Environmental Protection
Agency
Office of
Emergency and
EPA/ROO/R03-88/028
S«oiemB«f 1986
SEP A Super-fund
Record of Decision
Industrial Lane, PA
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1S. SU"I.IMIH1'A"Y HOTIS
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The Industrial Lane site encompasses approximately two square miles in Wili~ms
Township, Northampton County, Pennsylvania. A portion of the Chrin Landfi 11, a -
Pennsylvania Department of Environmental Resources permitted landfill, is on the site dS
, -e several active and abandoned industrial properties, commercial establishments,
A.ilroads and farming/residential areas. As a result of the detection of low level
ground water contamination, the Chrin Landfill was placed on the NPL in February 1983.
In addition to the preparation of a Remedial Investigation, two Feasibility Studies Eor
the Industrial Lane site were also prepared. The first, known as Operable Unit I,
focuses on the remedial. alternatives for private well users. The second, Operable '1ni-:
II, will focus on remedial actions addressing ground water remediation. No consisten':
contaminant plume has been detected to date due to the complex geology of the area.
Possible industrial activities contributing to the contamination include, but may nt:)': ::..
limited to, iron ore ext ract ion and iron works operations. The possibility also ex L s ':.'
that refuse and/or other unknown substances were more recently disposed of into o\'\e 0=
more of the iron are extraction pits on the Chrin Landfill and industrial complex
facility. While residential wells located upgradient of the Chrin Landf ill have
historically contained only background levels of VOCs, the chemicals detected in ''''ell:;
within the Glendon Boro residential community represent the primary contaminants of
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Record of Decision
I ndust rial Lane, PA ,
.
Contaminated Media: gw
Key contaminants: VOCs, TCE
JIST~I'u1'IO'" STATIMINT I'. SICu"'T" CI.ASS / rIll' R~p(J'" 21. NO. 01' IIACiS
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~PA/ROD/R03-a6/02a
rndustrial Lane, PA
16.
ABSTRACT {continued)
concern. Thes. include tetrachloroethene, trichloroethane. and chloroform.
The selected remedial action for this site involves the provision of an
alternate wat.r supply to approximately 15 households. Since existing curb
service is available this action only i~volves installation of several lines
to the designated households. The estimated capital cost for this action is
$30.800 with no annual o&M.. .
-.
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Record of Decision
Remedial Alternative Selection
Sice; Industrial Lane Site - Operable Unic I
NereTiaapcon County, Pennsylvania
Docuaencs Reviewed
I an basing ay decls.ion primarily on che foliovi-g
doc u.aunts describing che analysis of cost-effectiveness and
escene of contamination at cha Industrial Lac.a 3 i t a as d i : a r -
uined during che Renedial Investigation,'Feasibility Study.
- Industrial Lane Site Remedial Investigation
NL'S Corporation
June l*>Jo
- Industrial Lane Site Endangeraent Assessment
NUS Corporation
June 1936
- Industrial Lan* Site Focused Feasibility Study,
Operable Cnit I Private Wall Users • .
NL'S Corporation
September 1936
- Staff suaaari-is and reco-aandat ions
- Public Coanefits and Responsiveness Suaaary
- Letter of concurrence froa Coaaonvealth of Pennsylvania
Description of Selected Raaady for Operable I' n it I
Alternactve N'uabar three (3J Alternative Water Supply has
beer, se letted, vh.ch. consists of '<:; 3 '.•: i r. : up numerous private
veil uiers in tvo high ris* araas, Lucy's Crossing and Gler.djn
Baro to existing water aains belonging co cha Zaston City
Suburban Water Authority. No oo-jration and aai r.t-ananca is
necessary for this raaedy.
Declarations
Consistent with the Coapra'r.ensiva Er./'. rar.aer. t al Response,
Coao-snsation, and Liability Ac: of 1930 (CIRCLA) and the
Sacior.al Csntingency Pl-.i (^v C~X Part 300), I have 'de t e r-=i nsc
that hook-up to che existing public vacer systaa, Alternative
3, is the -:ost cost-effective rszei;-- fjr the Ir.dustriil lar.e
Site. As a result of the Reae^ia. Investigation, ir.dan.je.raen:
Assjssaer.t and "ocused Feasibility Study, i aplizer. t a 11 :n of
the selected raaedy will aitigate currer.: ar.d fu:ura ria'<
to public health c'roo the consuap tion of cont aainacad grouniva
associated with che Industrial Lane Site.
-------
~ have also dec~r~i~ed ch~c c~~ a:cL,n ,~t~g Ca~~~
is appropriate ~h~~ 'a:a~:ej a5li~s: :~~ a~~i~a~ilicv ,:
!rusc Fund manias for use ac .ocher sic~s. .
.
.
. .---..-.
..
Sta~lay t. taskows~i .
~~put7 1e~lonal A:~inlitrator
~~;~,~ :~! - ~~.:~~
Dace
--.
The Deputy ~ional Mninistratcr's signature and the 1Q) signature date,
September 29, 1987, did net xerox 'Nell fran the original.
.
.
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
INDUSTRIAL LANE SITE
NORTHAMPTON COUNTY, PENNSYLVANIA
SITE LOCATION AND DESCRIPTION
The Industrial Lane Site is a geologically varied and complex area
which encompasses approximately 2 square miles in Williams Township,
Northampton County, Pennsylvania (See Figure 1). The study area borders
on the Southern boundary of the City of Easton and the Lehigh River to
the north and northwest. " The community of Glendon, which includes Lucy's
Crossing and Glendon B~o, is located to the west and southwest portion
of the study area. Key features within the study area are an active
Pennsylvania Department of Environmental Resources (PADER) permdtted
landfill known as the Chrin Landfill, several active and abandoned industrial
properties, commercial establishments, railroads and farmdngl residential'
areas. The area has a long history of industrial activity that has
impacted the surface and subsurface of the region.
In 1980, low level g~oundwater contamdnation was detected in the area,
at which time Chrin Landfill was called to the attention of the Environmental
Protection Agency's (EPA) Superfund program. The site was placed on the
National Priorities List (NPL) in" February 1983. After the site was
placed on the NPL EPA conducted a Remedial Investigation (RI) in order
to characterize the type and extent of contamdnation at the site and
evaluate the potential public health and environmental concerns. In
addition to the RI, two Feasibility Studies (FS) for the Industrial
Lane Site were prepared. The first, known as Operable Unit I, focuses
on the remedial alternatives for private well users. The second will
focus on remedial actions addressing groundwater remediation in the study
area.
This Record of Decision (ROD) will address Operable Unit I; the
selected alternative of remedial action for private well users.
SITE HISTORY
During the Remedial Investigation phase of the study, a review of
available historical photographs and additional documentation was conducted.
It has been concluded from this investigation that:
o Significant industrial activities characterized the Industrial
Drive area before development of the Chrin Landfill. The most notable
include; the Pennsalt Industrial Complex, which operated during the early
1890s', the Glendon Iron Works, which operated between 1844 and 1896; and
limdted iron ore extraction activities which occurTed between 1840 and
1890.
o Scattered industrial development was also observed north
and northeast of the Chrin Landfill on 1947 aerial photographs. The
area corresponds with the present day locations of Easton Car and
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SOUTH EASTON
PENNSYLVANIA /-
SOURCE, usis CASTOM,NJ-PA
LOCATION MAP
INDUSTRIAL, LANE STUfW
SCALE
FIGURE 1
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Construction, Specialty Products, and Dynatherm, Incorporated. These
facilities were all in existence prior to the development of the Chrin
Landfill and prior to the enactment of present day State and Federal
environmental regulations.
o The Chrin Landfill and adjoining properties to the northeast
have had a documented history of iron ore extraction activities. The
probable location of at least three of these extraction pits or shafts
fall within the area which is presently occupied by the Chrin Landfill
and the abandoned pennsalt Industrial Complex.
o The possibility exists that refuse and/or other substances
were disposed into one or more of these pits on the Chrin Landfill and
Pennsalt facility area.
--.
The Chrin Site remained undeveloped and slightly wooded until 1958
when the current owner/operator purchased the property and began land-
filling actl~ties in 1961. The landfill is now active and operates
under a PADER sanitary landfill per~t. The landfill consists of 30 acres,
but a 13 acre expansion east and adjacent to the landfill for municipal
and demolition waste has been proposed by the owner and approved by PADER.
Significant changes to the area are expected to occur along the proposed
1-78 right-of-way corridor which will extend east to west approximately
850 feet north of Industrial Drive and near the Chrin site. Zoning.
changes in the area will occur to provide for commercial development
along the highway. .
LAND USE
The land use in the Industrial Lane Site study area is light industry,
single family dwellings, forests and cropland. The light industry includes
the Chrin Landfill along with 10 other active industries. The single/family
dwellings are concentrated in the communities at Glendon Boro, Lucy's
Crossing and Morgan Hill. Forests occupy the land just east of the
landfill that extends upward to Morgan Hill and crop lands occupy parts
of the Morgan Valley and Glendon areas (See Figure 2).
SITE GEOLOGY AND HYDROGEOLOGY
Geologically, the region consists of highly weathered and structurally
deformed rocks which are older than 500 million years, from the Cambria
and Precambrian era. Few outcrops exist in the area owning to tbe difficulty
in determining tbe complete structural geology. In addition, the Musconetcong
Fault runs through a portion of the Site. These conditons have created a
complex geologic setting. .
Compression forces have generated deformation which has left the area
with more or less parallel longitudinal folds consisting of crystalli~e
rock overlain by sedimentary strata. These folds are broken by faults
but tend to follow the general northeast-southwest trend of the strata.
Extensive weathering of the Precambrian crystalline rock and cambrian strata
have left large clay deposits such as the one on which the Chrin site was
constructe,d.
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SCALE IN PCET
LOCAL INDUSTRIES
INDUSTRIAL LANE REMEDIAL INVESTIGATION .NORTHAMPTON CO..PA.
(SCALE ABOVE)
F I G U P
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. .
Ground water in the Industrial Lane study area flows primarily
under water table conditions. The Byram gneiss, which forms Morgan
Hill, supports a semi-confined ground water system as a result of a
poorly interconnected fracture system. Though only anomalous flow systems
were identified, it is reasonable to expect they are caused by the major
structural features and strata of low permeability silts and clays to cause
isolated flow systems. The varied subsurface lithologies (such as dolomite,
silt, clay, quartzite and gneiss) result in a complicated assortment of
ground water velocities and flow paths. The majority of potential contami-
nation sources are located in the carbonate region.
SURFACE WATER HYDROLOGY
Surface waters within the study area were evaluated both locally and
regionally. An inventory of local surface waters includes Morgan Valley
Creek (area 2 of Fig. 3), the unnamed tributary to the Lehigh River
that drains the Chrin Landfill (area 1), the unnamed tributary to the
Lehigh River which drains at South Easton (area 4), the unnamed tributary
flowing past Ashland Chemical, and the unnamed tributaries flowing into
the Delaware River on the eastern side of Morgan Hill. Aside from sedi-
mentation control basins at the Chrin Landfill, no significant natural
or man-made impoundments were identified. Regional surface water bodies
include the Lehigh Canal, the Lehigh River, and the Delaware River. .
SURFACE AND GROUNDWATER DRINKING SUPPLIES
Water supplies for users within the study area come from both ground
water and private domestic wells and from a public municipal distribution
system. The public water system that extends into the study area i8
operated by the Easton Area Suburban Water Company. Water supplies for
this system are purchased entirely from the city of Easton. The Company
in turn draws 100 percent of its water from an intake on the Delaware
River. This intake is located approximately 1-1/2 miles up the Delaware
River from the confluence of the Delaware and Lehigh Rivers. The Easton
Area Suburban Water Company distribution lines extend to all residential
areas of the Industrial Lane study area except Morgan Hill. Residents
of Morgan Hill, therefore, depend entirely on private wells, cisterns,
or bottled water for domestic water needs. Though water main lines
exist within the communities of Lucy's Crossing and Glendon, several
individual home owners within these areas have chosen to use private
wells. 'Figure 4 illustrates the general layout of the existing Easton
Area Suburban Water Company's public service district within the study
area and the locations of confirmed drinking water source wells still
actively used within the study area.
Despite the availability of public water, Lucy's Crossing, Glendon
and the Western End of Industrial Drive are still areas of concern due
to the localized potential ground water situation through the use of
private wells. The threat to the ~stern End of Industrial Drive however,
has been virtually eliminated through the supply of public water from
Easton Area Suburban Water Company.
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, > .»•>*.* »*
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EASTON AREA SUBURBAN WATER AUTHORITY PUBLIC SERVICE DISTRICT AREA
INDUSTRIAL LANE REMEDIAL IN VE STI GAT ION . NORTHAMPTON CO . PA
( !,( A| I AHOVt I
FIGURE 3
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SURFACE WATER INVENTORY MAP
INDUSTRIAL LANE REMEDIAL INVESTICATION. NORTHAMPTON CO .PA
(SCALE »BOVf I
FIGURE 4
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Of the households that make up Lucy's Crossings, approximately 8
still obtain water from their own wells with one resident using well
water for bathing and cleaning but not for drinking. Only individual
home hook-ups are required to provide service. The remaining households
already receive public water.
Glendon Boro consists of 3S residential homes approximately 28 of
which receive public water and the rest which are now utilizing private
wells for drinking water needs. (See Fig. 5)
FINDINGS OF THE REMEDIAL INVESTIGATION/FEASIBILITY STUDY
During the Remedial Investigation, geologic and hydrogeologic
investigations and water sample analysis were performed in the site area
to determine subsurface conditions, ground water flow patterns and the
mechanism for contaminant migration. The primary focus of the investigation
was to identify a contaminant plume(s) and to ultimately identify the
potential source(s) of the low-level, area-wide ground water contamination.
These tasks were facilitated by conducting a literature review, a well drilling
and groundwater monitoring program, a limited geophysical investigation, and
a ground water monitoring and sampling program.
The analytical results from the study and ground water elevation
data revealed that the greatest variety and most pronounced occurrence of
ground water contamination is in the community of Glendon Boro. Residential
wells down gradient of the landfill and the other potential contaminant
sources were sampled. Compounds detected in groundwater samples from a
number of the residential wells included tetrachloroethene, tricholoroethene,
l, 1 ,'l-trichloroethane, and chloroform.
No consistent' contaminant plume could be detected. Indeed, some wells
were found to contain chemical contaminants, whereas others located only a
short distance away contained no detectable levels of contaminants. These
apparently anomalous features are probably a manifestation of the lateral
and vertical proximity of the various wells to bedrock fractures.
The Chrin Landfill lies directly upgradient of Glendon Boro and may
be hydrologically connected to Lucy's Crossing. All chemicals detected
in the residential wells have been found at higher concentrations in
monitoring wells within and downgradient of the landfill. Wells located
upgradient of the landfill have historically contained only -background-
levels of any chemicals (i.e., isolated occurrences of volatile organic
compounds or VOCs; generally less than 5ug/l [ppb)). The upgradient
wells lie in proximity to the landfill, and the occasional occurrence of
VOCs in these wells may be a result of influx caused by well purging
prior to sampling.
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CONFIRMED DRINKING WATER WELLS
INDUSTRIAL LANE REMEDIAL INVESTIGATION .NORTHAMPTON CO.PA
I SCALE ABOVE I
FIGURE 5
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A partial leachate collection system is in place at the landfill,
however quantities of leachate are not captured and escape into the sub-
surface. Analytical results for leachate samples (coupled with results
for the groundwater samples) indicate that HSL chemicals are being leached
from the landfill waste deposits.
Primarily due to the lack of any discernable contaminant plumes,
receptors could not be confidently tied to a single or multiple set of
sources. Never the less, the available data is sufficient to provide a
qualitative assessment of contaminant migration and source location
indicating that the residents .of Lucy's Crossing and Glendon are at a
potential risk from ingestion of ground water. Carcinogenic risks could
be incurred through drinking and through inhalation of volatile chemicals
released from groundwater during showering.
The current carcinogenic risk for each exposed individual has been
estimated to be approximately 1 x 10-6 (or a 1 in 1,000,000 chance that
an exposed person will~~ontract cancer over a 70-year lifetime of exposure)
for residents of Glendon Bora, and 2 x 10-5 (or a 1 in 50,000 chance)
for exposed persons living in Lucy's Crossing (NUS/FIT 1986). These
risk estimates were established based on the average concentrations
detected in contaminated residential wells from separate sampling rounds.
The potential future carcinogenic risk estimate was generated by
assuming that a residential well would be placed in the immediate vicinity
of the Study area's mQst contaminated monitoring well (N-8) because it
has not been possible to characterize the transport and fate of the HSL
chemicals in leachate from the landfill because of the complicated
hydrogeology. The exposure assessment approach employed in the Endangerment
Assessment (NUS/PIT, 1986) was coupled with these worst-case groundwater
concentrations to arrive at an incremental cancer risk of 7 x 10-3 (ingestional
and inhalational exposure through drinking and showering, respectively).
This corresponds to a 1 in 140 chance that an exposed individual will
contract cancer over a 70-year lifetime.
It should be noted that, although the future potential risks posed
by the maximum concentrations in NUS monitoring well N-8 are much greater
than those to which receptors are presently exposed it is unknown whether
residential concentrations will reach, or possibly exceed, these levels.
A number of factors such as dispersion, degradation, and adsorption
.
should preclude concentrations in the residential wells from reaching
levels similar to those in well N-8 unless contaminant release from the
landfill or other sources dramatically increase in the future and cannot
be attenuated by natural processes. .
ALTERNATIVES DEVELOPMENT
The Feasibility Study - Operable Unit I, focused on providing remedial
actions which would mitigate human health risks of the residential well
contamination under present and future conditions for those residents
in the highest risk areas, namely well users in Lucy's Crossing and
Glendon Boro. .
Based on the criteria of implementability, applicability to site
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conditions, cost effectiveness, and technical development status the
following alternatives were derived:
o Alternative 1 - No Action - under this alternative no-action
would be taken to remediate the private wells. Present site conditions
and environmental risks would continue with a possibility of natural
deterioration in the future.
o Alternative 2 - No Action with Monitoring - Under this alternative,
no remedial technologies would be implemented and no action would be
taken at this time to remediate private wells. Essentially this alter-
native would involve a long-term (30 year) monitoring program for groundwater
and private wells on a quarterly rotating basis and the construction of four
monitoring wells, (2 per cluster) two near Lucy's Crossing and two near
Glendon Boro.
The results of th~s program would be evaluated by a designated agency
to track further migration of contamination.
o Alternative 3 - Alternative Drinking Water Supply - Since the Easton
Suburban Water Company has existing curb service available to all homes
in the communities of concern, installation of service lines ftom the
street mains to the designated households would involve furnishing and'
installing a curb box, valve, 50 lineal feet copper pipe, trenching
and 'backfilling.
o Alternative 4 - Individual Well Treatment Systems and Monitoring
Under this alternative, an individual treatment unit would be
installed in each home using private wells in Glendon Boro and Lucy's
Crossing. . This involves the installation of a granular activated carbon
(GAC) treatment unit consisting of a galvanized steel tank filled with
GAC and a fiberglass tank for the temporary storage of back wash.
~
)
COSTS
The cost for each alternative are presented in Table 1.
RECOHHENDED ALTERNATIVE
Remedial Action No 3 - Alternative Drinking Water Supply was selected
as the appropriate remedial action at the Industrial Lane Site.
The evaluation method used on. each action consisted of the following
criteria.
o Technical Aspects (effectiveness, useful life, performance,
constructability time)
o Public Health and Environmental Concerns
o Institutional Issues (Regulations or performance standards)
o Cost (including Operation and Maintenance)
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TABLE 4-1
REMEDIAL ACTION AL TERNA TlVES COST SUMMARY
INDUSTRIAL LANE SITE
(COSTS ARE IN 1986 DOLLARS)
Remedial Action Alternative. Capital Cost O&M Cost Present-Worth
(per year)
1. No Action NA NA NA
2. No Action with Monitoring 563,700 $44, 160 $480,000
3. Tap-In to Public Water System "I' 530,800. N"~: 530,800. .
4. Individual Well Treatment Systems 5134,600 591,920 51,001,000
with Monitoring
-
NA. Denotes Not Applicable
* Cost is approximate based on estimate of number of homes using private wells without
public water supply. .
..
.
.
4-13
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Implementation of this alternative will eliminate the .health risks
associated with exposure to contaminated groundwater. By eliminating the
potential for ingestion, inhalation, and direct contact, the public health
would be adequately protected.
Those residents within Glend9n.Boro and Lucy's Crossing who elect
to continue to use their private wells for nonpotable and non showering
purposes are not expected to incur any risk. Non-potable water uses, such
as car washing and watering of vegetable gardens, may have associated
exposure pathways, but these are deemed insignificant.
Alternative No.3 has no readily apparent occupational or public health
risks associated with implementation. The low probability of construction-
type accidents associated with heavy equipment operation and materials
handling is not a major consideration.
--.
The alternative water supply can be provided by the Easton Suburban
Water Company once the installation of the individual service lines is
complete. The cost of providing this service to the approximately 15
residents at risk is a capital cost of $30,800. This utility is licensed
to provide public water.
If this alternative is implemented, existing domestic wells in the
communities of concern maybe sealed. This could be implemented on an
individual voluntary basis. The capital cost for sealing (including all
construction and engineering mark-ups) is estimated at $500 per well.
This is based on backfilling a 4 inch diameter, 100 foot deep well with
a cement grout. This cost is not included in the cost of alternative
No.3, since it will be subject to the discretion of each affected resident.
An institutional issue of concern is the groundwater control required
for future residential development in the site area. A potential
requirement is restriction both of groundwater use by future developments
and of future well construction at existing residences. ..
EVALUATION OF ALTERNATIVES NOT SELECTED
The other alternatives .considered at the Industrial Lane Site were
rejected on the following bases:
1- .No Action
Since no-action would be taken no costs would be incurred. However,
as discussed earlier, the residents of Glendon and Lucy's Crossing
are at risk from the ingestion of contaminated groundwater. The groundwater
risks for present use are 1 x 10-6 for residents of Glendon and 2 x 10-5
for residents of Lucy's Crossing. As discussed earlier, potential
future risks may be as high as 7 x 10-3
'EPA policy is to consider a risk range of 10-4 to 10-7 in determing
an acceptable risk level for carcinogens with a 10-6 level as a target.
Current risks in Lucy's Crossing exceed this target and are only maragina1ly
-------
meet the target in Glendon. Potential future risks far exceed the target.
Since the compliance with the target risk level is not assured, the no action
alternative was rejected.
2-
No Action with Long-Term Monitoring
This alternative is the same as alternative No.1. However it would
involve construction of (4) new wells, sampling, laboratory testing and
regulatory monitoring. The purpose of the 30 year monitoring program is
to determine whether contamination decreases to acceptable levels through
natural flushing processes, or if contaminant levels are increasing and
further remedial actions are necessary. . .
Monitoring will s~ve as a warning program to current private well
users but will not protect them against possible increases in contaminant
levels.
Also, institutional restraints such as Right of Entry Agreements
between EPA and private property owners would be required. The total
cost of the monitoring program is projected at $480,000 present net worth
including 30 years of operation and maintenance.
Monitoring is less protective and more costly than providing an
alternative water supply. For these reasons it was rejected as not
being cost-effective.
4-
Individual Well Treatment Systems - CAC
The intent of this alternative is ~o eliminate the present and future
health risks associated with the potable and non potable use of contaminated
groundwater.
Granular activated carbon (GAC) can remove abroad range of
organics from drinking water. However, it is not effective in treating
vinyl chloride which is a known potent carct.nogen and has been detected
in well N-8. .If vinyl chloride were to appear in private wells the CAC .
unit would be in-effective in mitigating exposur.e.
Considering the questionable
the unitsf the $1,001,000 cost of
maintenance, this alternative was
not cost-effective.
level of future protection provided by
capital equipment and operation and
rejected as being unreliable and
COMPLIANCE WITH OTHER ENVIRONMENTAL LAWS
Implementation of the preferred alternative will be done in accordance
with 311 applicable Federal, State and Local laws and regulations regarding
the installation of water lines. The source of the public water is
the Easton water supply system which is fully licensed to distribute
public drinking water.
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OPERATION AND MAINTENANCE
There will be no operation and maintenance associated with the
preferred alternative.
SCHEDULE
Initiate Design
Complete Design
Begin Installation
Complete !nstallation
November 1986
January 1987
April 1987
August 1987
Note: The schedule is contingent on CERCLA being reauthorized 1n October 1986
--.
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.-! .
aA
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
PENNSYLVANIA
I:EEW
Post Office Box 2063
Harrisburg, Pennsylvania
September 10, 1986
17120
Bureau of itaate JlaDaCje8eDt
(717) 783-7816
Ms. Lorna Shull (3HW21)
u.s. EPA - Reqion III
841 Chestnut Buildinq
9th' Chestnut Streets
Philadelp:.,ia, PA 19107
--.
Dear Ms. Shull:
This letter is in response to your request to provide comments on the final
draft Focused Feasibility Study Operable Unit 1 for the Industrial Lane Site
located in Williams Township, Northampton County, Pennsylvania, dated AUCJUst 1986.
The Department has reviewed this document and supports the Remedial ActioD Alter-.
Dative No.3 - Tap-In to Public Water System. This alternative. involves the.
installation of. water service lines from the East Suburban Water Company's
existinCJ street water supply mains to residential buildin98 located in".t:he-
communities of Glendon and LUCY's Crossu9. The estimated capital cOst. of; :th.i'-
remedial actionaltemative is $30,800..00, with no Operation.and Maintenance' COd.
costs. . '. .
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Do not hestitate to contact 111.8 if we can offer' any 'aclclitioDal assi~c:e. .
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Donald M. Becker, Chie~ . .. .. ,,,,,::,~,,,,,,:,::,".:~;
Remedial RespoD8e; Sec:t:.iOJi.: :./, .::.,,:'~...~ ::;'~'?;;.::.):;:~'~:.'~';':H"-~'
DiVisioD ot-mneJ:'C]81icy"',' Remildi.1~R..pOiI_,:':':,:_".:;.~-:
Bureav. of Waste ManaCJement; -..~::.:., >./7::
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INDUSTRIAL LANE SITE
WILLIAMS TOWNSHIP
NORTHAMPTON COUNTY, PENNSYLVANIA
RESPONSIVENESS S~Y
OPERABLE UNIT 1
SEPTEMBER 1986
This community relations responsiveness summary is
into the followinq sections:
Section I.
Section II.
Section III".
Section IV.
divided
Overview. This section discusses the EPA's
preferred remedial action alternatives and
the anticipated public reaction to this
alternative.
Backaround ot Communitv Involvement and
Concerns. This section briefly describes
the history ot community interest and
concerns that arose durinq remedial planninq
activities at the Industrial Lane Site.
"
"
Summarv of Maior Comments Receive~ durinq
the Publ~c Comment Period and t e EPA's
ResDonses to these Comments. Comments
received are summarized and cateqorized
accordinq to topics. The EPA's responses
are also sUmmarized and included. '
'Remainina Concerns. All remaininq concerns
that the EPA or the Pennsylvania Department
ot Environmental Resources (PADER) should be
aware ot durinq the remaininq remedial
activities proqram tor this, site are
discussed in this section.
In addition to the above sections, Attachment A provides a
listinq ot community relations activities that were
conducted durinq the remedial response activities at the
Industrial Lane Site.
I.
Overview
The draft Focused Feasibility Study - Operable Unit 1,
prepared for the Industrial Lane Site, presented tour
remedial action alternatives for private well users in the
1
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study area. Durinq the public comment period, at an open
meetinq held in the community, the EPA discussed its
preferred alternative. If this alternative is implemented,
those residences that depend on private wells for drinkinq
water and that are now at risk due to site contamination,
as well as those that are perceived to be potentially at
risk, will be connected to the public water supply lines of
the Easton Suburban Water Authority. These waterlines are
already in place and only need be connected to the
desiqnated houses. This alternative will protect the
public health by eliminatinq potential exposure to
contaminated qroundwater.
All indications are that community residents,
officials, and the PADER support this alternative.
local
II.
Backaround of ~-Communi tv Invol vementand Concerns
Community interest in the quality of area qroundwater
became apparent in 1978 when the operator of the Chrin
Brothers Landfill applied to the PADER for permission to
expand. the facility. This landfill is located within the
study area now known as the Industrial Lane Site. Local
citizens suspect. the landfill has contributed to local
qroundwater cont~ination. When the community learned that
the landfill owners planned to expand the landfill, many
residents beqan to question the potential impact of the
facility on local qroundwater quality. They also beqan to
wonder if hazardous wastes may have been deposited in the
landfill, either leqally or illeqally.
Local officials representinq Williams Twp., Glendon, Easton
and other nearby communities have shown continuinq interest
and concern in onqoinq site activity and qenerally have
been supportive of the investiqations into site-related
contamination.
A citizens' qroup called SOLVE (Save Our Lehiqh Valley
Environment) formed in 1981 to fiqht the landfill expansion
and to investiqate local qroundwater quality and the
possibility that hazardous wastes may have been disposed in
the area. To these ends, SOLVE has published newsletters
discussinq its concerns and has retained an attorney and
contracted with a hydroqeoloqist from the University of
Pennsylvania to perform a qroundwater analysis of the study
area. The qroup also requested shippinq manifest
information from neiqhborinq states and shared the
information it received with both the EPA and the PADER.
-In addition, site-related documents have been provided to
the qroup, under the Freedom of Information Act, by both
aqencies.
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Major concerns expressed durinq the remedial planninq
activities at the Industrial Lane Site included concerns
about the identity of contaminants at the site, the
source(s) of those contaminants, the potential health
effects of the contaminants, the adequacy of qroundwater
monitorinq, the proposed landfill expansion, and whether
the EPA would pay for alternative water supplies prior to
implementinq a remedial action alternative.
T~st results identifyinq contamipants and information
describinq potential health effects were provided to the
public by the EPA; however, the source(s) of contamination
is still unknown. Onqoinq studies are intended to discover
the answer to that question. ' In Auqust 1986, DER approved
the' Chrin Brothers. application to expand their landfill
under the provision that such expansion does not interfere
with the onqoinq Superfund cleanup.
III. ~~:::~ ~;r~li~n~o~~~ts ~;~~;ve~e:~~~~:sth~o ~~;~
Comments.
Comments presented to theEPA durinq the Industrial Lane
Site public comment period from Auqust 29, 1986 to
September 19, 1986 are summarized below. .
Because the EPA's preferred alternative appears to be
unanimously supported by state and local officials and
local residents and because no neqative comments were
received reqardinq the preferred alternative, no discussion
of other remedial alternative preferences appears.
l'
The comment
presented in
received.
summaries are cateqorized by topic and
descendinq order of the number of comments
Selected Remedial Alternat~ve (Waterline Hook-un)
Several questions were received concerninq
hookup to the public water supply line.
the
proposed
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1.
The issue of greatest concern in this category was
which residences were actually going to be connected
to the public water supply. Several people were
concerned that their homes or the homes of their
neighbors had been excluded from the list presented in
the draft EPA report.. Some were concerned that homes
with wells that were not currently contaminated, but
that might be contaminated in the future, would be
overlooked. One resident expressed concern that a
neighbor whose well was contaminated but who was "over
300 feet" from the water main would not be connected.
Two residents asked if everyone in the Boro of Glendon
would be connected. Residents and local officials
suggested that the EPA meet with community members in
. the near future to determine which homes should be
connected to the waterline.
EPA Resconse: The EPA's intention is to hook-up everyone
in Glendon and in Lucy's crossing, within the study area,
who is not already connected and whose well is either
contaminated now or has a potential for contamination in
the future. For the EPA's purposes, the study area extends
approximately from Hiqh Street and Berger Road to Lucy's
Crossing.
It is important to remember that the 1U and the FS reports
are still in draft form and that the EPA is sOliciting
publ ic comment, in part, to be certain that all of the
affected residences are contacted.
If anyone has information about any residence that should
be on the EPA's list but is not, the EPA would like to have
that information. EPA offered to seta date to meet with
local officials and local residents to be sure that no one
who is affected is overlooked.
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Two residents and some local officials expressed
concern about the costs that will be connected with
waterline hookups. While the residents seemed
concerned about the initial cost of waterline
connection, one official stated that he believed the
additional. expense of. a monthly water bill might
create a hardship situation for some area residents.
EPA ReSDonse: The remedial action alternative, as
presented in the report, will include the fOllowing: a
curb box; a valve; 50 lineal feet or more, as necessary, of
1-1/2-inch diameter copper pipe; all trenching and
backfill; and the water meter. "Door-to-door service" will
be provided by the water company and paid for by the EPA.
The. only thing that residents will have to pay is the
monthly water bill~!
3.
2.
The anticipated date that water line connections
commence was of concern to some residents and
officials.
will
local
EPA ReSDonse: The EPA is restricted right now by a lack of .
funding. The Agency has not had the authority to collect
money throuqh the. Superfund for almost a year.
As soon as the Superfund bill is reauthorized work at the
Industrial Lane Site can beqin. It is EPA's under-
standinq that passaqe of the Superfund bill is imminent.
Waterline Extension
Several questions were received concerninq extension of
waterline in addition to the proposed waterline hookups.
1.
the
Three residents suqqested that it would be cost
effective for the EPA to extend the waterline
throuqhout the Boro of Glendon. They pointed out that
areas surroundinq the Industrial Lane Site (most
notably, Ashland Chemical Company Property) are
potential problem areas that may not come to public
attention for a number ot years, at which time costs
will be hiqher due to inflation. It seemed to .these
citizens that the most economical course ot action
would be to expand the study area and extend the
waterline while the EPA was already workinq in the
area. One of those residents stated that he would
qladly pay for his own connection, if the EPA extended
the line.
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EPA Resoonse: The EPA intends to connect homes that are
may be impacted by the contamination that is present in
study area now.
Groundwater problems in surroundinq areas may not be
related to the Industrial Lane Site. However, if
information is discovered that leads the Agency to believe
there is a connection between this site and another or that
other residences could be impacted by this site, then, the
Agency will reassess the situation. .
or
our
Whatever remedial' action alternative the EPA
groundwater monitorinq will be present for many
come. If there are additional contaminants cominq
area they will be detected.
chooses,
years to
into the
,~.
2.
One citizen sugqested that consideration should be
qiven to extendinq the waterline into areas of
expected tuture qrowth, it those areas are potentially
at risk from site-related contaminants in the qround-
water.
EPA can address only those homes which are now
It cannot extend: the water line in anticipation
development.
Shio9ina Manitests
eXistinq.
ot tuture.
SOLVE expressed considerable concern about wordinq in the
remedial investiqation (RI) report that reters to the
shippinq manitests that the qroup collected trom other
states and presented to the DER and the EPA as "alleqed".
The report stated that the manitests were unsigned, and,'
while SOLVE is upset by these statements, the qroup says
that their main concern is that this intormation is beinq
used by persons in favor ot the landtill expansion plan to
support that interest. SOLVE members were concerned that
the EPA appeared to be iqnorinq the qroup's intormation.
EPA Res1)onse: At this point, the verity of the manitests
is alleqed. That does not mean that the EPA's
investiqation is closed. Any and all documents that the
Aqency' tinds or is qiven will be addressed in the
enforcement portion ot this investiqation. The EPA's
search for potentially responsible parties (PRPs) is still
open.
2.
SOLVE requested the name ot the specitic person who
will be involved 'in reviewinq the final RI document so
that the qroup can contact that person and be sure
that the final RI document contains accurate
. information about the shi~pinq manifests.
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EPA Resconse: Paula Luborsky, Enforcement Project Officer
stated that she was the enforcement project officer for the
Industrial Lane Site. She said it must be understood that
the feasibility study (FS) is not the same thing as a
search for potentially responsible parties (PRPs). A PRP
search is done to determine 'who is responsible for site
contamination, and it is not interchangeable with an FS.
TYPES AND CONCENTRATIONS OF CONTAMINANTS
1.
A resident commented that a neighbor was told by
person who delivered the well sample report that
, family's well was highly contaminated.
the
the
~.
EPA Resconse: The contaminant concentrations that were
found in the wells in the area for all tour contaminants of
concern was under 5 ppb, so certainly the well is not
highly contaminated. The person who made that statement
was wrong.
2.
Two residents expressed concern about vinyl chloride:
the tirst questioned whether that substance had been
found in any wells other than well number eN-8) during
the RI. The second resident stated that vinyl
chloride had been tound by the PACER in well number
eN-9) in January 1985 and in well nUmber 3 in July
1984.
EPA Resconse: Question 1 - During the RI, vinyl chloride
was detected only in well number eN-8). The source has not
been determined. However, because ot the risk posed by
that particular well to the public and environmental
health, the EPA teels that it is necessary to go back out
into the field and trace that source. The Agency will
perform a groundwater evaluation and remediation study.-
This wirl involve installing more wells and pertorming pump
tests. A date tor this study depends on Supertund
reauthorization.
Question 2 - EPA has been provided with past DER sample
results.. A summary of those results, although not each
individual tinding, is included in the RI/FS. Regarding
vinyl chloride specitically, EPA will examine its tiles to
be sure this data was received. .
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CONTAMINANT SOURCE AND PLUME IDENTIFICATION
A member of SOLVE expressed frustration that the EPA
has not given the group or the community any
satisfaction aDout the source of contamination despite
the information provided to the EPA by the group. A
second individual inquired if the EPA intended to
install any additional monitoring wells down gradient
of well number eN-a) to determine if a contaminant
plume exists.
EPA Res~onse: The EPA has not yet pinpointed a contaminant
source due primarily, to the complex qeoloqy of the area.
In the next phase of our remedial proqram, Operable Unit 2
will focus on source identification and on groundwater
. remediation. Monitorinq wells will be placed down gradient
from monitoring well number eN-a) as a part of that effort.
1.
2.
Another citizen inquired about who would be billed
site remediation.
tor
EPA Res~onse:
Unknown
THE SCHWAR WELL DATA
I
I.
I
Members of the qroup SOLVE raised questions concerninq
the treatment in the RI of data from the Schwar well.
They were concerned that the well was not listed as a
residential well and that it was not reinvestiqated
durinq the RI. It seemed to some that the Schwar. well
test results should have been used as a basis for
conclusions in the endangerment assessment. These
people did not understand why the. EPA did not consider
sample analysis from an earli.r study conducted by
E&E, an EPA contractor, to be verifiable.
EPA Res~onse: The EPA contractor had historic data that
was collected prior to the RI. No additional data was
collected during the RI because the Schwar well was closed
when the RI beqan. Because no blanks were drawn during the
earlier study by another EPA contractor, it was impossible
to conduct quality assurance. and quality control of the
Schwar. . well sample data. Therefore, the current EPA
contractor determined that the. information could be listed
as historic data but not as verifiable data. So, the data
was not tabulated and incorporated into the endangerment
assessment.
1.
An EPAtoxicologist stated that the inclusion of the Schwar
well data would not change the outcome or the level of risk
associated with those communities.
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CONTAMINANT MIGRATION AND RISKS
Some residents were concerned about the
the migration of contaminants in the
potentially impact wells on Morgan Ridge.
1.
possibility
groundwater
that
could
There is concern that contamination from the landfill
might migrate to one particular well (the Deegan well)
on Morgan Ridge. This concern arises from the fact
that the well is 460 feet deep which places the bottom
of the well at the same elevation as the Chrin
Brothers Landfill.
EPARes~onse: Groundwater and groundwater contamination
will flow from a higher gradient to a lower gradient. It
will not flow up~ill. Accordinq to data collected from
monitorinq wells and to the elevations of the water in
those wells and the elevations of the topography, both the
topoqraphy and the groundwater are higher in the Horgan
Ridqe area than in the landfill area. This means that
there will only be flow from the crest of Horgan Hill down
to. the lower area: there will not be a backflow going
upward toward the wells on Morgan Ridge. Therefore, the
EPA feels that there is no threat of contamination from the
landfill to any wells on Morqan Ridqe.
There was additional concern that development
presently occurring in the Horqan Ridge area or that
may occur there in the future would place an increased
demand on the qroundwater supply and that the addition
of residential pumping wells could cause groundwater'
and contamination to be drawn uphill from the Chrin
Brothers Landfill. This concern was intensified by a
report. produced by a hydroqeologist hired by' SOLVE.
The report stated that there was a definite
possibility that such a scenario cQuld occur.
EPA Res~onse: It is the professional opinion of the EPA's
enforcement project manager, who is a trained
. hydroqeologist, that there is no possibility for this to
happen. Because of the qeoloqy in the area and the
distance and gradient variations from one point to another,
the E~~ does not believe that residential pumpinq wells,
now or in the future, can draw contaminants from 1800 to
2000 feet away. '.
2.
The EPA's project manaqer stated that she would appreciate
it if SOLVE would send her a copy of the hydroqeoloqist's
report. She also expressed an interest in talkinq with ~e
consultant to discover if he had additional site-related
information that had caused him to believe such a
possibility existed.
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3.
One citizen was concerned that receiving a letter
about the site from the EPA meant that his well was at
risk.
EPA Resconse: Everyone on the EPA's mailing list received
one of these letters whether or not they were potentially
affected by the site, including the newspapers.
ASHLAND CHEMICAL COMPANY
1.
One ~esident stated that the Ashland Chemical Company,
located near the southwestern edge of the Industrial
Lane Site, had closed its onsitedrinking water wells
and was using bottled water. The resident also stated
. that Interstate 78, which was originally intended to
cut across th&~.Ashland Chemical Company's property had
to be redesiqned because a chemical dump containing
buried drums has been found in the area originally
proposed for the highway. This citizen telt that, it
Ashland Chemical Company's water was unsuitable for
drinking~ area residents were probably consuming water
that was unhealthy. He tel t that, it EPA was in the .
area addressing the question ot a public water supply,
the Agency should-consider providing water to all of
Glendon Boro. A second citizen agreed that it seemed
an economically sound idea tor the EPA to take care of
problems at the. Ashland site while the Agency was
already working in the area.
EPA Resconse: What is happening at the Ashland Chemical
Company is not necessarily related to the Industrial Lane
Site study area. Ashland is in a ditterent watershed, so
contamination there probably is not related to
contamination appearing in the Industrial Lane site study
area. -
PADER Resconse: The Ashland Chemical Company case is part
of a continuing, joint PACER/EPA investigation. It has
long been of concern for the Norristown PACER regional
office and for the Bethlehem PACER district oftice. The
agencies have been monitoring and inspecting the facility
on a reqular basis.
If Ashland has chosen to use bottled
company decision not an agency decision.
IV.
water,
that
is
a
REMAINING CONCERNS
Concerns that remain include contaminant sources and the
specific residences that will be connected to the public
water supply. As stated previously, these issues will be
addr~ssed in the continuing RI, as soon as tunds become
available.
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The verity of the shipping manifests continues to be an
important issue for members of SOLVE who want to block the
expansion of the Chrin Brothers Landfill until the current
groundwater problems are clearly defined and remediated.
The group is very concerned that the draft document has
invalidated the manifests as support for SOLVE's efforts to
halt landfill expansion.
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ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES CONDUCTED
AT THE INDUSTRIAL LANE SITE
Community relations activities conducted at the
Lane Site to date include the followinq:
. 0
o
o
Industrial
o
An EPA press release announced the addition of
the Industrial Lane Site to the Superfund list.
(September 1984)
Followinq the preparation ot a Remedial
Investiqation Work Plan, the EPA conducted a
public meetinq in the community to inform
residents of upcominq events and the Superfund
process. A fact sheet that described RI/FS
objectives was prepared for this meetinq.
(October 1984)
o
Intormation repositories were established at the
Glendon: Boro Buildinq and the Williams Township
BUildinq in Easton, Pennsylvania. (October,
1924)
o
EPA. conducted community interviews with local
citizens and local otticials. (February 1985)
o
EPA prepared a Community Relations Plan
site. (March 1985)
A dratt RI report and a draft Endanqerment
Assessment were released to the public. (June
1986)
for the
o
o
A dratt
public.
the
tocusedFS report was
(Auqust 1986)
released
to
o
A press release announced the availability
documents, the openinq ot the public
period, and the time ot the public meetinq
community. (Auqust 1986)
ot the
comment
in the
'. EPA met with SOLVE in EPA Reqion III
Philadelphia. (September 1986)
A public meetinq was held in the community and
local officials were brieted on the preferred
alternative. A fact sheet describinq remedial
alternatives was prepared for the public
meetinq. (September 1986)
oftices
in
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o
The public comment period opened on
1986 and closed September 19, 1986.
August
o
A Responsiveness Summary was prepared
inclusion in the ROD. (September 1986).
.-.
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29,
for
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