United States
Ery-ronmemai Protection
Agancy
Office *f
Emergency and
Remedial Response
EPA/ROO/R03-87/038
September 1987
Superfund
Record of Decision:
Palmerton Zinc, PA
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TECHNICAL REPORT DATA
(PftfU~ rtad IfIIlftlCIIO'U 011 tht ,tVt"t ~f"'t CO",,,ltlillll
1. ~e"O"T NO. 12. 3. ~ECI"I(III"5 ACCE5SI0~ NO.
EPA/ROD/R03-87/036
4. TlTI.! Alii 0 SU.TITI.' 5. "'II'O"T OAT I
SUPERFUND RECORD OF DECISION C::~ntember 4 1987
Palmerton Zinc, PA s. P£"',"Ol'lMINO O"'OANIZA"OIII CODE
Interim Remedial ~easure
7. AUT~OR(S) 8. PERFOI'IMIIliG Ol'lOAIIIIZA"ON AEPO"',...o
9. PERFORMING ORGANIZA'ION NAME AND ADDAESS 10. PI'IOGAAM E\.EMENT NO.
1 I. C:ONT"'~T/G"'AIII' NO.
12. SPONSORING AGENCY NAME AND ADOAESS 13. TYPE OF "'EttORT 4NO PERIOD COVE"'EO
U.S. Environmental Protection Agency Final ROD Reoort
401 M Street, S.W. 14. SPONSORING AGENCY COOE
Washington, D.C. 20460 800/00
\5. SUP"LEMI!NTA~Y NOTES
18. A8STRACT
The Palmerton Zinc site is locat.eq in Carbqn County, Pennsylvania. The New Jersey
Zinc Company currently operates two zinc smeltors in Palmerton at the base of Blue
Mountain. These two smeltors are referred to as the east and west plants. Since 1898,
the New Jersey Zinc facility has produced zinc and other metals for machinery,
pharmaceuticals, pigments and many other products. Prir1ary smelting of concentrated
zinc sulf ide ores which was terminated in December 1980, is the main source of
pollution. Prior to December 1980, the smeltors emi tted huge quantities of zinc, lead,
cadmium and suI fer diox.ide '.vhich led to the defoliation of approximately 2,000 acreS on
glue Mountain, adjacent to the east smeltor. Vegetation damage first appeared on a 1951
aerial photograph as isolated patches on the steep, north-facing slope of Blue Mountain
located immediately south of the east plant. By 1985, vegetation damage progressed OVer
a continuous widespread area leaving barren, eroded land visible. The primary
contaminants of concern leading to the defoliation of Blue t10untain include: zinc '
lead, cadmium and sulfur dioxide.
The selected interim remedial :neasure focuses on the establishment of a natural
eastern forest ecosystem and includes: onsite installation of a concrete pad with berm~
to mix offsite sewage sludge and fly ash: construction of access roads: application of
lime (10 tons per acre) and potash (80 pounds actual potassium per acre) on areas
(See Attached Sheet)
17. I(EY WORDS AIliO DOCUMENT ANALYSIS
Ia. DISC"'I'TO"S b.IDENTlFIEFliS/OPEN ENDED TEFIIMS C. CDSA TI Field/Gloup
Record of Decision
Palmerton Zinc, PA
Interim Remecial /1easure
Contaminated Media: woods, so it, S'N
Key contaminants: zinc, lead, cadmium,
sulfur dioxide, inorganics, h-=avy metals
18. DISTRIBUTION STATEMENT 19. secuAI TY CI.ASS {Tll1~ Rtpon, 21. NO. OF !>AGeS
tlone 34
20. secuAI Tv CI.ASS ; T'II~ pall!! 22. !>FIIICE
~),.,n~
1_'. ,.,.. 2220~1 (.n. 4-77)
""aVIOUI aOITION', o.,o\.aTa
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E?A/ROD/R03-87/036
Palmerton Zinc, PA
Interim Remedial Action
16.
ABSTRACT (continued)
targeted for revegetation; application of fly ash and offsite sludge on
target areas; application of grass seed or seedlings onto target areas; and
application of mulch to protect the seed. The municipalities that ~ay apply
the sewage sludge and other amendments should do so at no cost to EPA,
provided the cost of implementing the alternative is less than it costs the
municipalities to dispose of the sludge. A minimal capital cost may be
developed pending the outcome of municipality implementation issues. O&M
will not be required.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Palmerton Zinc Superfund Site - Blue Mountain Operable Unit
Town of Palmerton, Carbon County, Pennsylvania
STATEMENT OF PURPOSE
This decision document represents the selected r~edial action
for this site developed in accordance with CERCLA, as amended
by SARA, and to the extent practicable, the National Contingency
Plan.
STATEMENT OF BASIS.
This decision is based upon the administrative record (index
attached). The attached index identifies the items which
comprise the administrative record upon which the selection
of a remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
rhis is an interim remedy which focuses on the first of three
separate operable units at the New Jersey Zinc smelter. The
other two operable units are being investigated by the responsible
parties and will be addressed at a later date.
The selected site remedy does not attempt to ensure compliance
with all ARARS, but will be consistent, to the extent practicable,
with those action specific ARARS addressing sludge application,
the Clean Water Act and Best Management Practice requirements.
The selected remedy consists of using a mixture of sewage sludge
and fly ash to revegetate the defoliated areas of Blue Mountain.
The general procedures -for the,revegetation program would be as
follows :
- Step 1: Heavy equipment (i.e., bulldozers) would be used
to install access-roads in the areas targeted for
revegetation.
A concrete pad with reasonable berms would be
installed to mix the sludge and fly ash on-site.
- Step 2:
Lime potash application -- Lime and potash would.
be sprayed on the areas targeted for revegetation.
Lime would be applied at approximately 10 tons per
acre and potash at 80 pounds actual K per acre.
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- Step 3:
Sludge-fly asrl ~plication -- The sludge-fly ash mixture
would be ap~lied by spraying the mixture or.to the target
area. The sludge-fly ash ratio will be bas~ on further
analysis of the field test plots. The sludge will be
obtained fran the Ta.m of Palnerton, Allentown, and, if
necessary, Philadelphia.
- Step 4:
Plant target area -- Grasses would be planted by blowing
a mixture of grass seed onto the target area. Studies
are continuing on the feasibility of also blowing tree
seed onto the-area.- If tree seed will not germinate,
seedlings will be planted.
- Step 5:
Apply Im.l1ch - To protect the seed and permit germination,
actcquate mulch will have to be applied. Hulching may be
reduced or eliminated if spring oats are planted in the
fall. This will provide winter cover that will die by
spring. The target areas can then be seeded with the
permanent tJlant s~cies in the spring, and the spring
oat stubble will serve as a protective "rrulch" cover
for the permanent species needed.
DECIARATI~
'The selected ranedy is an interim remedy and is protective of human
health and the environrrent, attains Federal and State requirenents that
are applicable or relevant and apprcpriate, and is cQSt~ffective. This
remedy satisfies the preference for treatment that reduces mobility or
volume as a principal element. Finally, it is determined that this remedy
. utilizes permanent solutions and alternative treatment technologies to the
maximum extent ~racticable. .
Date
o/1~7
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Sit~ Description and
Sunu.'dry ot Rer;lf;dial Alternative Selection
for the Palr.erton Zinc Su~rfund Site
-Blue Nountain C{>erable Unit-
. Introduction
The Superfund investigation of the New Jersey Zinc Company smelter
(aka Palrrerton Zinc srrelter) focuses on three problem areas: first, the
deposition of heavy metals, mainly cadmium, lead, and zinc, throoghout
the valley as a result of air emissions from the smelter; second, the
tremendous slag pile, approximately 2.5 miles long which consists of
an estimated 33 million tons of slag; and third, the defoliation of
Blue Mountain next to the smelter.
The investigation of the defoliation of Blue Mountain next to the
smelter is the subJect that will be discussed herein. This Record of
Decision (ROD) will surnr.arize the results of a Superfund Raredial
Investigaton/Feasibility Study (RI/FS) that focused on the defoliated
sections of Blue tlountain and will present an interim remedy for
remedial action. The other two problem areas are being investigated
by the responsible parti~~.
On Septanber 2.., 19G5, the U.S. Envirerated the facility up until 19U1, when it was
purchased by its current owner Horsehead Industries, Inc..
Geographically the topography surroondi~ the site is rrountainoos.
It lies in a deep valley within the Appalachian Mountains between Blue
~kuntain (elevation 1,5UU feet) and Stony Ridge (elevation 900 feet).
The Appalachian Trail runs along the top of Blue ~~tain.
The smelti~ q>erations' are located. at two separate locations, a
west srne1ter and an east srrelter. Both srelters are located at the
base of Blue Nountain (see Figure 2).
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SOURCE: RANO McNAUEY ROAD ATLAS
SITE LOCATION
PALMERTON ZINC SITE, PALMERTON, PA
SC 1" - 95040*
I- igure
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AGGREGATES
FIELD BRIDGE
STATION
BRIDGE . AQUASHICOIA CHEEK
POHOPOCO
CREEK
HARRIS
BRIDGE
WESTv
PUNT\
TATRA INN
BRIDGE
PENNSYLVANIA TURNPIKE
PALMERTON ZINC EAST & WEST PLANTS
AQUASHICOLA CREEK & LEHIGHRIVER
PALMERTON, PA
LEHIGH VALLEY TUNNEL
USCS GAGE STATION
(WALNUTPOOTI
SOURCE: NEIC REPORT 1979
SITE SKETCH
PALMERTON ZINC SITE, PALMERTON, PA
SCALE r - 2520',
l-'igurc 2
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4
Th~ major watercourse in the project area is the Lehigh River.
The drainage pattern of the study area is toward Aquashicola Creek, a
tributary of the Lehigh River. Aquashicola Creek fla«s thrwgh a
buried valley, between Blue Hwntain on the south and Stony Ridge on
the north. The creek flows southwesterly and is joint:..'(j by Buckwha
"Creek about one-half mile upstream of Harris Bridge and by Mill Creek"
near the east plant's main gate. Aquashicola Creek flows into the
Lehigh River approximately 1.5 ru.les swthwest of the zinc plant.
The ream of Aquashicola Creek in Palnerton is classified as a
trout-stocking stream by the Pennsylvania Department of Environmental
Resources. According to the criteria of water uses in this classifica-
tion, the creek should maintain stocked trout from February 15 to.
July 31. It should also maintain and prq>agate fish species and
additional flora and fauna that are indigenous to a warm-water habitat.
A water intake is locatt:..'<.i on the Aquashicola Creek near the Field
Stone Bridge. This intake pllI'Cps water from the stream for industrial
use at the east plant. Aquashicola Creek water is also punped fran
an intake located between the t-lain Gate Bridge and the Sixth Street
Bridge during times of emergency need for industrial process water.
Ground water in the site vicinity occurs in both the unconsolidated
ooposits and the underlying bedrock. The glacial outwash deposits in
the stream valley contain significant quantities of available ground
water, as is typical of this type of deposit. .
At the foot of Blue Hountain, the Palrrer Water Coopany, which
supplies water to the towns of Palmerton and Aquashicola, has as its
water source fwr production wells, ranging in depth from aboot 200
feet to rrore than 400 feet, drawing grwnd water fran bedrock. The
yield of these wells reportedly ranges from 115 to 130 gallons per
minute.
Site History
The New Jersey Zinc Carpany currently operates two zinc smelters
in Palrrerton, referenced to as the east and west plants, respectively.
The west smelter began cperations in 1898, and in 1911, the east plant
opened for q;)eration. The New Jersey Zinc facility has produced zinc
and other metals for maminery, phannaceuticals", pigments, and many
other p~cts.
Primary smelting of concentrated zinc sulfide ores, which is the
main source of pollution, was stopped in I)!cember of 1980. However,
up until then the smelters had emitted huge quantities of zinc, lead,
cadmium and sulfur dioxide which has led to the defoliation of
approximately 2,000 acres on Blue Mountain which is located adjacent
to the east smelter. Aerial photography of the site taken fran 1938
to 19u5 has shown the variws stages of vegetation damage. Vegetation
damage is def ined as areas of exposed rock and soil where the original
vegetation, as seen on a 1S,3~ aerial photograph, has probably been
Uestroyed as a result of the smelter's "emissions.
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;)
Vegetation cJa.r.iagefirst appearcd on a 1:;~1 aeria.l photograph as
isolat~~ patches on the steep, north-facing slope of Blue Mountain,
locatod immediately south of tnu PaiQerton Zinc smelter's east plant.
Dunny the perioo of analysis, the vegetation damage progressed and .
additional areas of damage appeared. By 1~u5, vegetation damage appeared
.over a continuous widespread area with barren, eroded land visible from
aerial photographs.
Current Site Status
Surface soils samples were collected from the defoliated portions
of Blue ~1ountain. Five sample sites from different locations of the
rountain were selected. aoo analyzed for the metals of concern. Recorded
levels of cadmiu~ ranged from a high of 1,3UO ppm to a low of 364 ppm, lead
from from u,475ppm to 1,2u~ ppm, and zinc from. 35,000 ppm to 13,000 ppm.
The rnaxirm.un levels are up to 2,600 tines the typical regional background
levels for ca~ium, over 2,000 tUnes the regional background levels for lead,
and over 400 tiQes the regional background levels for zinc. Depth profiles
showed that rost of the metal contamination is contain~~ within the top .6 to
lu inches of soil. This is because the rretals are bound in organic materials
whim I,>revent significant downward r.overrent of rretals.
\Jater flowing across the defoliated portions of Blue Mountain has
erc::Oed the surface and becc::r.e contarainated with rretals contained in
the soil. The runoff and erosion has carried the retal ladened soil
into Aquashicola Creek.
The runoff has been sampled twice in recent years. In l-1ay of 1979,
EPA sampled the runoff as part of a comprehensive study of the smelter.
In Hardi of 1966, Horsehead Industries sampled the runoff under a
Superfund consent agreenent with EPA. The levels obtained '.¥ere corrpared
to EPA's ambient water-quality criteria. At alrrost every sampling
location, the criteria was exceeded; in some instances, the levels '.¥ere
20 times higher than the criteria. The results of the sartq;)ling effort
~rformed in 19&6 by Horsehead Industries is presented in Table 1.
A 19134 study by the U.S. Fish and Hildlife Service found very high
netal concentrations in fish taken from streams in the area. Although
the major source of the metal contaminating the creek canes frcm the
smelter property, the runoff from the mountain contributes to the
contamination and, in turn,. to high metal levels in the fish. Figure 3
is a summary of all fish-sampling results.
The envirormental ir.pacts of the metal contamination on the affected
area of Blue rtountain are obvioos to the naked eye. Besides the defoliated
vegetation and erosion, a noticeable absence of microflora, lichens,
arthropods and wildlife species has occurred. Researchers have studied
this area extensively and have concluded that due to the impact on such
a wide variety of organisI'i'lS in the ecosystem, a COItprehensive picture
of the effects of poorly controlled.metal emissions emerges.
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Table I
Blue Mountain Runoff-1986 Sampling Results
Cadmium Zinc lead
AWCX; AWQC AWQC
1 day == 3.9 1 day == 120 1 day == 83
Sample 4 day == 1.1 4 day == 110 4 day == 3.2
# T D T D T 0
Spring SW of bog 52 8 18 1,740 1,680 9 ND
Seep in middle of bog 53 20 20 2,400 2,960 25 NO
Seep on east of bog 55 1 1 8 700 590 . 7 ND
0'
Seep that flow to pool
near road 57 30 20 2,030 1,620 70 ND
Draining from large gulch
on Blue Mountain 58 1 1 11 820 680 16 NO
Small rill from
Blue Mountain 59 13 1 1 7,090 550 13 ND
Confluence of two rills
off Bloe Mountain 60 NO NO 410 360 NO NO
Concentration in parts per billion
T -- Total metals
0 -- Dissolved metals
AWQC -- Ambient water quality criteria -- based on hardness of 100 mg per liter CaCO
NO -- Not detected . 3
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'. f
• V \ , .'7 ^0J V
.0 . ' Cd 0.36 ^- f V* -
Pb-3.5 Pb-2
CuO.81 Cu-2.7
Zn-33.0 Zn-110.0
Cd-0.37 Cd-0.59
I /K;"-'i;;r .
SAMPLE LOCATIONS
WHOLE FISH ANALYSIS
Figure 3
30 Lehigh River 85 5 SCFO 30A Rock Bass NJ2
30 Lehigh River 85 5 SCFO 30B White Sucker NJZ
31 Lehigh River 85 5 SCFO 31 White Sucker-NJZ
32 Aquashicola Creek 85 5 SCFO 32-White Sucker NJZ
33 Buckwha Creek 85-5-SCFO33A American Eel NJZ
34 Princess Run 85 5 SCFO-34 White Sucker NJZ
35 Ross Common Creek 85 5-SCFO-35A Brook Trout NJZ
36 Bushkill Creek 85 5 SCFO-36 Brook Trout NJZ
37 Hokendauqua Creek 85 5 SCFO 37A Brown Trouc NJZ
38 Bertsch Creek 85 5 SCFO 38A Brown TroutMJ7
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8
Alternative Evaluation
The major objectives of remedial actions to be taken at the Palmerton
Zinc Superfund Site include (1) minimize dir~ct contact with contaminated
soil, (2) reduce volume of runoft, (3) reduce contamination in runoff, and
(4) mitigate environmental damage.
Based on the above objectives, nUQerous source control and mitigation
control technologies were screened to provide a limited number of .
technologies applicable for remedial actions at the site. . Same of these
tectlnologies were removed from further consideration based on site-specific
information and other canparative criteria. These other criteria include:
o
o
o
o
Technical perfornance/reliabili ty
Cons truct ibi li ty
Health and environmental impacts
Institutional considerations
In th~ rUfFS report each technology was evaluated not only in terms of
theoretical feasibility, but also in terms of whether the technology is
applicable to the site specific conditions. The candidate technologies that
were dismissed from retention are presented below with a summary of the
justification for elimination. (An expanded discussion is in the RI/FS report).
Technology
Feason (s) for El imination
- Site Fe:nci~
High cost and does not minimize risk
- In-situ chemical
precipitation
Poor performance and unreliable
Removing substances for
offsite disposal/treatment
High cost; negative environmental
and public health ~cts during
construction; unavailability of
adequate treatment/disposal
services
- Capping the site
High cost and not iIrplelrentable
- Collecting and treating
runof f
Poor performance
~ferred for subsequent RIfFS
- Diverting upland flow
The technologies that have been retained for further analysis can
be grouped into the following three alternatives:
o
No-action
o
Deed restrictions only
o
Soil amendments' and revegetation with deed restrictions
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-,
To analyze these alternatives,.an evaluation was conducted that
considered the new requirerents of the Superfund Amendments and Eeauthoriza-
tion Act of l~b~ (SARA)(P.L. ~9-49~) and the current version of the National
Contingency Plan (NCP) (50 Fed. Reg. 47912, November 20, 1985). Three tread
cateyori~s were used for the evaluation: effectiveness, irnplementability, ~nd
ccst. ~Jithin these categories there are seven factors that consider the short-
tean and 10ng-tean effects of each alternative (see Table 2). The evaluation
is presented in detail in EPA's April 1987 RI/FS report on the Blue Hountain
project. The foliowing is a SUI:"lItary of the evaluation:
Alternative 1. - No-Action
The NCP requires that the no-action alternative be considered. This
alternative will have no environmental or public health benefits. It will
not be protective in the short-tean or the long-term. The metals on the
rrountain will not degrade and will remain rrobile and toxic for decade~ and
probably centuries. The enviroranental and public health problems will
continue into the foreseeable future.
Taking no actlOn would not carply with the requirements of the
Clean vJater Act. regarding Best Manager.ent Practices (BMP). As discussed
in a 197~ EPA report by the National Enforcement Investigation Center
(Nl;IC), steps should be taken to minimize erosion and runoff fran the
rountain in order to canply with the BtIP requirements of the Clean Water
Act.
The factors in these categories do not require an implementability
and ccst analysis since there are no implettentation issues or costs
associated with taking no action.
Alternative 2. - Deed Restrictions Only
This alternative would consist of placing restrictions in the deeds
of the property for the defoliated portions of Blue Mountain. The
restrictions would prd'libit the use of the prc:perty for residential
developrrent, agricultural use and other activities that would result in
the direct use of the prcperty.
The effectiveness of this action would be limited to ensuring that
expc6ure to risk.s pcsed by the site does not increase. Currently, the
side of the roountain which has been defoliated is not used (although the
Appalachian Trail runs along' the top of Blue Mc:untain), and the deed
restrictions woold only ensure that this nonuse contilU.les. The environmental
and public health problems would contilU.le and would not be mitigated by deed
restrictions. The deed restrictions would not, of coorse, reduce the toxicity
or robility of the hazardoos sut:stances on the mountain. As discussed under
the no-action alternative, this action would not IOOet the BMP goals of the
Clean Hater Act.
This action would be an administrative action only: therefore, concerns
related to technical feasibility and availability are not relevant. The
primary administrative issue is the uncertainty of the Federal Government's
ability to require deed restrictions. An action such as this would have
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" i
. Table 2
EVALUATION FACTORS FOR ALTERNATIVE EVALUATION
EFFECTIVENESS IMPLEMENT ABILITY COST
Reduction 01
Toxicity, Technical Administrative
Mobility,
Protectiveness or Volume Feasibility Feasibility Availability Remedy Replacement
SHOAT. Reduction 01
TEAM existing risks
Compliance wilh .
ARARs
Compliance with
other criteria,
advisories, and
guidances
Protection of
community during
remedial actiqns
Time until prottiCtion
is achieved
LONG- Reduction 01 luture
TEAM ~isks
long-term reliability
Compliance with ARAAs
Prevention 01 future
exposure to residuals
Potential need lor
replacement
Permanent and
aigniticant reduction
0' toxicity, mobility or
~olume
Use 0' permanent
solutions and treat-
ment technologies or
resource recovery
technologies
. Ability to construct
technology
ility to obtain'
provals Irom other
gencies
ikelihood 0' favorable
mmunity response
rdination with
ther agencies
Short-term reliability
of technology
Ease 01 undertaking
additional remediat
action. i' necessary
Ability to monitor
effectiveness of
remedy
Ability to perform
operation and main-
tenance 'unctions
Availability of treat-
ment, storage, and
disposal services
and capacity
Development and
construction costs
Operating costs
'or implementing
remedial action
......
o
Availability 0'
necessary equip-
ment and specialists
Other capital and
short-term costs'
until remedial
action is complete
Costs 0' operation
and maintenance
'or as 1009 as
necessary
Potenlial 'or
remedial action
or replacemenl
costs i' remedy
were 10 lad
Costs 01 5-yaar
reviews
-------
, .
very little prec~ent uncer Su;::>ertund as a stunG-c1l0(10 action. Tr,~
effective ir:1pler;-cntation of the action would, therefore, r.lOst likely
depenu on the landC!vln~L-s voluntary placer.lent of restrh::tions in the
c:.c<.:(. .
J:'he CCGts of this action are minimal if done voluntarily by the
. Current lan<..ia..ners and would only involve the small le<;;al fe;es of
i,oJiryir~ the deed.
Alternative j. - Soil Amendr.ents and Revegetation with Deed Restrictions
This alternative would consist of using a mixture of sewage sludge
and. fly as!"1 to revegetate the defoliated portions of Blue Hountain.
A greenhouse study was conducted from ~cember 1%5 to June 19uu as
a ~rclir.tinary ~tep in determining if the application of a sewage sluJge-
t:L1' ash r.tixture to Glue ~iountain ...'ould be an effective technolCJ<;j)' for
revegetatiraJ the defoliated areas. The study was designed to evaluate
the proposed sludge-fly ash r.tixture ratios and to screen vegetation.
species. Ten tree species and twelve herbaceous species were planted and
~rown under controlled con~itions.
OVerall, results
species and eleven ot
continui~ to gr~.
study, ~PA determined
were appropriate.
of the %-day study were successful with all tree
the twelv~ herbaceous species germinating and
I2sect on the successful outcare of the greenhouse
that large-scale field test plots on Blue Mountain
Ten l-acr~ plots were installed by the City of Allentown fram ~~y
to June of 19u6. The plots were located in sets of three for the
applicatlon of various sludge-fly ash ratios (ie. lS:lFA, 2S:1FA, 3S:1FA).
Agricultural limestone and potash were applied on each plot at specified
application rates. The plots were then hydroseeded and ~lched and tree
seedlings were later planted.
Germination and emergence of herbaceous species occurred within 10
days following hydroseedingjrnulching. Root development and root reserves
were all no~l and well developed. The survival rate of planted tree
seedlings uepended on species with some influence on sludge-fly ash ratios.
Generally, all harclwocx.l species had a survival rate of over 73 percent
over all sludge-fly ash ratios, except red maple which had a rate of 23
pe rcent .
BaSed on the results of one growing season, it appears that this
remedial alternatlve is feasible to continue the revegetation of Blue
Mountain.
Although the exact design and procedures for the full-scale program will
be based on further analys is of the field plots and on the best judgement
of experts in the field ot revegetation as the revegetation program is
ir:lplecrented, it ap~ars that the general wtline that was followed during the
field plot trails will be implemented on a larger ~cale.
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12
It would take over 10 years to rcvegetat~ the n~untain using
Allentown and Palmerton sludge alone unless Philadelphia sludge or
other sources are made available. There is also tn6 possibly that
Allentown sludge will not be available in 3 to 5 years if a QUnicipal
waste incinerator is built in the Allentown area because the City of
Allentown would dispcse of its sludge in the incinerator. These
uncertainties and tUne delays indicate that a large and reliable source
of sludge should be considered to augment the sludge from the Palmerton
and Allentown areas. .
This alternative will be effective by being protective in both the
long-term and short-term and will reduce the robility of the hazardous
substances on the rountain, thereby, meetirtJ all four of the rer.edial
action objectives.
EPA's National Enforcement Investigat~on Cer~er (NEIC) conducted a
study of the Palmerton site in 1979 (NEIC,l979). This study evaluated
the runoff and surface water discharge fram the site and recommended a
series of measures to ensure cOqJliance with the Clean Water Act. Relevant
to the Blue Mountain area, tile NEIC recommended revegetation of the rountain
to Ireet the Clean \later Act requirements of BHP to reduce surface water
discharges.
Guidelines regardi~ the land application of sewage sludge have been
developed by the State of Pennsylvania. The Pennsylvania Departm:mt of
Environmental Resources (DER) has in effect regulatory guidance titled
"InterUn Guidelines for Sewage Use For Land Reclamation, 1977."
These guidelines have maximum loading rates for metals. These rates
are:
Element
~1aximun Ibs ./H::.re
Cadmium
Copper
Chromium
Lead
Mercury
Nickel 0
Zinc
3.0
100.0
100.0
100.0
0.3
20.0
200.0
These lOadirtJ rates will not be exceeded. If necessary, Palmerton
sludge will be mixed with the other sludges to ensure that the loading
rates for cadmium and zinc are not exceeded. .
The guidelines °a1so have a maxUnwn dry sludge application rate of
6lJ tons per acre. The anticipated rate for this project is 20 to 25
tons per acre and the 60 tons gar acre will not be exceeded.
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13
fh0 guidelines also r~quire soil pH be adjusted to 6.0 in the first
year, up to u.~ ~H by the second year and maintained at ~.5 for 2 years
after application. \lith joint applications of lirrestone and fly ash
d.cse levels should be attainable. A protective erosion and sedi~ntation
. contrcl plan will be developed and ifl\)lerrentt..'C.
It is technically i~ractical to QCet some of the guidelines because
of tile terrain on Blue ~lountain. Specifically, the rocky terrain prevents
incor~ration of the sluuge into the soil as preferred by the gui6elinesi
the slqJes of the mountain are in excess of the 20 percent rnaxiITU.U:\ reconr.ended
by the guidelines; and, there are bedrock outcrops on the mountain that
the guidelines recanr.end be avoided. To overcane tnese problems, the
project can be implemented to nunirnize any erosion caused by the steep
slopes and the inability to incorporate the sludge. OVerland move~nt
of sludge was nonexistent during the field test. Application of the sludge
on outcrCf/s should cause no negative iIrpacts and may irrprove water quality
by reducing the am::>unt of contaminated runoff entering th~ bedrock.
. Operation and maintenance will not be necessary because the goal is
to establish a natural eastern forest ecosystem. Consistent with Section
121 of the Superfund ArnendIrents and Reauthorization Act of 19d1i (SARA)
(P.L. ~~-499), the site would be revisted every five years to ensure continued
effectiveness of the selected alternative. .
The cast to implerrent the alternative would be minimaL The
municipalities that may apply the sewage sludge and other amendments
should do so at no cast to EPA, provided the cast of in'plerrenting the
alternative is less than it casts the municipalities to dispose of
the sludge.
Comparative Analysis
No environmental or public health benefits would result fran irrplerrenting
Alternatives 1 or 2. The reduction. of existing or future health risks by
preventin;r contirued exposure to retals would not be addressed. Unlike
Alternative 3, the rretals would remain mobile and will continue to contaminate
area surface waters by not minimizi~ runoff and erasion. This would not
cc:xtq)ly with the requirerrents of the Clean \later Act regarding Best Managerrent
Practices (~1P).
Addressi~ irrplerrentability, Alternative 1 does not require an implerrent-
ability analysis since there is no implementation issues associated with taking
no acti~. The effective implementation of Alternative 2 would depend on the
prq:>ertyowners voluntary placement of restrictions in the deed. . Based on the
results ot field test plots, Alternative 3 is in'plerrentable, provided their
are reliable sources of' sewage sludge to cOmplete the revegetation of the
defoliated areas.
There are no casts for Alternative 1 since this involves no action. The
castS for Alternative 2 are minimal which should involve only small legal
fees for the nodification of deeds. Likewise, casts for in'plementing
Alternative 3 woold also be minimal, if the cast of applying the sewage sludge
for municipalities is a cast effective means of disposal in lieu of their
current practices.
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14
Recommended Alternative
Section 121 of SARA and the .current version of the National Contingency
Plan (NCP)(50 Fed. Reg. 47912, November 20,1985) establish a variety of
requirements relating to the selection of remedial actions under CERCLA.
Applying the current evaluation criteria in Table 2 to the three remaining
remedial alternatives, ve recommend that Alternative 3 be implemented at
at the Palmerton Zinc Superfund Site.
This is an interim remedy for the site. When the RI/FS's for the
other operable units are completed by the responsible parties, ROD's
will be issued to address all aspects of the site. This interim remedy
will not, however, be inconsistent with a final comprehensive remedy for
the site. This Interim remedy does not attempt to ensure compliance with
all ARARS for the entire site, but as discussed above under Alternative 3,
will be consistant, to the extent practicable, with those action specific
ARARS addressing sludge application, the Clean Water Act and Best Management
Practice requirements.
This alternative consists of using a mixture of sewage sludge and
fly ash to revegetate the defoliated areas of Blue Mountain. Based on
greenhouse studies and results of field test plots it appears that this
technology is feasible.
Although changes may be made to application rates and/or sludge-fly
ash ratios, it appears that a general outline of the procedures for the
revegeratlon program would be as follows:
Step 1: Site preparation — Heavy equipment (i.e., bulldozers)
would be used to Install access roads in the areas targeted for
revegetation.
A concrete pad with reasonable berms would be installed to mix
the sludge and fly ash on-site.
Step 2: Lime potash application — Lime and potash would be sprayed
on the areas targeted for revegetation. Lime would be applied at
approximately 10 tons per acre and potash at 80 pounds actual K per acre.
Step 3: Sludge-fly ash application — The sludge-fly ash mixture
would be applied by spraying the mixture onto the target area. The
sludge-fly ash ratio will be based on further analysis of the field
test plots. The sludge will be obtained from the Town of Palmerton,
Allentown, and, if necessary, Philadelphia.
Step 4: Plant target area •— Grasses would be planted by blowing
a mixture of grass seed onto the target area. Studies are continuing
on the feasibility of also blowing tree seed onto the area. It is not
yet clear if tree seed will germinate on the site. If tree seed will
not germinate, seedlings will be planted.
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..J
Step 5: Ap\?ly mulch -- To ;;>rotect tne seoo and t;>errnit germination,
adequate mulch will have to be applied. r-lulching!MY be reduced or
eliminat~~ if s~ring oatg are planted in the fall. This will provide
wlnter cover that will die by spring. The targ~t areas can then be
seeded with thE:.: peI:'IPanent plant gpecies in the SlJring, and the spring
. oat stubble will serve as a protective "rrulch" layer for the pernanent
species seed.
Schedule
The anticipated schedule is to continue with same limited design
studies in the Fall of 1~o7. Beginning as soon as possible, but
probably not before the end of 19~7, large scale, multi-acre revegetation
will begin. It. will take a number of years to complete the remedial
action, the exact time depending on the anount of sludge available.
EPA's goal is to complete the project in five years.
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Responsiveness Summary
. This responsiveness su:nmary is divided into the following
sections:
Section I
Overview. A discussion of EPA's preferred remedial
alternative.
Sect i on II
Background of Community Involvement and Concerns.
A discussion of the community interest and concerns
raised during remedial planning activities at the
Palmerton Zinc Superfund Site.
Section III
Summar of Ma'or Comments Received During the Public
Comment Perlod and Agency Responses. A summary 0
comments and responses received by the general public
and potentially responsible parties.
I. Overview
The proposed remedial action is to revegetate the defoliated areas
of Blue Mountain using a mixture of sewage sludge and fly ash. An RI/FS
report discussing the environmental and public health problems associated
with the defoliated portions of Blue Mountain was prepared by EPA. The
report also examined potential methods to address these problems. Based
on the information in the report, the revegetation program is recomme'- i.
The RI/FS report and a description of the recommended alternative
was released for public review and comment on May 22, 1987, a public
meeting was held on June 18, 1987 and the comment period closed on
July 6, 1987. A total of five written comments were. received.
II. Background of Community Interest and Concerns
The community has generally been concerned about the environmental
devastation and the negative image the barren mountaian projects. The
action being considered at this time deals only with the mountain,
however, there are two other major contamination problems which have
been of public concern. Widespread soil contamination exists because
of the deposition of heavy metals from past air emissions from the
. smelter. There is also significant ground water and surface water
contamination on and near the smelter property.
The public has been concerned about the potential health effects
of the soil and groundwater contamination and also about the potential
financial impact on the zinc company of any remedial action. The
current owners of the smelter, Horsehead Industries, are completing
and RI/FS on the ground water and surface water problems on and near
the smelter property. An RI/FS on the widespread soil contamination
is being completed by the previous owners of the smelter, Gulf & Western
Inc. These RI/FS's are being done under a consent order with EPA and
the reports will be available for public review and comment in the.
coming months.
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~
.III. Summar~ of ~ajor Comments Received Juring the Public Com~ent
Period
Public Comments
Comment:
Re91y:
CO:TIment:
Re91y:
Comment:
Re91y:
Comment:
Reply:
Comment:
Reply:
The real reason for this project is not for the reveget~tion
of Blue ~ountain, but a means for the City of Philade19hia
to dis~ose of its sewage sludge.
This is not a sludge disposal program.
be used as a 50il conditioner in order
necessary nutrients to sustain initial
defoliated areas on Blue Mountain.
Sewage sludge will
to provide the
plant growth in the
Questions were raised on the dangers and public health
effects of the continued operation of the New Jersy Zinc
smelter.
The Superfund program does not regulate the daily operations
of such facilities. Air and water discharges into the
environment are regulated under the Clean Air Act and the
Clean Water Act, respectively. Specific complaints will be
directed to the Pennsylvania DER or EPA program offices
administering programs in these areas.
Questions concerning the area wide contamination of surface
50ils and the consumption of vegetables grown in private
gardens were raised.
These issues are currently being studied in a separate RI/FS
being prepared by Gulf & Western Industries, under an EPA
enforcement order. The RI/FS report will be ready by the end
of 1987 or early 1988~
What will happen to the sludge-fly ash mixture in the event
of a heavy rainfall.
Based on the performance of test field plots on Blue Mountain,
there is no evidence of overland movement of sludge or
erosion problems due to rainfall.
Public notification for the EPA meeting held at the
. Aquashicola Fire House was inadequate.
Public notification was done in accordance with the legal
requirements of th.e Superfund Amendents and Reauthorization
Act. The public comment period on the preferred alternative
and the RI/FS report was initiated on May 22, 1987, a public
meeting was held on June 18, 1987, and the comment period
remained open until July 6, 1987. Additionally, a number of
articles appeared in local newspapers discussing the report
and preferred alternative, and EPA placed an ad in the
Lehighton Times on June 15, 1987.
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Co~ment: QU2sti~n3 of reside~ts concerns regarding the qualitj oE
drinkinJ W3.ter il1 the area.
~e?Ly:
The quality :)f are~ drinKing water :neets the standards oE
the Safe Drinking Water Act. In addition, an ongoing
study is being performed by Horsehead Industries, Inc.,
under an EPA enforcement order. The RI/FS report will be
ready by the end of 1987 or early 1988.
from Potentially Responsible Parties
On behalf of the New Jersy Zinc Company, the" firm of
Squire, Sanders & Dempsey submitted the following comments
which addressed the proposed remedial action for Blue Mountain
in their letter of June 29, 1987. "
Co:nments
Comment:
~eply:
Thirty days is an insufficient tim~ for New Jersey Zinc
to retain technical experts to review the report.
The report addressing the Palmerton Zinc Superfund Site
(April 1987) was released on May 22, 1987. The comment
period was opened until July 5, 1987." In addition, EPA
has always ke?t an open channel of communication with New
Jersey Zinc.
Comment: Where has this technique been used previously on ste~p
slopes near populated areas besides remote mining areas.
Reply:
The selected remedial alternative is an innovative technology
which has proven to be a feasible remedy for Blue Mountain.
After one growing season, the field test plots have performed
satisfactorily and has shown no overland movement of sludge
which was applied to sloped areas.
Comment: The historical air emissions provided in chapter three of
the April 1987 report are estimates only and may be
substantially an error.
Reply:
Since there is no known historical stack emission data
for the New Jersey Zinc smelter, estimates were made as
stated on page 3-8 of the April 1987 report. These estimates
were provided to EPA by the New Jersey Zinc Company.
Comment: U!S. EPA water quality criteria do not apply to incidental
runoff from Blue Mountain.
Reply:
EPA water quality criteria are a good basis for assessing
the qu~lity of the runoff since it directly impacts area
surface waters.
Comment: Fish contamination -- no documentation in report to indicate
that these levels are high.
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~e?ly:
At the request of EP~, the Agency for Toxic Substances and
Disea3e Registry (ATSDR) evaluated the health signific~nce
of metal concentrations in fish taken from streams in the
area. ATS~R stated that levels of lead and cadmium in
the fish were found to pose a potentially significant
health threat if consumed. The U.S. Fish and Wildlife
Service has also found that these levels are among the
highest ever found in Pennsylvania.
Comment: Metal contamination of fish can be mitigated by a health
advisory to fishermen.
Reply:
Comment:
Reply:
A health advisory would not resolve the problem of metal
contamination in area fish. An advisory would only side
step the main concern which is the elimination of future
fish contamination due to metals.
The lack of vegetation on Blue Mountain is not a condition
requiring remediation under Superfund and furthermore, the
statutory prerequisites for remedial action have not been
met.
The lack of vegetation on Blue Mountain requires remediation
under Superfund because the present condition of Blue
Mountaln allows the release of hazardous substances into the
environment. The statutory prerequisites for remedial action
have been met because of this condition.
Comment: Expenditure of large amounts of public money to rectify what
is apparently a minor problem is inconsistent with Superfund
and the National Contingency Plan.
Reply:
Comment:
Reply:
Contamination of some 2,000 acres of land with heavy metals
which are being released into the environment can not be .
characterized as a minor problem and remediation of such a
condition is consistent with Superfund and the National
Contingency Plan.
New Jersey Zinc does not at this time agree to any
restrictions being placed on the use of its property for
any purpose and questions the legality of such restrictions
under Superfund, the U.S. Constitution or other applicable
l.aw.
While Superfund and State law may not provide a definitive
means by which use of the property can be restricted,
Superfund does provide for injunctive relief should the
property be used in a manner which permits an actual or
threatened release of a hazardous substance. .
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CO.:TI;nent:
Reply:
s
L~tter dated July 16, 1987 commenting upon Jovern~ent's
approach to the site incorporated by reference.
Comments in the letter were primarily directed at the
problems associated with the cinder bank. It would
therefore be ina?pro~riate to respond to those comments
at this time. .
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palmerton Zinc Site
Enforcement Status
. Historical zinc s~elting operations created widespread
heavy ~etal contamination both on and off the Palmerton Zinc
plant property. The contaminated areas have been divided into
three district areas by EPA and are referred to as the Blue
i'1ountain project, the Cinder 3ank and Off-Site Contamination.
An RI/FS for both the Cinder Bank and Off-Site Contamination are
currently being ~erformed under a Consent Order by the res~on-
sible parties (RPS) associated with this site. The RPs had
declined participation in the alue Mountain RI/FS which was
completed by EPA in April, 1987.
In a letter dated June 10, 1987, EPA gave the RPs notice of
their potential liability with regard to the implementation of
the Blue Mountain Project remedial action. Enclosed with this
letter was a copy of the completed RI/FS and a copy of EPA I S
proposed remedial alternative. The RPs were extended the
opportunity to present a good faith proposal to conduct the
Remedial oesign and Remedial Action to the Agency within sixty
(60) days of receipt of the June 10, 1987 notice letter. EPA
expects a proposal from at least one RP by the week of August 9, 19~7.
prepared by:
patricia Tan
Hazardous Waste Enforcement Branch
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PALMERTON ZINC PILE (BLUE MOUNTAIN)
SARA ADMINISTRATIVE RECORD *
INDEX OF DOCUMENTS
Site Identification
1) Report: Field Investigations of Uncontrolled Hazardous Sites Report on
Palmerton Zinc Company, Palmerton, Pennsylvania, dated 2/19/81.
2) Report: A Preliminary Assessment of New Jersey Zinc at Palmerton, PA,
dated 2/7/80.
3) Potential Hazardous Waste Site Identification form, dated 5/28/80.
4) Report: Evaluation of Runoff and Discharges from New Jersey Zinc
Company, dated 12/79.
Remedial Enforcement Planning
1) U.S. EPA Administrative Order By Consent, dated 9/85.
2) Letter to Mr. Martin Davis from Mr. Stephen Wassersug regarding public funds,
dated 8/1/84.
3) Letter to Mr. William E. Flaherty from Mr. S. Wassersug regarding public funds,
dated 8/1/79.
Remedial Response Planning »
1) Report: Palmerton Zinc Superfund Site Blue Mountain Project, dated 4/87.
2) Memorandum to regional administrators froa Mr. J. Winston Porter regarding
eleventh remedy delegation, dated 3/26/87.
3) Memorandum to Mr. J. Winston Porter from Mr. James Seif regarding delegation
of remedy selection, dated 2/10/87.
4) Report: Evaluation of Sludge - Flyash Mixtures as Potential Amendments to
Facilitate Revegetation of Blue Mountain; A Literature Review, by Mr. John
Oyler (undated).
5) Report: Evaluation of the First Year Effects of the Sludge-Plyash
Amendments of Surface Soil Chemical Properties and Vegetation Growth
Responses, by William E. Sopper, dated 12/86.
6) Report: Installation of Field Plots on Palmerton Blue Mountain to Evaluate
the Use of Sludge-Flyash mixtures as an Amendment to Facilitate Vegetation
Establishment, by William E. Sopper, dated 8/86.
7) Interagency Agreement between U.S. EPA and the U.S. Department of Agri-
culture Soil Conservation Service, dated 8/1/86.
* Administrative Record available 7/31/87.
1
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8) Commitment Notice for Region III oversight, dated 6/19/86.
9) Report: Evaluation of Sludge-Flyash Mixtures as Potential Amendments to
Facilitate Revegetation of Palmerton Blue Mountain, by William E. Sopper,
dated 7/86. '
10) Report: A Preliminary Survey of Contaminants in Fish in the Vicinity
of Two Zinc Smelters at Palmerton, Carbon County, Pennsylvania,
by David J. Putnam and Cynthia L. Rice, dated 8/86.
11) Letter to Mr. Ed Shoener from Mr. Joseph MeMahon regarding Allentown/
Palmerton sludge for Cinder Bank revegetation, dated 6/13/86.
12) Letter to Mr. Joseph MeMahon from Mr. Ed Shoener regarding temporary
storage of wastewater residuals, dated 5/8/86.
13) Letter to Mr. Ed Shoener from Mr. Joseph MeMahon regarding temporary
storage of wastewater residuals, dated 5/5/86.
14) Letter to Mr. Ed Shoener from Mr. James Olson regarding budget for
Phase III, dated 5/5/86. Budget is attached to letter.
15) Letter to Mr. Ed Shoener from Mr. Joseph MeMahon regarding experimental
land reclamation requirements for the Blue Mountain at New Jersey Zinc,
dated 5/2/86. Attachments to letter are listed in paragraph 2 of the letter.
16) Report: Palmerton Zinc Site National Priorities List Site Atmospheric
Deposition Analysis of Cadmium, Zinc, Lead, and Copper in the Vicinity
of the New Jersey Zinc Palmerton Facility, by Alan J. Cimorelli, dated
5/86.
17) Letter to Mr. Bob Heidecker from Mr. Ed Shoener regarding Pennsylvania
DER permit, dated 4/16/86.
18) Letter to PSC Environmental Services Incorporated, from Mr. Joseph
McMahon regarding New Jersey Zinc land reclamation, dated 3/21/86.
19) Letter to Allentown Wastewater Treatment Plant from Mr. Russell Smith
regarding Borough of Palmerton sludge disposal permit, dated 2/19/86.
ASW Environmental Consultants Inc. laboratory results are attached to letter.
20) Interagency Agreement between U.S. EPA and U.S. Department of
Agriculture Soil Conservation Service, dated 2/11/86.
21) Interagency Agreement between U.S. EPA and U.S. Department of Agriculture
Soil Conservation Service, dated 2/11/86.
22) Report: Application for an Experimental Permit to Evaluate the Use of
Sludge/Flyash Mixtures to Facilitate Revegetation of Blue Mountain at
Palmerton, PA, by William E. Sopper, dated 1/86.
23) Letter to Mr. Ed Shoener from Mr. Robert Heidecker regarding Phase I
Feasibility Study, dated 1/2/86. Proposed Greenhouse Study and proposed
budget are attached to letter.
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24) Letter to Mr. Gene Lucero from Mr. Bruce Blanchard regarding preliminary
natural resources survey, dated 12/20/85.
25) Report: Feasibility Study for the Revegetation of Blue Mountain at
the New Jersey Zinc Company Plant a~ Palmerton. Pennsylvania. by
William E. Sopper, dated 12/85.
26) Letter to Mr. Ed Shoener from Mr. John Oyler regarding progress reports
for six specific tasks, dated 10/4/85. AERO-SPREAD advertisement and
photographs are attached to letter.
27) Interagency Agreement between U. S. EPA and U. S. Department of Agricul-
ture Soil Conservation Service. dated 8/1/85.
28) Letter to Mr. Ed Shoener from Mr. John Oyler regarding literature review,
dated 8/27/85. Literature review is attached to letter.
29) Interagency Agreement between U. S. EPA and U. S. Department of Agriculture
Soil Conservation Service. dated 7/1/85.
30) Letter to Ms. Linda Paul from Hr. Edward Shoener regarding Palmerton Zinc
project. dated 1/29/85.
31) Work Plan for Remedial Investigation/Feasibility Study of alternatives.
dated 8/84.
Community Involvement
1) Letter to Mr. Ed Shoener from Mr. Larry Latzgo regarding meeting at
Aquashicola Fire Hall. dated 7/5/87.
2) Letter to Hr. Ed Shoener from Mr. James F. Allen regarding proposed
remedial action. dated 6/29/87.
3) Letter to Ms. N. L. Sinclair from Hr. Allen Green regarding meeting at
Aquashicola Fire Hall. dated 6/28/87.
4) Letter to Ms. Nanel Sinclair from Hr. P. Latzgo and Mr. Larry Latzgo
regarding meeting at Aquashieola Fire Hall. dated 6/28/87.
5) Letter to Ma. Nanel L. Sinclair from Hr. Steve Borbe regarding meeting
at Aquashieola Fire Hall. dated 6/22/87.
6) Public Notice regarding public meeting at Palmerton. dated 6/18/87.
7) Press release from Hr. Bruce Conrad. Carbon County Office of Planning'
and Development. regarding Remedial Investigation/Feasibility Study
of Palmerton Zinc Site. dated 5/22/87.
3
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8) Press release from U. S. EPA regarding Remedial Investigation/Feasibility
Study (RI/FS) of Palmerton Zinc Site, dated 5/21/87.
9) Press release from U. S. EPA regarding Consent Order with New Jersey Zinc
and Gulf and Western, dated 10/11/85.
10). Letter to Senator Arlen Specter from Mr. Stanley Laskowski regarding letter
sent to County Commissioners, dated 2/15/85.
11) Letter to Senator Arlen Specter from Mr. Thomas Eichler regarding the
expression of thanks for letters from the public. dated 1/23/85.
12) Letter to Congressional liason, U. S. EPA from Senator Arlen Specter re-
garding pu~lic inquiries and communications, dated 12/14/84.
13) Letter to Mr. T. Eichler from Mr. John Brown regarding Palmerton Remedial
Investigation/Feasiblity Study dated 11/13/84.
14) Letter to Mr. Thomas Eichler from Mr. Stanley Cope, M. D., regarding
new information on site, dated 11/7/84.
15) Letter to Mr. Thomas P. Eichler from Ms. Barbara Spadt regarding a
proposed study, dated 11/8/84.
16) Letter to Messrs. Koch, Wildoner and Delong from Mr. Thomas Eichler
regarding the Palmerton Remedial Investigation/Feasibility Study, dated
11 /8/84.
17) Letter to Mr. Keith McCall from Mr. Thomas Eichler regarding the Palmerton
Remedial Investigation/Feasibility Study, dated 12/4/84.
18) Letter to Mr. Gus Yatron from Mr. Thomas Eichler regarding letter from
Commissioner" Albert Koch, dated 11/29/84.
19) Letter to Mr. Thomas Eichler from Mr. Rodney Borger regarding support of
New Jersey Zinc Company, dated 11/27/84.
20) Letter to Mr. Howard Grossman from Mr. Thomas Eichler regarding response
to his letter of concern, dated 11/20/84.
21) Letter to Hr. Thomas Eichler from Mr. Jeffrey Zachon regarding support of
New Jersey Zinc Company, dated 11/20/84.
22) Letter to Hr. Thomas Eichler from Hr. Ronald Hihalho regarding support of
New Jersey Zinc Company, dated 11/16/84.
23) Letter to Mr. Thomas Eichler from Mr. Gerald Noll regarding support of
New Jersey Zinc Company, dated 11/9/84.
24) Letter .to Ms. Judith A. Dorsey from Mr. W. R. Bechdolt regarding draft
work plan, dated 11/13/84.
4
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25) Letter to Mr. Thomas Eichler from Mr. Keith McCall regarding support of
New Jersey Zinc CompanYt dated 11/8/84.
26) Letter to Mr. Thomas Eichler from Mr. Robert Miller regarding support of
New Jersey Zinc CompanYt'dated 11/7/84.
27) Letter to Mr. Thomas Eichler from Mr. J. N. Ord regarding work plant dated
11/6/84.
28) Letter to Mr. Thomas Eichler from Mr. James North regarding support. of
New Jersey Zinc CompanYt dated 11/5/84.
29) Letter to U. S. EPA from Mr. Albert Serpes regarding support of New Jersey
Zinc CompanYt dated 10/29/84. .
30) Letter to Mr. Stephen Wassersug from Mr. Steve Barbe regarding support of
unbiased studYt dated 10/24/84.
31) Letter to Mr. Thomas Eichler from Ms. Janet Snyder regarding support of
EPA actions at sitet dated 10/24/84.
32) Letter to Senator Arlen Specter from Mr. Frederick Schanstine regarding
use of public funds. dated 10/22/84.
33) Letter to Mr. Joe Donovan from Mr. M. Luther Fuller regarding concern for
site actions. dated 10/26/84.
34) Letter to Senator Arlen Specter from Mr. Albert Koch regarding the RI/FSt
dated 10/9/84.
35) Letter to Mr. John Heinz from Mr. Albert Koch regarding the RI/FS. dated
10/19/84.
36) Letter to Mr. Thomas Eichler from Mr. Frederich Schanstine regarding EPA
actions at the site. dated 10/19/84.
37) Letter to Mr. Thomas Eichler from Mr. Bill Bechdolt regarding the RI/FS.
dated 10/15/84.
38) Letter to Mr. Joe Donovan from Mr. M.Luther Fuller regarding EPA meeting.
dated 10/15/84.
39) Letter to Mr. Thomas Eichler from Mr. Lester Grady regarding use of public
funds. dated 10/15/84.
40) Letter to Mr. Thomas Eichler from Mr. Joe Ebeley regarding support of
New Jersey Zinc Company. dated 10/13/84.
5
.~
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41) Letter to Mr. Thomas Eichler from Mr. Clifford Jones regarding support of
New Jersey Zinc Company, dated 10/10/84.
42) Letter to Mr. Thomas Eichler from Mr. Koch, Mr. Wildoner, and Mr. Delong
. regarding EPA actions at the site, dated 10/9/84.
43) Letter to Mr. William Bechdolt from Mr. John Kasten regarding burden on
local economy, dated 10/9/84.
44) Letter to Mr. Thomas Eichler from Mr. James Rhoades regarding additional
testing at New Jersey Zinc plant, dated 10/9/84.
45) Letter to Mr. Steve Borbe from Ms. Mary Anne Daly regarding analysis of
wa ter sample at Borbe' shouse, dated 10/3/84. Laboratory analysis report
is attached to lettet.
46) Press release from U. S. EPA regarding public meeting on Palmerton work plan,
dated 10/2/84.
47) Fact sheet on Palmerton Zinc Site, dated 10/84.
48) Letter to Mr. Stephen Wassersug from Mr. Steve Borbe regarding 80il and
groundwater testing results, dated 9/12/84.
49) Letter to Mr. Stephen Wassersug from Mr. Steve Borbe regarding water, 80il,
and air testing of Palmerton area, dated 6/13/84.
50) Letter to Mr. Steve Borbe from Mr. Stephen R. Wassersug regarding work
plans from water, soil, and vegetation studies at Palmerton, dated 5/31/84.
51) Letter to Mr. Stephen Wassersug from Mr. Steve Borbe regarding a request
for testing at Palmerton, dated 5/14/84.
52) Letter to Mr. Stephen- Wassersug from Mr. Steve Borbe regarding alleged
pollution caused by New Jersey Zinc Company, dated 3/27/84.
6
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SITE SPECIFIC GUIDANCE DOCUMENTS
1) "Heavy Metals in Cottontail Rabbits on Mined Lands Treated With Sewage Sludge.
Sludge." by R. L. Dressler, et al, dated 7/86.
2) "Contamination of the 02 Soil Horizon b! Zinc Smelting and its Effect on
Woodlouse Survival ,It by W. N. Beyer, et al, dated 1984.
3) "Heavy Metals in White - Tailed Deer Living Near a Zinc Smelter in
Pennsylvania ,It by L. Sileo and W. N. Beyer, dated 5/30/84.
4) "Use and Disposal of Municipal Wastewater Sludge," by the U. S. EPA, dated
. 9 /84 .
5) "Lung Cancer in Relation to Environmental Pollutants Emitted from Industrial
Sources," by Linda Morris Brown, et al, dated 1984.
6) "Environmental Zinc and Cadmium Pollution Associated with Generalized
Osteochondrosis, Osteoporosis, and Nephrocalcinosis in Horses," by Diane E.
Gunson, et al, dated 1982. .
7) "The Impact of Zinc Smelter Emissions on Forest Litter Anthropods ," by Carl
L. Strojan, dated 1978.
8) "Forest Leaf Litter Decomposition in the Vicinity of a Zinc Smelter ,"
by Carl L. Strojan, dated 1978.
9) "A Nationwide Survey of Heavy Metal Absorption in Children Living Near
Primary Copper, Lead and Zinc Smelters," by Edward L. Baker, et al, dated
1977 .
10) "Effects of Zinc Smelter Emissions and Fire on a Chestnut - Oak Woodland,"
by Marilyn J. Jordan, dated 1975.
11) "Effects of Zinc - Smelter Emissions on Forest 5011 Microfluora ," by
Marilyn J. Jordan, et al, dated 7/28/75.
12) "Influence of Effluents from a Zinc Factory on Lichens," by Thomas H.
. Nash III, dated 1975.
13) "Contamination of Soil and Vegetation Near a Zinc Smelter by Zinc, Cadmium,
Copper, and Lead," by Marilyn J. Buchauer, dated 1973.
14) "Interim Guidelines for Sewage Sludge Use for Land Reclamation ," by
Pennsylvania Department of Environmental Resources (undated).
15). "Heavy Metal Exposure in Populations Living around Zinc and Copper
Smelters," by Tyler D. Hartwell, et al (undated).
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GENERAL GUIDANCE DOCUMENTS *
1) "Promulgation of Sites from Updates 1-4," Federal Register, dated 6/10/86.
2) "Proposal of update 4," Federal Register, dated 9/18/85.
3).Memorandum to U. S. EPA from Mr. Gene Lucero regarding community relations
at Superfund Enforcement sites, dated 8/28/85.
4) Groundwater Contamination and Protection, updated by Mr. Donald v.
Feliciano on 8/28/85.
5) Guidance on Remedial Investigations under CERCLA, dated 6/85.
6) Guidance on Feasibility Studies under CERCLA, dated 6/85.
7) "Proposal of Update 3," Federal Register, dated 4/10/85.
8) Memorandum to U. S. EPA from Mr. Jack McGraw entitled "Community Relations
Activities at Superfund Sites - Interim Guidance ,It dated 3/22/85..
9) "Proposal of Update 2," Federal Register, dated 10/15/84.
10) EPA Groundwater P~otection Strategy, dated 9/84.
11) Memorandum to U. S. EPA from Mr. William N. Heckman, Jr. entitled
"Transmittal at Superfund Removal Procedures - Revision 2," dated 8/20/84.
12) "Proposal of Update 1," Federal Register, dated 9/8/83.
13) Community Relations in Superfund: A Handbook (interim version), dated
9 /83.
.14) "Proposal of first National Priority. List ,It Federal Register, .dated
12/30/82.
15) "Interim Priorities List," Federal Register, dated 10/23/81.
16) "Expanded Eligiblli ty List," Federal Register, dated 7/23/82.
17) Uncontrolled Hazardous Waste Site Ranking System: A User's Manual
(undated) .
18) Field Standard Operating Procedures- Air Surveillance (undated).
19) Field Standard Operating Procedures- Site Safety Plan (undated).
*Located in U. S. EPA Region III office.
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PENNSYLVANIA
DEAl!
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL ReSOURCES
Post Office Box 2063
Harrisburg. Penl'1sylvania 1 7120
August 20, 1987
Deputy Secretary for
Environmental Protection
, Stephen R. Wassersug, Director
Hazardous Waste Management Division
U.S. Environmental Protection Agency
. 841 Chestnut Building.
Philadelphia, PA 19107
Dear Mr. Wassersug:
We have reviewed the draft "Site Description and Summary of Remedial Alternative
Selection" Report for the Blue Mountain Revegetation Project. The Department supports this
project and agrees that the trial demonstration plots installed in 1986 proves the viability of
spraying a sludge and fly ash mixture to provide a growth media for permanent revegetation of
the mountain.
, '
We find the report satisfactory in its present form and have no recommendations.
Thank you for the opportunity to review this report.
Sincerely,.
~~A~
Mark M. McCleUan
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