United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-86/024
July 1986
EPA
Superfund
Record of Decision
Westline, PA
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TECHNICAL REPORT DATA
(Pleat rtad Instructions on the rtvene btfon completing)
1. REPORT NO.
qPA/ROD/R03-86/024
3. RECIPIENT'S ACCESSION NO.
. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Westline Site, PA
S. REPORT DATE
_ gor»<-omhor
IQflft
«. PERFORMING ORGANIZATION CODE
7. AUTMOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
«. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
* . CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Pt»pr>r<-
14. SPONSORING AGENCY CODE
800/00
IS. SUPPLEMENTARY NOTES
16. ABSTRACT
The Westline Site is located in Westline, Lafayette Township, McKean County, PA. The
site, encompassing approximately 40 acres, is bordered by Kinzua Creek to the south,
Turnip Run to the east, and a wetland area to the west. For the purpose of this
investigation, the northern border extends 250 feet north of the former chemical plant
foundation. Located at the center of the site is a popular landmark, the Westline Inn.
Beginning in 1901, the Day Chemical Company, converted lumber into charcoal, methanol
and acetic acid. The plant changed owners three times before equipment deterioration
and declining profits forced its closure in 1952. Several tar-like deposits from the
wood chemical processing operations remain onsite. The largest deposit was excavated in
September of 1983 by the removal action implemented by the EPA. Another tar deposit,
approximately 6 inches deep and 1,500 square feet in total area, still exists. Several
smaller tar deposits are located intermittently in the low-lying areas of the ground
surface. Tar is also seen along the banks of an unnamed tributary. The FS has
estimated a total of 710 cubic yards of tar and tar soils onsite. During the initial
EPA site inspection in July of 1982, a sample of waste material was collected from tar
seepage and analyzed for priority pollutants. Eighteen tentatively identified compounds
were detected. In March 1986, a second wood tar sample was collected to verify the
presence or absence of polynuclear aromatic hydrocarbons (PAH). The primary
(See Attached Sheet) .
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENOEO TERMS
c. COSATI Field/Group
Record of Decision
Westline Site, PA
Contaminated Media: gw, sw, sediments,
soils, wetlands
Key contaminants: phenols, PAH compounds
21. NO. Of PAGES
45
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EPA Perm 2220.1 (R.». 4.77)
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EPA/ROD/R03-86/024
Westline Site, PA
16. ABSTRACT (continued)
contaminants of concern include phenol, 2,4-dimethylphenol, PAH compounds.
The selected remedial action for this site includes: excavation of all
wood tar deposits and subsequent hauling of these wastes to a permitted
offsite facility; backfilling of the excavated areas with clean soil and
vegetation; incineration of excavated deposits with a high heating value and
low ash content technique; ground water verification study; air monitoring.
The baseline capital costs for this remedial action is $744,000. O&M will
not be required for the areas where tar will be excavated, but periodic
inspection of the areas to assure the remedy is effective will be
necessary. Following the ground water verification study, O&M will be
re-considered.
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~
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Si te :
Vestline Site, McKean County, Pennsylvania
Documents Reviewed:
The following documents which describe the analysis of cost-
effectiveness and feasibility of remedial alternatives for the Westline
Site have been reviewed. Also, meetings to discuss these remedial
alternatives have been conducted with the State and the general public.
I have been briefed by my staff on the documeots aod the meetings aod
they form the principal basis for my decisioo.
- Remedial Investigatioo Report, Volumes 1 and II, Westlioe Site,
McKean County, Peonsylvania, April 1986, prepared by. NOS
COrporation. .
- Feasibility Study Report, Westline Site, westline, Penosylvaoia,
May 1986, prepared by NUS Corporation.
- Remedial Action Master Plao, Westline Site, KeKean Couoty~
Pennsylvania, October 1983, prepared by NUS Corporatloo.
- Federal On-Scene Coordinator's Report, Emergeocy Response/I.-ediate
Removal Action, Westline, Pennsylvania, Hike Zickler~ On-Seeoe
COordioator.
Description of Selected Remedy:
1.
The waste tar will be escavated from the existing pit behind tbe Westline
Church, from the toterspersed tar deposit areas 10 tbe south aod .outh-
western portions of the site along Kiozua Creek and from the baoks
of the unnaed tributary.. The waste tars will be incioerated offsite.
2.
Backfilling the excavated areas with cleao .oil aod revegetatiog
will be required.
3.
The tar deposits will be excavated to the soil level. Sampling a~d
analy.is vill be cooducted during excavatioo to be sure cont881oated
soil. are r880ved to a level equivaleot to a 10 -4 caocer risk for
direct contact with soils over a 20 year period. This level 1.
chosen because it Is siailar to soae of the background level. found
io the C088UDlty. Tbe removal of the tar deposits will _lso insure
that the remaining PABa in soils will oot leach froathe soil. to the
groung water 10 concentrations that will.exceed levels equivaleot to
a 10- caocer risk for ingestion of grouod vater. .
4.
As a safety precaution, air monitoring will be conducted during
excavation.
5.
Packaging of the waste tar materials will be compatible with
incinerator facility requirements.
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-2-
6.
Transportation and disposal of the waste tar materials will be
conducted in accordance with State and Federal Department of
Transportation (DOT) requirements, including applicable Resource
Conservation and Recovery Act (RCRA) requirements; the material will
be transported to a RCRA permitted facility for incineration.
7.
A ground water verification study will be conducted to determine if
the contamination at monitoring well MW-006 is present downgradient
or in higher concentrations in the upper most zone of ground water.
Specifics of the number and well locations will be determined in the
next stage for design of the remedial action.
Operation and Maintenance (O&M):
o & H will not be required for the areas where tar will be excavated,
but periodic inspection of the areas to assure that the remedy is effective
will be necessary. Following the ground water verification study, 0 & H will
be re-considered.
Declarations:
Consistent with the Comprehensive Environmental Response, .Compensation
and Liability Act of 1980 (CERCLA) (42 U.S.C. "9601-9657) and 'the National
Contingency Plan, 50 Federal Register 47912 (November 20, 1985) to be codified
at 40 CFR S 300, I have determined that the remedial action described above,
together with proper operation and maintenance, constitute a'cost-effective
remedy which mitigates and minimizes damage to public health, welfare, and
the environment. The remedial action minimizes or eliminates the threat. of
further contamination to the ground water, the wetland areas, and the
environment. The Pennsylvania Department of Environmental Resources has
been consulted and agrees with the approved remedy. These activities will
be considered the approved action and eligible for Trust Fund monies.
I have determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
sites. .
-
,
James M. Se1f
Regional Administr
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-3-
Suanary of Remedial Alternative Selection
Westline Site
Site Location and Description;
The Westline Site is located in the rural town of Vestline, Lafayette
Township, McKean County, Pennsylvania. As shown in Figure 1, the site is
located in northwest Pennsylvania and is approximately IS miles south-
southwest of Bradford and 8 miles northwest of Kane, Pennsylvania.
The* town of Westline is situated along Kinzua Creek and is completely
surrounded by the Allegheny National Forest. As shown in Figures 1 & 2,
the site is bordered by Kinzua Creek to the south, Turnup Run to the
east, and a wetland area to the west. For this Remedial Investigation/
Feasibility Study (RI/FS), the northern border of the site extends about
250 feet north of the former chemical plant foundation. The site area
encompasses approximately 40 acres.
Located at the center of the site, adjacent to the sain intersection
in town, is the Westline Inn. The Westline Inn is a popular landmark
that provides overnight accommodation, a restaurant, and a bar.;.
Several tar-like deposits from the wood chemical processing operations
remain onsite. The largest deposit was once located next to -the Westline
Inn (See Figure 3). However, this deposit was excavated in September of •"
1983 by an Emergency Response Removal Action implemented by the United
States Environmental Protection Agency (USEPA), Region III, in Philadelphia.
Another tar deposit still exists behind Westline's church. This deposit
is approximately 6 inches deep and 1,500 square feet in total area. A
fence has been erected around it to avoid surface soil disturbance and
direct contact. Several small tar deposits are located In the southcentral
and southwest areas of the site. These deposits are located Intermittently
but are generally found in the low-lying portions of the ground. They
range from a few square feet to 25 square feet in total area and from one
inch to'one foot thick. There are 10 to 20 tar deposits in each of the two
areas. Smaller tar seepages can be seen with dredged material along
portions of the unnamed tributary.. A backhoe is periodically used by the
township to dredge portions of the unnamed tributary to permit flow into
Kinzua Creek.
Site History;
In the late 1890*s, Ralph Day and his son Edmund purchased thousands
of acres of land extending east of Thundershower Run to the ••all town of
Guffy. Timber rights were obtained and a chemical plant was constructed
in the town of Westline. The plant, known as The Day Chemical Company,
began operating in 1901. The plant converted lumber into charcoal,
methanol, and acetic acid. The basic process consisted of heating the
lumber in the absence of oxygen, to a very high temperature, driving off
the chemicals and turning the remaining wood into charcoal. The chemicals
were treated to produce methanol and acetic acid. The charcoal was then
sold to iron producers. The methanol and acetic acid were also sold,
since they generated a reasonable profit.
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oV.
• A MORTON of rm «*«*,
LOCATION MAP
WESTLINE SITE. WESTLINE. PA
SCALE' Tf £000*
FIGURE 1
o
IMUfc,
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in
GENERAL/
WESTLINE SI1
. t" *
L I..,-' -
MYC&ICI
:(FOUND*
\> '";>>^v;:fc«y
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The Day Chemical Company was closed in 1930 due to the poor health
of Edmund Day (Ralph Day had already passed away). The plant was then
sold to David Hancock of Olean, New York, and the name of the plant was
changed to the Union Charcoal Company. By 1940, the plant deteriorated
and was just about ready to shut down when an explosion occurred in the
ether separating unit. With the insurance money from the explosion
damage, the plant was rebuilt and soon began reaping great profits because
World War II brought an increase in demand and consequently a rise in
prices. However, because of high taxes,, the company was dissolved and
the plant was sold to David and Robert Handcock and their wives who
named the plant the Westline Chemical Company. In 1946, the plant was
bought out by the Susquehanna Chemical Company and operations continued
for six more years. In the summer of 1952, the plant was closed due to
equipment deterioration and a decline in profits.
Today, all that is left of the chemical plant is the foundation.
The plant site, located behind the Westline Inn, is presently covered
with demolition debris and is overgrown* Most of the thousands of acres
bought by, Ralph and Edmund Day in the late 1890's are now part of the
Allegheny National Forest.
Findings of the RI; •,
The purpose of the RI was to determine the nature, extent and impact
of the contamination. Then appropriate remedial actions could-be evaluated
to mininlze the public health and environmental risks.
The RI field activities consisted of the following:
- Installing monitoring wells
- Collecting ground water samples from monitoring and domestic wells
- Collecting surface water and sediment samples in wetland areas
- Collecting surface soil samples
- Collecting subsurface soil samples
- Collecting benthic organisms and fish samples
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--.:.-
Waste Tar
Tar deposits are still present at the Westline Site. The largest of
these 1s located behind the Westline Church. This deposit covers
approximately 1,500 square feet and is six inches deep. Tar was also seen
along the banks of the unnamed tributary. Deposits have also been detected
at two other areas of the s1te. These deposits are relatively small in
size and are, generally found in the low lying areas of the ground surface.
The FS has estimated a total of 710 cubic yards of tar and tar s01ls
oneHe.
During the initial site inspection, conducted by EPA Region III in
July of 1982, a sample of the waste material was collected from a tar
se.page located along "the berm of the road and analyzed for acid extractable
and base neutral priority pollutants. The results are given in Table 1.
Phenol and 2,4-dimethyl phenol were the only priority pollutants detected,
at 953 and 934 mg/kg, respectively. However, 18 tentatively identified
compounds were detected at estimatedconcentrat10n ranging from 110 to
5,700 mg/kg.
To better determine the contaminants at the Westline Site, another
wood tar sample was collected from the tar deposit behind the ~es~line
Church in March of 1986. The purpose for collecting a second yood tar
sample was to verify the presence or "absence of polynuclear aromatic
hydrocarbons (PAHs). PARs are common constituents of waste materials
that form by either pyrolysis or combustion. The previously analyzed
wood t.ar sample (collected in July of 1982 by EPA) did not indicate the
presence of PARs because of interference in the detection instrument
caused by the viscosity and chemical complexity of the wood tar sample.
The second wood tar sample (collected in March of 1986) was dissolved
in methylene chloride and was analyzed by Gas Chromatography using a single
packed column and flame" ionization detection (GS/FID) for PAH compounds
only. Analysis of this sample exhibited the following PAR compounds in
the following estimated concentrations:
.
,
Compounds
Concentration (mg/kg)
naphthalene
acenaphthene
acenaphthylene
fluorene
phenanthrene
fluoranthene
pyrene
benzo(a)anthracene
15,000
26,000
5,600
11 ,000
1,900
1,900
2,600
1,600
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P. P.
No.
...- .
DRAFT
TAR SEEP ANAlYSIS OF HSL ACID AND BASEINEUTML CONTAMINANTS
SAMPLED BY EPA REGION III (8112/82)
(All vilul. In mg/kg)
CAS No.
G5A
34A
108-95-2
105-67-9
Contaminants
Acid Extractabll
phlno'
2.4-dlmlthyl phlnol
.... Nlutrli
Nonl dltlctld
Tlnt8tfvlty Id.nttfted Compound. (11Ca)
Dlhydro- 2-(3H)-furlnon.
3-M.thyl-2-cyc'oplntln-1-onl
2-Mlthyl- 2.5-cyclohlXldllnl-1,.-dlon.
2-Hydroxy-3-mlthyl-2-cycloplnt.nl-1-on. ;.
Mlthylphlno' '.omlr .
3.4.5-Trlm.thyl-2-2cyclop.ntln-1-on.
Dlmlthyl phlnol Ilomlr
1,2-Blnzlndlol .
Ethylmlthyl phlnol Isom.r
Ethylmlthyl ph.nol Ilom.r
Mlthyl blnzlnldlol
2.6.Dlmlthoxyphlnol
1-(4-Hydroxy-3-mlthoxyphlnyt)lth8none
1-(4-Hydroxy-3-mlthoxyphlnyt)-2-propanon.
2.6-Dlmlthoxy-'-(2-prop.nyt)pt1lnOI
1-(4-Hydroxy-3.5-dlm.thoxyphlnyl)8th8nOn.
Hydrocarbon (Belt Mitch - 17-plnt8trtcom.n.)
Hydrocarbon (Beat Mitch - 17-p.nt8trlcomln.)
J - d.not.a an Ilttmlt.d conclntratlon
". .
.
,
TABLE 1
Concentration
953
934
590J -
2.oJ
360J
1600J
540J
770J
650J
3200J
1600J
1300J
880J
5700J
320J
820J
.50J
480J
110J
110J
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-9-
A total of eight PAR compounds were found by this analysis. To
confirm the pr~sence of the above compounds, the tar solution was analyzed
by the Gas Ch~~ographic/MaSS Spectrometric (GC/MS) method for bale/neutral
and acid extractable compounds. The analysis of the tar solution revealed
phenol at 1,6S0 "'ta. This detection corresponds well with the presence
of phenol in the analysis of the wood tar sample collected in July of
1982. However, PAR compounds were not reported in the tar solution sample
from 1986 because of high GC/MS aetection liaits. The GS/FID detection
limits were lover than the GC/MS. Therefore, the presence of PAR coapounds
could not be confirmed by GC/MS analysis due to insufficient analytical
sensitivi ty.
In February of 1983, tbree vaste s..plel vere collected by EPA
Region III and evaluated for corrosivity, ignitability, EP toxicity, and
reactivity, as defined in CFa 40, Part 261, Subpart C. The tar waate
did not exhibit the characteristics of corrosivity, ignitability or
reactivity and the EP Toxicity Test extract did not esceed the aaximua
allowable concentration8. Even though thil ia not a RCBA ..ate, there are
public health ri8ka alaociated with the carcinogenic PAB coapouDda and the
levela of phenols in the waste tar. Also the ..ate tara are located in the.
flood plain and escavation of the tar il necelaary for protection of the
environment. .
Geology and Hydrogeology
. . .,
The Westline Site lies in the Appalachian Piateaul phyaiographic
province. The province is an old plateau which has been deeply diaaected
by stream erosion. In the general area of the .ite, flat hill top. lie
at about 2,100 feet elevation with valleys cut 500 to 600 feet below the
tops of the hUls. 'lbe region is part of the Allegheny 11 ver Drainqe
basin and the site l1el on the flood plain of I!nzua Creek.
'lbick alluvial deposits of clay, silt, 8aDd and gravel are found in
the valleys and flood plains. The 10111 in tbe Ve.tllne area conlilt of
the Braceville silt 10... The bedrock unit ¥bich underlie. the alluvlua
at the Westline Site is the Cattaraugul FOr8Stion. It ia coapoled of
shale, siltstone and eandstone.
The;site .pacific geologic investigation involved the drilliDg of
eight boreholel to deteraine the lublurface stratigraphy, obtain lublurface
loil I..plel and to inltall aonitoriDg veill. Pigurel 3 . 4 lhow the
geologic croll lectionl and 1088 of the aonitortng well locationl.
The vater produciDg zones conlilt of tbree balic lubunitl, each
conliltiUl of coarle-srained ..terial at the bale and fine-srained
lediaenta at tbe top. 'lbe lowelt lubunit, Zone 3. 11 co.poled of coar.e
gravel., cobblel, and landl and raDiel froa five to 15 feet thick on top of .
bedrock. Thil unit il. overlain by approxiaately 2S feet of .ilt and
clay. 'lbe second lubunit, Zone 2, raDiel froa 13 to 19 feet thick and
bottoal approsiaately 50 feet below ground. Thil lubunit il c08po.ed of
clean landl and gravell to lilty landl and gravel.. It i. overlain by
landy liltl to claYI rangiDg froa nine to 20 feet in tbicknell. Tbe upper
lubunit, Zone 1, is also c08po.ed of clean sandI and gravell to lilty
sands and gravels. The bale of the upper unit raDgelfroe IS to 30 feet
belovtbe ground. 'lbin 8ilty soil overliel thil unit to the lurface.
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A1
\
i
man
CLMCVM.T
M.T. MMMM
•MEMUWU MtCOMO »/»/•*
QEOLO6IC CROSS-SECTION A-A'
WESTLINE SITE. WESTLINE. PA
NUS
•ORATON
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I
M.TV IHMD • MAVCL
CUMTtf MIT
GEOLOGIC CROSS-SECTION B-B'
WCSTLINE SITE. WESTLINE. PA
VfHTlCM.
IMUSi
OORPORATON I
A Hifttxrton Company
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-12-
The gro~ water flow in Zone'~ is southwest and discharges into
Kinzua Creek. Figure 5 shows ground water contours which are based on
the elevation of the water table at differeDt locations o~ the site.
Ground water flows fro. higher elevatioDs to lower elevations. Ground
water velocity in Zone 1 is estimated between 16.5 and 125 feet per
year. The ground water flow through Zone 1 was estimated to be 1.3 to
10.1 gallons per day (gPd) per foot.
ID ZODe 2, there are oDly two 8ODitoring wella and the exact direction
of ground water flow canDot be accurately determined, but it appears that
Zone 2 may be discharging into KiDzua Creek. The ground vater velocity
in Zone 2 Is estimated to be 2~100 feet per year. Water flow through
Zone 2 vas estimated to be 137 gpd per foot.
No monitoring wells were placed in Zone 3 aDd the ground water flow
direct~oD and velocity were Dot deteradned.
Ground Water Chemistry and Contamination:
Samples of ground water were taken fro. five dcaestic vella and the
eight 8ODitoring wells installed for the RI/FS. Theae aaaples were
analyzed by the US EPA contract Laboratory progr.. and tbe reaults have
been reviewed for quality control.
The domestic well samples were free of detectable levela of EPA'a
Hazardous Substance Ust (HSL) organic contamination. Bovever, well
UW-004 did exhibit total petroleum hydrocarbons (TPH) at 2 8111. This
could be due to an oil well located nearby. Two domestic wells
exhibited inorganic contamination. ODe well (DW-001) exhibited elevated
levels of chromium, cobalt, copper, iron, lead, nickel, vanadium and
zinc. The other well (DW-004) contained elevated levela of barium,
iron, chloride and sodium. Basically, the analyaes shoved that tbe .
ground vater has a high level of dissolved particles and is not used for
drinking because it is dirty.
In the monitoring wells, HSL organic contamination is limited to
three IDOnitoring wells: MW-001, -003, and -006. The organic chemicals
aDd the concentration detected in the ground vater arp. shown in Table
2. All three vells are located near the fOr88r chemical plant and
excavated tarpit (See Figure 2). . .
Cont881nat1on in MW-001 consista entirely of low level pbenola and
creoeols, tbe .oat water-soluble of the contaminant a detected in aite
soils. MW-003 aDd MW-006 are cluster vella located adjacent to the Westline
Inn (See Figure 3). MW-006 is acreened at tbe top of Zone 1 near the
water table surface aDd MW-003 ia partially acreened near tbe baae of
Zone 2. Both wella are contaminated with lov concentrations of .onocyclic
aroaatics including to.luene, ethylbeuene and xylenes and lov concentrations
of naphthalene, the .ost water aoluble PAK.. Alao detected in MW-006
were benzene (80-94 ug/l), phenol, 2-.etbylpbenol, 4-.ethylphenol, .
2,4-diaethylphenol and 2-methylnaphthalene.
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.T. -..,: .,r. ....
KMC I
m no* BMCCIIQK
yATER TA*H-E
WESTLXE SITE. WESTHNE. PA
ffl
IMUS
OQRMDRATOM
A Haftburton Convany
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..-.::
-14-
Table 2
HSL Organica fro. Three Ground Water Monitoring Wells
KW-od 1
Phenol
2 - Methy1pheuol
4 - Kethylphenol
2,4 - Dimethylphenol
KW - 003
Toluene
Ethylbenzene
To&:al Xy1enes
Naphthalene
KW - 006 (with duplicate results)
Benzene
Toluene .
Chlorobenzene
Ethy1benzene
Total Xy1enes
Phenol
2- Hethylphenol
4 - Methy1phenol
2,4-Dimethylphenol
Naphthalene .
2 - Hethylnaphtha1ene
TPH
8 mi/1
11 mg/1
21 mg/l
34 mg/l
9 rag/l
12 rag/1
43 rag/1
2 rag/I
80 rag/1 J
450 l1li/1 J
480 111/1 J
2,000 mg/l J
.66 111/1 J
100 111/1 J
320 III/I J
160 III/I J
77 III/I
43 ../1
2 1111/1
J
J
J
J
84 118/1 J
480 ../1 J
500 111/1 J ;,
2,000 118/1 J
160 111/1 J
260 111/1 J
970 111/1 J
360 113/1 J
71 113/1
37 1111/1
3 111/1
J - lab qualifier indicatiog value is an approximate
-
.
-------
-15-
The gro~ water contaminants represent the more vater soluble
contaminants found in the surface soils. Percolating precipitation
is evidently leaching these contaminant. from the soils to the ground water
table. This mechanism probably explains the relative absence of phenol,
the 80st water IOluble lite contawdnaat, from the surface 80118. Phenol
associated with the tar has either leached to the ground water or has
been conveyed from the site by surface water runoff. Phenol vas detected
at only 3 ug/l in downgradient well HW-008 which is adjacent to Kinzua
Creek. This detection is a good indication of the 8mall extent of ground
water contamination downgradient and the liadted 8ubsurface adgration.
A ground water verification Itudy will be conducted. The 8tudy viII
define the extent of contamination found in HW-006 and will provide more
information to estimate the ground vater flow velocity in Zones 1 and 2.
Thi. information will be evaluated and remedial action for ground water
will be recon8idered.
Surface Water and Sediment Cheaistry and Contamination:
Kinzua Creek and Turnup Run border the Westline Site to the .outh
and east respectively. Kinzua Creek, a third order 8tream, flows westward
for roughly four miles 1nto the Allegheny Reservoir. Turnup lun flows
southward to its confluence with Kinzua Creek. Both .treams support a
sizable population of fish and are uaed for recreationai fi.hing. . ,
Intersecting the site is a small unnamed tributary which discharges
into Kinzua Creek. The tributary i8 not formed naturally but'i8 88n-
made. The banks of the tributary have been carved with a backhoe. Tbe
tributary, which is fed by ground vater, vas probably used at one time to
carry tar away from the main tar deposit area.
The objective of the surface vater investigation was to deteraine
if contaminants have been transported fro. the site and into the .tream
via surface runoff or ground vater discbarge. Surface water sampling
locations are Ihown in Figure 2.
Surface water I..pling locations SW-oOl and -002 were chosen to
detera1n~ background .urface vater quality. S..pling stationl SW-004
and -005 were positioned directly adjacent to tbe site to deteraine the
presence or abaence of .ite related contaadnants. Sampling locations
SW-006 and -007 were selected on the unnaaed tributary; one up.tream of
the tar depolit and one near the confluence with Kinzua Creek. To e.tiaate.
the impact on down.tre.. water quality, lampling location SW-008 wa.
stationed along I1nzU& Creek about. one-half aile dOWDstream fro. the
aite.
Eight 8urface water s..ples and a duplicate s..ple were collected in
July, 1985. The ...ples were analyzed for full BSL organicl and inorganicl,
total petroleum hydrocarbons, and standard water quality par88eterl.
No organic contaainant8 were detected with the exception of total
petroleum hydrocarbons, detected at 2 81/1 at lamplelocation SW-006.
Thi. detection 88Y be attributed to lurface runoff of oils from car. or
truck8. (SW-006 is located near the 88in interlection of the town).
-------
-16-
A few inorganic contaminants were detected in the surface waters.
Samples SW-o~and -007, taken along the unnamed tributary, had slightly
elevated levels of manganese and lead when compared to background samples
(Sw-oOl and SW-002) or other s..ples collected in Turnup Run and Kinzua
Creek. .
Sediment samples were obtained from all surface water sampling locations
and were analyzed for fUll BSL contaminaDts. The analytical results are
presented in Table 3.
Sampling locations SD-001, -002, -003. and -008 did not exhib1t
any cODtamination.
. Samples collected from the unnamed tributary exhibited some organic
conta81nation. For the most part, the contaminants vere PABs and coincided
wi:h those detected in the surface soils. The concentration of the
contaminants ranged from 23 ug/kg (2-methylnaphtbalene at 51>-007). Tbe
PABs have high soil/sediment adsorption coeffic1ents and are only s11ght1y
soluble 1n water. These contaminant8 ..y have reached the sedi88nt. via.
surface soil runoff. The more mobile contaminants, n88ely toluene and
2-methylnaphtbalene. were detected only in ...ple locations 51>-006 and
-007 respectively. However, neither contaminant va. found in the surface
waters. No pesticide/PCB conta81nation was detected in any of thes..ples.
Inorganic contamination, when. compared with background ...ples So-o01 and
-002, 1s limited to the unnamed tributary. Sampling location SI>-006
exhibited very high concentration8 of 1ron.
Surface and Subsurface Soil Chemistry and Contamination
The surface soils of the study area vere inveltigated to deter81ne areal
which ..y exhibit contamination via migration from the tar deposits. The
primary group of cont..inantl found throughout the .ite vere PABa. . PABs .
are relatively water insoluble and have low vapor pressurel, therefore they
tend to adsorb to lurface or lubsurface loill. The pr1mary mechan1.. by which
they ..y be transported 1s convection of particulates with .urface water
runoff. The widespread distribution of PAHa over the entire Itudy area vas
a result. of smokestack e81slion. of particulates from the che8ica1 factory,
which o~rated far over 50 year8 in combination with the seasonal flooding
which can move soi18 around the site.
The aver..e concentration of total PABa in the soil. at the Weltline
Site .. approxiutely 1,000 US/kg. This i. not unCom8C)n aince other
Itudie. bave shown the detection of PABa in the upper .oil layers to be
bet_en 100 to 1,000 US/kg. The highe8t level. can be found near highway.
and industrial settings.
Although the average concentration of PAHa is appro:l:1..tely 1.000
ug/kg. one .ample exhibited al high a8 49,000 UI/Iri of totalPABs. Bovever,
tar vas reported to be mixed with the 80i1 of thi8 .ample. Another 1011
...ple revealed high concentration. of volatile. and acid-extractable
contaminants 8uch al ethylbenzene (9,100 ug/kg), total xylene. (30,000
US/kg). and variOU8 phenollc constituents (over 75,000 ug/kg). This .ample
was collected near a tar deposit and tar vas a180 evidenced In the 8011 lsaple.
-------
-17-
~
Table 3
HSL Organics for Surfa~e Water
sw-006
Total petroleum hydrocarbons
2 111/1
HSL Organics of Sediments
SD-004
phenanthrene
fliloranthene
pyrene
benzo (b) fluoranthene
23 ag/kg
44 ../kg
30 1I8/kg
38 III/kg
SI>-005
phenanthrene
fluoranthene
pyrene
benzo (a) anthracene
chrYlene
benzo (b) fluoranthene
benzo (a) pyrene
.65 mg/kg
.67 III/kg
57 III/kg
22 mg/kg
35 III/kg
88 III /kg
47 1I8/kg
.
.
SI>-006
toluene
fluoranthene
pyrene
bis (2-ethylhexyl) phthalate
chrYlene
benzo (b) fluoranthene
35 mg/kg
280 mg/kg
320 q/kg
260 q/kg.
250 q/kg
540 1I8/kg
SI>-007
2-.ethylnapbthalene
phenanthrene
1,000 III/kg
570 mg/kg
-------
-18-
A 118Iied number of volatile and acid-extractable contaminants were
detected during the lurface loil inveltigation. The compounds generally
have higher water-Iolubilities and vapor prellures than base (neutral
estractablea, 8uch as the PABs). Thus, the presence of monocylic aromatics
and chlorinated aliphatics wal Dot.. significant in the lurface loil.
since they are aore lusceptible to ground vater or ataoapheric transport.
Soil ...plel collected during the drilling progr.. lupport this pheno.-non.
Saaplel collected near the lurface indicated .o.tly PAB contaminantl.
The .ore water-.oluble cont88inants, luch al ethylbenzene and 2-aethylnaphthalene,
were found .t 10-12 feet in the overburden ..terial. With the exception of
naphthalene, no PABa were detected in any ,ub.urface loil I..plel.
(Naphthalene il a Ilightly .obile PAB). Table 4 lbova the entire range of
coaPQundl found in the surface loil lamples.
Aquatic Survey:
The purpole of thil inveltigation val to al.el. any iapact that ..y
be occurring around the Weltline Site on the local aquatic cOS8UDity
re.ulting froa contamination of the local waterway. Two coaponentl of
the biota in the Itre... were allel.ed, the benthic aacroinvertebrate
and fi.h c088unitiel.
A total of 15 fish vere collected and analyzed for BSL organics.
Three different types of filh were analyzed: broVD trout, white'sucker
and brook trout. The brown trout 18 Itocked in Kinzua Creek. Table 5
IU888rizel the relults. Very low concentrationl of benzoic acid and
4,4'-DDE were found in 11 of the 15 samplel.
The presence of thele contaminantl is not well understood for two
realonl: (1) neither benzoic acid nor 4,4'-DDE were found in the lediment
or lurface vater lamples; and (2) S088 of fish containing these contaminants
were collected upstre.. of the lite. 4,4'-DDE, a chlorinated pesticide,
il highly perlistent in the environment. The bioaccumulation of this
pelticide could have originated in any agricultural (including forest related)
area in the Kinzua'Creek vaterlhed. Benzoic acid is a breakdown
product of toluene. The oxidation of toluene forms benzoic acid.
AccoEding to Ogata, et al. (1970), toluene i8 detoxified by oxidation to
benzoic acid in .....ls, which then reacts with glysine to form hippuric
acid. Hippuric acid i8 rapidly excreted in the urine (Versor, 1979).
Thil I.e reaction ..y be taking place in the brown trout. Thil is not to
. lay that the source of toluene is the Weltline Site, since upstream laaples
allo indicated the prelence of benzoic acid. Benzoic acid vas detected in
all three species of fish.
. The relultl of the benthic Itudy show reduction in the total number of
benthic ..croinvertebrates from one location in Kinzua Creek. This reduction
il attributed to the discharges froa the interaittent tributary. Hovever,
I..ples collected downltream of thil point indicated a coaplete recovery.
Overall the benthic community structure in terms of total tases collected
and total numberl is generally escellent in Kinzua Creek.
-------
o RAFT
<'
OCCURRENCE AND OISTRIBUT10N SUMMARY OF HSL CONTAMINANTS
' IN SURFAce SOILS
Concentratfon
PP Ranoe
No. of Min. Max.
!2. ~ Comoound Occur. ~ (ue/lea)
"V 15-09-2 Methylene Chloride 1 1000 1000
61-~-1 Aceton. 1 150 850
15-15-0 Carbon Dllutflde 1 10 160
30V 156-60-5 Tranl- 1.2-dlchloro8ttlene ~. 13 48
23V 67-66-3 Chloroform 1 3 3
11V 71-55-8 1,1, 1-Trlchloroethane 8 2 18 .
81V 19-01-6 Trtchloroeth.ne 8 2 380
4V 11-43-2 88nzen. ~ 8 500
85V 121-18-~ Tetrachloroeth.n. 2 3 ,10
86V 108-88-3 Tolu.n. ~1 2 11.000
38V 100-~1-~ Ethytbenz.n. 13 2 8100
85-41-8 Total Xyl.n.a 13 8 30000
85-'8-7 2-Methylphenol 3 150 7SOoo - .
108-"-5 ~-M8thylph.nol 5 300 220000
85-85-0 Benzoic Acid 19 81 . 10000
55B 91-20-3 Naphthal.ne 1~ .. 23 " 75000
91-51-6 2-M.thytnaphthal.ne 18 M 110000
71B 131-11-3 Dimethyl phthalat. 1 ~O ~o
778 208-96-8 Acenaphthylene 13 28 1700
99-09-2 3-nttroanlUne 1 2~ 24
1B 83-32-9. Ac8naphthen. 5 28 1100 .
132-64-8 Dlbenzoturan 15 25 22000 :
70B ~-e6-2 Dlethyl phthalate 3 II 5000
808 88-73-1 Fluo.... 15 ~1 . 38000
128 88-30-1 N-nttroaodlph.nytamlne 2 3800 37000
818 85-01-8 "'eft8nthren. 53 23 27000
78B 120-12-1 Anthracen. 25 31 3000
88B ~-7~-2 Dt-N-butyf phthalate 19 20 880
388 206-"-0 . Fluoranth.n. 82 37 1.000
M8 ;121-00-0' PyT8f88 10 58 11000
818 85-18-1 8utyt benzyt phthalate ~ .00 13000
728 5HI-3 B8nz0(a)8ntt1racen. 38 37 ...00
888 117-81-7 "a(2-ethyth8XVI)phthllate 18 22 ~OO
788 218-01.. Ch,.,..n. 37 58 !WOO
748 205 .2 "nzo(b8dc)ftuorantften.a 41 55 8-
738 50-32-8 88nzo(l)pynn. 33 58 3IOCt
838 183-31-5 Ind.no( 1.2.3-cd)pyrene 15 AD 1800
828 : 53-70-3 Dlbenzo(a.h)lmttracene ~ 70 780
788 191-24-2 "nzo(ghl)peryt.n. 13 28 2-
8IA 108-15-2 Ph.nol 1 100 100
34A 105-67-1 2,4-dlm.thylphenOI 7 1100 3I000O
31A 120-33"'2 Z.4-dlchloroph.nol 2 210 140
64A . 81-88-5 Pentechloroph.nol 1 ~SO 450
'l'ABLE 4
-------
0RAf.
.. ~ ,.
.... GICIf1I8C COIffM8IMIJ1 fGt88 . .... M8U1 "
WlSft8E 1111
IMI ..... .. "111 11. III ...,..
.... .............. _-fl...., WI-fI-tIJ WI-fl'" WI -II"'" WI-fl-" WI-fl-I" WI-"-II'
....... S88II8It: Ie, ltC, Ie, ItCJ ItCJ ItCJ Ie]
'''' .. "8111: .... ,.... ..... ,.... WIllIe ...., WIllI. .... ..... ,.... Ir... ,.... Ir.... I,....
PP. '''' ........ ,... ..., Perl, ..., ...., .., Perl. ,... ..... ...... ,....
...!!L WJII. c.............
.,..... ......
.... ....,... ....
.... .........
.............
I
I AcN.""""" N
11-11-1 ......... ,,., .. .. .. ,..J NO 400J ?
~
U8 UP JI-"" U'-GOI .. II .. .. .. JI No
NUS s....-........ WI-fHlI WI-fl-II' WI-Fl"" WI -fl-I" WI-fl-In WI-fl-OZ4 WI-fl-Oll WI-f'-Oll
S..... 51......: ItCJ ItCJ ltC, ltC, ItCI ItC' "' 1ft
I,pe 01 fl...: Ir.- ".... ..- ".... ..... I'''' WIllI. .... .Ir... I''''' ...... s.c... .... ,.0lIl ...... troue
.P. '''' .. S.....: ,..., .... Perl, ,.... .... Perl. ,.... WMI8 .... f.... 1kMt, ......
...!!L.. ~. ConI""""
VoI8tII8 ......-,
..... .....,... .....
.... ........ ..
.
.-- ...eel"8
AcN 11IIr8C181118
H-"'" '-'ole eelil .. .. NO 1MJ Z81.1 - JJOJ JIOJ
PCII1P8It1cIlie.
I. 1I-li-'. 4,.'-001 , 10 .. NO NO NO NO NO
J : .......... ........... ......
NO : ..... Oeleel..
-------
-21-
~
Wetlands and Flood Plain Assessment:
According to the National Flood Insurance Program, the Westl!ne Site
lies within the lOO-year flood plain. Most of the site area extending
north to south from the Westline Inn to Kinzua Creek would be affected
by a IOO-year flood event. This includes the tar deposits located behind
the Westline Church and those scattered throughout the southwestern and
southeentral portions of the site.
These wetlands are extremely valuable to the environment at this site.
The flood plain supports natural animal and plant life. It 1s valuable
for storm water retention and it is also an area for ground water discharge.
The natural functions and values of the wetlands make it necessary for
re.Dedial actions to protect the surface water. ground water and .urface
soils on the Westl!ne community. The remedial action selected in the
Record of Decision will minimize or eliminate the threat of further
contamination to the wetland areas.
.
.
;.
-------
-22-
.-..:-
Public Health and Environmental Concerns:
To' assels the risks to human and environmental receptors posed by
chemical contaminants at or originating from the Westline Site, three major
aspects of the chemical contamination and environmental fate and transport
of lite chemicals must be considered.
- The carcinogenic and non-carcinogenic health hazards associated with
the organic and inorganic chemicall detected at the site.
- The potential for human or environmental exposure to site chemicals
and the concentrations to which the receptors may be exposed.
- The risks associated with exposure to chemicals at the concentrations
detected on site as compared with regulatory guidance.
From all the compounds found in the site area a list of "indicator
chemicals" was developed for the Westline Site. Indicator chemicals were
selected by considering the health related effects and the frequency of
occurrence on the site. Table 6 lists these chemicals for concern. Table-
7 shows the regulatory guideline values for these chemicals. .
HSL organic contamination of ground water is limited to t~ree'site
moni tori ng wells and poses li ttle potential for direct human exposure at
this time. Residential wells in West11ne are not being used. Instead,
the residents of Westline are using a spring, which emerges far upgradient
of the study area. Contaminated ground water following the flow direction
determined during the Rl would ultimately discharge to Kinzua Creek. No
HSL organics were detected in samPles taken from Kinzua Creek or other
site surface waters. Again, a ground water verification study will be
conducted and [PA will reevaluate public health and environmental concerns.
Surface soil is the most contaminated environmental medium at the
site. This is apparently due to the bulk transport of tar and charcoal via
surface runoff. The predominant soil contaminants, PABs, tend to adsorb
to soils and are also likely to. be dispersed from tar deposits via eroded
SoUSe 7 .
Based on the chemical analytical data and. the hydrogeologic conditions
at WestUne, the primary potential exposure mechanisms are felt to be
associated with the contamination of tar and surface soils. These
mechanisms include direct dermal contact with waste tars and contaminated
sol1, and the potential for the urs and contaminated soUs to leach to
the ground water which could be used for drinking water in the future.
tnhalation of soil contaminanta is not considered a potential exposure
mechanism for the following reasons:
- The extremely low vapor pressures of the predominant contaminants,
PAHs, makes volatilization and subsequent inhalation of vapors
unlikely.
- The lush vegetation of Westline,includi ng wooded areas and lawns,
provides adequate cover to limit fugitive dust and inhalation of
contaminated particulates.
-------
" i
.....
INDICATOR CHEMiCAlS AND RANKiNGS
(ICF. INC. 1985» .
WESTUNE SITE
Water
carcinogenic chemicals
Soli
Water
1. Benzen.
1. Benzo(a)pyrene
2. Olbenzo(a.h)anthracene
3. eenzo(b)fluoranthene
4. Benzo(a)ant"racene
5. Chrysene
e. Idenol1.2.3-cd)pyrene..
4. Benzene
5. Xylene-
1. Phenol
2. Ethylbenzene
3. Toluene
!
CJ\
DRAFT
f;
toxic chemicals
Soil
1. Benzo(a)pyrene
2. Ethylbenzene
3. Benzenil
4. Toluene
I
tV
W
I
5. DI-n-butylphthalate
e. Bis(2-ethylhexyl)phthalate.
7. 2-methylphenol.
8. 4-methylphenol-
Notes:
.1. Score and ranking are derived for non-carcinogenic health e«eol& 0' even known or suspected carcinogens.
-- . Suspected carcinogen for which no toxicity IndeM Is avaUable. .. .
. . No lo.lclty Ind.. Ivallable but Included because 0' prevalence or concentraUon.
~,;,
-------
DRAfT
""1.
. REGUtATORY GUmEUNE VAlUES foR
INDICATOR CHE~ AT WESTI.H SITE
,;
".
ADI AWOC MCl SNARL
Chemicil Jm8l5I!Jl lug/It (mal!) Chronic I ualll CPI
PAM. (BaPt NA 2.8 ng/l- NA NA 3.000
BEHP 42 15,000 NA NA HC
DI-butylphthll.te 88 34.000 NA NA NC I
! 0.66. IV
aenlen. NA 0.005.. 10 40 01:1-
I
EthylHnlen. 8.5 1,400 NA NA HC
.... Ph.nol 1 3,500 NA NA HC
Toluen. 30 14,300 2.0.. 340 NC
2-m.thylphe"oa NA NA NA' NA NC
4-methylphenol NA NA NA NA NC
2,4-dllmethyphenol NA NA NA NA NC
xylene. (tot." 160 NA 0.44.. 620 NC
H.phtIYI.ne 18 ItA NA NA NC
. .'
Not..:
NA . Not .vllllble
HC - Non-clrclnogen
. . 88.841' on 10'" clncer rt.k
.. . Propolld MCl (PMClt
-------
-25-
- The climate of Westline provides average annudl precipitation of
49.5 inches in the form of rain or snow. which would eliminate
particulate. emissions during much of the year.
- The more heavily contaminated areas include bulk tar wastes, which
are highly viscous and are unlikely to become airborne.
Potential human receptors of soil contaminants via exposure routes
(dermal absorption and ingestion) are the residents of Vestline and those
who frequent the area to hunt, fish, hike or otherwise enjoy the outdoors.
A detailed risk calculation is presented in Volume 1 of the Westline
R1/FS in Chapter 7. Under present site conditions, detrimental exposure
is expected to occur only through prolonged direct contact with tar deposits
or heavily contaminated 80ils. Chemical analysis of fish from Kinzua .
Creek indicate no significant risK for consumption of fish from local
streams. Site conditioDS have been similar to present conditions for at
least the past 30 years and have put no noticeable stress on the aquatic
or terrestrial ecosystems.
Potential detrimental exposure to ground water contaminants would occur
only if present usage changes and contaminated domestic wells ~ere'put back
into use.
Review of Alternatives:
Remedial Action Alternative No.1 - No Action
A no-action alternative must always be considered in order to determine
the long-term effects a site will have on public and environmental health
if nothing is done to clean up the site. The FS found this alternative
unacceptable because it does not protect the ground water from contamination
or prevent direct contact with the wood tar wastes.
Technical Evaluation
;
This alternative will not require any implementation of remedial
activities after the RI/FS other th~D a study to verify the extent
and degree of aquifer contamination. The FS proposes a ground water
verification study consisting of four shallow wells. One will be
hydraulically upgradient from the contaminated MW-006 well and
three will be downgradient. The wells will be sampled and analyzed
for HSL organics. EPA will evaluate the results to determine if any
further action is needed. .
- Public Health and Environmental Concerns
The no-action alternative will not reduce any of the present or
potential future risks to the public or the environment. The
present unacceptable risks associated with the site are dermal contact
with the wood tars and the potential future ingestion of ground .water.
-------
-26-
~
Remedial Action Alternative No.2 - Excavation of Wood Tars and Onaite
Land fUl1 ng
This alternative requires the construction of an onsite hazardous
waste landfill. Following the landfill construction, wood tar deposits
behind the Westline Church and in the southeentral and southwestern portions
of the study area would be re.oved and placed 1n the landfill. AD impermeable
cap would be placed over the waste ..terials, and the ezcavated tar pits
would be backfilled with clean soils. The soils would then be seeded. The
baseline present-worth cost of Alternative No.2 is approziaately $644,000.
- Tecbnical Evaluation
This alternative includes two key remedial technologies in addition to
the ground water verification study. These are ezca.ation and onsite
landfilliog. A new access road will be conatructed to the proposed
location of the landfill. A road .ust also be constructed for ezcavation
of the tar pit behind the Westline Church. A landfill liner systea
will be constructed. This liner will cover approzi..tely 6,000 square
feet. Once tbe liner sy.tea bas been constructed, the laudfill 1s
ready for deposition of the ..Ite ..terials. A total of 710 cubic
yards of tar and tar/soil wastes il esti..ted for on.ite d~spo~al.
Conventional earthmoving equiP88nt can be used to re.ove the tar
deposits fro. the pit. Tbe interspersed tar deposit. will require
ezcavation based on visual deterwdnat10ns and analysi. of soils
duriog excavation. Backhoe equipaent, in combination with hand and
shovel excavation, will be appropriate for the interspersed tar areas.
All excavated materials will be placed in the onsite landfill and a
multilayered cap will be placed on the cell. The landfill .ust
Co.ply with the U.S. EPAand Pennsylvania Department of EnviroD88ntal
lesources (PADER) hazardous waste regulation.. OaIoiag ..intenance
and 8Onitoriog of the landfill will be required.
Reaedial workers ~ll need deraal protective clothiag duriag .ite work.
Respiratory protection is not anticipated to be nece.sary. Por safet,
pre~autions, air aonitoriog is rec~nded during ezcavation.
,
- Public Health and EnviroD8ental Concerns
Alternative No.2 addresses all. of the present and potential future
unacceptable risks to the public including deraal contact and iogestion
of groUDCI _ter by hU8&ns.
0081 te disposal in a hazardous .ste landfill is ezpected to pronde
contaiD8ent of the vaste tar _terials and any liquid leachates.
"sidual risks to the public and the enviroD8ent are ezpected to be
negligible. A comprehensive post-closure care plan will be prepared
that will address requirements for ..intenance and 8Onitoriog. PADE.
will be responsible for tbe polt-closure care.
-------
-27-
ExcavatTOn of the tar deposits and construction of an onsite landfill
will cause a temporary disruption in daily activities, mainly because
of' the operation of heavy equipment and haul trucks. Dust control
measures will be used. Production of harmful vapors and gases
18 not expected, based on all available information on the tar
materials, although an increase in objectionable odors might occur.
- Institutional Issues
All applicable Federal and state standards and regulations related to
the remedial action will be met for Alternative No.2, including
onsite disposal of hazardous wastes.
Remedial Action Alternative No.3 - Excavation of Wood Tars and
Oflsite Landfilling
This alternative requires that the wood tar deposits and the adjoining
contaminated Boils be removed and transported to a RCRA-approved hazardous
waste management facility (HWMF). If this alternative is chosen, the wood
tar waste materials could be taken to one of several facilities that meet
RCRA standards. The baseline present-worth cost of Alternative No.3 is .
approximately $409,000. . .
.
'.
- Technical Evaluation
Excavation of wood tar deposits and of adjoining contaminated sonstlas-
been evaluated and described previously under Alternative No.2.
Therefore, technical evaluation of this technology will not be
repeated. The technical evaluation in this section focuses on
offsite landfill technology. Excavation and subsequent offsite .
disposal is a permanent remedial action for the site. Based on available
data, this alternative will reduce the possibility of future contamination
by removi ng the known sources of contamination. Offsi te landflll1ng
will not require periodic maintenance or monitoring by PADER. In
addition, offsite -landfilling will permanently remove the waste
material and eliminate the aspect of potential failure of an onsite
dis "osal unH.
- Public Health and Environmental Concerns
This alternative will address the present and potential future unacceptable
risks to the public health and environment, including dermal contact.
and ingestion of ground water by humans. The removal and subsequent
offsite landfilling of waste materials will provide adequate protection,
maintenance, and monitoring of the disposal unit. The responsibility.
for proper disposal practices and long-term environmental assurances
will be with a licensed hazardous waste facUity, under the 8upervision
of professional environmental scientists and engineers. The health
and environmental impacts of excavation were previously evaluated and
described under Alternative No.2.
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-28-
~.
- Institutional Issues
Offsite disposal of waste .ateriall in a permitted hazardous waste
landfill facility fulfills the RCRA closure and post-closure
requirements (40 CFR 1264.310).
Remedial Action Alternative No.4 - Excavation of Wood Tars and
Offsite Incineration
This alternative, like Alternative *Nos. 2 and 3, completely removes the
wood tar deposits and the adjoining contaminated 80ils. Like Alternative
No. 3, i~ transports the excavated waste materials to a RCRA-approved,
offsite incinerator, rather than disposing it on site. At the incinerator
plant, hazardous materials will be des~royed by burning at high temperatures.
Ashes remaining after the burning process will be properly disposed by the.
incinerator operator. The baseline present-worth cost of Alternative No.4
is approximately $744,000.
- Technical Evaluation
Implementation of this alternative will result in excavating all wood
tar deposits throughout the study area and subsequent hauli~g. of these
wastes to a permitted offsite incineration facility. Site remediation
of this alternative will begin with excavating the wood tar deposits
behind the Westline Church and in the southwestern and southcentral
portions of the study area. The amount of excavated materials and the
methods of excavation are the same as those described under Alternative
No.2. Therefore. the technical evaluation as well as the public
health and environmental concerns of excavation are not repeated here.
The remainder of this section focuses on the technical aspects and
health concerns regarding offsite incineration.
Incineration is considered to be technically feasible because of the
high heating value (approximately 11,000 BTU per pound) and low ash
content (0.05 percent) of wood tar. Common types of incinerators that
were;consldered for the destr~ction of the wood tar wastes were rotary
kiln~ fluidized bed, multiple hearth, and liquid injection incinerators.
Incineration is a proven technology for destroying hazardous materials,
including the wood tars such as those at the Westline Site. Residual
ashes, Which remain after the thermal destruction of the waste material,
will be properly handled by the operators of the incineration facility.
-.Public Health and Environmental. ConcerDs
The health and environmental impacts of this alternative are due to
excavation activities rather than incineration. This is because the.
incineration Is conducted off site at a licensed and approved RCRA
facility. The health and environmental impacts of incineration on the
local community are therefore eliminated.
As outlined under Alternative No.2. the most significant impact of
this alternative Is the disruption of daily activities, mainly because
of the operation of haul trucks and heavy equipment. Production of
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-29-
harmful vapors and gases is not expected. based on all available
infor.aWoou ~)n the tar uterials. Proper engineering practices during
excavation will reduce the likelihood of emi88ioD' and a8sociated
respiratory probleas. The.e practices would include dust control
mea.ures on local roade as needed.
- Institutional Issues
Offsite incineration at a licensed incineration facility will require
compliance with both the RCKA requirements a8sociated with the remaining
ash residual and the eaissions requirements as defined by the National
Ambient Air Quality Standards (NAAQS).
Remedial Action Alternative No.5 - Excavation of Wood Tars and Onsite
Incineration
This alternative includes the complete removal of wood tar deposits
and the adjoining contaadnated soi18. Following excavation of the
contaainant., this alternative providea for onaite incineration in a
.obile Incinerator that Is removed from the 8ite vbeD the project i8
coapleted. Ashes reaaining after the burning proceaa will be tranaported
to a RCKA-approved facility. The baseline preaent-worth coat of Alternative -.
No.5 i. $1.077.000. .
- Technical Evaluation
.
.
Impleaentation of this alternative will require the escavation of all
wood tar deposits throughout the 8tudy area and subaequedt de.tructioD ".
of these va.tes in a permitted incineration unit that will "be 80bilized .
to the Westline Site. The amount of excavated va8te ..terial, approsi88tely
700 cubic yards. and the aethods of excavation are the aa.. aa thoae
de8cribed under Re..dial Action Alternative No.2. Therefore, "the
technical evaluation a. well as the public bealth aDd enviroD8ental
concerns of excavation are not repeated. Tbe re..inder of thia aectioD
focuses on the technical aspects and health concerns regarding onsite
incineration.
~
Rotary kiln was found to be the only type of incinerator available
c~rcially"a8 a aobile unit for onsite use and it ia the incinerator
best suited for .oila. Portable, rotary kiln incinerator a are generally
aounted on tractor-trailer trucks for eaay aobllization. A nuaber of
trailera are required to house the control rOGa, laboratory, boilers,
.crubber, and the incinerator. Tbe ..ate ..terial ia uaually belt
fed in balk fora into a charging hopper and 8ubaequently into the
rotary kiln incinerator. Tbus, there 18 DO need to contain the ..ate
..terial in druas prior to tran8porting it to the aobile aD1t.
The initial aite activity will C0888nce with tbe conatruction of a new
acce.. road.. "Following the conatruction of thia road, escavated
waite ..terial will be hauled to the propoled onaite incineration area
and 8tockpiled near tbe bopper. A t..porary Itorage area will be needed
" to contain the excavated vaste ..terial prior to incineration. (Tbe rate
of excavation is greater than the rate of incineration). Tbe di88n.ionl
and de.ign details of this storage area will be dete~ned during the
deaign pha.e of cleanup.
.'
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-30-
- Public Health and Environmental Concerns
...:
Alternative No.5 will address all of the present and potential future
unacceptable risks to the public and the environment.
Excavation of the wood tars and construction of an access road il expected
to cause a temporary disruption in community daily activites, mainly
because of the operation of heavy equipment and haul trucks. Safety
considerationl will include restricting the public from excavation
areas and require control of equipment traffic within the community.
Dust control mealures will be used, when neceslary, to minimize the effect.
on adjacent properties. Generation of harmful gases is not expected
from excavation, although an increase in objectionable odors might occur.
Onsite air monitoring during excavation activities should be conducted
to ensure protection to the community and the remedial cleanup personnel.
The operation of an onsite incinerator could pot~ntially generate a
substantial amount of noise. The proposed location for operating
the incineration unit is approximately 200 feet from the closest
residence. This factor will result in a nuisance problem, especially-
if the unit starts early in the morning or continues to operate late.
into the evening. Emissions must meet ICRA standards and should pose
no health threat. :.
- Institutional Issues
All applicable Federal, state, and local (county and township) standards
and regulations related to remedial action will be met for Alternative 5,
including onsite incineration of hazardou8 wastes.
Cost Evaluation Summary
. . .
The summary table given in Table 8 outlines the applicable capital
costs, O&M costs, and low, baseline, and high present-worth costs for all
applicable remedial action alternatives. Appendix B of the II report
presents, additional detailed information regarding the development of
these cci,sts.
Recommended Alternative
Section 300.68 (1) of the .National Contingency Plan (NCP) 50 Federal
Register 47975 (November 20, 1985). to be. codified at 40 CFI 1300.68(i)
states that the appropriate extent of remedy shall be determined by the
lead agency's selection of the remedial alternative which the agency determines
il cost effective (i.e., the lowest cost alternative that is technologicaily
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. lased on our evaluation
of the proposed alternatives, th~ public comments and the information
received from the PADEI, we recommend implementation of Alternative No.4:
Excavation of Wood Tars and Offsite Incineration. .
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" i
DRAfT
...,.
REMEDIAl AC110N AlTERNATNES COST SUMMARY
WESnJNE SITE
CCoata ar. In 1986 OoIlars)
I;,
Annual O&M Coats 1$1,000)**
Includes Monitoring and
Capital Coat Post-Closure Maintenance Present-Worth Costs (StOGG)
Remedla' Action Alternative ~ Years 1-5 Years 6-30 Low Baseline l!!a!L
1. No Action -0- -0- -0- -0- -0- -0-
! 2. Excavation of Wood Tar. and 175. 63 41 572 644 782
On.lte LandfilUng
GO 3. Excavation 0' Wood Tar. and 260 29 7 288 409' 820
Off.It. I.8ndtllllng
4. Excavation 0' Wood Tar. and 595 29 7 455 744 1,746
Oft."e ,"clneratlon
5. . Excavation of Wood Tar. and 828 29 7 1,072 1,077 1,788
. On,lt. Inclne,atlo"
** These oosta will be reevaluated after the gtour¥iwater verification study.
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The specifics of the recommended alternative are:
--..: ."
1.
The waste tar will be excavated from the existing pit behind
Ch~rch, from the interspersed tar deposit areaa in the louth
western portions of the site along Kinzua Creek and from the
of the unnamed tributary.
the WestHne
central
banks
2.
Backfilling the excavated areas with clean soil and revegetation will
be required.
The tar deposits will be excavated to at least a 10-4 cancer risk
based on a direct contact 20 year exposure of total PAHs. This level is
chosen because it is similar to Some of the background levels found in the
community. The removal of the tar deposits will also insure that the
remaining PAHs in soils will not leach from the loils to the ground
water in concentrations that will exceed levels equivalent to a 10-6
cancer risk for ingestion of ground water. This level il approximately.
70 mg/kg. Sampling and analysis will be conducted during excavation.
3.
4.
As a safety precaution, air monitoring will be conducted during
excavation.
s.
Packaging of the waste tar materials will be compatible with the
incinerator facility's requirements. .
.~
6.
Transportation of the waste tar materials will be conducted in accordance
with State and Federal DOT requirements. including appU.cable ICRA
requirements; the materials will be transported to a ICRA permitted
facility for incineration.
7.
A ground water verification Itudy will be conducted to determine if
the contamination at monitoring well MW-006 is present downgradient
or in higher concentrations in the upper most zone of ground water.
Specifics of the number and well locations will be determined in the
next stage for design of the remedial action.
Operation and Maintenance (O&H):
O&M;will not" be required for the excavated areas. The 11 activities
" have looked for any further pockets of tar and all the tar that was found
will be removed. but lince the lite liel in the flood plain there will
always be the poslibility for major changes in the ground surface and the
possibility for another tar seep to appear. Periodic inspections will be
necessary to Insure the effectiveness of the remedy selected here. Following
the ground water verification study O&H will be reconsidered.
Consistency With Other Environmental Laws:
All waste materials will be transported and disposed in accordance
with ICRA and DOT requirement..
A site specific risk assessment was conducted to determine the acceptable
levels of total PARs in soil and it is CERCLA policy that this approach to
leaving acceptable levels of contaminants is consistant with the RCRA
closure requirements.
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-33-
National Environmental Policy Act requirements have been met by the FS
evaluation o~al~ernati~es and the public participation during the comment
period for the FS.
. Since excavation will occur within the flood plain, any backfilling
must comply with the Section 404 (b)(1) Guidelines of the Clean Water Act and
the areas should be regraded to existing contours and with the same kind
of soils. Also the State Dams and Encroachment Regulations will be considered
during the design stage.
Evaluation of Alternatives Not Selected:
Remedial Action Alternative No.1 - No Action was not selected because
the present conditions woul~ present continuing unacceptable risks.
These include:
- ground water - Potential risk from future leaching of phenols and
benzene from wood tars is unacceptable based on . <10-4 cancer
risk.
- Wood tars - Dermal contact and ingestion risks are unacceptable
«10-4 cancer risk). .
Remedial Action Alternatives No.2 and No.3 Excavation of Wood Tars
and Onsite Landfilling and Excavation of Wood Tars and Offs1te Landfilling~
were not selected for a number of reasons: 1) Landfilling the wood tars.
will not provide the same degree of protection for the public health and
environment as permanent destruction of the wastes; 2) Wastes which are
placed into another landfill which may eventually cause another problem in
the future; 3) The space in existing offsite RCRA facilities is valuable.
The space available for disposal of industrial RCRA wastes is limited and
15 needed by our industries; 4) Since the waste tar material is not a RCRA
waste, both of the RCRA landfill options less appropriate; 5) The wood
tars have a relatively high heating value (approximately 11,000 BTU per
pound) ~nd low ash content (0.05 percent). These facts make incineration
. of the ~aste more suitable; 6) Additionally, landfilling is not as
cost-effective as incineration because incineration will provide for
permanent destruction of the wastes at a cost within the same order of
magnitude of the landfilling options.
Remedial Action Alternative No.5 - Excavation of Wood Tars and Onsite
Incineration was not selected because the mobile and length of time needed
to incinerate the 710 cubic yarts in a small incinerator makes this alternative
more expensive. Also, there wi II be greater community concern about health
and safety "for local residents from onslte incineraeion. Ie 1s also more
costly than offsite incineration.
Overall, onsite incineration would be disruptive to the local community
and storage of material to be burned and disposal of the ash would create
additional planning and expense.
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RESPONSIVENESS SUMMARY
WES1UNE SITE
McKEAN COUNTY: PENNSYlVANIA
JUNE 1886
This community relations responslvlness summary Is divided Into the following
sictions: .
Section I:
Overview - A discussion of the EPA's preferred alternative and the
public's expected response to this aiternativi.
~.ctJon II:
Backaround 01 Communltv Involvement and Concerns - A discussion
of the history of community Interest and concerns raised during the
remedial planning activities at the Westllnl Site.
Siction III:
Summarv of Malor Comments Recelvld durtna the Public Comment
Period and of Aaencv ResDonses - A summary 01 comments and
responsas categorized by topic. . -
Sec:tlon IV:
Remalnlna Public Concerns - A dIscussion of communIty, concerns
that the EPA and the Pennsylvania Cepartment 01 '"EnvIronmental
Resources (PACER) should consider In the remedial design and
construction phases at thl Wlstllnl Site.
L
OVERVIEW
The Aemedlal Investigation (RI) Report and the Feasibility Study (FS) Aeport were
released to the public for review and comment on May 15, 1986. This marked the
opining of the comment period, which extlnded to Junl S.
At the time 01 the public comment period, the EPA had Identified a preferred
alternative for remediation of thl Westllne Siti. Although Ixpressing a
preference, the agency presented a total 01 flve remedial action. alternatives in the
Feasibility Study Report. Thl prlflrrld Ilternatlvl, referred to as Alternative
No.4, consists of' thl excavation of wood tar dlposlts and IdJolning contamInated
solis; transportation of the excavatld matlrtals to an offslte, RCRA-approved,
Inclnlrator plant where thl materials will bl dlstroyed by burning at high
temperaturll; Ind disposal 01 any ashes that remain after burning in an appropriate
facility. This final stlP will be thl responsibility of thl Incinerator operator.
Comments received during thl public comment period Indicated that most
resldenu preferred the no-action alternative during the opening 01 the commlnt
plrlod. How.lver, following I public mlltlng during which local citlzlns werl able
to discuss the Remedial Invlstlgation and Flaslbility Study Reports with Statl and
EPA representatives, many residlnts expressld confidence in the EPA and Support
for the agency's preferred alternative.
1
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II.
. BACKGROUND OF COMMUNITY INVOLVEMENT AND CONCERNS
,
...
-
The Westllne Site consists of severll pits 01 wood tar thlt are all that remlln of a
wood proclssing plant that operated in West"ne from the late 1800's until 1952.
The tlr pits, discovered In 1982 during a routine Inspection of 011 operltlons In the
Allegheny National Forest. were of little Ipparent concern to IOC81 residents until
the EPA proposed to perform an Emergency Responsl Action to remove the largest
wood tar deposit from the property of the town's main Industry, the Westllne Inn.
The EPA, prompted by the concerns of the Centers for Dlse8s8 Control, Intendld
to protect residents and tourists from dermll contaCt with the phenolic
contamln8nts In thl wood tar. Howlver, the. 50 residents who 8ttendld I public
melting to discuss the emergency Ictlon on M8rch 3, 1983, werl primarily
concerned that persons owning property with wood tlr deposits could potentl811y be
hlld liable for the costs of cleanup. To protest this possibility, property owners
refused to allow equipment onto thllr 18nd to begin clelnup actlvltle.. Instead,
thlY fenced the large wood ter deposit and pi Iced shlet metll OVlr smiller
deposits. Although the EPA 8pprovld the Installation of the fence In March 1983,
an Emergency Responsl ACtion W8S plrformed In September 1983. Prior to this
removal, the EPA c8pped the wood tar dlposlt with I 8-inch soli cover. In response
to local. complaints that tar WIS oozing. from under the cap 8nd crlltlng an
untoler8ble condition, EPA decided to excavate the wood tar and transport It to
CECOS International's landfill In Nfagarl F811s, New York. -
On October 18, 1984, Inother public meeting W8S held to discuss the Wark Plan for'
the site 8nd the tentative project schedule. Once 8geln~ the prlmiry concern for
the local residents was property-owner 118blllty.
':,'.' ..~
. .
In December 1985, prior to the release of the RI and FS Reports, EPA held an open
house at the Westllne Inn to discuss rem.!lnlng concerns. The open house was
attended by a sm811 number 01 citizens whosl prlm8ry concerns were thl 8mount of
money being spent 8nd the Intrusion of government Into their community. Most
people expressed the oplnfon that the wood tars W8re an old, established feature of
the community and th8t thlY were 01 IIttll consequlncl. These people did not
believe th8t the disruption of their community and thl expense. of remldlal actions
were warranted at the site.
.:
Thesl concerns continued and wIre presented by slveral residents at . public
meetfnSJ on May 22, 1986. Thlse Ind additional commlnts and concerns are
discussed In the following slctlon.
III.
SUMMARY OF MAJOR COMMENTS RECEIVED DURING THE PUBUC
COMMENT PERIOD AND OF AGENCY RESPONSES
Commlnts raised during the Westllne Sitl public comment period are summarized
~rfefly below. Thl comment perfod WIS held from M8V 15, 1986 to June 5, 1986 to
hear thl opinions of concerned cltlz~ns on the remedial action alternatives
recommended In thl FS Report. The comments recllved during this plrlod are
categorized by relevant topics. At thl time of the public comment period, EPA
had focused on Alternative No.4 (excavatlon/offslte Incineration) as the preferred
alternatlvI.
2
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Remedial Action Alternative.
....:. .
,.
With regard to Alternatlv. No.1, no action, It was suggested that the
community should be viewed IS . collective .gent with the right to choose to
accept the risks posed bV the wood tar deposits. It was Iiso suggeste~ that
there are sites with more serious problems and that as taxpayers the tocal
residents should have a vole. as to how and where money be spent.
EPA Response: The EPA Is bound bV law to protect the environment IS. well
IS the public health, and this site POSIS a threat to the Invironment. The
wood tar pits should not be. down played as a hlalth hazard. Neither should
cancer risk be the only factor considered. This town could grow; the water
supply could become contaminated. Th.n, there would be IVln more people
In need 01 water, and thl site would be off thl National Priorities Ust.
Westllne would be right blck to zero.
2.
Regarding Alternative No.2, .xcavatlon of wood tar dlposlts with on site
landflillng, citizens wanted to know how delp thl Iindfill would be and how It
would be constructed.
EPA Response: The landfill would be built .bove the ground surface. 11
would consist of a substructure with I plastic liner and a Ilachati collection
system to catch anything Iialdng from the structurl. It would be capped with
a multi-layer, plastic-lined cap that would create I Idnd of vault. . .
.~
3.
Citizens Inquired about the proposed action for a similar wood tar sltl In the
nearby community 01 Kane.
EPA Response: The EPA Is trying to make these responses consistent, but
the Kane Site is on a fast track, and the Westllne Site is moving on a much
slower courSl.
4.
Citizens suggested two .ddltlonal remedial actions for the site. One
suggestion was to simply fence the site to prevent access. The second
suggestion w.s to Isolatl the wood tar deposits bV ringing them with concrete
or other suitable mat.rial to prevent groundwater from contacting the
wastes, and then, monitoring the groundwater to determine If the barrier Is
working. .It was sugg.sted thlt thl blrrier could be extended upward to.
create a will to prevent ICC.SS. Sine. monitoring wells alreadv Ire In. place
. this appeared to the cltlz.n recomm.ndlng It to be an economical solution
that would require no funher action unl.ss le.ks were detect.d.
EPA Response: The EPA would stili hive to cap the site even If a blrrier
were In piacl. The Igencv really flels these wastlS should be removed to
prevent potential leaching Into the groundwater. .
As everyone knows, caps have not worked well IS shown In the plst here at
Westline. Also, these wood tlr deposits Ire within I flood pllin. Therefore,
I specially designed cap would hive to be constructed to withstand potential
flooding.
3
-------
Regarding fences, the EPA has found that these do not last long. Children
see tMcn .as a challenge, and It doesn't matter If the fence is In a rural
setting or an urban setting. The vandals may not even be members of the
community. The EPA has lost fencing, and three trailers at a site in suburban
Erie, Pennsytvanla. It Is almost 'mpossible to protect fencing.
Technical auestlons/Concerns Regarding Remedial Alternatlv..
1.
One commentor was concerned that If the wood tar deposits were excavated
and thl resultant holes were filled with permeable materials, . void would be
created that would draw water through the most contaminat'd areas, thereby
Increasing the likelihood that groundwater and surface water would become
contaminated~ Another Inquired about an environmental impact statement
regarding excavation of the wood tlrs.
EPA Rlsponse: The wood tar deposits .re estlmlted to be about 2 feet dlep
behind the Westllne Church, and In other are.. that border Klnzua Creek.
Excavltlon at this depth Is not expectld to prllent a problem with regard to
groundwater becoming contaminated through voids. If the wood tars are
removld, the Impact will be the protection 01 the groundwater.
2.
The estimated construction start-up date and the time needed to complete.
remedial activities was of Interest, and the Idea 01 . vltual determination of
the presence 01 wood tars concernldsom. citizens who .nvisioned both
project costs and duration escalating. '. .
EPA Response: If Alternative No.3 or No.4 Is chosen, th. time Involved Is
primarily for excavation.
Following the comment period, the EPA will produce a Record 01 Oecislon
(ROO) that will explain why each discarded technology was rejected and why
the alternative chosen was selected. Then a bid specification will be
developed and the design phase will begin. Whan a contractor Is selected
construction can begin. It will be a surprise 11 the removal action takes more
than one month once activity begins at the site. The only problem that might
occur would be the discovery 01 an unexpected quantity 01 wood tar. Seeps
may keep cropping up in some areas, and the EPA wants to b, sure they ar.
r~ovld. . This will require .n on-scene coordinator to make a vlsulil
determination. 5011 sample. will be.lnalyzed to bl sure the salls are cleaned
up to .t least 10,000 ~g/~gfor carcinogenic polynuclear aromatic
hydrocarbons. The EPA wants to prevent future outbreaks of wood tar on the
ground surface. However, there is no effectlvI way to remove all the wood
tar dlposlts In this area, and. so wood tar d.posits may surface .Isewhere.
The pit can be removed though, and there will not be any more deposits like
that occurring.
,.
3;
Several comments addressed the possibility that bids recelv.d 10r slte-
remediation might be higher 'than anticipated. Commentors f,lt that, If the
price increased significantly, the EPA should consult the community before
4
-------
proceeding with remedial activities. Inquiries were also made about the.
possiQWty that the community might agree to the removal of the wood tar
deposits vet feel that a cheaper method could b. found.
EPA Respons.: If the bids received by the EPA ar. higher than anticipated,
thl EPA will have to decide what It "Is willing to PlY. The only time the
agency wtll return to the community ,. when the recommended alternative
changes from what was presented during thl comment period. If the EPA
decides the bids received are too high, th.n It may be necessary to select
anoth.r alternatlv., and that would bring the EPA back to the community.
Congress Is pushing very hard to get site. remedlated. The new law will
require not only cllanup but cleanup by a clrtaln date. (Th. latter response
was an Indication that there wasn't tlm. to begin searching for another
r.medlal alternative).
Public Health and Environmental Concerns
,.
Concerns were expressed about groundwater. On. comm.ntor asked that the
dlff.renc. betWeen groundwater and surfac. wat.r be .xplalned, and others
sought reassurance that no one was at Immedlat. rfsk from the water supply
In us..
EPA Response: Groundwat.r Is thl water beneath the ground surface. Loca'
domestic wells obtain their wlter from thl groundwater. All the domestic
wells were tested and found to be clean. None contllniJd the organic
chemicals or gasoline-type compounds associated with the wood tar deposits.
Only one monitoring wen had unacceptable Ilveis of cont~mlnants; and that
well Is not In use as a source of drinking wlter. Sampling did show that a lot
of particulates occur in the groundwat.r In this area which Is probably the
reason that residents had already stopped using their wells and started using
water from the upgradlent springs Instlad. A new water line Is not
necessary; the groundwater Is not a health risk at this time. Wood tars will
not dissolve easily but there Is a potential for them to '.ach Into the
groundwater .v.ntually. The only immediate threat comes from people who
ar. coming Into direct contact with the wood tars.
2.
One commentor challenged the EPA's contention that I serious health risk is
present In Westline. He suggestld IS a comparfson that the local inn
presented .an Increas.d risk of cirrhosis of the liver but that the Federal
Gov.rnment h.d no right to dlctat. whether the community took that risk or
not. Another resident stated that the agency hasn't established that a
pot.ntlal for contact exists. This Individual said that, since the most notable
contact. had been made Iccldlntally, th.y should be considered singular
Incident. and should b. dlsr.garded.
. EPA Response: The EPA hIS singled out one contamlnlnt. b.nzo(a)pyrene,
from aU of the other contaminants as an Indicator of health rfsk. . This
conumlnant Is found In the wood tar and has been singled out becausl It Is
the only one of the entire group of polynuclear aromatics (PNAs) found at the
Westlln. Sitl that is known to cause Clncer. In truth, PNAs cln be found In
III tars. The tars on the road and the tlrs on your roof II so contain It.
5
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The Igencv worries about the cancer risk associated with the compounds
founut the site. It considers the concentration of this compound that will
cause can"cer in 1 out of a million people, If those people are exposed to the
compound for I 70-year lifetime. The amount of benzo(a)pyrene found at
WestUne can be expected to cause cancer In 1 out of 10,000 people. Because
West"ne Is a community where people live III of their lives, the EPA feels
that the wood t8rs are unsafe. . .
Also, there J. more to the health risk Issue than the potlntlal to cause
cancer. There Ire other diseases, such as liver disorder., that can be
Issociated with the contaminants at Westllne. There Is Iiso the potential for
accidents, even fltal accidents, to occur. The EPA wants to remove those
risks, and It 81so wants to protect Individuals, such as children and tourists,
who have no say In this matter.
3.
Citizens were concerned about the Impact removal actions might have on air
qU8lity. They recalled that, during the earlier emergency removll, odor was
a problem for the community and especially for tho.e at the Westllne Site.
EPA Response: During removal Ictlons the EPA will monitor Ilr quality.
This Is Plrt of the Impact statement, and It It Included In the project costs.
These wood tar deposits ar. unlikely to crllte must dust, but If It appelrs.
that dust Is a problem, the arel will be hosed down with water. That's a
simple and accepted engineering. practice. There will be monitoring for other
air releases as we". The problem ofsme" Is another matter. '-The wood tars
. do smell Ind air monitoring wIU be conducted throughout the excavation
activities to ensure public safety.
Public Participation Process
1.
Some commentors were. angry that the no Ictlon alternltlve was ruled out by
the EPA before the public comment period opened. They suggested that the
agency hid already made Its selection of In alternative Ind was merely going
through the motions to make the public feel . Involved In the agency choice.
One commintor cited Alternative No.2, which cilled for an. onslte landfill to
be constructed on' the site of the old wood processing plant, IS an example of
the EPA's e11o" to manipulate the public. This Individual reasoned that no
o",e in the community would vote to loclte a landfill above the town's only
~ommerclal business and upstream of the drinking water supply; therefore, he
felt thlt. by presenting this Iitemltlve, the EPA hid deliberately narrowed
the number 01 acceptable alternatives. Commentors wanted to know 11 the
EPA had ever discarded Its preferred alternative also the local community
objected to the agency's choice. -
EPA's R.spons.: The EPA has changed Its choice of alternatives In the past
because 01 public opinion. The public comment period Is the time to speak
up. But, the EPA reserves. the right to dlslgree.
Conslderltlon of the no-action alternative Is required. under Superfund so that
the risks 01 nO-lctlon are fully understood. A preferred alternative Is also
presented. so that the public his a specific remedial alternative with which to
6
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agree or disagree. Most people seem to prefer this. However, EPA hIS
presetrntd . several possibilities, all of which meet all of the requirements
placed on the agency by the Congress.
The EPA cannot accapt a no-action alternative at this site because It would
allow the risks of dermal contact and groundwater contamination to continue.
The EPA wants the tars removed, and all of the suggested alternatives
Include excavation of the wastes and adlolnlng salls. The agency also Intends
to do I verification study of the groundwater to determine the extent of
groundwater contamination regardless of which alternative Is chosen, but
there Is no reason to believe It will be necessary to pump and treat
groundwater at this time. The PNA. In the local solis are not above
acceptable level., Just In the wood tars.
Regarding the location of an onslte landfill, the former plant site was chosen
because It Is the source 'of the problem. It would be unfair to locate a landfill
on the property of anyone who was not responsible. However, the EPA Is
leaning away from Iindfliling when It Is pos.lble to get rid of wastes more
efficiently. In response to the commentor Indicating that the landfill would
be upgradlent of the local water supply, that la Incorrect
2.
A commentor asked If, In overriding the pUblic opinion with regard to the no-
action alternative, the PEA Is setting I precedent that every tlme.'a ter pit Is
exposed the EPA will step In and remedlate It. . :, . .
EPA Response: Ve., the EPA II setttng a precedent.
.
CostslFundlng Issue.
1.
A number of residents were concerned about the cost of remedial action.
They questioned whether It was necllsary to choose Alternative No.4, one of
the most costly alternatives, yet they Iiso wondered If the most expensive
alternative, Alternltlve No.5, which cilled for onslte Incln~ratlon might be a
good Idea If It could provide Jobs for local citizens. They reminded the EPA
that even If the cleanup I. funded by the chemical Industry, the consumer
stili pays the bill-In Increased product costs. One citizen suggested that the
EPA was -bllldng- the chemical Industry and -squandering- the money in
c~ooslng a .more costly remedlll IItematlve. .
EPA Response: The EPA prefers Alternative No.4 over Alternative No.3
becluse the Igency Is moving away from Iindfilling. Incineration saves
valuable landfill ,plce and prevents the excavated wastes from becoming a
problem for another community It some time In the future. Although It Is
true that the consumer does pay an Increased product price, 85 percent Of the
cost of Superfund Is plld for by the U.S. chemical Industry. Where a
responsible party Is Identified Ind Is stili In operation, the EPA requires that
the Superfund be reimbursed, but this Isn't possible at WestUne.
The cost of the preferred Iitemative Is very modest by Superfund standards.
The EPA Is neither squandering Superfund monies nor bllldng the chemical
Industry. It Is using the monies as they were Intended to be uS.d. By
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comparison with other Superfund cleanups, 5400,000 to $700,000 Is not very
much._-Some sites cost IS much as $30 million, and sometimes the people
Involved complain that the EPA Is not doing enough.
The Wlstlln. Site fs not as serious a threat IS those sites, but It Is on the
Natlona' PrJorltles Ust, and the EPA must clean it up.
Regarding Alternative No.5, which calls for onslte Incineration, that could
be the Agency's second cholca, but It would bl likely to provide Jobs for local
residents. Both the Incinerator and the personnel to operate It would come
from out of town.
2.
Several com mentors raised Issues related to property value. They Inquired
whether the EPA wasfequlred to Include an Impact statement concerning
property valuls In Its report. One clt'zen discussed the flct that, Iithough
the law requires seliers of property to disclose the presence 01 I hazardous
waste site at the tl.me of a sal., many sellers are failing to do this, and
unsuspecting buyers are suffering.
EPA Response: There Is no requlr.mont that the EPA attempt to project or
reimburse personal losses due to the existence of a hazardous wllte site.
One of the ong~ing battles In Congress Is about compensation for the vlctlms-' .
of others' Ictlons. Congress has not yet bltn Ible to tlclde this Issue. In
fact, the liability Issue will be the most difficult and onl of th.1 most visible
of all Issues before the Congress. "
Insurlnce Is a very expensivi proposition, Ind It Is extr~mlly difficult to
determine where to drlw the line. For Instance, 11 one were to seek
compensation for I health-relatld matter; how could It be determined it
health problems relate to a site and not to personal habits such as smoldng or
to employment factors.
While It Is trul that thl law rlqulres property owners to disclose the pr"ence
01 hazardous wastes on site at the time a property Is sold, thlse laws ar.
relatively new. Some sltls arl so old that no onl knows. thlY are there.
Some states arl blglnnlng to make these laws very harsh. .In Nlw Jersey, the
law requires that sails bl voldld and slll.rs be fined, 11 It can bl shown that
a seller lied It thl tlml 01 sail.
3.
One comment conclrnld thl breakdown of. costs and thl dlfferlnce In the
costs 01 thl various "tlmatlvli. Another concern was whether thl funds for
remedlll Ictlon at Westllnl werl alrtldy committed.
EPA Rlsponsl: Capital costs Includl the cost of design and Instillation and
also thl cost 01 transporting exclvated matlrlals to the required facility.
Operation 'and malntlnance costs for Aiternativi No.2 Includl the txpense at
maintaining I Ilachati colilction systlm and monitoring thl groundwater for
30 years. The differenci In oplratlng and maintenance costs Imong the
alternatives Is only about $' 50.000.
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4.
..
~ ;'
Funds fQr ithls site .re not available at this time, but when they become
avaiiabTi: we will spend them on the chosen alter"atlve.
As e point of Interest morl than concern, one resident observed that. If the
EPA hes as many peop'e at other Superfund sites. as It has in thl Westllne
ar.., there must be 8S million people- on the EPA payroll. Another citizen
mused that, if the community chose Alternativi No.3 Instead of
Alternative No.4, the government might be Inducld to allow the community
to split the $300,000 saved.
EPA Response: Not a" thl peop'e In the Westllne area are EPA employees,
although their work la funded by thl EPA, but soml areas are heavily
burdened with Superfund sites, and many EPA personnel are In those areas.
New Castle County, Oelawarl for Instance has nine Superfund sites. There
are 888 sites on the National Priorities List and more than 24,500 sites on the
CERCLA list. And we Irl only talking Superfund; there Ire also programs
for Ilr, water, RCRA. Injection wells. The EPA Is a vlry long Irm.
(The commentor who wanted to divide savld funds Imong community
resldlnts was Idvlsld good-naturldly to Sll his legislator.)
Other IssuI'
1.
A prlmarv concern of the Westllnl community was to re.llz, an. economic
benefit from remedial activities. .Inquirtes wert made concem(ng the use of
local contractors and laborers. . The EPA was asked to makl BOA forms
available In the community.
EPA Response: The government Is required to take bids for this work. but
there is no reason why locil contractors can't bid. Bids are handled by the
Corps of Engineers. The EPA can certainly make BOA forms available
locally and also request that the Corps advertlsl heavily In this area.
Normally, the call for bids Is advertised In thl Congress Business Daily, and
anyone can respond to It.
2.
A number of citizens statld that Westllne received a great deal of negative
p.ublicity when the site was first placed on thl NPL. Thev felt that the EPA
was responsibll for telling thl world that Westllne had a problem and that It
would bl onlv fair to expect thl EPA to make an equal Iffort to notify the
world, whln the probllm II resolved. Thesl. plople cautioned the EPA that, If
an effort Is going to bl mlde to promotl the town to outsiders, the wording
of promotional statlmlnts will bl most . Important: The term -monitoring-
was ~onsldertd to connote an ongoing problem.
EPA Response: The EPA Is ge.ring Its public Involvement to promoting
community cleanup,. and it Is very. eager to hear public viewpoints on this
subjlct. When the remedial actions are completed, Wes~lInl will not have a
problem anymore. The EPA will try to convlY this mlssage to thl public.
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It IS I mlsco.: .:t,tlon to view monitoring negatively. Monitoring is a safety
valve. -As . fl~:url: s ;~re r,ub!ished 88ch vear and the numbers decrelSe, it Is
proof that thint:~ ar. h.1proving, and everyone will be able to see It.
3.
One commentor '"r:Jlr,}d '.'Ihether EPA would see that the medii pr.sent
Westllne fav~r.;i)ly, ;,.,d one v/ondered. if It would be , lie to say thlt the
town, following rer.10'.f:.! tctlons, will be safe,
EPA Response: T;~. i::~':\ ~;oes not control the media, but It cln try to present
what Iho!Jld be J Jd abC)ut the site In the lite documents. The EPA knows
that there .r.J 0,;-,., ',ar pits In northwestern Pennsylvanl'. The precedent
that the 'gl< n~.,. ,:. trying to Sit I. that these wood tlr deposits be removed
from the SUf'i't:i~;\oi where th IV can prlSlnt a dermal thre,t. There Is always a
potentl" for recurring proble.11S 8" hazardous waste sites. Sometimes all the
EPA can really do Is to put a b,ndald on a site, but I removal action is the
best cleanup I . ..~1 do. I' am g~h'g t~ Sly that thl sltll. cleaned up. That Is
how It Is ~olng to (;;1:,.-;11 out.
A st:ate")~l1t ~ - - ;n.td" by one of thf; IIf6!or) ". -;Idents of WlstUne. HI .Iid thlt he
had COlT,,';.. ~ ..d pUr,ll~ meet.!ng b"~f:'t . .IG ~~t t h8 wantld to .upport thl no-action
alt9rnaiJ'", ~m1 \ht~~ ~" had changer.! his rniiid. He d!d not f.el that he would benlflt.
'much'iQrr. ..:-.. remtal,' :~f.:tlvltl.s, but he belilved that the EPA WI' on the .rlght.
tn...;"- ~j,d i.i1~t :-'ia g:-:_,.J(,:t';..Jren might benefit from thl Aglncy'. efforts. he also
~ug~' ;,$L\I that the mo~t \lOCi I OPPJsitlon to' the EPA's plans came bom ~ndlvldu8Is.
",hI) t"~d otle" In the comrr~'. ,Ity less than 1 yelr Ind who did noi'own property
tt)l!J;"s. His support of thl"5.: A's prafcrred Iitentative was Immediately Joined by
uit~er r~)at!n,~.
IV. REMAINING PUBUC cr
~NS
Issues !and concerns
planning Ictlvitles In('
the EPA sho~11 M~nlln sWire of during the remedial
1.
The belief .~
cOmmufJlf
.r1 o ,'d.,j.. for the IIlte ~I"~nup to be truly beneflcia' to the
.I resl~:!nts must realize ~ G!'tlJre of the monies being spent.
2.
ihe p- .- ;en:Jlt!vlty of local r~"sidents \0 the wlY that site activities are
!J'-.i11.Q pn.,: Joted to '~h. outside w.-:I:d '/ia ~.);~ representatives and the media.
.' '.
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ATTACHMENT A
,.
r/
, ./
. .
...--
COMMUNITY RELATIONS ACT1V1T1ES CONDUCTED
AT THE WESTUNE SITE
):
. A prlss rll.ISI Innouncld thl Ipproprtltlon of funds to plrform In
Emlrglncy Rlsponsl Action. It Iiso Innouncld I public mlltlng to discuss
thl pllnnld response. Flbrulry 1983-
. A pUblic mletlng WI' hlld It thl Wlstllnl Inn to discus. thl Work Plln
Ind thl proposld proJlct SChldull. Prtor to thl IVlnlng mlltlng, I
brllflng of locI I offlcilis WIS cO~dUCtld, Mlrch 1983.
. A prlss relll.1 Innouncld I public mlltlng which WIS hlld to dlscu.. thl
pllnnld IChlduJ. tor thl Rlmld~11 InvIstlgltlon (RI), Octoblr 1984.
..."
. An opln housl WII conductld It thl Wlatllnl Inn to discuss thl RI Rlport
with Intlrlstld PlrUIS,. Olclmb.r 1985. .
. A prill rllllSI WIS ISluld to InnounCI I public mlltlng conclrnlng thw
Fllslbillty Study Rlport, MIV 1988.
. .
'. A tlct ShHt conclrnlng Rlmldlll Action Altlrnltlvls wli~ preparld Ind
dlstrlbutld It I public m.ltlng hlld It thl Wlstllnl Fire HIli, May 1986.
-
.
. ~ . 6
", '.- -..1 .
... 8. .. "-'".' . . ." ..: ""
",' .'" ... .
..: : ..:':.~.(;.~1~~g~~~~:If.:~;;.> ..:..:': . ....
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