum storage areas. Although surface soil sampling in these areas did
not indicate significant lev~ls of contamination which may have occurred
from spillage of unpermitted disposal activity, analyses did indicate
levels above background samples. The estimated volume of material to be
excavated is about 2,600 and 1,850 cubic yards, respectively. The depth
of excavation is again limited to the landfill cover above the municipal
garbage (as described in Alt. 2). The total volume of material to be
excavated for complete removal is estimated to be approximately 18,500
cubic yards. The additional excavated areas would also be backfilled 50
.that exposed refuse would be covered with local soils or mine spoil to
minimize adverse environmental concerns related to landfills and provide
a cover for revegetation.
Alternative No.5 - Completely Remove Contaminated Materials, Stabilize the
Materials, Dispose Onsite in Storage Area 6, and Cover with a Soil Cap
This Alternative is similar to Alternative 3, with the additional
areas described in Alternative 4. Based on this additional excavated
material, the estimated volume of stabilized waste material to be disposed
would be 40,000 cubic yards; an increase of approximately 10,000 cubic
yards over the non-stabilized complete removal.
Alternative No.6 - Partially Remove Contaminated Materials, Dispose Onsite
in Storage Area 6 and Cover with a Clay Cap
This alternative is identical to Alternative No.2 with the excep-
tion of placing a clay cap rather than a soil cover over disposed onsite
materials. This cap would consist of a proposed minimum 2 feet of com-
pacted clay material with a permeability of less than 1 x 10-7 cm/sec
placed across the surface of the deposited waste. This clay material
would have to be hauled in from offsite, since materials found onsite
-------
15
are not sufficiently impermeable. A 12-inch-thick drainage layer would
then be placed over the clay. This drainage layer would be composed of
sand and/or pea gravel, and have a minimum permeability of 10-3 cm/sec.
The drainage layer would be covered with a geotextile material acting as
a filter to minimize fine soil materials from clogging the drainage
layer. A minimum of 24 inches of soil would then be placed over the
clay to pro~ect the clay and to provide a root-growth zone.
Alternative No.7 - Completely Remove Contaminated Materials, Dispose
Onsite in Storage Area 6, and Cover with a Clay Cap
This Alternative is identical to Alternative 4 with the difference. of
placing a Clay Cap over disposed onsite materials instead of a soil
cover.
Alternative No. 11 - Partially Remove Contaminated Materials and Dispose
Offsite at RCRA-approved HWMF
This alternative is similar to Alternative No.2 with the exception
that contaminated sediments, soils, and crushed drums would be loaded
into 20 cubic yard trucks, and hauled to an offsite RCRA-approved Hazardous
Waste Management Facility (HWMF) for disposal. The estimated volume of
material to be disposed i~ approximately 16,800 cubic yards.
C.
Alternatives that Attain All Applicable Standards
Alternative No.8 - Cover Individual Contaminated Areas with a Clay Cap
This alternative entails draining and treating Ponds 1 and 2 which is
common to other althernatives but not excavating contaminated soils and
sediments in former drum storage areas 1 and 2, and within the ponds.
The strategy is to treat all of the former drum storage areas as individual
waste management areas. These would be covered with a clay cap and
monitoring wells would be placed outside but adjacent to each individual
area in an effort to monitor for post-closure migration.
Alternative No.9 - Completely Remove Contaminated Materials, Dispose
Onsite in a RCRA-Approved Landfill
A RCRA designed onsite landfill would be located on natural soils at
the south end of the site. Contaminated soils and materials from the
former drum storage areas (as described in Alt. No.4) as well as sediments
from Ponds 1 and 2 would be excavated and disposed in this landfill.
The landfill cap is the same as described under Alternative 6 with
the addition of a 30 mil synthetic liner between the clay and the drainage
layer. The bottom double liner is. a combination clay and synthetic
membrane liner. A leachate collection and removal system will collect
leachate generated during and after construction and store it in a 5000-
-------
16
gallon underground storage tank. Geotextile filter fabric would be placed
between the waste and the leachate collection zone to prevent clogging of
the collection zone by soil fines migrating with the leachate from the
waste. The primary liner is a minimum 30 mil synthetic membrane. The
leak detection zone is directly beneath the primary liner and monitors
the integrity of that liner. Both the leachate collection and the leak
detection zones will have a permeability> 10-4 cm/sec. The leak detection
zone will drain to the same SOOO-gallon underground storage tank as the
leachate collection zone.
The secondary liner is a composite liner of synthetic membrane and
clay. The synthetic membrane will also be a minimum thickness of 30 mil
and be placed over a 2 foot clay barrier.
Prior to construction of the landfill, all mine voids below the
landfill must be grouted closed to alleviate the potential for mine
subsidence. An eight foot base of clean fill would also be placed where
the onsite disposal facility is proposed to provide a barrier between
the landfill and the seasonal high water table. Associated with this
alternative is post closure groundwater monitoring.
Alternative No. 10 - Drain and Treat Surface Waters, Backfill Depressions,
and Cover Entire Site with a Clay Cap
The surface waters from the site will be drained and treated
depressions backfilled with local soil, and the site covered with a
clay cap. With the exception of the depres~ions, the cap will basically
follow the current slope of the site. St. John's Creek will be channeled
"through a 72-inch corrugated metal pipe culvert.
Because of the presence of garbage onsite, gas vents would be required
to dissipate the methane gases formed from anaerobic decomposition of
biodegradable organics. Two rows of gas vents will be required,. one row
in .each strip pit. They will be spa~ed on 100-foot centers and be con-
structed of 6-inch, perforated PVC pipe and gravel. To prevent gases
from escaping at the edge of the strip pit, a 4-inch-diameter perforated
PVC pipe will be installed in a gravel trench. Four-inch PVC risers
installed on 200-foot centers will vent gases from the trench to the
atmosphere.
Alternative No. 12 - Completely Remove Contaminated Materials and Dispose
Offsite at a RCRA-approved HWMF
This alternative is similar to Alternative No.4 with the exception
that contaminated sediments, soils, and crushed drums would be loaded
into 20-cubic yard trucks and hauled to an offsite RCRA approved Hazar-
dous Waste Management Facility. The estimated volume of material to be
disposed is approximately 30,000 cubic yards.
-------
17
Alternative No. 13 - Cover Area Bounded by former Drum Storage Areas 3
and 6 Inclusive, and Drum Storage Area 4 with a 50il Cover
. A soil cover will be placed over former Drum Storage Areas 3 and 6
and the entire area between the two. Initially, however, the depressions
will be filled in with local backfill or spoil. When needed, extra back-
fill will be brought in to provide for proper drainage. The existing
grade will 'be.used where possible. The soil cover will consist of a.
minimum of 1.5 feet of material with a with a final 6 inch layer of top-
soil. The cover would then be vegetated to prevent potential erosion
and sedimentation. A grass lined diversion ditch will be constructed
around the entire covered area to convey runoff and run-on away from
the area.
A methane gas generation survey will be performed during preliminary
design to evaluate the need for a gas venting system. If the rate of gas
generation is low, it would be less hazardous to allow the gas to permeate
through the soil cover versus a central collection and venting system. A
build up in concentration and pressure could result in an explosion or
fire. For costing purposes, a passive gas venting system has been incorpo-
rated into this alternative. Gas vents could be installed on 100-feet
centers to vent methane gas that is generated from the anaerobic degrada-
tion of solid waste (figure 8). Since this area will be final-graded to
a relatively flat condition, a chain link fence will be installed around
the perimeter to protect the soil cover from site trespassers. The
access road will also be relocated at the southern tip of the covered
area.
Former Drum Storage Area 4 will be backfilled with local fill or
spoil to a slope of 3:1 (horizontal:vertical) to provide for run-off.
The area will then be covered with a minimum of 1.5 feet of covered
material, 6 inches of topsoil, and vegetated. This cover will overlap
the top edge of the highwall by about 20 feet. The existing access
road will be relocated around the area at the bottom of the slope.
Figures 9 and 10 show a plan view and a cross-section, respectively, of
this area. A chain link fence will also be installed surrounding this
soil cover.
Common to most of the other alternatives, Remedial Action Alternative
No. 13 also includes site monitoring and remediation of former Drum Storage
Areas 1 and 2, including Ponds 1 and 2.
D.
Alternatives that Exceed All Applicable Standards
The complete removal of the entire landfill site (125 acres) was
screened out because there is no evidence that the entire landfill was
used for unpermitted hazardous waste disposal. The costs to excavate
6,100,000 cubic yards of predominantly municipal wastes and mine spoil,
dispose offsite in a permitted Hazardous Waste Management Facility (HWMF) ,
and then backfill the area would be in excess of 1.2 billion dollars.
Furthermore, based on known data, the result would provide no greater
benefit than excavating and/or covering the former drum storage areas
and sediments in Ponds 1 and 2.
-------
.
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AREA TO BE COVERED " .. ~ ':,' ,. '":,, ' .' . , ~;;;",.' r': ",: /"/
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ENU.!lUL
APPROXIMATE LIMITS OF SOIL COVER
TAYLOR BOROUGH SITE. TAYLOR BOROUGH, PA
SCALE: (=200'
200
r----
SCALE IN FEET
o
200
.
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FIGURE 9
SOIL ,COVER OVER AREA 4
TAYLOR BOROUGH SITE, TAYLOR BOROUGH, PA
SCAlE: 1"=200'
-------
A
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RELOCATED
[~E~S~~AD 1
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15.0'
96.0'
FIGURE 10
GENERALIZED CRa ECTI N A-AI
TAYLOR BOROUGH SITE. TAYLOR BOROUGH, PA
NOT TO SCALE
-------
1--.
Al
Costs (xl000)
. ternati ve/O:miponents . Cap. Present Public Health Environmental Technical
Considerations Considerations Considerations Other
. No Action with 16 1 ,400 Continued direct Low migration po- Two new wells needed Not acceptable
Monitoring contact exposure tential of exist- to supplement exist- tQ public
and inhalation to ing contamination ing wells. Source ,
site trespassers but direct contact of ground water co~-
of contaminents in and inhalation tamination will need
Ponds 1 and 2. from Pond 1 and 2 to be identified
sediments. and still remain. (mine spoil/municipal
surface soils. waste/industrial
disposal).
. Partial Removal, 1,418 3,341 Will prevent direct Does not totally Depth of excavation Does not com-
Dispose Onsite and contact with highly remove source of is limited to muni- ply with RCRA
Cover with a Soil contaminated mate- site contaminants. cipal garbage buried regulations-
Cap rial. beneath existing material not
soil/spoil cover. disposed in a
Depressions will double lined
require extensive facility.
quantity of back-
fill material.
. Same as Alt. 2 with 1,681 3.604 Same as 2 Leaching of conta- Performance of bind- Sames as 2
Stabilization of minated materials ing agent is depend-
Materials prior to will be greatly ent on percentage
Onsite Disposal red uced. and type of soil
bein2 mixed.
. Complete Removal. 1,408 3,403 Same as 2. Totally removes Same as 2 Same as 2
Disposal Onsite and Addresses all con- source of site Addresses
Cover with a Soil taminated areas contaminants. areas where
Cap found above back- concentrated
ground. disposal of
surface drums
had occurred.
1
i2
I
I
[
i3
I
,
4
-------
Alternative/Components
5.
Same as Alt. 4 with
Stabilization of
Materials prior to
Onsite Disposal
6.
Same as Alt. 2 but
Cover with a Clay
Cap.
7.
Same as Alt. 4 but
cover with a Clay
CaD
8.
Cover Individual
contaminated Areas
with a Clay Cap
9.
Complete Removal
and Dispose Onsite
in a RCRA Approved
Landfill.
10. Drain and Treat
Surface Waters,
Backfills Depress-
ions, Cover Entire
Site with a Clay
Cap
Costs (xlOOO)
Cap. Present
2,002
1,835
1,897
2,343
12, 185
.47,029
3,925
3,758
3,820
6,051
14,296
48,594
Public Health
Considerations
Same as 2.
Same as 2.
Same as 4.
Same.as 4.
Minimizes worker
exposure to con-
taminated ares.
Same as 4.
Sames as 4.
Environmental
Considerations
Same as 3.
Clay Cap would
reduce infiltra-
tion through
contaminated
materials.
Same' as 4 & 6.
Same as 6.
Provides greatest
onsite protection
against contami-
nated materials
Same as 6. No
additional hene-
fit wou ld be
realized.
Technical
Considerations
Same as 3.
Due to settlement/
subsidence potential
maintenance of clay
cap would be more
difficult than a
soil cover.
Same as 6.
Subsidence potential
would require grout-
ing of mine voids -
Higher cost.
Grouting of mine
seams may be diffi-
cult. Eight foot
base of clean fill
needed to avoid
seasonal high water
table.
Without grouting
mine voids and pre-
venting settlement
of garbage integrity
of cap is question-
able and will re-
quire maintenance.
Methane Gas vents
,.,,: 11 k,.,
;-.-, ,., 'J':.J 17' ,.-u,''''
Other
Same as 2.
Same as 2.
Same as 2.
Would meet
intent of RCRA
Will comply with
RCRA if success-
fully con-
structed
Would meet in-
tent of RCRA
-------
,
Costs (xlOOO)
Alternative/Components Cap. Present Public Health Environmental Technical
Considerations Considerations Considerations Other
11. Partial Removal, 5,612 6,998 Will eliminate Only risk would Depth of excava- Does not comply
Dispose Off site direct contact with be low but finite tion will be li~ited with RCRA since
at RCRA approved hi~hly contaminated probability of to municipal g,arbage all above back-
HWMF. materials. Poten- exposure in tran- buried beneath' ground surface
tial for accidental sit due to acci- existing soil/spoil soils are not
spill in transit. dent spill. cover. addressed.
12. Complete Removal, 9,793 11 ,179 Will eliminate. Same as II. Same as ll. Complies. with
Dispose Off site at direct contact with RCRA.
RCRA approved HWMF. a1l areas found
with contamination
above background.
13. Cover area Bounded 4,237 5,764 Same as 2 & 4. Proper grading and Same as 10 but re- Complies with
by Former Drum cover should re- habilitation of soil RCRA. Accept-
Areas 3 and 6, in- duce infiltration cover will be easier able to public.
clusive, and former through contami- than repairing clay/
Drum Storage Area 4. nated materials. synthetic cap.
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18
E.
Alternatives that Specify Offsite Disposal
Alternatives 11, 12, and 13 would comprise alternatives which fit into
this category.
Recommended Alternative
Section 300.68(j) of the National Contingency Plan (NCP) [47 FR
31180; July 16, 1982J states that the appropriate extent of remedy shall
be determined by the lead agency's selection of the remedial alternative
which the agency determines 15 cost-effective (i.e., the lowest cost
alternative that is technically feasible and reliable) and which effec- .
tively mitigates and minimizes damage to and provides adequate protection
of public health, welfare, and the environment. In selecting a remedial
alternative EPA considers all environmental laws that are applicable and
relevant. Based on the evaluation of the cost-effectiveness of each of
the proposed alternatives, the comments received from the public, informa-
tion from the Feasibility Study and information from the Pennsylvania
Department of Environmental Resources, we recommend Alternative No. 13 be
implemented at the Taylor Borough Site. This selected remedy will satisfy
all of the site surface contamination objectives identified in the Remedial
Investigation.
Specifically, drain~ng and treating contaminated surface water in
Ponds 1 and 2 will eliminate the direct contact and ingestion pathways.
Removal of contaminated sediments would also eliminate the threat of
direct contact exposure.
Excavation and offsite disposal of contaminated soils and waste
materials in former Drum Storage areas 1 and 2 will eliminate further
contamination of Ponds 1 and 2. Capping this area was determined to be
less cost effective;
The results of the surface soil investigation of former drum
storage areas did not find concentrated levels of contamination which
would indicate that severe drum spillage or bulk disposal of industrial
wastes had occurred, but did indicate above background levels. In order
to prevent direct contact with these areas and to minimize the transloca-
tion of low level contaminated surface soils where sample results indicate
higher than background levels, a soil cover will be installed. The soil
cover will provide an effective barrier for direct contact and with proper
grading will reduce the amount of infiltration caused by precipitation.
The final cover must have a permeability less than or equal to the perme-
ability of any bottom liner system or natural subsoils present. Based
on: (1) the low levels of contamination (both inorganic and organic)
found in the surface soils; (2) groundwater samples taken from the Rock.
Coal Seam which did not exceed primary inorganic maximum contaminant
levels; and (3) organic compound mobility indices, it is not felt that
surface soil contamination will have an adverse impact on the mine pool.
-------
19
Upon completion of the recommended remedial actions, future land
use activities should be restricted so as not to result in damage to or
removal of the soil cover, gas vents (if installed), and other structures
necessary to ensure long-term integrity and effectiveness of the remedial
response.
It is further recommended that a selection of remedial response
measures, if any, for contaminated groundwater be deferred. Additional
studies will be conducted to determine if remedial action is required.
Operation and Maintenance
Monitoring and Post-Closure. Maintenance activities are required to
verify the site cleanup, effectively maintain permanent onsite actions,
and monitor potential contaminant migration. Sampling of surface water
and sediments in St. Johns Creek and Ponds 1 and 2 should be performed
for at least five years on an annual basis to verify respectively that
contaminants either are not migrating or have been removed. These samples
will be analyzed for Hazardous Substance List (HSL) parameters. Should
Ponds 1 and 2 be eliminated by not restoring the access road, surface
water sampling would only be required for St. John's Creek.
Closure and Post Closure care will comply with RCRA Subpart G. (which
includes the closure performance standard) and also section 264.310. A
groundwater monitoring program will be developed during design only for
the soil covered waste management areas.
Toe soil cover will be effective as long as it is not disturbed.
Post-closure inspection and maintenance is required to restore and
rehabilitate the soil cover should subsidence or differential settlement
occur. Routine vegetative cover regrading and reseeding would also be
required to ensure the integrity of the cover.
All operation and maintenance requirements will be the responsibility
of the State of Pennsylvania one year subsequent to completion of
construction.
The long-term groundwater monitoring segment for the entire site (as
described under the "No Action-with Monitoring" alternative) will not be
implemented at this time. Specific groundwater monitoring requirements
will be proposed upon completion of additional study.
Evaluation of Alternatives Not Selected
The No-Action with Monitoring alternative was not selected since
residual surface soil, sediment, and surface water contamination will
continue to pose a direct contact threat to human health and the environ-
ment. The odors emanating from Ponds 1 and 2 also would persist, causing
a localized inhalation concern to site trespassers.
-------
20
Alternatives 2, 4, 6, and 7 all have a common implementation problem.
Once contaminated materials are excavated, these materials, in order to
comply with RCRA, must be deposited in a secure, "double lined" land
disposal facility. Disposal of contaminated materials under these alterna-
tives is accomplished by simply placing the contaminated materials in an
onsite depression without any bottom liner( s).
Alternatives 3 and 5, which propose stabilization of contaminated
materials, were not selected since this treatment method would require
that testing procedures, treatment methodologies, and final properties
of the ultimate material be proven reliable and effective. Waste charac-
terization, compatability with other waste materials, physical properties,
and leachability of the stabilized wastes would require detailed treata-
bility study and lengthy testing in order to demonstrate whether this
alternative could be acceptably implemented.
Alternative 8 was not selected since it does not effectively remediate
former drum storage Areas 1 and 2. Covering these two areas with a clay
cap will require grouting of mine voids to ensure cracking due to potential
subsidence. Grading and backfilling would be required to divert site
runoff from coming in contact and ponding against the cap. These added
costs would make this alternative less cost effective than the selected
alternative.
Alternative 10 was not chosen since it was not established that the
entire 125 acre site warranted remedial action. Surface sampling and
subsurface investigations did not indicate remedial action was needed for
the majority of the site. This alternative was less cost effective by
an order of magnitude than the selected alternative.
Alternative 11 was not selected based on not addressing above back-
ground levels of inorganics in the surface soils. These areas were not
proposed to be covered or excavated.
Alternatives 9 and 12 both would achieve the same level of cleanup
as the recommended alternative but were more expensive to construct and
implement. Thus, these two alternatives are less cost effective.
Consistency with Other Environmental Laws
EPA is currently proposing regulation requiring the agency to
select a remedial Superfund remedy which "... attains or exceeds applicable
or relevant Federal public health or environmental standards~" See
proposed 40 C.F.R. ~300.68(f).
-------
~
21
Environmental laws which may be applicable or relevant to remedial
activity are:
- National Environmental Policy Act (NEPA)
- Clean Air Act (CAA)
- Clean-Water Act (CWA)
- Safe Drinking Water Act (SDWA)
- Resource Conservation and Recovery Act (RCRA)
- Pennsylvania Clean Streams Act
- Toxic Substances Control Act (TSCA)
This alternative meets NEPA functional equivalency exception because
the necessary and appropriate investigation and analysis of environmental
factors as they specifically relate to the Taylor Borough Site and the
recommended alternative were considered and evaluated in the Remedial
Investigation and Feasibility Study. In addition, a meaningful opportunity
for public comment on environmental issues was provided before the final
selection of the remedial alternative was made.
Compliance with all applicable substantive requirements of the CWA
and CAA as well as the Pennsylvania Clean Streams Act will be incorporated
into the design of the remedial alternatives. Any discharge into the
atmosphere of ~as from the excavation of former drums storage areas 1 and
2 will be monitored and treated as necessary. All state permits for
discharge of treated surface water will be acquired and complied with as
necessary.
The soil cover placed over former drum storage areas 3, 4, and 6
and the area between 3 and 6 shall be designed to meet EPA's engineering
specifications for constructing the RCRA cover required by 40 C.F.R.
~264.310. Ground water monitoring shall be developed during design to
satisfy the requirements ~264 Subpart F.
Excavation of contaminated materials and sediments in former drum
storage areas 1 and '2 will be removed to background levels which will
~ eliminate the need for ~.RCRA cover and post closure requirements for rand
disposal at these locations and also comply with TSCA.
Further investigations of ground water was elected to satisfy the
requirements of RCRA Part 264 Subpart F. Organic contamination was
detected in monitoring well 3C. RCRA Part 264 Subpart F would require
further investigation as to the nature, source, and extent of this
contamination. Additional study work will determine the need as to
whether Subpart F will be implemented.
-------
SUBJECT:
FROM:
TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
841 Chestnut Building
Philadelphia. Pennsylvania 19107
Poss4ble Public Health Hazards at the
Taylor Borough Site
Dick Brunker, Toxicologist (3HW23)~
Site Investigation and Support ~
DATE: JUN! 8 1985
Joe Dugandzic, Environmental Engineer
Site Response Section (3HW2l)
Levels of soil contaminants reported at this site are, in general,
typical of those found at municipal landfills. There are no data
citations that indicate the presence of substances that are particularly
outstanding or alarming nor is there any reasonable scenario that
could establish a linkage to human or ecological receptors that would
justify any remedial measures that should extend beyond those designed
to minimize the translocation of contaminated soils. Such measures
should be limited to those that would stabilize this site and should
include the elimination of occasional ponds and the integration of
the drainage patterns of the site into the watershed in a manner that
would minimize or eliminate the movement and impact of surfical
sediments on the local ecology.
The area that emanates the odor of volatile organic compounds or
similar odors is the cause of some concern. Although the precise
chemical nature of these odors is not known, past reports of detectable
levels of airborn carcinogens such as tetrachloroethylene and methylene
chloride as well as other volatile organic compounds could indicate
the presence of a conceivable hazard to individuals who trespass into the
area. It is recommended that measures be taken to remediate the emanation
of these vapors from this area. The protection of workers concerned
with this remediation is also recommended.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
841 Chestnut Building
Philadelphia. Pennsylvania 19107
SUBJECT: RCRA Review of Taylor Borough
Draft Feasibility Study
FROM:
Gary Molchan, Environmental
MD/DE/DC Section (3HW32)
Eng(~ni\~(
1..1 ' .
/
DATE.:J UN 19 1985
THRU:
Thomas Voltaggio, Chief
Superfund Brapch (3HW20)
/. /' ..~. .
-" '" --,',,:,,'.:.~.-:' ..t:. ..JI"'.-''---.. .
Patrick'" R-. A'nde-rson,- Acting Chief
Waste Management Branch (3HW30)
TO:
Attached you will find the RCRA review of the alterna-
tives proposed by NUS for the-Taylor Borough Superfund Site.
This report was developed to determine if outlined Remedial
Alternatives (RA) meet the provisions of the RCRA regulations.
The site's geologic and hydrologic conditions severly limit
the alternatives available. This is evidenced by the informa-
tion contained in Sections 2, 4, and 5 of the RI.
The attached table compares Superfund alternatives to
proposed Remedial Actions. Each of these alternatives lacks,
the sufficient background information necessary to make a
determination regarding the ability of the alternatives to
meet the provisions of RCRA. Development of a dynamic ground
water monitoring program that will identify the release of
hazardous constituents into the ground water must be undertaken
in order to comply with the provisions of RCRA in the event
that CERCLA chooses to allow hazardous constituents to remain
on site. Determination of the degree of contamination that
exists in the soils should accompany any action prior to
development of a dynamic ground water monitoring program. This
may be accomplished by evaluating remaining soil samples for
hazardous constituents at the base of the units after the con-
taminated soil has been removed to determine the depth and
lateral migration of contamination. Proper RCRA closure of
the facility must also include a cover with a permeability
less than or equal to the permeability of the natural subsoil
present with assurances for long term stability.
-------
Remedial Actions
No Removal of Soil*
Partial Removal*
Complete Removal**
,Di spose- On-s i te
Soil Cover
RCRA Cover
Stabilize
RCRA Landfill
Dispose Off~site
RCRA Landfill
Table 1
CERCLA ALTERNATIVES
1 2 3 4 5 6 7 8 9 10 11 12 13
x x x x
x x x x x
x x x X
x x x x x
x x x x
-
x x
x
x x
. *A dynamic ground water monitoring program must be developed in order to
implement these alternatives.
**A scientific determination of the excavation limits due to background
must be identified in order to implement these alternatives.
-------
RCRA Review of the Feasibility Study of Alternatives for
the Taylor Borough Site, Lackawanna County, Pennsylvania
Ground Water Monitoring
These alternatives propose a long-term monitoring program
to provide information on the migration of contaminants. Fig-
ure 2-2 of the FS identifies approximate limits of complete
removal of soil and drums from the site. These areas, eight
(8) in total, could each be considered a waste management unit.
subject to the monitoring requirements of RCRA in the event that
clean closure is not possible. Hypothetically, the eight units
identified could be consolidated into 1 waste manag~ment area;
the area must however be monitored according to its final
disposition. Complete removal requires testing of the soil to
certify that background has been achieved. This would eliminate
the monitoring requirement and allow clean closure.
The complex natural geology, strip mine activities, deep
mine activities, landfill area, and subsequent development
along the perimeter make the conditions for monitoring and
identifying hazardous constituents and their projected locations
of origin very difficult. Development of a monitoring program
may be undertaken to identify the hazardous constituents that
exist in the vadose zone, saturated zone, deep rock formations.,
and mine pool. All of these monitoring alternatives must incor-
porate a dynamic philosophy as the RCRA ground water monitoring
regulations do not ideally fit the conditions of this site.
Further, in the event that a dynamic ground water monitoring
program is developed that satisfies the RCRA requirements,
serious consideration should be given to the validity of the
data that will be provided in determining the origin of the
pollutants and their rate and extent of migration in the uncon-
solidated soil and ultimately their potential disposition in
the mine pool.
Therefore, in order to clearly meet the ground water
protection standard of S264.92, a strategy must be developed
to clearly delineate the hazardous constituents previously
identified in Section 3 of the FS in lieu of Appendix VIII as
identified in S264.93, the concentration limits of S264.94, and
the point of compliance in S264.95. Only then can a corrective
action program be developed according to S264.100 incorporating
the ground water monitoring requirements of S264.97 that will
monitor the constituents that exceed the respective concentration
limits, the rate and extent of the migration and the ground water
flow rate and direction.
-------
Closure
The closure options available at the waste management units
are identified in S264.l78, S264.228 and S264.258. In the event
that after removing all residues and making all reasonable
efforts to"effect removal of contamina ted subsoils, one finds
that not all contaminated subsoils can be removed practically,
the units must be closed as a landfill under S264.3l0. In
this event, ground water monitoring would be required and a
program to identify contaminant levels prior to a corrective
action plan being implemented should be developed.
Also Section 4, pages 4-5 through 4-8, of the RI clearly
identifies areas of high magnetic intensity creating anomalies
5% above background base levels of 56,000 gammas. None of the
test pits were in these areas of higher magnetic intensity; they
are on the perimeter. Therefore, the potential of additional
buried drums is a problem that should be addressed. Additional
studies should be completed before the alternatives proposed can
be determined technically sound.
Identification of background constitutents is necessary
prior to taking any action at the site in order to identify
the increasing levels or decreasing levels of pollution and
the resulting effects due to releases of waste constituents
presently traveling toward the point of compliance.
Remaining containers, liquids, liners, bases and soil
containing or contaminated with hazardous waste or hazardous
waste residuals must identify a testing procedure and protocol
to identify the hazardous constituents in the soil, removal
standards to attain the closure performance standard in
S264.lll and identification of background limits. The separa-
tion between hazardous waste and municipal waste is difficult
to ascertain; however, this separation must be clear and
consistent in this and all future applications of hazardous
and non-hazardous waste coexisting in waste management units
for which Feasibility Studies are completed.
In the Feasibility Study Report Section 3.3.2, excavation
in drum storage areas 1, 2 and 6 including ponds 1 and 2, must
identify a testing procedure whereby excavation and removal
will cease. Identification of a depth of approximately 8' is
inappropriate. .
-------
Composite samples of the soil and testing of these samples
to determine the toxicity thru extraction (EP toxicity) will
clarify the question that has arisen regarding the mobility of
the inorganic and organic hazardous constituents in the 'soil
and solid waste. Due to the lack of this information, the
proposed alternatives are presently not complying with the
closure-r~quirements of S264.178, S264.228, and S264.258.
In 3.3~4, the alternative of excavating contaminated soil
and depositing this soil on-site in an unlined land disposal
unit is unacceptable. Once excavated, the contaminated soils,
sediments, and wastes must be deposited off-site in a RCRA
approved landfill.
Stabilitzation thru excavation and treatment (use of a
bonding agent) or in-situ treatment is an alternative that
requires approval of the testing procedures, treatment method-
ology and final properties of the ultimate material. The
characterization, compatibitty, physical properties and leacha-
bility of the stabilized wastes are not provided. In the event
that this alternative is pursued, procedures and information
necessary to comply with RCRA are outlined in the Guide to
Disposal of Chemically Stabilized and Solidified Waste (SW-872).
Anyon-site construction of a RCRA facility may not be
possible due to the present siting criteria which restricts
construction due to site characterization. High hazard and
unstable terrain, and ground water monitoribility, are two
items that have not been fully addressed.
Cover
The strip mine operation and deep mining of coal both con-
tribute to undermine the foundations that would be necessary
for construction of a '264' landfill. Clearly, the technical
standards could not be met because of subsidence potential which
effects the integrity of the bottom liner and RCRA cap. In
addition, the location of the deep mines have not been identified
and superimposed over the strip mined area to clearly delineate
areas where subsidence will not occur. As a result, in order
to close the facility properly, the cover material must have a
permeability less than or equal to the permeability of the
natural subsoils present. In 3.3.3, any cap of the areas, in
question must conform to S264.301. Use of the soil cover must
have a permeability less than or equal to the natural subsoil,
not the unnatural mine spoil.
-------
Subsidence due to failure of the deep mines must be
addressed in the development of the soil caps. Continual
maintenance must be required in the event that the subsidenge
monitoring program that will be developed to identify the
occurrence of subsidence shows failure. In the event that_the
alternative to grout the deep mine is chosen, the areas to be
grouted, the methodology and success of the program must be
identified prior to implementing the balance of the recommendation.
Conclusion
The recommended actions do not presently comply with the
RCRA regulations due to the man-made alterations at the site
that limit the alternatives that are presently proposed. The
unconsolidated deposits have been extensively altered by strip
mining activitiy, which mixed the natural soil, mine spoil,
and landfill debris. Above and below the coal seams, rock has
been extensively fractured, and in some cases, has subsided
due to the deep mining activities in the Diamond, Rock and Big
Coal mines. The site's geologic and hydrologic conditions
severely limit the -Remedial Actions Alternatives available;
this is evidenced by Sections 2, 4 and 5 of the Remedial
Investigation.
It would appear that alternatives 12 and 13 may be able to
maet the provisions of RCRA with additional work being required
prior to that determination.
1.
Monitoiing of ground water in this regime. would
require a dynamic.ground water monitoring program.
A dynamic ground water monitoring program must be
developed, and evaluated to ensure that it has a
high degree of success, prior to any alternative
implementation. .
2.
Determination of the limits of contamination must be
completed. A vertical and horizontal limit of
excavation must exist in order to determine the
extent of excavation to allow for clean closure
with no ground water monitoring.
3.
Subsidence is a major concern at this site. This
may be addressed through successfully grouting the
deep mines, developing a monitoring and maintenance
program to determine the degree of subsidence. and
projected repair and maintenance to the RCRA cover
and ground water and subsidence monitoring systems.
-------
Taylor Borough Responsiveness Summary
June, 1985
Located-ln-Taylor Borough, Lackawanna County, Pennsylvania, the
Taylor Borough Superfund Site is an abandoned municipal landfill situated
in a reclaimed strip mined area. The site extends several miles northeast-
southwest along Bald Mountain, a wooded ridge used for hunting and other
recreational activities. Approximately 1,000 residents live within a one
mile radius of the site. A recreational area, known as McDade Park, borders
the site to the northeast, and a residential development borders the south
end of the site. Land surrounding the site is used mostly for recreational
and residential purposes. McDade Park is maintained by Lackawanna County
and contains a small museum, a swimming pool, and several picnic areas.
The Taylor Boro site is part of the Lackawanna River Valley, large portions
of which are reclaimed strip mines now experiencing residential and light
industrial development.
In the early 1980's, the surrounding community became highly interested
in the Taylor Borough Site. The area surro~nding the site contains several
landfills located in Taylor Borough, and in the adjoining town of Old Forge.
Three of the landfills are on the Superfund List. The Taylor community is
very concerned about the impact that these sites will have on their health,
environment, and future generations. As a result of the number of landfills
~nd Superfund Sites in their area, the Taylor Borough residents want a
health study performed in Lackawanna County. This has been a continuing
concern of the residents, since the Pennsylvania Department of Environmental
Resources performed the site's first investigation in June, 1981.
In May 1982, EPA began a Field Investigation at the Taylor Borough
Site~ At that time a group of citizens who lived closest to the site
formed the Taylor NeighbQrhood Association. The Hazardous Ranking Score
(HRS) for the site did not make it eligible for inclusion on the National
Priorities List in July, 1982. The group urged other Taylor residents
to send letters to EPA Headquarters in Washington, DC, requesting that
the site be re-evaluated. After additional documentation from PADER
indicating larger quantities of potentially hazardous substances have been
dumped at the site, the HRS score was revised. In August, 1983, a brush
fire occurred at the Taylor Borough Site. The spilled contents of some of
the drums oneite burned, and local officials received numerous calls from
residents complaining of dizziness, severe headaches, and skin and eye
irritation. The Taylor Borough Site was placed on the National Priorities
List in September 1983.
In November 1983, 1200 drums and their contents were removed from the
site, under an immediate removal action. In addition to the drum removal,
security gates were erected at the site access roads to prevent vehicular
traffic from entering the site. However, the site is still accessible by
foot or cycle. In March, 1984, a remedial investigation began at the site.
-------
- 2 -
The citizen's group keeps in contact with the EPA Regional Office and
has requested copies of EPA documents for the Taylor Site. EPA responded
to this request by sending copies of the RI/FS reports to the group, and
also a copy to the Borough Administrator, on May 21, 1985. The official
repository 18 at the Taylor Borough Hall. In addition to the RI/FS
reports, sample results during the remedial investigation were shown to
the Taylor Neighborhood Association and to local officials.
In an effort to elicit citizen input during the remedial investigation
stage of the project, the EPA Community Relations Coordinator and the Remedial
Project Manager met with local citizens in their homes to answe.r questions
and to review and explain sample results. This opportunity was also
extended to the Borough Administrator. When the local officials were
questioned by residents about the progress of work at the site, EPA was
contacted and the local officials received a complete update. Each time,
before work began at the site, EPA contacted the Chairperson of the
Taylor Neighborhood Association and the local officials, in an effort to
keep the community informed. Press interest was not high at the Taylor
site, but citizens and the local officials showed a high level of concern
during all stages of the project. .
On Tuesday, June 4, 1985, a public meeting was held at the Taylor
Borough Hall to acquaint the residents with the EPA and PADER recommended
clean up alternative- for the site. This alternative is the cost-effective
and environmentally sound solution, which proposes to:
o Remove and dispos~ of approximately 125 crushed and intact drums
and remnants remaining on the surface or partially buried.
o Drain and treat surface water in ponds 1 and 2 and excavate soil
and sediments from former drum storage areas 1 and 2 and both ponds, then
properly dispose off site.
o Place a minimum 2~ inch soil cover over: (a) drum storage areas 3
and 6 and the entire area in between, and (b) drum storage area 4.
~.~.
The purpose of the meeting was to provide information to the_public
concerning field work during the remedial investigation; to inform the
public of the various proposed remedial cleanup alternatives; and to afford
the public the opportunity to comment on the recommended cleanup alternative.
Public notice of the meeting was made by sending a press release to
all newspapers, radio stations and television stations in the'Scranton/
Wilkes-Barre area. The Chairperson of the Taylor Neighborhood Association
was contacted, as well as the Taylor Borough Administrator. The. Remedial
Investigation Report and the Feasibility Study were placed in the repository
and sent to the citizen group two weeks prior to the public meeting. The
public comment period was open until June 14, 1985. About 30 residents
and local officials attended the public meeting. One radio station, one
television' station, and one newspaper was represented at the meeting. The
Remedial Project Manager discussed what work was done at the site since
March 1984, and then annoQnced the preferred cleanup alternative. Before
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- 3 -
the meeting, the site's EPA Community Relations Coordinator distributed
fact sheets to the attendees. The fact sheets detailed the history and
status of work at the site, and listed the recommended cleanup alternative.
Included with the fact sheet were two site maps. The Remedial Project
Manager showed slides of the site maps as he described the Remedial
Investigation and cleanup alternative~
The Taylor Neighborhood Association, interested residents,
representatives of potentially resposible parties, local officials. and
EPA and PADER representatives attended the meeting.
EPA has incorporated the comments received from the public during the
comment period into the Taylor Borough site Record of Decision. The
majority of concerns and comments received by EPA from the community
were in favor of having a health study conducted in Lackawanna County.
The residents asked that Taylor Borough and neighboring Old Forge Borough
be considered for a health study because four Superfund sites exist in
the two towns. EPA Community Relations Coordinator contacted the CDC
representative who in turn contacted the Pennsylvania Health Department.
EPA explained to a resident who called after the meeting that CDC will
not do a health study in an area unless the State Health Department
requests that such a survey be done. The name and address of a doctor
who chairs a state environmental committee was given to the caller.
This health study request is the primary concern of the citizens group
and other residents in the area.
Another concern is future use of the site. EPA explained that deed
restrictions and zoning laws can only be instituted by the local governing
body. The landowners 'can also place deed restrictions on the land.
The citizens accepted our cleanup method, without any objections,
but they were concerned about the health and welfare of the residents
while work was being conducted onsite. EPA explained that during the
design stage of the project, Site Specific Health and Safety Plans will
be developed. EPA went on to explain that during the design stage, local
fire companies and local and county emergency services will be contacted
and updated by EPA and the Army Corps of Engineers. The Coordinator of
the Taylar Borough Emergency Management Agency explained that an evacuation
plan is already prepared.
Another major concern of the citizens was an unidentifiable odor in a
specific area of the Taylor Borough Site. In response, EPA took samples at
that location during the Remedial Investigation, and did further test pit
investigation in an effort to determine the source of the odor. The area is
being addressed in EPA's recommended cleanup alternative, through excavation
down to natural soils, and offsite disposal of the contaminated soil. . This
effort will eliminate contamination and either reduce or eradicate the odor.
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- 4 -
The original public comment period for the Taylor feasibility study
lasted from May 23 thru June 14, 1985. At the request of the potentially
responsible parties, the comment period was extended to June 21, 1985.
By June 14, EPA received one comment, from a potentially responsible
party. During the week of June 17, EPA received a letter signed by
two residents of Taylor Borough, one letter from the Taylor Borough
Council, a l~tter from the Taylor Borough Emergency Management Agency
and one letter from a potentially resposible party. The residents
had five comments, which were answered as follows:
1. Comment:
Courthouse.
Land use restrictions should be recorded in the Scranton
Answer: This issue has been addressed in the Record of Decision,
under the heading Recommended Alternative. See page 18 in the Record of
Decision.
2. Comment:
made public.
Site monitoring should continue, and results should be
Answer: Under the heading Operations and Maintenance, in the
Record of Decision, a minimum of 5 years of surface water and sediment
sampling is recommended. Groundwater monitoring requirements will be
addressed in a later study. See page 21 in the Record of Decision.
3. Comment: Cover material used during the cleanup project should
not be from another dumpsite.
Answer:
Taylor Site.
Fill material will be tested before it is used at the
4.
Comment:
Site specific fireflghting plans should be developed.
Answer: Taylor Borough Emergency Management Agency is accepting
calls regarding specific training for firefighters. The Remedial Project
Manager will address this issue and meet with the Borough Agency during
the project design stage.
5. Comment: Efforts are continuing to have a health study conducted
in Lackawanna County.
/
Answer: All requests for a health study are being referred to
the Pennsylvania State Health Department. In response to this request,
a contact name and address has been given to each citizen.
The Taylor Borough Emergency Management Agency commented favorably on
the Preferred Remedial Alternative that was announced at the June 4
meeting. They also noted that any questions regarding training for
firefighters in the Borough be referred to them.
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- 5 -
A site specific evacuation plan for the Taylor Borough Superfund
Site has been developed by the Borough Emergency Management Agency.
Members of the Agency will meet with EPA personnel and EPA's contractor
during the design stage of the project to discuss the Site Specific
evacuation plans
The Taylor Borough Council commented in writing' on the Feasibility
Study. They stated their position that all high concentrations of hazardous
substances be thoroughly removed from the site. Council also requ~sted
that specific security measures be taken; specifically, fencing each
individual area once the cleanup is complete, and erecting warning signs
in an effort to keep trespasses from crossing over the areas and possibly.
destroying the soil cap.
Borough Council also informed EPA that no plans are underway to
construct a child's play area adjacent to the site.
Taylor Borough Council is also working to get a health study conducted
in Lackawanna County, and has asked EPA for assistance in this matter. EPA
sent Council the address and name of a doctor at the Pennsylvania Department
of Health, who could present their request to the Department's Environmental
Council. .
In response to verbal requests from the citizens, EPA will hold a public
meeting to discuss details of the cleanup, once the design stage is complete.
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- 6 -
Comments by the Potentially Responsible Parties ("PRPs")
PRPs submitted written comments on the preferred alternative
three separate occasions. All comments were made through the PRP
Committee, which represents several generator companies which EPA
to the Taylor Site. The three submissions were as follows:
on
Steering
has linked
1)
6-10-85 :
An initial contemplated alternative in
EPA's preferred alternative No. 13, in
a request to extend the public comment
July 30, 1985;
response to
addition to
period to
2)
6-14-85 :
Comments on EPA's Draft Remedial Investigation and
Feasibility Study ("RIfFS"), including:
a)
The PRP's version of the Hazard Ranking System Score
based 00 the data and ocnclusions of the draft RI and
FS reports; .
b)
A summary of the activities at the Taylor Borough Site
and Analysis of RIfFS findings;
c)
A Summary Table showing raw wastewater toxic pollutants
from coal mining operations;
d)
Detailed technical comments on EPA's preferred alternative
No. 13; and
3)
6-21-85:
Revisions and Supplemental information to the PRP proposed
remedial alternative of 6-10-85.
The specific comments of the PRPs will be set forth below, along with EPA's
response. Additionally, EPA considered the PRPs request to extend the public
comment period to July 30, 1985, and on June 14 we partially granted this
request, allowing ~ne additional week of comment period to June 21, 1985. As
set forth above, additional PRP comments were. received on June 21. EPA
believes that an extension beyond this time is not necessary, since the
PRPs have been fully involved in all aspects of the on~site Remedial Investigation
since March 1984, they received the bulk of the technical data collected
concerning the site by March 1985, and their representatives met with EPA
in early Hay 1985 to present information for EPA's inclusion in the Remedial
Investigation. The involvement of the PRPs included meetings with EPA in 1984 to
critique details of EPA's proposed investigation of the site. In response to
these meetings with the PRP's, EPA did make revisions in the planned
investigatory work at the site. Based on this extensive participation, EPA
believes that it has given the PRPs an adequate opportunity to review information
concerning the site, and to present comments to EPA. Nevertheless, we did allow
them an additional week in the event they had comments beyond their detailed
submission of June 14.
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Comment #1:
Answer:
Comment 82:
- 7 -
Remaining materials in Drum Area Nos. 1 and 2 are not
hazardous wastes. Test pit logs indicate they are primarily
a mixture of garbage. soils. mining overburden and -
miscellaneous rubble and construction debris (typical of a
sanitary landfill). (from 6-21-85 letter)
EPA agrees that the remaining materials are not hazardous
wastes. However. the materials contain elevated levels of
hazardous substances. sufficient to cause a concern for the
protection of human health and the environment. For example.
commonly used industrial solvents such as "ethyl benzene. toluene.
xylene and 4-methyl-2-pentanone. as well as polynuclear aromatic
hydrocarbons and PCB-1254 were found in former drum storage areas
Nos. 1 and 2 (see page 5 of the Record of Decision for a full
discussion; also see table 3-6 of the Remedial Invetigation).
As such. it is necessary to take appropriate remedial measures
to ensure that these materials do not pose unwarranted risks
to human health and the environment. EPA's guidance for the
remediation of CERCLA sites states that in determining site
clean-up measures. applicable and relevant provisions of other
environmental laws should be considered and followed. EPA has
thus determined that the regulations promulgated under the
the Resource Conservation and Recovery Act. specifically 40
C.F.R. Part 264. subparts F and G (ground water monitoring
and closure). are relevant to the remediation of the Taylor
Borough site. Therefore. although there may be no hazardous
wastes at the Taylor Site. the RCRA standards are relevant
and provide helpful guidance in determining appropriate
measures for the remediation of the Site.
The fact that the hazardous substances were found intermixed
with garbage is not controlling. Hazardous substances
that are not typical of municipal waste were found in
drums areas No.1 and 2. such as the chemicals described in the
previous paragraph. Additionally. it is uncontroverted
that there were drums of industrial waste which had been
located at these areas. and that some of these drums were
deteriorated and could have leaked. both on the surface
and into the garbage layer. It is unfortunate that industrial
waste was disposed on top of a municipal landfill. and
has complicated both the study and remediation of this
site. However. EPA must evaluate and address the site as
we found it. and simply treat the existence of the municipal
landfill as a unique feature of this site, just as other
CERCLA sites have other unique features which are similarly
complicating.
Test pit data shows only isolated evidence of hazardous
substances and does not support a 4200 cubic yard removal
(letter of 6-21-85).
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Answe r :
Comment (/3:
Answer:
Comment #4:
- 8 -
Th~ test pits were intended to be just that - - an indication
of contamination throughout the site. Hore extensive sampling
to chemically characterize every few feet of the site would be
prohibitively expensive, based on an average of $1,OOO/sample.
It was EPA's intention while conducting the test pit program
at the former drum storage areas not only to identify the nature
of hazardous substances. were causing the persistent odors in
these areas but also to define the vertical and areal
extent of the waste in these areas. Although detected hazardous
substances may be attributable to mine spoil and/or municipal
trash as well as industrial disposal, the PRP proposal has not
established that by removing 1000 cubic yards of waste material
the remaining waste is at background levels, in order to meet
the requirements of RCRA. Test pit data does show hazardous
substances. Any contaminated materials above background left
onsite would require the site to be properly closed as a land
disposal facility for hazardous wastes, according to the RCRA
requirements.
The remainder of this comment is discussed in the answer to
comment (/19, below.
The potential for direct contact can be totally eliminated by
cutting the high wall to a 3:1 slope and applying a
geotextile material and cover. This will also eliminate the
potential for any odors emanating from the area and is more
cost-effective.
EPA does not believe that these steps will eliminate the
.chemical odors or potential odors from this area. The odors
are tentatively identified as toluene, but methylene chloride
and 4-methyl-2-pentanone have also been identified in this area
Firstly, geotextile material is very permeable, and would
not prevent the chemical odors from being released.
Mining overburden provides relatively little protection
against the release of chemical odors. The 6" of topsoil
- would also be insufficient to prevent the odors from escaping.
Even the addition of more topsoil would not necessarily be
effective to control the chemical emissions. EPA's Feasibility
Study Guidance states that impermeable material should be
used as a cover in any event, which would mean the installation
of a clay cap. Then, in order to ensure the integrity of the
clay cap, it would be necessary to grout the mine voids to
prevent potential subsidence of the cap (see comment 17, below~
Grouting would cost an estimated $2.2 million, with the total
cost for installation of the clay cap then reaching anestimated
$2.7 million. This alternative would therefore not be cost.<
effective.
The PRP Plan adequately addresses stormwater control, by
eliminating the pond Nos. 1 and 2 depressions and providing
stable cover and preventing erosion of the cover and
safely directing stormwater from the area.
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Answer:
Comment 1/5:
Answer:
Comment 1/6:
Answer:
Commen t #7:
Answer:
- 9 -
Without going into. a detailed discussion of the technical
merits of this proposal. several problems arise which prevent
the PRPs alternative from being implemented at the site.
The major feature of the PRPs alternative is that it would
leave elevated levels of hazardous substances at the site'.
whereas EPA's alternative would not. However, in order to
leave these materials on-site and still protect human health
and the environment it would be necessary to have a rigorous
monitoring program to ensure that the hazardous substances
were not being continually released into the environment.
The PRP proposal does not include such a monitoring program.
Additionally. RCRA closure standards would have to be followed.
Both of these measures would be extremely expensive. In view
of this as well as other factors. EPA has concluded that
the preferred alternative is to remove the threat Of release by
removing the materials from the site.
Pond Nos. 1 and 2 sediments contain no elevated inorganics and
minimal levels of organics. Pond water (to be removed) shows
slight contamination. much less than typical urban stormwater
run-off. (letter of 6-21-85)
The chemical makeup of urban stormwater run-off is irrelevant
to this site. It is not disputed that the Taylor Site is not
located in an urban area. but rather in a remote rural setting.
The remainder of this comment is discussed in the answer to
comment 1/4. above. Of note. the PRPs comment recognizes that
there are elevated levels of organics found in these areas.
The singular risk. direct contact. is cost effectively eliminated
by leaving the sediments in place and providing a stable cover.
(letter of 6-21-85)
As discussed in the answer to comment #4. above. the PRPs have
failed to include the costs of RCRA closure and monitoring in
- their cost assessment for this proposal. This would
significantly impact their cost-effectiveness determination.
Such closure and monitoring would be necessary to ensure that
contaminants from the site were not released into the
environment. EPA's selected alternative eliminates the risk
that these substances can be released into the environment from
this site. .
Such ditches at shallow grades are difficult to maintain and
tend to promote further depressions and subsidence in old
landfills when not maintained. (letter of 6-21-85)
The PRPs comment is referring to their preference for substitutina
two percent grading at the site for EPA's alternative. which
includes the installation of ditches to direct ground water flows.
EPA agrees that there 1s a possibility of subsidence and further
depressions at the Taylor site. particularly since the site 1s
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Comment U8:
Answer:
Comment 1/9:
Answer:
Comment t! 10 :
Answer:
- 1U -
located over a mined area where subsidence is common. In fact,
this is one of the reasons why EPA's selected alternative includes
removal of the hazardous substances from the Taylor site - -
maintenance of the landfill could prove to be difficult, and
if hazardous substances are left at the site, future direct
contact with the substances cannot be ruled out. .
However, EPA does not necessarily disagree with the PRPs approach
of using a two percent grade rather than the ditches. This is
a fairly minor comment, and adjustments in this type of work can
be made during the design phase of the remedial project.
The adjacent property owner has placed a large mound of fill
material along the property line which would make placement
of drainage ways difficult. (letter of 6-21-85)
EPA does not necessarily disagree with this comment. Similar
to comment #7, this point can be addressed during the design
phase.
The dr?inage basin areas are small. (letter of 6-21-85)
EPA does not necessarily disagree with this comment.
point can also be addressed during the design phase.
This
The Hazard Ranking Score calculated for the Taylor Site is.
arbitrary, inaccurate and too high, and has caused public
misconceptions about the site.
The initial ranking of this site in the summer of 1982
caused public concern because it was felt to be too low
(see Responsiveness Summary, p. 1). The Taylor
Neighborhood Association petitioned EPA Headquarters to
reevaluate the score, based on the public's serious
concerns about the site. On the basis of additional collected
information about the site, the site was rescored in 1983,
resulting in its current EPA scoring of 30.94. Thus, the
EPA scoring has not caused public misconceptions; rather, the
public has been active in pushing EPA to address the site.
It is possible that different consultants scoring the site
will come up with slightly different scores, and EPA does
not maintain that the PRP's consultant, Hart, is not
qualified. Add~tionally, it is not feasible to address
a detailed comparison of scores in this summary response.
Suffice to say that EPA's formulation of the score was based
on reliable data and information concerning the site, and
the PRPs have not taken issue with this data. Thus, there
is no reason for EPA's formulation to be questioned.
-------
Commen t # 11 :
Answer:
- 11 -
The PRPs must also recognize that are errors in their
analysis of the information io their formulation of the
HRS score. Without going into a detailed review of all
of these areas, one obvious example is the PRPs erroneous
formulation of the total waste at the site. In that
formulation, the PRPs have subtracted from the waste total
the approximately 1200 drums which EPA removed during the
emergency activities in 1983. But this approach only
encourages PRPs to take "band-aid" measures at CERCLA sites,
so as to lower the score and remove the site from the NPL.
The remainder of the problems at the sites would then
never be addressed! For this reason, EPA has established
clear guidance stating that partial clean-up measures at
sites will not be taken into account in HRS formulations.
This sound policy approach ensures that environmental and
health hazards posed by these sites will be fully addressed.
Thus, in the HRS formulation of the score by the PRPs, the
waste quantity has been calculated erroneously.
Another error of note is the PRPs characterization of
air emissions. In their HRS formulation, they state that
"No air contamination detected throughout RI activities.
1200 drums have been removed from site. Previous air
contamination was probably due to presence of drums
containing hazardous materials." (PRP worksheet, p. 11).
This is clearly inaccurate. The person preparing the
worksheet for the PRPs has obviously not visited the site
recently, because if (s)he did, (s)he would observe that
there still is a clear chemical odor emanating from former
drum storage areas Nos. 1 and 2, and the adjacent ponds
Nos. 1 and 2 (referred to by field investigators as
"Shoe Polish Pond"). EPA has been unable to quantify or
definitively characterize this odor, although field
investigators identified it as toluene, perhaps combined
with other organics. This error by the PRPs has resulted
in their calculation of an inaccurate score for the site.
In selecting a remedial alternative, EPA must abide by the
restrictions of CERCLA and the NCP taking into account
actual site conditions. The Selected Remedial Alternative
does not conform to the legal and regulatory constraints
imposed on EPA. ... Alternative 13 contains many aspects
that are unnecessary given the present condition of .the
Taylor Site. (submission of 6-14-85, p. 9)
EPA agrees with the PRPs that clean-up actions must conform
to CERCLA and the NCP. In support of their assertion, the
PRPs have cited a number of selected portions of the NCP
and of CERCLA. A detailed review of all of these provisions
would be exhaustive, and is beyond the intended scope of
this Responsiveness Summary. However, the PRPs have cited
only selected portions of NCP. EPA's actions must be
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Comment 1112:
Answer:
Comment #13:
Answer:
- 12 -
guided by the entire NCP, not just selected portions.
Additionally, EPA's actions must be guided by relevant
guidance, including our policy of compliance with
applicable and relevant environmental laws. One of those
laws is the Resource Conservation and Recovery Act ("RCRA").
EPA determined that the standards of RCRA are relevant to
the Taylor Site, particularly since the RCRA standards are
the only detailed guidelines the agency has for handling
hazardous materials. Further, the Subtitle C portion of
RCRA was determined to be the relevant portion of RCRA to
apply, since it is undisputed that industrial wastes as
well as municipal wastes were disposed at the Taylor Site
(see answer to comment #1, above). .
For these reasons, EPA believes that it has correctly
applied CERCLA and the NCP in the determination of the
appropriate clean-up at the Taylor site.
Background conditions at the site should reflect previous
site activities (municipal landfill and mining). The
PRPs should not now be called upon to address the
contamination that did not originate from the disposal
of hazardous substances, if any. (Submission of 6-14-85,
Appendix B, p. 3). .
This comment has substantial merit, and EPA has taken
background conditions of the site into account in the
Remedial Investigation (Section 3) and in the
selection of the remedy (Record of Decision, pp. 4-5).
EPA's overriding concern in the remediation of this
site is the adequate protection of human health and
the environment from exposure to hazardous substances,
and as discussed in comment #1, above, the existence of
the municipal landfill and the mining is a complicating
factor in differentiating the source(s) of the hazardous
substances. It is difficult to see how the PRPs can
contest the disposal of industrial wastes at the site, in
view of over 1000 drums at the site which the PRP's own
representatives saw and sampled. Thus, EPA believes that
it has taken these considerations into account in the
selection of the remedy. .
Present site conditions pose no significant potential for
airborne contamination, either from organic vapors or dust.
See EPA's answer to PRP comment #10.
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Comment #14:
Answer:
Comment (/15:
Answer:
- 13 -
. . . There is neither an appreciable public health or
environmental risk posed by contaminated soils remaining
on the site. Localized areas of elevated contaminants in
the soils can be appropriately addressed in a remedial
action program for the site.
EPA agrees that there is not a serious public health or
environmental risk posed by the contaminated soils; however
there is still an appreciable risk. The contaminants of
concern are primarily volatile organics typical of
industrial solvents. and lead. well-known for its adverse
health effects particularly in children.
Thus. EPA agrees that localized areas of elevated contaminants
in the soils can be appropriately addressed in the remedial
action program for the site. and we believe that we have
appropriately addressed these with the selection of our
alternati ve II 13.
. . . Contamination [of surface water and sediments] is
limited to the areas of Pond Nos. 1 and 2. ... there
is no evidence of off-site migration of these contaminants
and no evidence of exposure pathways for those contaminants
within the Pond Nos. 1 ~nd 2 area.
This comment indicates that the commenter recognizes that
contamination in Pond Nos. 1 and 2 was found. As such. it
must be considered for remedial action. Even if there were
no evidence of off-site migration. this is not necessarily
controlling since this was not extensively studied.
EPA considered the data discussed by the PRPs in comment #15.
and reached the conclusion that the contaminated materials
must be removed from the site primarily to prevent human
exposure, and also to comply with the guidance of the RCRA
standards. In order to comply with the RCRA regulations. the
contaminated materials must be: (1) removed to background
levels, or (2) if above background material is left on site
then the area must be closed as an existing land disposal
unit which requires (a) a RCRA approved cover, (b) ground
water monitoring of the unit. and (c) post closure
maintenance of both the unit and monitoring program. The
alternative of leaving these contaminated waters and sediments
on site would have to incorporate such additional measures,
which also have their associated costs. The PRPs do propose
an alternative which would leave the sediments on site, but
it does not address these RCRA points.
-------
Comment IJ 16:.
Answer:
Comment 1117:
Answer: .
Comment 1118:
Answer:
Comment 1119:
- 14 -
Groundwater contamination is minimal.
EPA agrees with this comment, but also notes that
. - groundwater contamination was found, in well tJ3C,
including the contaminants~4-dichlorobenzene, 2,4-
dinitrotoluene, and N-nitrosodi-n-propylamine (see.
page 6 of the Record of Decision).
There are no potential receptors of contaminants.
EPA disagrees with this comment. The site is
adjacent to a recreational area and a housing
development. Picnickers and children have been
observed at the site, as well as individuals
gathering wild fruit. All of these people are
potential receptors of contaminants.
In summary, the RI has conclusively demonstrated that
minimal risk to the public health and the environment
exists from either air or groundwater routes of
exposure. Moreover, the RI indicates that for the most
part, surface water, soils and sediments show contaminant
patterns consistent with background leve11 found in the
area or levels which are attributable to sanitary landfill
and/or mining activities. . Several localized areas showing
elevated surface soil, surface water and sediment
contamination levels have been identified and only these
limited areas need be addressed at all, and if so, in a
cost-effective manner to minimize dermal contact.
EPA believes that it has adequately addressed this
comment in the Record of Decision and in its previous
answers to the PRPs comments. Further, the PRPs must
consider the pathways of ingestion or inhalation of
the contaminants in addition to the dermal contact route.
Alternative 13 includes components which go beyond that
which is required to meet this objective without any
supporting analysis or rationale. . . (such as]:
- methane gas venting,
- extent of soil cover,
- off-site disposal of contaminated soil and sediment, and
- ground water monitoring.
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- 15 -
Answer: -
EPA will first address the specific criticisms made by the
PRPs, and then will generally discuss their alternate
proposal.
Methane gas venting: EPA agrees with the PRPs that methane
gas venting may not be necessary. Thus, the preferred
alternative has been revised to allow for a determination
during the design phase of the project whether the- methane
system is warranted.
Extent of soil cover: As discussed in the answer to comment
818, above, inhalation and ingestion must also be considered
as exposure routes. This is of particular note in the case
of lead, which exhibits elevated levels in the areas of the
site designated for the cover by EPA. Additionally, the
toxicological recommendation for this site was to minimize
the translocation of these surface contaminants, in order
to adequately protect human health. These are reasons why
EPA has concluded that a surface cover on selected portions
of the site is necessary.
Off-site disposal of contaminated soil and sediment: Although
it may be preferable to use an alternative that does not
involve off-site disposal, both on-site treatment or disposal
are not feasible alternatives for this site. The PRPs have
not identified what would be a feasible "treatment" for the
- wastes at this site, and on-site disposal is prohibitive
because of the location of the site in a mine subsidence
area. In order to ensure the integrity of an on-site disposal
option, it would be necessary to grout the mine voids, an
extremely difficult and costly task (approximately $5.7 million).
Thus, off-site disposal at a site effectively monitored for'
release of wastes is rreferable, both as a matter of environmental
and health protection and of cost.
Groundwater monitoring: This comment has merit. EPA has
revised the preferred alternative to postpone consideration
of the groundwater issue. Thus, the present alternative does
not include a long-term groundwater monitoring program.
Other concerns EPA has with the-PRP's proposal are as follows:
In comparing remedies for the former drum storage areas Nos.
I and 2, EPA proposes to remove approximately 4,000 cubic yards
of hazardous materials while the PRPs propose to remove only
1,000 cubic yards. The major reason for EPA's higher quantity
18 to prevent the future migration of hazardous substances into the
adjacent surface water (ponds 1 and 2 and possibly St. John'sCreek
and also eliminate the persistent chemical odor emanating from this
area. By removing the contaminated 8oil!spo11!garbage!rubble/
crushed drums/construction debris material to sub-soil
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- ---.---- ~
...
- 16 -
(which was approximated by a testpit program to be about
8 feet below the surface) the potential for future
washout and migration of hazardous substances will be
effectively mitigated. Excavating only 1000 cubic yards of
exposed wastes and drums currently on the sideslopes of the
former drum storage areas Nos. 1 and 2 to an approximate
3:1 grade (as the PRPs propose) may not be an effective
source control measure. Additionally, removing only the
exposed wastes and drums on the sideslopes of the former
drum storage areas, grading and backfilling with permeable
material may not adequately eliminate the persistent chemical
odor emanating from former drum storage areas Nos. 1 and 2
and Ponds 1 and 2.
The PRP's proposed remedy for addressing the above-background
surface soil contamination at former drum storage areas 3, 4
and 6 and the area in between areas 3 and 6 closely resembles
the EPA selected remedial measure for these areas. Because
of the RCRA requirements, the cover material mus~ have a
permeability less than or equal to the natural subsoi~s
present. Using mining overburden material for fill material
in depressions as the PRPs propose would be acceptable;
however, the final cover would need to be constructed of
soil material with a similar or less permeable property than
natural subsoils. .
Further, in order to ensure the integrity and effectiveness of
the soil covered waste management areas, EPA recommends the
installation of a chain link fence for protection of the
covered area from vehicle damage. Although the PRPs intend
to institute a post-closure inspection and restoration
program, the frequency of one inspection per year is not
acceptable. The likelihood that minibikes may damage the
soil cover is a strong possibility at this site. More
importantly, should settlement or subsidence occur, restoration
of the soil cover should be taken care of as soon as
feasibly possible.
As discussed previously, since above background levels of
contamination would be left under the 80il cover, compliance
with 40 C.F.R. t 264.310 would be required, which specifically
requires a post closure ground water monitoring program.
Again, the PRPs did not address the development of this
program.
As a final point, there was no mention of removing the remaining
crushed and intact drums and remnants scattered throughout the
surface of the site and partially buried. The PRP proposal is
incomplete without this and the required RCRA elements.
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Comment 020:
Answer:
I
- 17 -
The PRPs letter of 6-10-85 is also included in the
public comments for the Taylor site.
This letter is more in the nature of a proposal, and
does not detail specific comments about EPA's preferred
alternative for the site. However, a number of the
PRP comments and answers set forth above address the
issues raised in this proposal. EPA believes that this
is adequate to respond to the comments contained within
the proposal.
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