United SIMM
Environmental Protection
Agency
Office of
Emergency •no
Remedial Response
EPA/ROO/R03-85/018
September 1985
Superfund
Record of Decision:
Moyer Landfill, PA
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INSTRUCTIONS
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18. SUPPLEMENTARY NOTES
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1.. ABSTRACT ' .
Include a brief (200 words (N less) factual summary of thc mosl signilkant infurmalion L'untainl'd III ,hl' fL'l,orl. 11 Ih,' fL'I"'" \'II..lalll';I
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Prepared in cooperation Wilh, Tran":!",," ".., l'rC"'IIIL'\I ;II \'UlIll'I\',i.... ..I', '
'17. KEY WORDS AND DOCUMENT ANAL yalS
(a) DESCRIPTORS. Select from the Thesaurus of t:nginecrir.! and xienlilk Terlft~ the pruper aUlh"ri/l:lltwlls thaI idenlify Ihe majur
concept of the research and arc sufficiently specific and preciliC to beuliCd a~ indcJI \:nrries I'or !;alaluj:.n~.
(b) IDENTIFIERS AND OPEN.ENDED TERMS. Use identiflen for projecl nanlL~, eudc namc~. eQulpmcnt \I..,i~n..lur~. etc. Use lIJ'Cn.
ended terms written in descriptor form for those subjects for which no ck:scriptur e~iSI5, ,
(c) COSA TII'IELD GROUP .I:itld and BfouP a_ments are to be lak\:n from thc 1965 ('OS 1\ 1'1 Suhj\'ct (';aIL'!!lIry Ust. Sin~'\' the mOl'
jority or documents are multidisciplinary in nature, tbe Prinwy ':itld/Group 4Ini,nmenthJ will be \\X'dfiL' \li\L"plin.., 41ft'" of hum;l" '
endeavor. or type of physical object. The appUcationh) will be cro"ofcferenL'ed with
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TECHNICAL REPORT DATA "
(PlttlSt rttld Instructions on tht relltnt btfort compltting)
,. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO. '
EPA/ROD/R03-85/018
... TITLE AND SU8TITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION September 30, 1985
Moyer Landf ill, PA I. PERFORMING ORGANIZATION CODE
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7. AUTHORIS) 8. PERFORMING ORGANIZAT10N REPORT NO.
,
Ie. PERFORMING ORGANIZATION NAME AND ADDRESS '0. PROGRAM EL.EMENT NO.
, 1. CONTf'ACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS '3. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.w. ,... SPONSORING AGENCY CODE
Washington, D.C. 20460
800/00
15. SU"PLEMENTARY NOTES
'.. ABSTRACT
The Moyer Landfill is anina,ctive privately owned landfill located in Lower Providenc
Township in Montgomery County, Pennsylvania. The site was operated as a municipal' land-
fill from the 1940's until April 1981, during which time it received municipal refuse
and sewage sludges. According to local Federal Bureau of Investigation (FBI) officials,
the landfill accepted a variety of solid and liquid hazardous wastes, including ,poly-
chlorinated biphenyls (PCBs), solvents, paints, low-level radioactive wastes, and
incinerated materials in bulk form and/or containerized in drums. In 1972, when the
Pennsylvania Dept. of Environmental Resources (PADER) rules and regulations became more
restrictive, this landfill was cited, and finally in 1981,it was closed and brought into
receivership of the U.5. District Court.
The selected remedial action for this site includes: interim soil clay capping, com-
posed of a material having a permeability of 10-4/10-5 em/see to a depth of 36";
erosion and sedimentation control measures; surface water diversion; leachate collection
treatment and discharge; extraction, scrubbing and upgrading methane gas for delivery
to the Philadelphia Electric Company (PECO); security/fencing measures; ground water
monitoring; and all closure activities in compliance with RCRA at the conclusion of the
gas generation phase (10 to 20 years). Total capital cost for the selected remedial
cHternative is estimated to be $6,298,500 with O&M costs approximately $332,000 per
(see separate page)
7. KEY WORDS AND DOCUMENT ANAL.VSIS
I. DESCRIPTORS b~IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Moyer Landfill, PA
Contaminated Media: gw, sw
Key contaminants: heavy metals, VOCs,' toluer :!,
trichloroethylene (TCE) , arsenic, xylene,
radioactive materials
18. DISTRIBUTION STATEMENT 11. SECURITY CLASS (TlIU Rtpo,r) 21. NO. OF PAGES
None 28
20. SECURITY CLASS (Tlli3/H1lt) , 22. PRICE
None
I'. 'Of... 2220-1 (R... 4-77)
~"EVIOU' EOITION II O.'OLETE
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SUPE~D RECORD OF DECISION
Moyer Landfill, PA
Abstract
Continued
year. This alternative contemplates broad remedial work and its implementation will
depend upon the success of the gas gene~ation/recovery program and the contributions
from generators and other potentially responsible parties (PRPs).
If negotiations with the PRPs fail and/or the methane gas alternative fails, EPA
and PADER recommend: miscellaneous work preparatory to installation of a RCRA cap
(grading, flattening .of steep slopes, retaining walls and installation of rip-rap
at areas that. are most likely to be eroded); gas venting and monitoring; surface water
collection and discharge to Skippack Creek; leachate collection and treatment that
will meet the i~risk level in the ground water and discharge requirements in the
stream; ground and surface water monitoring; and maintenance of the cap. Total.
capital cost for this alternate remedial action is estimated to be $15,384,800 with
O&M costs of $343,100 per year.
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site:
Moyer Landfill Site, Collegevllle, Pennsylvania
Data Reviewed:
The following documents describe the analysis of cost-effectiveness
and feasibility of remedial alternatives for the Moyer Landfill Site. I
have beenbr1efed by my staff on their contents, and they f9rm the principal
basis for my decision. Unless otherwise specified, the underlying technical
information 1s included in these reports: .
- "Remedial Investigation Report", (Draft), Moyer Landfill Site,
Collegeville, Pennsylvania, (IMS Engineers, July 1985).
- ~Feasibi~ity Study Report", (Draft) Moyer Landfill Site, Callegeville,
Pennsylvania, (IMS Engineers, July 1985)
- "Work Plan", Remedial Investigation/Feasibility Study of Alternatives,
Moyer Landfill Site, (NUS Corp. Septem~er 1983)
- "Remedial Action Master Plan", Moyer Landfill Site, (NUS Corp.
September 1983)
- Summary of Remedial Alternative Selection.
- Recommendations by the Pennsylvania Department of Environmental
Resources.
- Notes and outlines provided by the site receiver.
- Staff summaries and recommendations, including these attached.
Description of the Selected Remedy:
After careful review and consideration of s~te areas identified in
the Remedial Investigation which warrant remedial action, and of all
alternatives developed by EPA in the Feasibility Study and the alternative
developed by the site receiver in the Addendum to the Feasibility Study,
the site receiver's methane gas generation/recovery alternative can be
implemented at the Moyer Landfill Site. This phased alternative will meet
the Superfund goals of minimizing present and future migration of hazardous
substances and protect human health and the environment, while also attaining.
all applicable and relevant Federal public health and environmental standards,
guidances and advisories at the point of closure (10 to 20 years).
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Specifically this option proposes:
o
. Soil cover with a permeability of 10-4/10-5 em/see
Erosion and sedimentation control measures
Surface water diversion
Leachate collection, treatment and discharge
Methane gas recovery and sale
Security/fencing measures
Ground water monitoring .
All closure activities in compliance with RCRA at the conclusion
of gas generation phase (10 to 20 years). .
o
o.
o
o
o
o
o
This alternative contemplates broad remedial work and its implementation
will depend upon the success ot the gas generation/recovery program and
the contributions from generators and other potentially responsible
parties (PRPs). If negotiations with the PRPs fail and/or the methane
gas alternative fails, EPA and PADER recommend Remedial Action Alternative
4.2. This alternative is the cost-effective remedy and will satisfy as'-
well all of the contamination snd migration objectives identified in the
Remedial Investigation. .
Specifically this option pr~poses:
o
Miscellaneous wor~ preparatory to installations ofRCRA cap:
grading, flattening of steep slopes, retaining walls and instal-
lations of rip-rap at areas that are most likely to be eroded.
o
Gas venting and gas monitoring.
o
o
Surface water collection and discharge to Skippack Creek.
Leachate collection and treatment that will meet the 10-6 risk
level in the ground water and discharge requirements in the stream.
o
Operation and Maintenance: ground and surface water monitoring,
maintenance of the cap and treatment of leachate.
Declarations
Consistent with the Comprehensive Environmental Response and Compensation
and Liability Act of 1980 (CERCLA) (42 U.S.C 19601-9657) and the National
Contingency Plan (40 C.F.R. Part 300), and 1101 (24) of CERCLA, I have
determined that either of the remedial actions described above, together
with proper operation and maintenance constitute remedies which mitigate
and minimize damage to public health, welfare and the environment. The
~ennsy1vania Department of Environmental Resources has been consulted
and agrees with the approved remedy. These activities will. be considered
part of the approved action and eligible for Trust Fund monies.
1 have determined that the action being taken is' appropriate
balanced against the availability of Trust Fund monies for use at
sites. ~/ ~~-
Date ~ .
when.
other
. LL/A~ .
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Summary of Remedial Alternative Selection
Moyer Landfill Site
Site Location and Description
The Moyer Landfill is an inactive privately owned landfill located at
Moyer Road, R.D. 12, Collegeville, in Lower Providence Township in Montgomery
County, Pennsylvania (figure 1). The landfill was permitted for 65.5 acres'
in 1976 of which 45 acres. had been used by 1977; however, some dumping did
occur on unpermitted land. The site area consists of open land aurrounded
by wooded areas on steep slopes. Located on the site are leachate sumps,
an office building, and a metal repair shed. Runoff from the slopes o~
the landfill flows westerly into Skippack Creek, which is located 350
feet west of the site.
The landfill is bounded on the north by Evansburg State Park, on the
south by land owned by Providence Builders, on the east by land owned by
Howard F. Moyer and Catherine M. Moyer, and on the west by other residen-
tial land. The area immediately surrounding the landfill 'i8 sparse
residential, while large residential developments are located within one
mile of the site. The nearbySkippack Creek, which flows through Evansburg
State park, has in the past been stocked' with trout.
According to local Federal Bureau of Investigation (FBI) Officials,
the landfill, during its operation, accepted a variety of solid and liquid
hazardous wastes, including polychlorinated biphenyls (PCBs), solvents,
paints, low-level .radioactive wastes, and incinerated materials in bulk
form and/or containerized in drums. .In 1972 when the Pennsylvania.
Depart~nt of Environmental Resources (PADER) rules and regulations became
more restrictive, this landfill was cited, and finally in 1981, it was
closed and brought into receivership of the court. Since then, some
remedial work has been done at the site under the direction of the
receivership attorney Ms. Joanne Denworth, appointed by the U.S. District
Court under a. 1982 Consent Order entered in a civil action initiated by
neighboring.residents. This work was carried out by SMC Martin the
receiver's consultant. They have performed certain activities, i.e.,
design of collection systems and leachate treatability studies, and SOme
site work including covering certain exposed areas of the landfill,
regrading, and revegetation. . Owing to increased involvement by local
residents and PADER, the site was eventually listed on the National
Priorities List (NfL) by the U.S. Environmental Protection Agency
(USEPA). .
Although access into and around tbe site is limited somewhat by a
heavy growth of trees, steep slopes, streams, puddles and ponds, the site
is still accessible by foot. The entrance to the site did have a fence
and a gate at one time, limiting access to vehicular traffic. Elevations
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'-
LOCATION MAP
MOYER LANDFILL SITE
C.OLLEGEVILLE, P A
\118
Scale:
1" . 2000'
Engfneel'8 . Architects, P.I
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...
range from 275 feet above mean sea level (MSL) along the west side of the
. site to 497 feet above MSL at the top of the landfill. Drainage from the
site area flows westward into Skippack Creek through direct runoff and
also via small streams located north, so~th, and southwest of the site.
Skippack Creek drains southwest into Perkiomen Creek approximately 3,000
feet downstream from the site Skip pack Creek is a recretional stream used
for fishing. Skippack Creek is not used tor municipal water supplies.
GroQnd water in the site area occurs in an aquifer which has poor
water yields. The average depth of the wells in the area is 151 feet.
Wells drilled into the deeper system are often artesian due to the dense,
relatively impermeable layer of bedrock overlying the deep system.
Site History
The site had been operated as a municipal. landfill from the 1940's
until April 1981, during which time it received municipal refuse and
sewage sludges..
In the early 1970's PADERdeveloped and implemented more comprehen-
sive landfill regulations. As a result, a leachate collection system
was constructed and began operating in 1972 at the Moyer Landfill Site
The co~lection system consisted of underground drain pipes placed on top
of the bedrock at the toe of .the landfill slopes. The leachate collected
in these pipes drained by gravity to earthen basins, called "Lagoon No.
1" and Lagoon No.2", from which the leachate was to be pumped. The
concrete basins were later converted to function as pumping stations.
After the pumps were installed, the usable storage volume in the lagoons
was reduced to one or two feet because a certain amount of leachate had
to remain in the lagoons to prevent the pumpS from running dry. Subsequent"
testing by the PADER revealed that leachate - contaminated ground water
was appearing as springs downgradient from the leachate collection pipe
on the northwest side of the landfill. An additional pump station was
then installed to intercept the springs and return this contaminated water
to Lagoon No.2. Several force mains connected the collection system pumping
stations to a concrete basin (which has since been abandoned) at the top
,of the landfill. From this basin, "leachate was applied to the top of the
landfill and disposed of by spray irrigation.
Because of increasingly stringent environmental regulations promulgated
by the State of Pennsylvania during the mid-1970's, the owners of the
landfill were prohibited from filling beyond the original boundaries.
The landfill owners then submitted an application to the PADER requesting
permission to expand the landfill boundaries. The. .original landfill was
for an estimated 5 acres. In the late 1970's, the landfill owners also
submitted an application to the PADER for a major expansion to an area
adjacent to the existing landfill, but this application was never approved
by the PADER.
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In the original fill area (39 acres), the waste was simply dumped,
compacted, and covered with earth. In the new fill area, the plans
called for installing an impermeable liner prior to filling. Site
preparation work began on the new area in 1977., Landfilling was reportedly
limited to this new lined area until the landfill was closed by a PADER
order in early 1981.
The early analysis on leachate from the landfill dates back to
February 1972 by Kappe Associates, done for the conventional parameters
such ss BOD, COD, and nitrogen. This analysis was conducted in order to
design an aerated lagoon to treat. the leachate.
Later, leachate from the landfill was sampled extensively by PADER
and to a lesser extent by EPA and by Moyer's Landfill Inc., through
Lancaster Labs and SMC Martin (PADER, April 3, 1980 to March 10, 1982;
Austin, March 10, 1980; Bonder, October 3, 1980; SMC Martin, November 26,
1980). A wide range of heavy metals and organics were detected. In one
,situation sulfate concentration was found to be four times higher than
USEPA Maximum Contaminant Level (MCL). The heavy m~tals are indicative
of sludges, both sewage and industrial, known to have been disposed of
on the site. The organics may have been components of certainin~ustrial
sludges (i.e. from the solvent recycling or plastics industries), but'
their probable origins cannot be determined at this time.
The USEPA detected several hazardous compounds in leachate emanating
. from the Moyer Landfill Site. These included benzene (2 to 4 ug/L),
toluene (7 to 50 ug/L), trichloroethylene (9 to 20 ug/L), tetrachloroethylene
(0.1 to 0.5 ug/L) and chlorobenzene (1 to 3 ug/L). Other compounds
detected by the USEPA include ethylbenzene (2 to 20 ug/L), vinyl chloride
(0.3 to 7 ug/L), methylene chloride (7 to 300 ug/L), chloroethane (0.7 to
2 ug/L), 1,I-dichloroethane (0.4 to 100 ug/L, and 1,I-dichloroethylene
(1 to 2 ug/L). 'These volatile organics in the concentrated or pure forms
are associated with industrial solvents.
, From the point of view of conventional parameters such as BOD/COD,
the leachate appears to be considerably lower than the leachate emanating
from a typical landfill. .
A detailed, chronological profile of the development of activities
and ope~ations at the site is presented in Appendix A. The site'is listed
in'Group 6 on the National Priorities List (NPL) of 418 sites, issued by
the EPA in December 1982. A work plan was developed which identified the
following data, needs:' .
.
To more fully delineate the extent and nature of ground water
contamination at the site. \
.
To determine the extent and nature of surface soil contamination.
at particular locations.
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o
To evaluate ground water aquifer characteristics through pumping
tests and to record water-level readings.
A remedial Investigation/Feasibility Study was funded at a total
Cost of $681,000 and field work began May, 1984.
Current Site Status
. IMS Engineers conducted a soil and rock sampling, and monitoring
well installation program 'at this site to define the geologic and
hydrogeologic regime of the site and areas adjacent to the site. A total
of thirteen monitoring wells have been installed. They consist. of four
clusters of two wells each, one (I) deep and one shallow, located within
5 to 10 feet from each other,. and five additional wells which are
interspersed around the boundary of the landfill site to give a broader
perspective of the geology and hydrogeology of the site. The shallow
wells are about 30 to 80 feet deep, and the deep wells are approximately
250 feet deep.
As indicated by the boring samples the Moyer Landfill is situated
on a high, resistive ridge of shale, argillite and siltstone of the Lockatong
Formation, of Triassic age (figure 2). At some of the boreholes, the rock is
disintegrated up to a depth of 40 to 80 feet, beyond which the formation
is very dense. .
Permeability testing of wells has indicated the permeability of the
upper bedrock above 100 feet is about 5 x 10-5 em/sec while below 100
feet, the permeability decreases from 1 x 10-5 cm/~ec to 5 x 10-7 cm/sec.
Ground water movement from the vicinity of the landfill site is generally
to the West with discharge around the toe of the fill and through seeps
along the steep valley of Skippack Creek. Hydraulic monitoring has
demonstrated that Skip pack Creek is a hydraulic boundary and no flow of
leachate crosses the creek. .
It is calculated that 95 to 98 percent of the flow is lateral and in
a downgradient direction from the landfill site while 2 to 5 percent is
vertical into the less permeable deeper aquifer zone. The rate of flow of
ground water through the fractures is in the range of 1 to 70 feet per
day. Permeability measurements at the site confirms the other investiga-
tions. The rate of leachate generation has been estimated to be at an
average rate of about 18,600 gallons per day. A leachate collection
system installed by the owners' is in a poor state of repair and is now
inoperable. Depending upon the year, excess leachate is generated and
discharges to the Skippack Creek system during a period of 5 to 8 months
each year.
.
Data was obtained from analysis of samples taken on two separate
occasions, May 21 thru June I, 1984 and October 2 thru 12, 1984. Samples.
were collected from onsite monitor wells along with offsite monitor and'
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(Baseci
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40f
40f
2 rOOT' KEY
10f
BED
20f
3 rOOT
.
55f
- 30f
KEY BED
15f
35f
Sf
25f
Scale: 1" -50'+/-
Total Cored Thickness:
approx. 455'
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Engineers - Architects, p.c.
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,
UACBA'tZ SAMPU LOCATIONS
HOtEll LANDFILL SIn
COLI..EGEVILL! I P A
IMS.
Engineers. Architects, P.c.
ROCHESTER, NEW YORK
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SEEPS LOCATIONS
HOYER LANDFILL SITE
COLLE~t fA
IMS
EnginHn . Architects, P.c.
ROCMESTER. NEW YORK
-.
L..
. ,
. .
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I
i
MONITORING VE1.LS LOCATIONS
HOYE1l1.AHDFILL SIn
COLLEGEVn.I.E. P A
LEGENDS
Shallow Wells
Deep Wells
.
C
Engineers. Architects. P.c.
ROCHEST£R. NE~ YOiU(
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-5-
domestic wells. Six leachate and six seep locations from the landfill
site were'sampled for water and/or sediment. Water sediments and fish
samples were collected from upstream and downstream locations in Skippack
Creek passing along its western boundary. Ground water samples from
twenty-two residential wells and thirteen newly installed monitoring
wells around the periphery of the site were sampled. These samples.
were analyzed for priority pollutants, PCBs, dioxins and radioactivity.
The laboratory test results indicate that some contaminants observed in.
the leachate and seep samples from the landfill site are a1so present in
water and sediment from the Skippack Creek, in the tissue of the fish
sampled downstream of the landfill, and in monitoring wells surrounding
the periphery of the landfill site..
The occurence, distribution and probably transport of the various
chemicals is summarized below. This will be presented under three sub-
headings: Onsite Contamination, Offsite Contamination, and Contamination
Transport.
ONSITE CONTAMINATION
Six (6) leachate (figure 3) and'six (6). seep samples (figure 4) were
collected. Leachate samples were analyzed for 129 priority pollutants.
One additional leachate sample was analyzed for radioactivity. the seep
samples were analyzed for pH conductivity, oxidation-reduction potential
and temperature. The landfill surface shows a number of leachate and
seep locations. These are supposedly discharging several of priority
pollutants and Beta radionuclides into the surface water. Therefore, the
landfill site is very unsafe for public trespass. It is a continous
source of polluting ground and surface water with several priority.
pollutants and radiation of probably hospital origin. The following is
a summary of contamination observed at. the site:
o
The samples are observed to be contaminated with 86 priority
pollutants and 16 metals. Although the concentration of most
of these contaminants is low, nearly all of them are contaminants
(e.g.. cyanide) of concern.
o
At least four (4) of the priority metals: arsenic. barium,'lead
and zinc, and eight of the organic priority pollutants: trichloroe-
thylene, toluene, xylene. di-N-octylphthalate. 2-hexanone, and
2-butanone, bis (2~ethylhexyl) phthalate are observed to be -
above ambient levels.
.
Lead and barium exceed United States Public Health Service Drinking .
Water Standards.
o
Beta Radiation (Technetium 99) 1s observed 1n the leachate sample
and 1s above World Health Organization (WHO) Standards. This contami-
nation is suspected to be' of hospital origin.
o
There 1s no evidence of any detectable level of a1r po~lut10n.
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OFFSITE CONTAMINATION
Thirteen monitoring wells (figure 5), twenty-two residential wells
(figure 6) bordering the landfill site, Skippack Creek flowing by the
western boundary of the landfill site, Perkiomen Creek accepting flow
from Skippack Creek, and fish from Skippack Creek (figure 7) were
sampled for priority pollutants, metals, organics, PCBs, dioxins, and
Beta radiation. The following is a summary of the contamination observed
off the Moyer Landfill Site.
o
The residential wells bordering the landfill site do not show
any detectable levels of organic or inorganic pollution. This
water meets all Federal USEPA Drinking Water Standards and is,
therefore, safe for human consumption.
o
The Skippack Creek shows detectable levels of contamination.
Those contaminants are: toluene, chloroform, 2-hexanone, bis (2-
ethylhexyl) phthalate, di-N-octylphthalate, manganese, iron and
poss1bly nickel. The concentrations of these contaminants are
very low. However., these contaminants are' present and their
source can be traced back to the landfill. The creek water meets
all Federal, USEPA, and State of Pennsylvania Drinking Water
Standards and is therefore safe as a raw water supply source.
o
The fish in the creek also show detectable levels of contamination.
The contaminants observed were lead, O-xylene, 2-hexanone, TCE, 2-
butanone, toluene, di-N-octylphthalate. Again, the concentrations
of these"contaminants are very low. None of these contaminants
exceeds FDA standards of fish consumption of this fish by humans.
The contaminants detected can be traced back to the landfill.
o
The shallow monitoring wells installed around the periphery of
the landfill site show substantial concentrations of some contami-
nants. These wells are located on the western boundary of the
landfill site~ The direction of ground water flow is also to the
west, northwest, and southwest. These contaminants are arsenic,
lead, bar1um, and nickel. The concentration of barium 1s 3,500
ug/l, whereas the USPHS standard is 1,000 ug/l. The concentration
of lead obserVed 1s 230 ug/l, whereas USPHS is 50 ug/l. The
USPBS'is considering revising the standard for lead. This is
expected to be more stringent than 50 ug/l. Both barium and
lead are toxic to humans. The arsenic concentration
observed .1s 25 ug/l, whereas the USPHS standard 18 50 ug/l.
-------
-7-
o
Thirteen monitoring wells and one residential well were tested
for radium 226, Gross Alpha and Gross Beta radiation. Monitoring
wells MW 5, 8, and 10 contained Beta radiation varying from a 34.9+6
to 124+20.3 pCi!l. These three wells are shallow wells and are
the most contaminated 9f the thirteen wells drilled at this site.
The residential well water indicated very low levels of radiation
including Beta radiation. The WHO guideline for Beta activity
is. 27 pCi/l.
Evidently the radiation activity in monitoring well.water far
exceeds the maximum recommended for drinking water. In order to make a
proper health and environmental impact of this contaminant, it is
essential to determine the exact nature of this contaminant at its
isotope level and also possibly identify its source. For this purpose,
samp,les from these wells were collected again. The Analytical test
results are indicated in Tables 1 and 2.
o
Potassium-40 is a naturally occuring isotope that may have been
. contributed by the large amount of suspended material present in the
collected samples. The ~echnitium-99 may be attributed to hospital
wastes buried at the site.
o
The shallow ground water is also'coDtaminated with several of
the other organic contaminants found in the creek water~ sediments,
and fish. Therefore, the shallow ground water floWing west and
northwest of the landfill Site is substantially contaminated.
o
The vegetation and tree~ on the western boundary of the landfill
site show stress.
CONTAMINANT TRANSPORT
There are numerous seeps at the site that are either seeping
lightly or leaching heavily contaminated water from the landfill.
Eighty six organic priority pollutants and sixteen priority
pollutant metals have been observed in the samples from the site.
There are three mechanisms'of transport of the contaminants from
the site: air, surface water and ground water.
No detectable levels of contaminants are observed in the air at
the site. Certain volatile contaminants such as toluene, xylene, and
cyanide have been. detected at the site, but have not been detected
during air monitoring.
-------
-8-
The ground water level is lo~er than the bottom of the landfill.
Therefore, ground water is not the direct vehicle of contaminant
transport from the site. The transport of .contamination 1s mostly due
to surface water percolation through the landfill. The exposed conta-
mdnants at the site are transported directly to the surface water bodies
(Skippack Creek and. Perkiomen Creek) via surface runoff and indirectly
through contaminated ground water (upper aquifer) discharging to the
creeks. The lower aquifer is not contaminated. Beta Radiation and
other contaminants observed in the monitoring wells (MW8 and MW4) are
the result ~f the transport route. Beta radiation and other contaminants
could also be transported directly via the surface water runoff from
the site to the surface water bodies. However, observed concentrations
in these receptors are low due to the enormous dilution effect in the
creeks. The shallow monitoring wells on the western boundary of the
landfill show this contamination. The majority of the pollutants.
(trichlorethethylene, toluene, xylene, 2-hexanone, 2-butanone, acetic
acid methylester) observed in the monitoring wells and the surface
water bodies have high Mobility Index and are consequently easily
transported from the landfill sit, to these receptors.
Tables )-5 summarize all critical contaminants associated with the
Hoyer Landfill.
ENDANGERMENT ASSESSMENT
The risk assessment for the Moyer Landfill Site is based on hydro-
geological and chemical analytical data obtained during previous
investigations and the RI conducted under this study. The objective of
this assessment is to define the health risks associated with the
presence of hazardous contaminants on and around the site and to define
the potential environmental effects associated with the contaminants in
site-specific circumstances. In order for a health risK to occur,
contaminants having known chemical and biological toxic characteristics
must be present, actual or potential exposure pathways ~st be present,
and human.environmental receptors must be located in the exposure paths.
Typically, the risk assessment procedures address the development of
the details of the location and demographics of the receptor population
and most sensitive environmental receivers. The risk assessment involves
assessing the significant contaminant migration routes and exposure
pathways, identifying the hazardous compounds of greatest concern, and
evaluating the possible effects in the context of probable exposure
scenarios.
The major potential contaminant transport path providing exposure
of human receptors to the landfill contaminants is the ground water
fl~w beneath the site. There are also several minor routes of transport
of contaminants. Volatilization of organic and/or inorganic contaminants
-------
T A8I..£ 3
Dttlm' Ccr.!~,.. - '...Iea !!If: II.!!!!!
(0Iemi...: r..IIICII, P.,.n ,t81 iJ
MJrwlAndnu Sitat CoII- ~... .... wrl_t.
RANE c.- aNrAtoelANl' DN:DfIRAm»L -
1--
~
I. Anenk:
....
-.:.!!14:..
0-11
.... .. -.II. ...
UII'aJ. .".
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10-2' '-n
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....
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.BI.L
10-11
c..... ~.. -
Jbb.....
....
~
.....a.. CI ..
..1.. .. r uaIk9 ..
~~-~
2-10 1.1
2. 8.tum I".JIIO ".1" 50-"00 21-'" eJ-" IJ-n
J. L88d 0-115 D-JI 1.4-UO '-'1 '.'-21 ').0.11
.. M811IJ8I". '12.".- 'JO.n20 2J- 11'1 '-III 11-" ":'420
,. Nc:hl &I.'IJ . '.'..1 ".201 .0 '-.1 0-'.1 ".1
L lInG 1'.21)11 JS.1I6 '-'JI 1)-20711
J. 8... R...'1an JJ-I" .,..
I. TrldII..t~l8n8 '.J
(TCE)
,. TolUene )-11
10. )(,1- ,-, 111-61
11. OI-N-OelrlPt*"'I... lU<
11. I.He.- 1.&1
n. 2-8ut- 10-11 1.o-,tO
I'. 81. U-..~.....,.) 6-10' U-II" "-1'1
Pht...I.,.
I ,. Ac:..lc Ac:Id ... u-,u
"'lt~I.8Cer
11.62
J
ZJ
.
. 2J
In."1 UO-89S
72.172
NR Not R8COftW .
. 0nI, one r..""'''' _II -. ,8It8d 'or ,...Uon
.. Concen'ratlon In tllhll8llment.. It I. In mghr, 'or -"" and UIJ/Ic9 'or ortJInI-=-.
K MJIP8C'''' concen'ratlon
L ,... ,hen
, .
I-I'
. 7
2-.ZJ
8 10
1.,11.1160 .
911
III
2~ 10-52110
Aa.i. a..tIII
T-lell, TOJddty
~ I!!!Il!!!I
Or.1 men TOL,
71SJ mq/\c.qJS'SY.
""",.,...a".r
n' ZOI,"J/lcCJ
t ..8th Advl....,
2-!!!!1IL--
1 \0.""..1
1\"....,,11,.,
",.1
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On1 -. 1'D...,,.
1nh.I.Unn -
TCt.. uno U41mJ
Intn.._..
fftU8CU1.f
nl SOmc)/I
-------
ceEXS SAMPLE VA'J:ER
HOYER LANDFILL SID
COLLEGEVIU.E I PA
IMS
!
engineers. Architects, P.c.
ROCHESTER. .'4C,W YORK
-------
HOHITORtD IESIDENnAI. 1lELLS
HOYER URDP'ILL SID
COLLECEVILLE, PA
1-
~ ,
En;in~rs. Architects, p.c. .
ROCHESTEA
.~%~
III. ..., ,:
NCW
vnRIC
-------
Table
I
RADIONUCLIDE - ANALYTICAL TEST D,rA SUMMARY
HOYER LANDFILL SITE, COLLECEVI LU:. JlA
..--,--.... .--..---.
226 itA I GI~1J5~ I LJ IIA
. -.- ..---.- . L.---:--..- . - .. ..- --_--...:..-. -..-..,-.-
Cou('clIl ral.i,):,: COIH:~'al..; Lion Ur.lccl'i"n
p(a!.~___.. ?~l/l -- ~~lIIit
.Ollst ltucnt-
, Source
v
I.
, 1 0.5 i 0.1
, 10 0.', J 0.1
f J1 2.1 ,1. O. t
f 12 0.2 :l 0.1
....J , 13 0.5 :1. 0.1
....
I~ I 2 U.5 \: 0.1
.os
CJ. , 4 0./. :I: 0.1
z
H
rr. , ~ 0.6 f: 0.1
o
.....
H , 6 . (). 1 0.1 .
:~ J
8 #
.... 1 0.1 .J: U.l
, 3 l . 0 :l O. 1
~ ') 0 J O. 1
., '" .1 ') , I. ','.5
,/,.,) .. )
0.1 .I J.) 3.1,:;9
~J . ~ I. '.. l 1 . r,P'(,
:,;,~) I 1.;3 1 . 1',',
:,1. I 2.'J 1 . ~; J'.!.
2.:; :1. lor" 0.'/~)1
0.8 :L 2.0 1.'/1J1)
C.2 ! ., . 1. Hi. 1 ~
1.6 J lo2 O.l:!l
'I.. ,. '1: I.. ~I 1. .".1
.. J
c,.,; :1: I.U II. (,J(J
-O.l .I: .. I I. ~d 'J
-.---. ------.---..-
. ._- -- -.---.. -.--.---....--. .--
o' I,RAltY
1U~S-WF.t.IA
I
:1.2 J n.1
1.1\ II.:.
(J.r,:~'J
4
..--.. --------.-.-.-
(:I(OS:'; :\:~TI\
C"lIcc~..L ,.:,:. i~'~-l-"i;::i',:'\"(-i';;;
rC ~ (~_.__._-_. .- .... ..I.! I;~ i_~_-
I') . 21 ~I. '1
3!, . 'J L (i. 0
1 I .'1 J' :'. I)
:!..'J .I ~.)
. -0.1..1 2.5
".7 I :~. a
4 . 4 .1: ). J
9 :! . 0 .1 ! 7 . "
j.] .I J.O
'..0 .1. '1..1
) :!!, .0 J ~(J.)
).0 : :~. 'j
---.----.-- .--.-. .. -- -... .
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I . r)~fJ
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I. :;0';
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t't. at):;
J. '/0]
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I . I,,:! 'j
-......------.., ..
-------
. TABU:
2
ADi:>Ii'IONAL RAe 1,l..Tl~ ~ ~L YSI S
MOYER LANDFILL SITE.. COLLEGLv'!LLE.. PA.
Sample Identification
MonltorlngWe", MW 5
Monitoring Well, MW 8
Men t tor 1 ng We 11, MW 1 O.
Leachate Water LS 2
Leachate Sed tments,
LSS 2 .
Xptt/gn (dry)
Gross Beta
26 :t 6
37 :t 7
32 :t 7
1 99 :t 12
7.8 :t 0.6
Garm-.a Spectrun
Contcmlnant
Pota5s1~0
Rad h.m-228
Strontt~90
PotasslUn-40
Radl~228
Str:ontl~90
Potasst~O
Radl~228
Strontl~90
Potassl~O
Radh.m-228
Strontl~90
Technetl~99
Manganese-Sit
Cestun-137
Potasst~O
Cacmlun-109
pCt/liter
27
<1
1.9 t 1.4
. 31
<1
<0.5
29
<1
< 0.5
167
<1
<0.5 .
35 :t 15
=0.07 :t 0.02
=0.09 :t 0.02
=5.66 :t 0.07
"1.31 :t 0.35
-------
TI ".1: 4
.......1:8. l.onlamlr n1l - TOIlIc:o~.II>aI.
(Em,lronm lt81 "P....meten
~ L81dRJI'Slte, :0. "J8'Wl8lo. P181111J1..".
. IANCI or c:onAHtIWl'l' co-cln. W:- A....I... Wol,.,... 5..." 11I1."blo,
-~~!!! I ~Itll!!'!. - .,_~!~~!'Ir,~_,
Sa,.
L""'t- GroInI W.t. .-£! ~ 5elllplo - Fl... O.I...bllj Fie"
W."er 81,,1 Orb..I,.., t Ir-I!!!.!! -~!!~Igj!l! -
..Sedlmmnta ...~ .... ".,,"'.ot. .. Ac' Dr""".) Woo....-
W.. -=: ".11 ..11 W.t. ..1.. or UJIk1J .. PPa.S ~.S Waler 0111, Iot"y 10.... Y d.'"llc
Cont8mIn81t uqJL DilL .a/L !!IA - --9~I- ~ !!Il! !!Ii!: !!!Jl.!. !!Il!. '.!'Jl!- !!JP..: !!~
1. Ar.onIc 0-8Z 10-Z4 S-2,S 10-11 2-10 II U.¥)50 DC UOCJI'..) (2.51""'.) SO
Z. Oarlum ZJ8-7Z10 .'-261 so-noo 2"" 41-5. l).n 2 ...... J ,000
). Lead o-an o-)Z Z...ZJO '''I 4.4.28 0.." 50 50 50 50 SO
4. "'8OI)8Oe.. Sl2-S.,800 6)0-2420 2)-7160 '-818 18-n '4-420 , 50 15." SO
,. Nickel 6...., 6.6-.8 98-201 40 5-18 0-9.7 0-2 150 lJ.4 5,'110
" Zinc 2-.U)O )5-124 S-9)1 U-1070 11-'1 4-1. 5.000
7. 8et. Radl.Uon n-144 86..
8. T rlchlor.thrl... ,,) ".7 1.. 0,(2.1) (2.8) 2.112 0.2 0.015
51. T olue08 '-11 ) 25-27 IS"'" 14,)(JIt 15,011" 21. 'i 2.2 D.}4
10. Xylon. '-6 .0"1 lJ 8-10 1l.1J I.) D.62
11. DI-N-Octylphthel.tl 141< 8 188-1760
U. 2-Hellanona 811 4 !) 98
U. Z-8utanona .0-18 140-59D 80
1". 81. U-othylhallYO 6-105 47.11" )9.160, n.-J62 I 20-895 2100-5200 21"",
Phthalatl
IS. Acotlc Acid 80. 22-546 11-172
Methyl..ur
.
Only DOlt relldonU,1 well WI' teltld 'or r.IIIUon
.. Concontr.Uon an lIah/lldiment.. It I. In nMJIkCJ for met.I. and UCj/kCJ lor OfCJ801. ..
K
I"'pected cancantr.U...
I... than
L
. .
-------
IAU.E 5
~
: : !!!!!nt. - "".,lIItf~
Mopr UnilnU 51 ".:oIlOlJllYIUIt. P...,IYIII.a.
...... or CClftAIUIIUI COlIC.. '1&11011
~. GnanI Weter - ~ ~!! S8mp11t FII.. SoII'llUtr ~III
VIpOI' In Af.....",. Wltlor
..SedlmenI MD.. .... "Se.._.,o '. ~- W.t. Ssteellac Pili 111- ...~ lit.
W... % -oUo Ir.U. W.. ."" 01' UI}I'cg.. at 21PC at Z~ ("_Ylty ('"..... en..n. ....".. 'a,
CGnt8m1n81t uq/L, sl1a. .sA. 2" .". ~ I!!!Q!II ~ -1jlOOC t~!~;l ~m! ...I!!.-
I. Anenle 0-12 10-24 $-25 10-11 2-10 U
2. 8arlum 2'8-7210 19-261 50-nOO 28-416 47-' n-S} Z
J. Lead o-In 0-'2 2.4..2)0 '-41 4.4-28 0- .7(.
.4. M8fIIJeneae 512-54,800 6]0-2410 %]-1160 5-118 18- S 64-420 ,
5. Nickel 61-4" '.6-18 98-202 41)' 5-1, 0-9.1 0-2
6. Zinc 24-21)0 )5-124 '-9J1 U-2070 11-62 4-14
1. 8.to Redlatlon ))-144 .'.4
8. T rlchlarethy'''''' 6.J 4.7 ... 1,100 I.G6 1211 1'111 2.1
9. T oluen. )-11 J 25-21 D 520 0.8" J911 Q~I U
10. Xylon. ,-, 10-U n 8-10 , 180 . 0.88 1611 ,/.11" 0.011
11. DI-N-Oct,lphthaiat. 141< 8 188-1160 1.2' 0.285 0.'" 4'J,t.')) 11.06.1114 L - III.
11. Z-He.enane 1-61 4 ZJ 98 I )),000 0.8' "'.8 II. '611 J.1
U. 1-8utanone 10-18 140-'90 80 24 125.000 0.8110 '.II~ ".Wl 5.64
14. BI. CZ-ethylhe.yU .-.u~ .'-1161 "-160 zn- 62 120-895 2700-5200 ".01 0.4 0.'» 41,01111 5..hlll" -1
Phthal.t.
15. AceUc Acid .a. 22-546 71-112 2D 2SZ,6J l.tt4'J 16.~ II. '>11 4.4'J
Methyl..ter
. Only one r."denUal well wa. &ated ror redlatlon
.. Concentration In nlhl..dlment.. It I. 1n'mg/IcCJ for II18t8l. end uglkg for OI'CJ nlc I.
o'
t Thi. vapor pre..... I. at 200 C
K
L
'UlpltCted concentration
I... then
-------
-9-
to ambient air, with the contaminated air moving offsite, has not been
observed at the Moyer Landfill Site. Surface water runoff mixed with
contaminated 1eachates emanating from the deposited wastes at Skippack
Creek, may affect the environment and surface waters of Skippack Creek,
and, consequently, may have a possible impact on the human health and
. aquatic environment.
.Potentia1 receptors include nearby users of groundwater for
drinking and all other purposes, persons using local surface waters for
recreational purposes, food grown in nearby fields, and persons eating
grazing animals fed from nearby fields. They include consuming milk
of animals fed from'nearby fields, consuming aquatic biota in affected
surface water, terrestrial fauna using affected aquatic animals as a
food source, vegetation that may be stressed, and onsite remediation
workers. Although the residential wells adjoining the Moyer Landfill
. Site were not contaminated at the time of sampling, the monitoring
wells on the western boundary of the landfill site did show contamination
from high levels of lead, barium, and arsenic. Beta radiation is also
suspected at the landfill. There are no nearby residential wells in
the direct path of leachate flow, which use water for drinking or any
other purposes. .
Individuals at risk for exposure due to Beta radiation and other
organic and inorganic contaminants would include remedial construction
workers or persons trespassing the site, who may encounter the compounds
emanating from the seeps or' leachate streams. However, this exposure to
contaminants would present concentrations in the environment of brief
duration. Ingest,ion of low doses of Beta radiation (Technitium - 99)
could be avoided by proper health and safety provisions for the workers
operating at the site.
ALTERNATIVES EVALUATION
Table 6 presents a brief comparison of all alternatives included in
this document. The major objectives for remedial action to be taken at
the Moyer Landfill site are to mitigate or eliminate environmental con-
tamination through collecting and treating leachate from the landfill
and capping the site to control leachate generation and soil erosion.
The overall strategy is to mitigate and minimize harm to the public
health and the environment. This should include minimizing further upper
aquifer contamination and the possibility of direct contact with the waste.
Leachate control is an integral part of the overall scheme in order to
eliminate the continuing migration of contaminants across the site and
off the site to the Skippack Creek. Implementation of these measures
will benefit both the health of the local residents, as well as the
environment. Contamination of the food chain will be eliminated by
both the prevention of contact with the waste areas as well as the
prevention of leachate migration into the local water courses.
-------
j
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-------
-10-
The NCP specifies that remedial alternatives should be classified
either as source control (40 C.F.R. 300.68(e)(2» or offsite (management
of migration) remedial actions (40 C.F.R. 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. Offsite
remedial actions address situations in which the hazardous substances hav~
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 identified for consideration in each.-
response action. Available technologies were then screened to eliminate
all but the most definitive and impiementable alternatives. ~his
screening included: technical (site conditions or wastes characteristics},
environmental and public health, institutional, performance and cost
criteria.
Certain response actions and technologies were not associated with
any specific remedial objective or feasible technology for this site.
These technologies and response actions and the rationale for not
including them are listed on Table 7. Further detail of this initial
screening is included in Section 12 of the Remedial Investigation/Feasibility
Study.
I.
1
Those technlogies which passed the technology screening process
were used to form remedial alternatives. Remedial alternatives were
developed 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.
In order to study a wide range of responses at this site, at least
one alternative has been proposed and developed in each of the five cate-
. gories suggested in US EPA Guidance Document for Feasibility Studies
Under CERCLA. Also, the Receiver Remedial Action Alternative (RRAA)
sugges~ed and prepared by the receiver attorney fortbe Moyer Landfill
Site, is included. A brief description of theBRAA and those of the
five categories is given as follows.
.
Receiver Remedial Action Alternative
The receiver proposes to meet all applicable standards by the
. implementation of a closure plan that includes among other
things collection and treatment of leachate, 80il cap, security
measures and a methane gas system. It is indicated that the
'revenues available to the receiver shall be used to remediate
the site. The Receiver's RRAA is presented in Section 13.1 of the
RIIFS as such.without any comments.
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-11-
TABLE 7
Rationale for Eliminating
Various Technologies
Response Action
1.
Alternative Water Supply
2.
3.
GroundWater Barriers
Ground Water Collection
4.
Source Reduction
5. .Incineration
Rationale for Elimination
No Residential Wells
Contaminated
Not Feasible
Not Feasible
-
Impossible to Identify
"Hot Spots"
Incineration Period
Estimated to be about
30 Years, Very. Expensive
Inadequate Cleanup
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-12-
o
No action:
activities. -
No-action alternatives could include monitoring
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 do not
attairt all of the applicable or relevant standards (This
category may include an alternative that closely aproaches but
does not meet the level of protection provided by the applicable
or relevant standards). .
o
Alternatives that meet the CERCLA goals and attain all applicable
or relevant federal public health or environmental standards,
guidance, or 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 EPA
standards.
. The ev~luation criteria selected were: tech~ical feasibility, public
health, environment, institutional evaluation, land 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 EnviTonmental Impacts
. Protection of Natural Resources
- Institutional Evaluation
. tegal Requirements, Institutional Requirements
, . Community Impacts
- Cost Effectiveness
. Capital Costs
o Operation and Maintenance
. Present Worth Values
o Sensitivity Analyses
Cos ts
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-13-
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 alternat~ves.
Description of Remedial Alternatives
Receiver's Remedial Action Alternative (RRAA)
The Receiver's Remedial Action Alternative (RRAA) is intended to
accomplish the closure of the facility using best engineering judgement
to select technologies to address problems at the site consistent with
requirements and objectives outline in the National Contingency Plan
(NCP). In particulaT,the program is designed to avoid significant
adverse environmental impacts, while at the same time providing adequate
control to keep chemicals onsite or to prevent their offsite migration
at levels having a detrimental and adverse effect under minimal circum-
st~nces of threat or harm to public health, welfare or the environment.
In this connection, the RRAA takes into consideration:
1.
the extent to which chemicals are a danger to public health,
welfare or the environment.
2.
the extent of ~hemical migration.
3.
previous experience in similar situations, and
4.
environmental effects and welfare concerns.
The ~ can be classified as a phased source control remedial action.
The RRAA provides for an interim soil clay cap as indicated under
the section entitled "Soil Cap" composed of a material having a permeability
of 10-4/10-5 to a depth of 36" which will substantially reduce rain
water infiltration into the landfill site. Also provided will be surface
water collection and discharge to the Skippack Creek, long term ground
water and surface water monitoring, collection and treatment of residual
leachate, extraction, scrubbing and upgrading of methane gas for delivery
to the Philadelphia Electric Company (PECO) instead of gas venting to
the atmosphere.
The provision of the interim soil clay cap will partially reduce the"
problem of erosion of existing ~over material and minimize transmission
of contaminated material from the landfill site. It will also partially
reduce the generation of rain induced leachate by decreasing rain water
infiltration into the landfill. .
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-14-
The leachate collection and treatment system proposed in the RRAA
are designed to intercept leachate for the entire periphery of the
landfill. The leachate collected will be treated at a plant constructed
as the site with the effluent subject to a NPDES permit discharged to the
Skippack Creek. After completion of methane gas collection, the site will
be closed in compliance with RCRA standards. .
Ground water monitoring, storm water management and erosion and
sediment control together with site security as proposed by the Receiver
are intended to meet all requirements applicable to the site.
Methane Gas Recovery
Information supplied by the EPA and independent measurements at the
site indicate that solid waste tonnage present may range from 4 million
tons of useable wastes up to 5.8 millions tons. Of these tonnages, ~
significant amounts are belived.to be composed of sewage sludges and
other similar wastes rich in gas production potential.
Assuming that 4 million tons of solid waste are present at the site,
Mandeville & Associates (M&A) estimates that approximately 1.5 million
. cubic feet per day of raw landfill gas ,can be generated for a period of
close to a decade. Additional tonnages, not accounted for, could permit
the production of greater amounts of landfill gas.
The 1.5 million cubic feet of gas per day is estimated to have a
methane content of 58%, and, after processing, approximatelY,625,000 cubic
feet to 700,000 cubic feet of pipeline standard gas per day could be
available for introduction into the PECO pipeline. Such production
numbers would be dependent upon various contingencies including:.
1.
Confirmation of gas availability from the landfill~
2.
The usage of available methane gas to run the facility, and
3.
Efficiency of the gas separation system.
At present, M&A is considering producing a high Btu gas (950 Btu's
per standard cubic foot) comparable to processed natural gas for sale to
PECO through the use of Monsanto PRISM gas separators. These separators
incorporate proven technology to upgrade and "clean" the methane gas
extracted from the site in order to produce pipeline quality gas. Addi-
tional processing steps may be required in the event that trace elements
of certain hazardou~ materials are found in the gas.
Tbe system will include, among other things, construction of a system. '
of gas collection wells toge~her tied into a common manifold, gas compressor,
membrane separators (the Monsanto PRISM separators), gas monitoring system,
gas pre-trea:er, control building, pipeline to PECO, gas measuring equipment,
and fencing security system. .
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-15-
Current capital for the proposed gas facility is $2,873,000, including
special contingencies relating to gas production at a superfund hazardous
waste site.
Projected annual operating and maintenance costs attributable .to the
gas processing facility are anticipated to be $332,000, a certain portion
of which are attributable to operations at a site containing hazardous waste.
Test wells drilled by SHC Martin at the site in 1983 provided certain
data concerning contaminants in the gas other than C02' Although the.
gas appears "clean", the gas generated at the Hoyer Landfill may contain
trace amount~ of toxic volatiles. To the extent that additional contaminants
are found, it will be feasible to install gas pre-treatment (carbon bed)
equipment to assure the delivery of gas to the pipeline meeting PECO
specifications. These contaminants will be treated. .
A. complete description is enclosed in the draft Addendum to the
Remed~al Investigation/Feasibility Study.
Summary of .RRAA
The RRAA defines the full scope of remedial work to be performed in
the immediate future. It contemplates broad remedial work and its
implementation will depend upon the success of the gas generation/recovery
program and the contributions from generators and other potentially
responsible parties (PRPs). The gases generated at the Hoyer Landfill
site are most likely to contain trace amounts of toxic volatiles and
gases; volatiles if any, will be properly treated. The economic
viability and public acceptability of the. gas recovery program is a
proven concept in present practice in other parts of the U.S. As proposed,
this program will meet the NCP criteria of a corrective action planned
for a hazardous waste site. The contamination at Moyer Landfill site
requires remediation to mitigate the public health and environmental
concerns; the gas recovery program and leachate collection system will
address and remediate the concerns. After completion of methane gas
collection, the site will be closed in compliance with RCRA standards.
The following remedial alternatives and sub-alternatives below have
been prepared by IMS Engineers for the EPA. A detailed description and
evaluation of each alternative are pres~nted as follows:
, 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 _onitoring program would be
established to provide information on contaminant concentration remaining
and extent of potential migration. The monitoring program would include
ground water, surface water, sediment sampling, and respective analysis.
-------
-16-
-
The Remedial Investigative work confirmed the presence of heavy
metals and the organic contaminants of concern in the monitoring wells,
creek waters, leachate samples, sediments and fish. Some of these
contaminants are arsenic, barium, lead, nickel, zinc, trichloroethylene
(TCE), toluene, xyle~e, di-n-octylphthlate, 2-hexanone and 2-butanone
methylethyl ketone (HEK). Besides, the shallow aquifer on the west and
southwest of the Moyer Landfill exhibits contamination with Beta radion-
uclides, lead, ana barium. Therefore, the no-action-monitoring program
should include analysis for all contaminants. Since fractures in the
geologic formations can provide a pathway for migration of c~ntaminants
in~o the lower aquifer, it is necessary to monitor the ground water. The
lower aquifer was not found to be contaminated. Monitor wells constructed
during the RI phase of this study could be used for monitoring migrating
contaminants downgradient from the site.
Surface waters are potential receptors for leachate that seeps from
the deposited wastes. Also the shallow (upper aquifer) ground water has,
a potential for contaminating nearby surface waters. These surface waters
may be used for bathing, irrigation, lawn watering and recreational uses
as well as providing a habitat for aquatic organisms. Under these cir-
cumstances, the sampling stations should include the creek, some selected
residential wells and monitoring wells constructed during the RI phase of
the study.
Notwithstanding that the RI study showed none of the residential wells
were contaminated, monitoring of selected residential wells is vital since
the water is being used for human consumption. ,The residential we,Us re-
commended for monitoring are 1, 6,7, 11, 16 and 19 as shown in figure'
6. Due to seasonal variations, sampling and analyses should be conducted
at least once every three months. For costing purposes, it is assumed'
that this program would be continued for 30 years.
This alternative will not reduce or eliminate any of the impacts re-
sulting from the landfill. It will be effective in providing information
about the movement of the contaminants, so that, if necessary, future re-
medial actions could be taken. The site would continue to be a source
of contamination. This landfill will continue to produce leachate that
will cause ground water to continue to exceed 10-6 risk levels offsite.
The possibility of the public coming into direct contact with the hazardous
substances or leachate would remain. Contamination of nearby surface
waters would continue as leachate flows unche~ked offsite. There would
be no capital costs for this alternative.
Alternatives that meet the objectives of CERCLA (BAAl)
Alternative No.2 - Soil Cover with Surface Water Collection and Discharge,
Long-Term Leachate Collection and Treatment and Long-Term Ground Water
Surface Water'Monitoring.' .
B.
"
-------
i
I
This alternative proposes to collect surface water from the landfill
site and proposes to .discharge to the Skippack Creek. It proposes to
collect leachate up to 0-30 feet depth for the entire periphery of the
landfill. These vary from a minimum .of 5 feet depth on the Northeast
boundary to a maximum of 30 feet depth on the western boundary of the
landfill site. It is presumed that up to 50% of leachate generated.
might be intercepted by this alternative. In order to assure a much better
interception of leachate (80%), it is proposed to intercept leachate up
to 60 feet dep.th from the western boundary of the landf1ll site. The
depths of interception of leachate on the other parts of the boundary of
the landfill stay the same. The leachate collected could be treated at a
plant constructed at the Moyer Landfill Site and the effluent discharge
to Skippack Creek. As an alternative, the leachate could be transported
to Oaks.Sewage Plant or the Valley Forge Sewage Plant for treatment and
discharged along with the plant effluent for the purposes of evaluation
of this alternative and more specifically development of costs.
Remedial Action Alternative 2 will be sub-divided as follows:
RAAl.I Leachate collection up to a maximum of 0-30 feet and leachate
treatment at Moyer Landfill Site.
o Soil cover, 4 feet thick (including top soil for vegetation)
o Surface water collection and discharge to Skippack Creek
. Leachate collection at depths up to a maximum of 30 feet
o Leachate treatment at onsite treatment plant
BAAl.2 Leachate collection up to a maximum depth of 0-60 feet and
leachate t.!eatment at Moyer Landfill SHe.
o Soil cover, 4 feet thick (including top soil for vegetation)
o Surface water collection and discharge to Skippack Creek
o Leachate collection up to a maximUm of 60 feet
o Leachate treatment at. onsite treatment plant
BAAl . 3
o All items similar to RAA2.I. except that leachate is collected.
transported and treated at Oaks Sewage Treatment Plant.
BAAl.4
o All items similar to RAA2.2 except that leachate i5. collected,
transported and treated at Oaks Sewage Treatment Plant.
RAA2.5
o
All items similar to BAAl.I except that leachate is collected,
transported and treated at Valley Forge Sewage Treatment Plant.
-------
-18- '
RAA2.6
o
All items similar to RAA2.2 except that leachate is collected,
transported and treated at 'Valley Forge Sewage Treatment Plant.
I
Soil cover has been demonstrated to be a fairly effective method of
excluding a substantial portion of rainwater from the wastes that are
being covered with soil. The expected useful life of the cover system
proposed herein is unlimited if the soil cover is properly maintained.
This can be accomplished by filling in natural,soil for any settlements
caused in the line and grade of the cover. Also proposed unit processes
for treatment of leachates are conventional technologies and are known
to perform ad~quately. '
Percolation of precipitation into the fill and into the waste would
be reduced by the proposed soil cover; however, leachate will contin~e to
be generated. The leachate collection and treatment will considerably
reduce the ground water contamination. Therefore the ecological receptors
will have reduced exposure to the contaminants. It is assumed ,that a
larger percentage of the leachate will be collected by using this alter-
native; however, if meticulous maintenance is not carried out periodi-
cally, there is always the possibility that cracks may occur during the
summer months and the leachate may eventually bleed out. Also tnis alter-
native does not take care of the leachate that might percolate below the
depths the leachate is intercepted. Even though it can be argued that the
contribution will be only miminal, this alternative does not resolve the
, grOund water contamination completely. Emis~ions' and discharges from the
leachate treatment process units should not adversely affect the environment
or ecological receptors if their operation meets regulatory permit levels.,
This alternative provides a distinct improvement in the protection of
ground water and surface water recept'ors compared to RAAI (Remedial Action
Alternative 1). The RCRA requirements stipulate provision of a soil cover
that should be less permeable than the bottom of the landfill. From this
standpoint, this alternative does not comply with the" current RCRA require-
ments. However, this alternative does reduce the contamina,t,ion of ground
water which is a major CERCLA requirement. The discharge requirement
levels will be met by way of leachate treatment. '
The capital costs of construction, annual operation and maintenance
, \ "
costs, present-worth of operations and maintenance costs for 30 years and
the total present-worth cost are presented in detail in the RI/FS. These
costs estimates incoprorated the sensitivity analysis for those items of
work, the costs of which are likely to vary during implementation of this
alternative. Depending upon the sub-alternative, the capital costs of
construction vary from $10,557,500 to $23,881,500, the annual operation
and maintenance costs from $254,300 to $327,000, and the total present-
worth costs including present-worth costs for operation and maintenance
for 30 years, varies from $13,085,000 to $26,812,100.
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-19-
C.
Alternatives that Satisfy All Applicable Standards (RAA3)
RCRA Cap with Surface Water Collecti'on and Discharge to Skippack Creek,
Gas Venting and Short-term Ground Water and Surface Water Monitoring.
This alternative provides for a RCRA cap to essentially eliminate
t~e rainwater infiltrating into the landfill site. It also provides
surface water collection and discharge to Skippack Creek, short-term
ground. water and surface water monitoring, and gas venting to the atmosphere.
This alternative does not provide for collection and treatment of residual
leachate that will be trapped once this RCRA cap is installed. Provision
of this cap Will stop the problem of erosion of existing cover material
and minimize transmission of contaminated material from the landfill
site. Compared to RAAl, this alternative will substantially reduce the
generation of the rain-induced leachate by preventing rainwater
i~iltration into the landfill.
The U.S. Army Corps of Engineers (Hydrologic Simulation on Solid
Waste Disposal Sites) has developed a computer model to estimate the
amount of leachate generated by the movement of. water through a multi-
layered system similar to the one that is being discussed here. Ithas
been demonstrated. that such an impermeable cap is extremely efficient in
diverting water away from the soil beneath it. On an average, 95 percent
of the precipitation that falls on the area.of infiltration-control would'
be diverted before it reaches the soil beneath the cover system.
The soil layers that are being contemplated for this alternative are
much more stringent and thicker than the soil cap described in RAA2. Therefore,
the quantity of leachate that is expected to be generated i8 negligibly
less due to the soil-clay cap option proposed here.
Theoretically, the quantity of leachate to be treated would be the
residual leachate that is captured within the site due to the construction
of the cap. For all practical purposes, that water that is percolating
through the landfill is assumed to be just enough to saturate the landfill
wastes, but practically no excess leachate bleeds out; it is the excees
leachate that normally bleeds out, and in this theoretical case, there
would be no excess.
This frequently applied capping technology has demonstrated the
ability to effectively eliminate infiltration and minimize' subsequent
leachate generation. Capping is perhaps the most consistently recommended
remedial technology for waste disposal sites. Gas collection and venting
are also reliable, remedial technologies.
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-20-
Maintenance of this alternative is relatively minor and straightforward.
O&M for RAA3 is considerably less than O&M for RAA2. Periodic inspection
of the soil and vegetative cover and of the gas collection system will be
required to ensure proper operation. Any problems resulting with the gas
collection systems or the cover layer" must be corrected. "Post-closure, .
ground water monitoring, and analysis will also be required for this
alterna~ive.
Under this alternative it is not proposed to collect the leachate
that may be given off by the waste material trapped under the RCRA cap.
These wastes have a high moisture content, and would be expected to
produce leachate for five to ten years. This leachate will be continuously
discharging into the ground and or surface water. The discharge of
leachate into surface water is not, however, through the surface run-off
but leachate' discharges into the Skippack Creek through ground water.
All hydrogeological evidence indicates that the creek acts as a sink ~or
the ground water'from the landfill site. The impact of this leachate on
ground water and surface water and other environmental and ecological
receptors ~annot be estimated at this time. Realistically, a major
concern that remains is that the upper aquifer might be infiltrated
laterally as well as vertically. if this is" the case, the site will
continue to generate leachate that could migrate into the lower aquifer
through fractured bedrock. However, the implementation of this alternative
does have the provision for ground water and surface water monitoring.
This provision will assist in making an assessment if the environment
is effected in the future.
Soil having permeability of less than 10-7 cm/sec. is not available
in the vicinity of the site. The closest source for the clay i8 at a "
distance of more than 20 miles. " This factor will significantly increase
the cost of this alternative. However, the other major components and
ancillary needs for contruction of a cap are obtainable close to the
site. There are no internal site restrictions that would prevent a timely
completion of this technology. Implementation of this alternative is
more efficiently performed during dry weather and could be completed in a
6-month period from ~ay to October. Scheduling of materials, labor, and
equipment should be done so that they are available onsite when needed.
The capital costs of construction, annual operation and maintenance
costs, present-worth of operation and maintenance costs for 30 years, and
the total present-worth costs are presented in detail in the RI/FS. "
These cost-estiamtes incorporate the sensivity analysis for those items
of work, the costs of which, are likely to vary during the implementation
of this alternative. The capital costs of construction for the alternative
vary from $16,777,700 to $20,506,000; the annual operation and maintenance
costs vary from $222,300 to 271,700, and the total present worth costs,
including present-worth costs for operation and maintenance for 30/5
years, vary from $18,290,100 to $22,354,400. "
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D.
Alternatives that Exceed All Applicable Standards (RAA4)
This alternative contains all the provisions made in RAA3. It also
proposes the following additional provisions under this alternative: .
o Residual leachate will be collected, treated, discharged.
The residual leachate will be collected and treated in the same
manner as the leachate generated, collected, and treated under Remedial
Action Alternative 3. Additionally, included in this alternative is the.
collection of leachate from 0 to 30 feet and 0 to 60 feet. For the.
purposes of e~aluation of this alternative and, more specifically, for
the development of. costs, the RAA4 will be divided as follows:
RAA4.1
o Miscellaneous work preparatory to installations of RCRA cap:
grading, flattening of steep slopes, retaining walls and installa-
tions of rip-rap at the areas that are most likely to be eroded.
o Surface water collection and discharge to Skippack Creek
o Leachate collection between 0 to 30 feet depth and treatment
at Moyer Landfill Site. .
RAA4.2
o Same as RAA4.1 except the leachate shall be collected between 0 to
60 feet.
RAA4.3
o Same as RAA4.1 except the leachate will be treated at the Oaks Sewage
Treatment Pla.nt.
RAA4.4
o Same as RAA4.2 except that the leachate will be treated at the
Oaks Sewage Treatment Plant.
.RAA4.5
o Same as RAA4.1 except that the leachate will be treated at the
Valley Forge Sewage Treatment Plant.
RAA4.6
o Same as 1AA4.2 except that the leachate will be treated at the
Valley Forge Sewage Treatment Plant.
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,~
In spite of the fact that interception of the maximum amount of leachate
is proposed, (an estimated 80%), it may not be possible to collect all the
leachate. However,some leachate will still percolate to ground water.
Based on,tbe findings of the RI, 2% of the uncaptured leachate would migrate
vertically and the other 18% would discharge into the creek. Short-term
ground and surface water monitoring might help assess the impact and also
indicate any potential future monitoring.
Under this alternative, the leachate would be collected and treated
to meet the 10-6 risk levels in the ground water and discharge requirements
in the stream. This is estimated to take 5 years. Secondly, the quantity
of leachate ~hat is expected to be generated under alternative RAA4 is less
than 50% of what would be generated under RAA2 (15,000 gpd vs. 30,000 gpd),
unless the upper aquifer is being recharged laterally.
As pointed out under RAA3, soils having permeability of less than 10-7
em/see are not available in the vicinity of the site. The closest ,source.of -
supply of the required cover material is at a distance of more than 20 miles.
This will consequently greatly increase the cost of -this alternative. However,
the other major components and ancillary needs for construction o~ a cap are'
obtainable close to the site. There are no local site restrictions that'
would prevent a timely completion of this technology. Implementation of this
alternative is most efficiently performed during dry weather and could be
completed in a 6-month period from May to October. Scheduling of materials,
labor, and equipment should be done so that they are available onsite when
needed.
The public and environmental health benefit of this alternative has been
discussed in RAA2.
The cap will comply with current RCRA requirements, which require that
the cap should not be less permeable than the bottom of the landfill. The
regulations also require elimination of ground water contamination, which
this alternative addresses through residual leachate collection and treatment.
As part of RCRA requirements for closure of existing land disposal facilities
(part 265), RCRA provides that no synthetic liner is required if the unit
does not have synthetic underliners to effectively control the quantities of
leachate produced presently. Monitoring of ground water and surface water,
leachate treatment, and maintenance of the cap would be part of the operations.
This alternative exceeds all the instituti~nal requirements, with no additional
public or environmental benefits. . -
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13.4.4.6 Cost
, ,
The capital costs of construction, annual operation and maintenance
costs, present-worth of operation and maintenance costs for 30/5 years and the,
total present~worth cost are presented in detail in the RI/FS. These cost'
estimates incorporate the sensitivity analysis for those items of work, the
costs of which are likely to vary during the implementation of this alternative.
Depending upon the subalternative, the capital costs of construction will
vary from $21,200,000 to $36,585,300, the annual operation and maintenance
costs vary from $287,700 to $371,410, and the total present-worth costs
including present-worth cost for operation and maintenance for thirty/five,
years, will vary from $23,912,500 to $40,153,100. '
,E. Alternatives that Specify OffsiteDisposal (RAAs)
This alternative consists of constructing a new RCRA landfill site
on an area of land adjacent and upstream of Moyer Landfill Site. The ,-
waste materials shall be excavated from the Moyer Landfill Site and
disposed of at the new landfill site. The existing site shall be minimally
graded and revegetated. Ground water and surface water monitoring programs
as in other alternatives, shall also be implemented for a period of five
(5) years. '
The Moyer Landfill Site currently covers approximately 61 acres of
which about 43.5 acres has been used for depositing waste materials. For
all practical purposes, the wastes are assumed to be dumped randomly all
over this 43.5 acres of land. The maximum elevation at the landfill is
493.5 feet. Different sectional views of the Moyer Landfill Site were
drawn in order to compute the total volume of the material contained in
the site. The volume of wastes buried on the site is computed to be
approximately equal to 1.8 million cubic yards.
Placing these wastes into a new secure landfill involves excavation ~nd
hauling waste material from the Moyer Landfill to a nearby onsite RCRA-approved
landfill. Contaminants would be released from the disturbed landfill through
volatilization, which would lead to possible air pollution. The level of
pollution will depend upon the location and the type of wastes buried at the
8ite and climatic conditions during excavation and transport of wastes.
Specialized construction/excavation techniques would have to be developed'to
mimiu1ze the amount of air pollution. The techniques under consideration are
the use of a temporary liner over excavated portions of the landfill and
covered trucks during.any type of transportation. Excavation and hauling
would take place 16 hours each day to minimize the length of time the material
is to be exposed. The excavation of the fill can be accomplished with power
.hovels. If, during excavation, any saturated material is removed, it will,
be deposited on the road by draglines. ' This wet trash will be picked up and.
moved to a dewatering pad for sub.equent disposal. Water from the dewatering
pad will be conveyed and mixed with residual leachate that is otherwise being
treated and discharged into Skippack Creek.
/
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-24-
Long-term operation of an onsite disposal facility, such as the one
described here, increases the risk of cancer, chronic health effects, and.
acute health effects to offsite receptors. This occurs becuase of the
potential for emissions during storage of the waste, following excavation and
prior to processing. A similar increase in risk to users. of offsite surface
water can be expected if discharges from the wastewater treatment plant exceed
the applicable health and safety water quality criteria.
Excavation of the landfill poses the highest potential for deleterious
environmental effects during the implementation of the alternatives
previously discussed. The level of increased risk cannot be quantified.
However, two.major factors that tend to increase health risk and'
environmental damage under this alternative are:
-Construction activity will be more intense and of greater duration
. during any of the previous options,
.
- The concentrated waste will be exposed to the environment and
handled rqutinely for a considerable length of time.
The capital costs of construction, annual operation and maintenance
costs,' present-worth of operation and maintenance costs for 30/5 years and
the total present-worth cost are presented in detail in the RI/FS. These
cost estimates incorporate thesensivity analysis for those items of work,
the costs of which, are likely to vary during the implementation of this
alternative.
Recommended Alternative(s)
Section 300.68(j) of the National Contingency Plan (NCP) [47FR
31180; July 16, 1982} states that the appropriate extent of remedy shall
be determined by the lead agency's selection of the remedial alternative
which the agency determines Iscost-effective (i.e., the lowest cost alter-
native that is technically feasible and reliable) and which effectively.
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.
Recei ver' s Remedial.' Action Alternative
Based on the evaluation of the proposed alternatives, the comments.
received from the public, information from the Feasibility Stu~yand informa-
tion from PADER) the Receiver's Remedial ActiQn Alternative (RRAA) can be
. implemented at the Moyer Landfill Site. This phased remedy will satisfy all
of the contamination objectives identified in the Remedial Investigation at' ,
the point of closure (10 to 20 years). '
The proposed gas recovery system will collect, clean and upgrade the
methane gas generated in the Landfill instead of venting it to the
atmosphere. and provide energy for the operation of the leachate treatment
plant. The receiver will receive royalties from the sale of the gas to
PECO which will be applied toward the overall closure cost. .
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The leachate collection system and treatment plant will eliminate
the offsite migration of untreated leachate into adjacent surface water~.
. The placement of a soil cov~r with a permeability of 10-4/10-5 cm/sec.
will allow the most efficient recovery of methane gas, and still reduce
the generation of leachate to. be collected and treated. At the conclusion
of the gas recovery program theRRAA provides for the 'construction of an
additional cap which will meet RCRA standards. The ground water monitoring
program will assure that necessary environmental standards are met.
It is contemplated by theRRAA that capital financing costs for the
leachate collection system and treatment plant, soil cap, soil erosion
program, securi~y and fencing, the methane gas recovery facilities and
all other related capital expenditures will be financed through limited
partnership investment, bank financing and other capital contributions.
Operating and maintenance costs relating to the methane gas recovery.
system (exclusive of those costs relating to the hazardous waste aspect
of such O&M) will be paid out of gross revenues generated from the
production and sale of methane gas at the facility. Operating and
maintenance costs for the leachate collection and treatment system and
other rela~ed costs including maintenance of the soil cap~ a portion of
security and fencing, debt and/or lease rental payments relating thereto
will be paid for by the PRPS and out of royalty payments due the receiver
from the methane gas recovery program. .
Capital investment for
range from approximately $2
with payment subject to the
quality gas for delivery to
PECO.
.
the methane gas recovery program, expected to
million and $2.5 million, will be .at risk
ability of the project to generate pipeline
PECO pursuant to the contract betwen ERP and
Revenues generated pursuant to the PECO contract are based upon the
amount of gas sold to PECO, paid for at the rate of 90% of the then
current Transco gas pipeline tariff. At the present, said tariff is
$3.55 per 1000 cubic feet of gas. ERP estimates that tariffs in effect
at the time of initial gas production in early 1986 will remain at such
level until 1987. Thereafter, annual price increases of' 5% are estimated.
It is anticipated that these gross revenues will be sufficient to
cover operating and maintenance expenses for the methane gas recovery
program, enable ERP to make necessary debt service payments and to prove
a fair return to its investors. . .
Capital expenses for the non-methane gas recovery portions of the
IRAA base cost is to be $3,425,500 million. Debt service on these amounts,
and operating and maintenance cost relating thereto will be paid for by
the PRPS pursuant to a closure agreement that provides security sufficient
to assure that required payments will be made.
The security for such payme~ts may include, provision of operating and
debt service reserve funds, letters of credit, or corporate guarantees as
appropriate under the circumstances.
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-26-
To the extent that the receiver's interim remedial measures are
insufficient to accomplish the permanent closure of the site in accordance
with applicable environmental standards. theRRAA includes provision that
the PRPS will furnish such additional funds as may. be necessary to. close
the site consistent with the remedial action alternative described below
and will post a bond or other security sufficient in amount to make
nec~ssary additions and alterations to the existing interim remedial
measures so as to permanently close the site.
The above financing program contemplates initiation of design and
construction of the facilities on a fast track basis which will allow
the methane gas generation system to be in operation in early 1986 and
the leachate treatment facilities to be operational by the summer of
1986.
The RRAA defines the full scope of remedial work to be performed in
the immediate future. . It contemplates broad remedial work and its imple-
mentation will depend upon the success of the gas generation/recovery
, program and the contributions from generators and other potentially
responsible parties (PRP). The gases generated at the Moyer Landfill
site are most likely ~o contain trace amounts of toxic volatiles and
gases; the gas will be cleaned to pipeline quality and toxics. if any.
will be properly disposed. The economic viability and public acceptability
of the gas recovery program is a proven concept in present practice in
other parts of the U.S. As proposed. this program will meet the NCP
criteria of a corrective action planned for a hazardous waste site. The
contamination at Moyer Landfill site requires remediation to mitigate
the public health and environmental concerns; the gas recovery program
will address and remediate the concerns.
If-negotiations with the PRPs fail and/or the methane gas generation/
recovery program fails, we recommend Remedial Ac~ion Alternative ~ with
a modification to the cap, be implemented at the Moyer Landfill Site.
This remedy will satisfy as well all of the contamination objectives
identified in the Remedial Investigation.
Alternative 4
The modified Alternative 4 meets all federal standards. It consists
of a 10-7 RCRA cap without the synthetic liner. with surface water
collection and discharge. leachate collection(ranging between 0-60 feet)
and treatment, gas venting and ground water and surface water mQnitoring.
The cap originally proposed in RAA4 does not provide any additional
health or environmental benefits, exceeds all standards, requires a
lo~er construction period and is not as costeffective as the proposed
10- RCRA cap. In addition, the leachate collection system wi,ll be
designed to .meet the 10-6 risk level in the groundwater and discharge
, requirements in the streams. The depth could vary anywhere from 0 to 60
feet. .
In spite of the fact that interception of the maximum amount of
leachate is proposed. it may not be possible to collect all the l,achate.
Some leachate will still percolate to ground water and also probably, to
a certain extent. through the ground water to the surface water. However.
the quantities of leachate will be so minimal that their exact impact
could not be predicted at this'time. Short-term ground'and surface water
monitoring might help assess the impact and also indicate any potential
future monitoring. .
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The cap will comply with current RCRA requirements, which require
that the cap should not be less permeable than the bottom of the landfill.
The regulations also require elimination of ground water contamination,
which this alternative addresses through residual leachate collection and
treatment. As part of the RCRA requirements for closure of existing
land disposal facilities (Part 265), RCRA provides that no synthetic
liner is required if the unit does not have synthetic underliners to
effectively control the quantities of leachate produced presently.
Monitoring of ground water and surface water, leachate treatment, and
maintenance of the cap would be part of the operations.
The capital costs of construction and annual operation and maintenance
cos ts are as follows: .
5.
6.
Soil/Clay 10-7 Cap *
Run Off Collection and Discharge
Gas Vent System
Access Road for Maintenance
Purpose
Leachate 'Collection **
Leachate Treatment
Total Capital Costs
$9,308,400
330,000
331,800
108,000
4,650,000
6'56,600
$15,384,800
1.
2.
3.
4.
Annual Operation and
Maintenance
343,100
* This cap does not include a 20 mil. synthetic liner.
** Design parameters which directly affect the size of the system and
quantities of the materials required influence costs. Trench depth
is the most cost-influencing factor. The exact depth of the
collection system will be based on coring results developed in
the Design Phase and a fate and transport model to determine the
amount of leachate that needs to be treated to maintain discharge
requirement levels into the Skippack Creek and iO-6 risk levels in
ground water.
Operations and Maintenance
Monitoring and Post-Closure Maintenance activities. are required to
verify the site cleanup, effectively maintain permanent onsite actions,
monitor potential contaminant migration. Detailed costs are itemized in
Volume I Section 13 of the Remedial Investigation/Feasibility Study. All
samples taken will be analyzed for Hazardous Substance List (BSL)
parameters.
Schedule for Alternative 4
Approve Remedial Action (Sign ROD)
Negotiations with PRP Conclude
9/30/85
11/30/85
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Start Design
Complete Design
Start Construction
12/30/85
8/30/86
9/30/86
Evaluation of Alternatives Not Selected
1
The No-Action with Monitoring alternative was not selected since'
soil, sediment, and surface water contamination will continue to pose a
direct contact threat to human health and the environment. ~here would
be a continued migration of contaminants to the ground water, surface
water and re~ease to the air. .
Alternative 2 and subcomponents meet CERCLA goals but fall short of
providing full protection from contamination of shallow ground water.
The soil cover will still allow leachate generation and subsequent
contamination of the ground water. O&M will be more expensive than O&M
in Alternative 4. Permits were unobtainable for offslte treatment.
Alternative
contamination by
does not provide
leachate that is
3 satisfies all ap'plicable standards, reduces further
stopping the generation of fresh leachate. However. it
for the collection, treatment and disposal of residual'
trapped under the impermeable cover.
Alternative 5 was not chosen due to extremely high costs, difficulty
in ~mplementing, safety concerns and lengthy construction duration of
10 to 20 years.
Consistency with Other Environmental Laws
EPA is currently proposing regulations 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. 1300.68(f). . "
.
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)
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-29-
Pennsylvania Clean Streams Act
- Toxic' Substances Control Act (TSCA)
These two chosen alternatives meet NEPA functional equivalency
exception because the necessary and appropria~e investigation and analysis
of environmental factors as they specifically relat~ to the Hoyer Lan~fill
Site. In addition, a meaningful opportunity for public comment on' environ-
mental issues was provided before the 'final selection of the remedial
alternati ves were made.
Compliance with all substantive requirements of the CWA and CAA as
well as the Pennsylvania Clean Streams Act will be incorporated 1nto the
design of the'remedial alternatives. Any discharge into the atmosphere
of gas will be monitored to assure all applicable standards are not exceeded.
Discharge of treated surface ~ater will comply with sppropriate standards.
The cap chosen will meet all of the RC~~ require~ents under 40 C.F.R.
1264.310.
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MOYER LANDFILL RESPO~SIVENESS SU~~~RY
INTRbDUCTION
. The preferred alternatives as described in this ROD generally are
supported by the local community and its leaders. Both residents and
public officials are frustrated by the duration of th~ RIfFS process,
and the relative expediency of the receiver's proposal is seen as its
most desireable feature. The comaunity also has voiced concern that
EPA's "fall back alternative" be ready for implementation if'the
receiver's proposal fails in some way. The only substantive change in
the ROD pr()cess. as a result of community input was an extention of the
comment period from September ,18 to September 23.
COMMUNITY INVOLVEMENT HISTORY
According to available information, the first three decades of Moyer
Landfill history were marked by minimal community interest. However, in
1977, when the operators of the landfill sought t.o expand the site from
44 acres to 185 acres, residents in the vicinity of the landfill joined
together and formed a group called the Lower Providence Concerned Citizens
(LPCC) to fight the expansion plans. In addition to stopping the gro~h
of Moyer Landfill, the LPCC demanded that the existing site be closed.
LPCC concern ()ver what was perceived as the PADER indifference to
citizen's complaints, and to obvious violations of ~tate and Federal
environmental laws at the Moyer Landfill Site, led to the filing of a
civil suit in Federal court in June 1980. The LPCC was joined in this
effort by approximately 100 individuals and several local civic 'and
sportsmen's groups, including the League of Women Voters of the Valley
Forge (Pennsylvania) area, the Valley Forge Audubon Society, and the
Country Boy Bass Association. The original suit named the PADER, as
well as the owners and operators of Moyer Landfill, Inc., as defendants;
but the suit was dismissed. Later, 8 combined suit was filed by the
citizens and organizations mentioned above and the PADER against the.
owners and operators of Moyer Landfill, lnc.
. Although the early years of LPCC existence were marked by difficulties
. with local government, the organization and other residents are pleased
with the present elected officials and report a good working relationship
with them. The community's relationship with the PADER can be characterized
8S cautious. Local officials.and residents were satisfied when the EPA
began investigating the Moyer Landfill Site, but both groups are unsatisfied
with the duration of the RIfFS process and have demanded effective clean up
action as soon as possible. .. .
- 1 -
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COMMENT SUMMARY
This section is divided into two parts:
I.
Remarks and issues voiced during a September 10 public
meeting.
II.
Other remarks and issues concerning the Moyer Landfill
site including those raised during a September 10 briefing
with Township representatives.
I.
. A public meeting was held at 7:00 p.m. on September 10, 1985, at the
Lower Providence Township Municipal Building in Lower Providence
Township, Pennsylvania. The purpose of the meeting was to discuss,
with interested parties, the results of the Remedial Investigation
(RI)!Feasibility Study (FS) conducted by EPA at the Moyer Landfill
site, and to request comments from the public concerning the cleanup
alternatives presented in the FS.
.
There were approximatley 40 individuals in the audience including
representatives from the local newspaper and television station,
various state agencies, contractors who have been involved in site
work, ,the. U.S. EPA, and interested citizens.
Officials hosting the meeting included Tom Voltaggio, Chief of the
Superfund Branch of EPA; Greg Crystall, member of the enforcement
section of EPA; Stephanie Del Re, site project officer of EPA; Ray
Germann, Community Relations Specialist of EPA~ Don Becker, from the
Pennsylvania Department of Environmental Resources (PADER); Joanne
Denworth, court receiver for the Moyer Landfill; arid Fred Ehmann,
representing Energy Recovery Partners.
Attached is a summary of issues and questions raised ~uring the
meeting, and the responses given by EPA.
Public and Environmental Health
ISSUE:
A number of questions pertained to the nature and extent of
contamination at the site. Several citizens wanted to know
. what health risks contamination (i.e., radiation) from the
site posed to them.
RESPONSE:
The remedial investigation report defines the nature and .
extent of contamination at the site. Radiation levels detected
of fsite were below drinking water standards. The main problem .
at the site is the heavy metals~nd volatile organics found
in the leachate that is flowing offsite into Skippack Creek.
The court receiver's remedial alternative would adequately
address the leachate problem.
- 2 -
-------
ISSUE:
RESPONSE:
ISSUE:
RESPONSE:
ISSUE:
RESPONSE:
ISSUE:
Several citizens expressed concern that leachate is entering
the shallow groundwater and contaminating their wells.
Most of the leachate is flowing into Skippack Creek via ground-
water and seeps. The rock formation separating the upper and
lower aquifers is very tight and residential wells' are drilled
below the rock formation. There is very litt~e seepage of
leachate through the rock formation and therefore little
danger of residential well contamination near the site.
Several citizens were concerned about leachate flowing into
the Skippack Creek. They wanted to know what kind of damage
this leachate could be causing to the creek, fish in the
'creek, and child~en playing near the creek. '
EPA has conducted extensive testing of Skippack Creek and has
found only low levels of contamination in the water and in
fish. EPA acknowledges that leachate flowing into Skippack
Creek is a major problem at the site. The recommended remedi~l-
alternative will provide for collection and treatment of .
leachate entering the creek. '
A citizen reported that periodically large trucks drive up
towards the site area at night and, return a short time later.
Is dump1ng still occurring at the site?
'.
The landfill is closed. Dumping has been reported on areas
adjacent to the site. Any specific information on illegal
dumping should be passe~ on to the EPA.
A few citizens were concerned that the proposed gas line from
the landfill would damage, their property.
RESPONSE:. The gas company will negotiate to buy
, 'and if this is unsuccessful, then the
be used. No residents will be forced
through their property. -
private right-of-ways
public right-of-way will
to accept the gas line
EPA Cleanup Process
ISSUE:
RESPONSE:
/
several citizens wanted to know why many studies have been
conducted at the site over the years but nothing has been
done to stop the flow of leachate from the site. Citizens
wanted to know a definitive date when site cleanup would begin.
Studies are lengthy but are required to accurately define the
nature and extent of contamination at the site. Information
from the RIIFS and hydrogeological assessment conducted at the
site will be carefully evaluated by EPA so it can select a
cleanup alternative that is environmentally sound and cost-
effective.EPA is, anxious to begin cleanup wOrk at the site and
encourages public comment,~n the various cleanup alternatives.
EPA will decide on the cleanup alternative by the end of, the month.
- 3 -
-------
ISSUE:
RESPONSE:
ISSUE :
RESPONSE:
ISSUE:
RESPONSE:
ISSUE:
RESPONSE:
IS SUE :
IE SPONSE :
Technical
ISSUE:
RESPONSE:
A citizen wanted to know if the people who are responsible
for contaminating the site will clean up the site.
The responsible parties should definitely playa role in cleanup
at the site. The court receiver's plan would provide for this
by making generators a financial party in any cleanup agreement.
At least 28 potentially responsible parties have been contacted
by EPA. If anyone has additional documentation of other
potentially responsbile parties, EPA would like to have this
information.
A citizen expressed concern whether funding was available to
clean up the site.
EPA will likely sign the record of decision (ROD) at the end of
the month. At that time, potentially responsible parties (PRPs)
have 60 days to enter into an agreement with EPA to help clean
up the site. After this 60 day period, funding is either made
available from PRPs or from EPA if no agreement is made. This
means that funding for site cleanup should be available. in late-
November. This schedule assumes that Congress passes a new
Superfund bill presently under debate in Co~gress.
Several citizens stated that they wanted to be informed of
cleanup progress at the site.
EPA will meet with concerned citizens agaIn in October to
inform them of progress and plans and to address additional
concerns. The court receiver also emphasized that citizen
participation is very important in the cleanup process.
A representative of some of the PRP, wanted to have the comment
period extended to have adequate time to comment on the RIfFS.
The comment period will be extended until September 23.
A citizen expressed the opinion that star wars and the Pentagon
is preventing the Government from adequately protecting the
public air and water. The individual suggested that cost
should not be a consideration in site cleanup.
None
A citizen who lives north and west of the landfill near
Eagle Stream wanted to know why his well bad not been tested.
EPA will investigate this possibility but it is likely that
the well. has been tested and EPAcan find the results In the
, RIfFS document.
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ISSUE:
RESPONSE:
ISSUE :
RESPONSE:
A citizen expressed concern that methane gas will cause the
clay cap to crack.
There will be continuous maintenance of the clay cap.
A citizen was concerned that leakage will slowly occur from
. the upper aquifer into the lower aquifer. . Have recovery wells
been considered to withdraw contaminated groundwater and tp
prevent seepage into the lower aquifer? .
The leachate collection system and RCRA cap will capture most of
the leachate and monitoring will continue to provide informatIon
on conditions in the lower aquifer. Recovery wells were
not considered cost-effective or necessary.
Remedial Action Alternatives
ISSUE:
RESPONSE:
ISSUE:
RESPONSE:
ISSUE:
A citizen wanted to know what will happen if the court receiver's
alternative fails due to a lack of cooperation from potentially
responsible parties. .
EPA has a preferred "fa11 back" alternative which provides for
a site cap, leachate collection and treatment, gas venting and
monitoring. If the court receiver's alternative fails, for
whatever reason, EPA would implement the "fall back" alternative.
A citizen was concerned that EPA's 'fall back" alternative
was dangerous because capping would trap the methane 'gas.
EPA's preferred "fall back" alternative includes a provision
for venting methane gas to stop any dangerous build-up of
gas and to prevent damage to the cap.
A citizen wanted to know what will be done to collect the
leachate seeps in Evan~burg State Park.
RESPONSE: The selected alternative will provide for collection of
leachate from all major sources of generation.
ISSUE:
RESPONSE:
ISSUE :
RESPONSE:
A citizen inquired whether EPA had accepted the court receiver's
alternative.
EPA prefers the court receiver's alternative but has not accepted
it. Public comment is required prior to making a decision. Publi~
comments are 8trongly encouraged by EPA during the cleanup process.
A citizen wanted to know what would happen 1£ something went wrong
after the court receiver's alternative had been implemented and
suddenly money was not available for site cleanup.
EPA requires
cleanup plan
enough money
that there be enough financial backing behind the
so that if something goes wrong there is still
to close the site as required under EPA guidelines.
-5 -
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,.
I
ISSUE:
RE SPONSE : *
Several citizens expressed a favorable opinion regarding the
alternative presented by the court receiver, but wanted to know
when the remedial action could begin.
If EPA approves the alternative, final closure and cleanup plans
could begin immediately. The facilities could be built and put
.into operation by late spring. EPA officials emphasized that.
the court receiver's alternative would allow cleanup to begin
sooner than allowed under EPA"s alternative. .
*
The response to. the comment was made by Joanne Denworth~
court receiver for the Moyer Landfill.
I I.
This section addresses past and present issues not already. included
in the meeting summary.
ISSUE:
RE SPONSE :
ISSUE:
RE SPONSE :
ISSUE :
RESPONSE:
ISSUE :
RESPONSE:
A Township' official was concerned that EPA's plans for cleanup
were not more specific, and that we did not alre~dy have specific
plans for the preferred alternative. .
EPA and lor the receiver will draw up specifications and begin
design after the comment period closes and a ROD is written. The
FS process outlines concepts, but does not draw up specifications. .
A local land owner suggested creating a lined landfill adjacent
to the current site and requiring that, for each ton of new waste
deposited in the lined landfill, the owner be required to accept
one ton from the Moyer landfill,eventually transferring the
entire Moyer landfill into a lined facility.
A variation of this suggestion is included. as an option in the
FS. It would include total excavation over a term of 5-15 years,
and encounter strong resistance from local residents.
Potentially responsible parties were not given adequate time to
comment on the RIIFS prior to development of. the ROD.
The RIIFS was received by PRPs July 24. The comment period ended
Sept. 23. The National Contingency Plan (NCP) calls for a 30-day .
comment period on the RIIFS before..a cleanup alternative is chosen.
The information obtained to date shows that the actual environmental
impact that has occurred and the potential for future impacts do
not represent any tmminent danger to the environment or human health
and safety near the Moyer Landfill. Also, there are several areas
in which the data base and analysis are insufficient.'
While the evidence suggests that there has been little or no tmpact
upon public health or the environment from site contamination to
date, the continued flow of contaminated leachate from the landfill
may pose a future threat to public health or the environment. This
possibility is sufficient to justify remedial action under the
Comprehensive Environmental Response Compensation and Liability Act
(CERCLA) and the National Contingency Plan (NCP). EPA considers
the sampling plan and protocol outlined in the RI sufficient to
accurately gauge potential risks posed by the site.
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ISSUE:
RESPONSE:
The RIIFS evaluates a number of remedial action alternatives. In
general. the environmental benefits which may be obtained from
their implementation have not been identified or weighed against
the risk of potential harm suggested in the RI or against any
risks which may be presented by the alternatives themselves.
Should a comprehensive risk assessment be conducted. it is likely
- that is would ~dentify either RAA-l or RAA-2 as the measures most
consistent wit~ the NCP.
As outlined in the FS, either of the preferred alternatives will
adequately address the flow of leachate off site, thereby
eliminating the future risk to public health or the environment.
EPA believes that the provisions in the preferred alternatives
provide cleanup 'benefits superior to those~ncluded in ot~er
remedial action alternatives.
- 7 -
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.~
Bureau of Solid Waste Management
COMMONWEALTH OF PENNSYLVANIA.
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Post Office Box 2063 -
Harrisburg, Pennsylvania 17120
September 27, 1985
. PENNSYLVANIA
~.
717-783-7816
United States Environmental
Protection Agency
Region III
841 Chestnut Building
Philadelphia, P A 19107
Attention: Thomas C. Voltaggio, Chief
Superfund Branch
.
Moyers Landfill Superfund Site
Lower Providence Township
Montgomery County
Dear Mr. Voltaggio:
Re:
This letter constitutes our response to the Remedial Alternative Selection Summary for the Moyer -
Landfill, which we received on September 26, 1985. It is the Department's position that government
funds should not be utilized for remedial action projects when other monies are readily availab1e
to be used for such purposes. This enables an agency to reserve funds for cleanup situations when
no other sources of relief are provided. In the Moyer Landfill case, we concur with EPA on the
recommended receivers Remedial Action Alternative (RRAA), as discussed on pages 24 through 28
of summary. As a precaution, EPA proposes to resort to Alternative 4 in event that the methane
gas recovery program does not materialize, or fails to accomplish the required remedial work.
This office strongly recommends that individuals who propose to undertake the gas
recovery program provide ample bond to assure that all the remedial work can occur. A proposed
schedule with remedial design phases concomitant with the progress of the methane recovery
rogram should be prepared first. EPA should then consider entering into a binding legal
greement with the PRPs to ensure their commitment to satisfy the entire scope of the remedial
ction, and to perform Operations and Maintenance at the site for 30 years.
We hope that all future activities at the Moyer Landfill will develop to everyone's
tisfaction, and especially to the improvement of the environment. .
Very truly yours,
[kfd'D IV~
Dwight D. Worley, Chief
Div ision of Emergency and Remedial Response
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