United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-87/037
September 1987
&EPA Superfund
Record of Decision
Presque Isle, PA
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TECHNICAL REPORT DATA
(Please 'tad InSl/UCl/OnS on (ht ,tvtne be/art complttingJ
.. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
PA/ROD/R03~87/037
.ITLE ANO SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION ~. ... 1n 1QR7
Presque ISle, PA 8. PERFORMING ORGANIZATION CODE
First Remedial Action - Final
7. AUTHORCSI 8. PERFORMING ORGANIZATION REPORT NO.
St. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM EI.EMENT NO.
". CONTRACT lu..AN T NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVEREO
U.S. Environmental Protection Agency Final ROD Reoort
401 M Street, S.W. 1.. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. A8STRACT
The Presque Isle site is located on the Presque Isle State Park Peninsula within the
city of Erie, Erie County, Pennsylvania. The site consists of a plugged, abandoned
natural gas well encompassing an area of approximately 100 ft2. In the early 1970s,'
)e Erie County Health Department noted a seep discharging a noxious, hy~rogen
,ulfide-bearing black liquid. Investigations focused around whether the li qu i d was a
natural brine emanating from the underlying Bass Island geologic formation, or was
related to the deep well injection of spent paper pulping liquid by a nearby paper
mill. The Presque Isle well was plugged in 1982, and subsequent investigations have
revealed no further release of the hazardous liquid to the environment. No direct
relationship between paper mill injection activities and the original release has been
established.
EPA determined that no significant risk or threat to public health and the
environment exists and therefore no further action wi 11 be taken at this site. There
are no implementation issues or costs associated with this no action remedy.
17. KEY WORDS AND DOCUMENT ANAI.YSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENOEO TERMS C. COSATI Field/Group
Record of Decision
Presque Isle, PA
First Remedial Action - Final
Contaminated Media: none
Key contaminants: none
,
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PlilaVIOI.I1 IEOITION II 0810L.IETIE
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e.
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Give namehlln ..:\)nyentlon,,1 order (John R. DM, J. Rob..,1 Doc', "IC',/. Li't .Iulhur\ allili;allun II" il .lin"r, hum Ih~' I"'rl""rmint: .,,~nl.
zalion.
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Iii DESCRIPTORS. Seleci from the Thc'.1uru~ of En~lnt:enr.1J .and S.:n:lIlIli..: r.:rlll' tht: plupt:r ..ulh..,./.:J 1"'111' IhOiI IJl:nllly Ihl: nIOl''''
concepl of the research ..nd ue suffiClenlly ,pe':lfic .nu pre':l~ to be u~u a, Inu..::\ .:nllll:, lur .:..IOIlu~lnt:,
Ib) IDENTlI'IERS AND OPf.N.ENDED TERMS. Use Idenufiers for proJe.:t nOlnl.:" wue Oilm"" "4u1pm,,01 J",,~n..tu", ..:11.:. 1.,;"" "I"'"'"
ended terms wmlen In descnptor form for thosc subjects for wlndl no dt:~flplur ':"'''IS.
ICI COS" TI I.ILLD GROUP. held .nd group "ullnmenu .are 10 be tOlkl:n Irum the I ~65 eOS".11 'iuh".t:1 c'lIq:ury \.i,I, Sln':l: Iht: ma.
Jorlty of documenu are multidisciplinary In nalure. the Primary held/Group ;a"'llnmt:nlh' \11111 bt: '1",",,1.. ul~ll'hnt:, art'a..f human
endea\'or. or rype of physi.;aJ object, The appllcallonu, "'III be cru".(I:If.:lt:nc:ecJ wJlII ~\.unt.l..ry , Idtli( ,((JUI' ""'1111111':11" thai \4',/1 ,,,/1,,\4
the p"mary posllngls»,
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the public. wllh ..ddreu ..nd pll.:e.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Presque Isle Superfund Site
Presque Isle State Park
City of Erie, Erie County,
Pennsylvania
STATEMENT OF BASIS
This decision is based upon the administrative record. The attached
index identifies the items which comprise the administrative record.
DESCRIPTION OF THE SELECTED REMEDY
Based on the current conditions at the Presque Isle Site, I have determined
that no significant risk or threat to public health or the environment exists.
Therefore, I have determined that no further remedial actions under CERCLA are
required.
DECLARATION
This decision document represents the selected remedial action for this
site developed in accordance with CERCLA. as amended by SARA, and the National
Contingency Plan. I have determined that the selected remedy is protective of
human health and the environment, attains Federal and State requirements that
are applicable or relevant and appropriate, and 1s cost effective. This remedy
satis1fies the preference for treatment that reduces toxicity, mobility, or
volume as a principal element. Finally, it 1s determined that this remedy util1zes
permanent solutions and alternative treatment (or resource recovery) technologies
to the maximum extent practicable.
The Commonwealth of Pennsylvania has concurred on the selected remedy.
Date
YSc)l?
/
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Site Description and Summary of Remedial Alternative
Selection for the Presque Isle Superfund Site
INTRODUCTION
The Presque Isle site is located on the Presque Isle State Park penin-
sula, within the City of Erie in Erie County, Pennsylvania (see Figure 1).
In the early 1970's, the Erie County Health Department noted a seep at the
Presque Isle site which is near Beach No.7. This seep was discharging a
noxious, hydrogen sulfide-bearing, black liquid. The discharge released
hydrogen sulfide to the air and a black fluid containing hazardous substances
to the soil and. shallow ground water.
Investigations by the' Pennsylvania Department of Environmental Resources
(PADER) from 1979 to 1982 revealed that the source of the discharge was an
unplugged, abandoned natural gas well which intercepted a geologic formation
known as the Bass Island Formation. This gas well was buried at the time
the discharge was first noticed and was originally described as a "seep." A
central issue of the investigations subsequent to the discovery of Che seep
has been whether the fluid discharging from the Bass Island Formation is a
natural brine, or is related to the deep well injection of wastes by the
Hammermill Paper Company (see Figure 2).
Hammermill Paper Company operated three underground injection wells be-
tween 1964 and 1971 and injected 1.1 billion gallons of neutral sulfite pulping
liquor waste into the Bass Island Formation. The nearest of the three Hammer-
mill wells is located 4.2 miles from the well at Beach No.7 (see Figures 1
and 2). Based on initial information, PADER concluded that there was a
reasonable cause and effect relationship between Hammermill's injection pro-
gram and the discharge at Presque Isle.
PADER contacted the U. S. Environmental Protection Agency (EPA), Region
III, in 1982 for sampling assistance while the plugging of the Bass Island
Formation in Beach No.7 well took place. The site was placed on the NPL in
September 1983 because of the possibility for similar releases from other
improperly plugged oil and gas wells in the surroundi~g area and the resultant
potential for adverse impacts to human health and the environment.
EPA conducted a number of additional studies to better define the cause
of the discharge and to determine whether there were any potential environ-
mental impacts from similar discharges. The Hammermill Paper Company also
conducted numerous investigations. The results of these studies are included
in a Remedial Investigation/Feasibility Study (RI/FS) document titled "Summary
of Investigations and Recommendations for Further Action." This Record of
Decision (ROD) summarizes the results of the RI/FS and presents the selected
remedy for this site.
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PRESOUE
BEACH NO.
GAS WELL
LAKE ERIE
7.5' USGS Tipographic map*. Eri* South, Eri* North and SwanvU* Quadrangtot,
Pennsylvania. Oalad 1957, Pholoraviaad 1969 and 1975, Scala 1* - 2000'.
Sf.AI I
zooo
2OOO 4OOO fit I
MAP SHOWING LOCATION OF PRESQUE ISLE,
CITY OF ERIE, PENNSYLVANIA
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PRESQUE ISLE'.
GAS WELL.
. EL ~81't
..a...
8~/~ DRIVE
CASING
TO 134'
.
+
4.2 MI LES-
.HAMMERMI L.L PAPER COMPAf'
WASTE DISPOSAL. WELL NO.1
... EL. 600 TO fL. 6~(
133ft II CASING
8. .
TO 40
. GLACIAL AND RECENT
w
~co
-
to-
W
LoW
~
-
UPPER DEVONIAN SHALES
..
LW
(.)
ct
~
a:
:::)
CI)
~ 1000
:::)
o
a:
C)
3:
o
...J
L4.I
CD
~ ISOO
Cl. -
L4.I
o
6~' CAS I NG
TO I 670 '
95~' CAS I NG
TO 1359'
ONONDAGA FORMATION
---
---
4"'NJECTION
TU81NG TO
1600'
3"TU8ING
TO 3572'
SA L J N A FORMAT I ON
::::::::::
1" CAS I N G
TO 2106 .
2000
LOCKPORT
FORMATION
~
-
* ELEVATIONS t.
MEAN SEA L
GENERAL STRATIGRAPHIC RELATlONSH IP
AND CONSTRUCTION DETAILS
HAMMERMILL INJECTION a PRESQUE ISLE WELLS
ERIE COUNTY,PA.
(USGS 1982)
NOT TO SCALE
FJ GHItf ?
,rrc
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- 2 -
SITE LOCATION AND DESCRIPTION
Presque Isle State Park and the Beach No.7 gas well are located in
northern Erie County, Pennsylvania. Presque Isle is a public recreational
.
area used for picnicking, swimming, and fishing. The park contains an eco-
logical reservation and is a natural habitat for deer, squirrel, water fowl,
and many herbivorous species. Presque Isle is a low-lying (elevation
approximately 580 feet above mean sea'level) sand spit, composed of coarse-
grained glacial sands that is connected to the mainland by a narrow causeway.
At the surface, the Presque Isle site consists of a single gas well.
The city of Erie, Pennsylvania, is located on a terraced bluff at an
elevation of 600-850 feet above mean sea level. The. elevations of the Hammer-
mill injection wells are becween 630 and 650 feet.
The overburden at this site consists of glacial deposits that produce
usable quantities of ground water. However, the bedrock consists of shale,
and in drilled wells, especially those near Lake Erie, one commonly encounters
salty waters, sulfurous waters, or even gas at shallow depths. In Mill Creek
Township, to the west of the City of Erie, the glacial sediments are roughly
50-100 feet thick. The Beach No.7 well is surrounded by dune sand consisting
of deep, loose, loamy fine sands and fine sands. These soils have high
infiltration and permeability rates.
The Bass Island formation is an extensive formation with variable charac-
teristics, ranging from Southern Ontario and Michigan to Ohio and Pennsylvania
and parts of West Virginia and New York. The formation in the Erie area is a
porous dolomite and averages approximately 75', ranging from 60' to 175' in
thickness.
The major surface body that could be affected by discharges from the Beach
No.7 well is Lake Erie and its associated bays adjacent to the City of
Erie. Lake Erie is ~he major source of drinking water for the City of Erie.
Ground water in the beach area near this well tends to be very shallow (i.e.
3 to 4 feet). Ground,water is not utilized for drinking water purposes on-
the Presque Isle peninsula. Shallow ground water flows downgradient from
this well area in a westerly direction toward Lake Erie. Potable ground
water in the Erie area has been noted in the glacial drift at approximately
25 feet. This shallow ground water is the source for domestic water supplies
for residents who prefer to utilize ground water rather than city water.
Below a depth of approximately 100 feet, the ground water is saline.
SITE HISTORY
In 1910, the City of Erie drilled the Beach No.7 well to a depth of
3,570 feet for use as a source of natural gas. The well was abandoned without
plugging in the 1920's and covered by a concrete road surface which was
later abandoned and covered with sand. The property on which the Beach No.7
well is located is owned by the Commonwealth of Pennsylvania. The Beach
No.7 well was extensively tested, plugged with cement up to the first 900 ft
(sealing the Bass Island Formation) and completed as a natural gas well
between October 18 and November 17, 1982 by PADER.
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- 3 -
Hammermill's use of the deep well disposal system for its pulping liquor
waste was permitted by the Department of Health, Division of Sanitary Engi-
neering, Commonwealth of Pennsylvania, for the injection of wastes into the
Bass Island Formation. This disposal operatfon was performed be~een the years
1963 to 1971 (see Table 1). An alternative pulping process that would enable
Hammermill to recycle the pulping liquor was developed and the injection of
pulp wastes ceased. The three Hammermill wells were plugged in September 1972
under plugging procedures approved by the Ground Water Section, Division of
Water Quality, PADER.
In the early 1970's, Presque Isle State Park personnel received complaints
about a seep of foul-smelling, black water near the western edge of a parking
lot at Beach No.7. The area was near several outhouses and sewage discharges
were suspected. According to a former inspector for the-Erie County Health
Department, the seep was sampled and it was determined that the seep was not
sewage, because it lacked coliform bacteria.
PADER's Bureau of Forestry was alerted in 1978 to the seep at Beach No.7
by a request from the State Park regional superintendent. The seep area was 4
feet by 40 feet and gas that smelled like hydrogen sulfide was bubbling over an
area of approximately 1 square foot. The request for investigative assistance
was referred to the Bureau of Forestry, Minerals Section which has jurisdiction
over oil and gas wells on state park property.
The well was uncovered by using a backhoe on March 21, 1979 and samples
from the seep and the well bore were taken and submi~ted for analysis. PADER
brought in clean sand to cover the area of blackened soil and removed the dead
trees that were standing nearby which were thought to have been killed by the
Beach No.7 well discharge. Subsequently, the USGS determined that a 6- to
9-foot rise in the level of Lake Erie may have been dn overriding factor in the
death of the trees.
PADER contracted with Roy F. Weston, Inc. to perform soil, surface water,
and shallow ground water studies at the Beach No.7 well in April, 1980.
Weston subsequently submitted its technical report on July 1, 1980 concluding
that there was no significant influence of the well discharge on the soil,
surface water and ground water underlying the beach (see Figure 3).
Water samples from the Beach No.7 well that were analyzed for priority
pollutants showed high levels of inorganics, but organic contamination was
quite low. A soil sample was taken approximately 12 feet from the Beach No.7
well area (see Figure 4). Concentrations of inorganic contaminants in the soil
extract were considerably below EPA criteria, and the soil would not be con-
sidered hazardous based on these constituents. West00 did not speciEically
test for organics in the soil, but they felt that the low levels of organics
in the well discharge indicated that organics would probably not be retained
by the soil (see Figure 4).
In 1981, the Erie County oil and gas inspector made visual inspections
of 87 011 and gas wells within a 5-mile radius of the Beach No.7 well. Most
were found in good shape, with no seeps or leaks observed or reported. People
living in buildings that were constructed over the sites of these wells were
questioned, and they reported 00 odors or seepages.
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DESCRIPTION AND INJECTION HISTORY
OP HAMMERMILL WELLS 1, 2 AND 3
AND OF THE PRESQUE ISLE WELL
(Adapted from D'Appolonia-HML, 3/33)
DESCRIPTION
Year Drilled
Surface Elevation
Approximate Depth
of Bass Island Fm.
(top to bottom)
Primarv Injection
ZoneU)
Period of Injection
Date of Sealing
Pump Capacity
Operating Pump/
Surface Pressure
Total Injected
Volume
Estimated Average
Injection Rate^ '
UNIT
-
feet
above
MSL
feet
feec
-
-
gpm
psi
gallons
goo
HAMMERMILL WELLS'
NO. 1
1963
629.3
1611-1688
1620-1670
5/64-5/71
9/72
388
1,150
4.5 x 108
121
NO. 2
1964
650
1658-1732
1620-1710
9/65-9/68
9/72
331
1,250
3.0 x 108
189
NO. 3
1968
647
1586-1737
1620-1720
7/68-5/71
9/72
831
1,250
3.5 x 108
237
PRESQUE
ISLE WELL
1910
580
1521-1586*
.(2)
-
-
-
-
—
(I)
(3)
Injection feasibility tests were also performed on the Lockport Formation
in Well No. 1 and in the Gatesburg Formation in Well No. 2 (Figure 3).
Results indicated these formations were not satisfactory for injection
zones.
"-" indicates not applicable.
Estimated from total injected volume during period of injection.
Corrected based on Walker (PADER, 8/15/83)
TABLE 1
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SMto: 1" • MM Appfoi.
All umollng point locations tpprotlmau
PBESOUE ISLE BEACH NO. 7
SAMPLING LOCATIONS
MAY 15. 1980
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LOCATION OF TEST HOLES AT PKESQUE ISLE STATE PARK. BEACH NO.7,
AND CHEMICAL ANALYSES OF GROUND WATER AND DISCHARGE PROM WELL
(Weston-PADER, 7/1/80b)
-------
- 4 -
Ecology and Environment, Inc. working for EPA, sampled the lake bottom
across a black lineation thought to be escaping Bass Island fluids and reported
its findings in an EPA FIT report dated March 23, 1982. This report states that
samples of the lake sediments indicated the presence of palmitic acids and very
low levels of poly-nuclear aromatic hydrocarbons (PAHs). The black lineation
was found to be ~ery close to the city sewer lines and later found to be caused
by leaks in the city sewer lines.
. In addition, Ecology and Environment surveyed domestic wells in the Erie
area in September, 1982. Eleven residential water wells were sampled because
they were near 17 gas wells that were not plugged and that had penetrated the
Bass Island Formation. These wells were sampled for 129 priority pollutants as
well as lithium, strontium, and ammonia. Additionally, the Erie County Depart-
ment of Health sampled 50 residential wells within a 10 mile radius of the City
of Erie. The results did not indicate a contamination problem.
. The proposed National Priorities List (NPL) was published on December 30,
1982, and the Presque Isle Beach No.7 Well was included. The NPL listing of
Presque Isle was finalized in September 1983. The Presque Isle Site RRS total
score is 40.59, and is based on releases to ground water and air.
In May, 1984 EPA asked Dr. Arthur Hounslow of Oklahoma State University
to undertake a literature search to determine: (1) the feasibility of pore
plugging reactions between the Bass Island Formation, the formation fluids, and
the injection liquor, and (2) whether the organic compounds in the formation
fluids of the Beach No.7 well were the result of naturally occurring petroleam
hydrocarbons. Hounslow reported that bacteria degradation and the differential
solubility of the organics present in petroleum complicate the issue of whether
the organic fraction in the samples is natural or waste derived. Examination
of the analyses of the organics in the seep and the Bass Island formation
failed to reveal an unequivocal origin.
A numerical model called NEMESIS was employed on behalf of PADER, to
simulate contaminant transport under various combinations of reservior con-
ditions, hydraulic parameters, mixing parameters, and injection pressures
appropriate for the Presque Isle setting. Some results of simulations using
this model indicate that the injected pulping liquor from the Hammermill
injection wells could have reached the Beach No.7 well. It is useful to note
that the issue of whether the seep existed prior to the documented complaints
in the early 1970's (i.e. prior to Hammermill's injection program) has been a
matter of dispute betWe'en PADER and Hammermill.
The potential populations at risk from this and other similar discharges
are the City of Erie which has a population of 119,000, and Erie County, which
has a population of about 280,000 (including the City of Erie). Additionally,
the average number of visitors to this park is approximately 4.3 million annually.
Surface water users potentially at risk include those who use Lake Erie
for recreational purposes. Lake Erie is also the major source of drinking water
for the City of Erie. There are two intakes in the lake both of which run in a
northwest direction approximately 4 miles northwest of the Presque Isle Site.
Another use of the lake is support for wildlife.
-------
- 5 -
All facilities in the park receive their water from the City of Erie Water-
works. There are numerous shallow ground water well users onshore in the area
adjacent to Presque Isle. however. the majority of residents in the city do
obtain water from the City of Erie Waterworks. Outside the city, ground water
is the primary source of drinking water. Any release of hazardous substances
into the ground water could have adverse effects on the well water supplies
of the area. .
COMMUNITY RELATIONS HISTORY
The first public attention which focused on the Presque Isle Site occurred
in 1963 when Hammermill, in an attempt to dispose of its pulping waste, proposed
using deep well injection to pump waste effluent into the Bass Island Formation.
Because this technique was newly developed at the time, press coverage high-
lighted the unique experiment as answering "the needs of both company and
the State."
~." . ",
. .
Additional press coverage was received in the spring of 1968 when one of
the injection wells was reported to have ruptured as a result of erosion. The
waste effluent, normally pumped into the Bass Island Formation. flowed into Lake
Erie for several weeks. This situation also fueled a controversy over offshore
drilling which was being proposed for Lake Erie at the time of the mishap. Area
newspapers speculated on the potential for similar accidents resulting in oil
spills on Lake Erie if offshore drilling was permitted. However, attention on
Hammermill appears to have receded after the injection well was repaired.
Very little community attention was focused on ";\e site in the early'
1970',5. The injection wells were capped by 1972 all irew little attention from
t he pub li c.
Unconfirmed reports indicate that odors and lii larges at the Beach No.7
well may have been noticed as early as 1970. Howev -. the first official
complaint was not recorded until 1976 when the Erie ,ounty Health Department
filed a complaint with the Presque Isle State Park \ ,flee. In 1979, an
abandoned gas well was uncovered and discovered to he leaking a foul smelling
discharge into the surroundin~ soil. Much publicit:' surrounded this discovery.
Substantial press coverage has been provided on the Presque Isle Site since
1980. Statements that emissions from the Beach No.7 well may be connected to
the Rammermill injection wells were first reported in 1980.
Currently, there i8 only a moderate level of cc'wlmuni ty awareness of the
Presque Isle Site. More recene: repore:s have concern..J a lawsuit filed by
Hammermill against EPA regarding inclusion of this ~ ~e on the NPL. However,
if regional ground water contamination occurs, or i ~arge amounts of hydrogen
sulfide gas are found to be located in the subsurfa., community concern could
quickly escalate.
Three RIfFS information reposie:ories were opend in the Presque Isle area
on August 3, 1987. The locations include the Presque Isle State Park Office,
the Erie County Health Department and the Erie Councy Library, Presque Isle
Branch, which also contains the Administrative Recor~. A public meeting was
held on August 13, 1987 to discuss the RIfFS and EPA's recommended alternative.
-------
- 6 -
A 30-day public comment period was also opened. One request to extend the
comment period was granted. . The public comment period closed September 18,
1987. The Responsiveness Summary lists all comments and responses related to
this public comment period.
CURRENT SITE STATUS
The Beach No.7 well at the Presque Isle site appears to be in good con-
dition. During a recent inspection, neither odors, discolored sand, or evidence
of stressed vegetation were observed. The well is typical of many in the Erie
area, and it is surrounded by a small 4-foot high wooden fence and the area is
covered with sand. While the Bass Island Formation was plugged off in the Beach
No.7 wellS years ago, the first 900 feet from the surface downward in this well
was not plugged. This well continues to produce natural gas from the Devonian
Shales above the Bass IslandForma~ion..The well is equipped with a bleed valve,
meters'and pressure gauge' in: 'order to control discharges.
The current status of the Presque Isle site has been discussed with PADER
officials in the Meadville office and EPA has been advised that there have been
no confirmed releases of hydrogen sulfide gas since the Beach No.7 well was
plugged in October 1982. PADER has indicated that' any reports of foul-smelling
odors during oil and gas well drilling in the Erie area were probably the result
of naturally occurring, sulfurous, aromatic hydrocarbons which are typically
associated with natural gas.
PADER also discussed the considerable logistical problem involved with.
confirming a hydrogen sulfide release. The Erie County Department of Health or
an oil and gas inspector must call the Bureau of Oil and Gas office, which then
must obtain the test equipment from another PADER Bureau and ~hen get the equip-
ment to the oil and gas inspector at the well. The amount of time required is
usually too great to allow for proper monitoring. The former Erie oil and gas
inspector, Mr. Harry Mackey, often required ~hat the driller have mud available
to immediately stem the flow of hydrogen sulfide-bearing gases or fluids as a
safety precaution. PADER's Bureau of Oil and Gas office in Meadville currently
performs routine inspections at the Beach No.7 well.
In July 1987, PADER's Harrisburg State Parks Maintenance Office tested the
sand around the Beach No.7 well for organic compounds and found no indication
of contamination.
CONCLUSION
Discussion
Four distinct possibilities can explain the seepage of hydrogen sulfide-
bearing fluids at the Beach No.7 well on Presque Isle: (1) Hammermill's
spent pulping liquor or its constituents were forced to the surface under
injection pressure, (2) Hammermill's spent pulping liquor or its constituents
-------
- 7 -
were forced to the surface under natural
the area; (3) a naturally occurring Bass
the surface under Hammermill's injection
wholly a natural phenomenon.
artesian pressure after migrating to
Island Formation brine was forced to
pressure; or, (4) the seepage was
The first two possibilities cannot be conclusively supported by the
available chemical evidence. Sample contamination, analytical problems,
geochemical complexity, appropriate background comparison criteria, and the
great amounts of time and distances involved make the chemical issue proble-
matic. Even additional monitoring wells and further sampling would probably
not resolve many of these issues. Chemical evidence indicates that even if
the pulping liquor was present in any of the previous analyses, it would have
been diluted greatly, beyond the level of statistical observation.
The second two scenarios are conceptually more simple, but the answers
are no more clear. Hammermill has presented evidence that the Bass Island
Formation could conceivably flow, under its own artesian pressure, but this
hypothesis is largely unprovable for the Erie area because the Hammermill
injection program has altered the normal hydrogeologi c -cegime. The inje cted
pulping liquor will probably migrate from the area in which it was injected.
The rate and extent of the migration cannot be estimated without acquiring
some site-specific information about the formation's hydrostatic head. Three
or more observation wells would have to be installed in the Bass Island For-
mation to generate sufficient information on the hydrostatic surface of the
Bass Island Formation. These wells could allow the measurement of the
potentiometric head in the formation and the periodic collection of samples
of formation fluid.
Such information would enable a more accurate projec:ion of whether future
problems may occur, but it would not necessarily resolve the lack of clear
chemi cal and geologi c evidence of the exi stence or rlOl1exi stence of a link
between the seepage of fltlid at the Beach No.7 well and the Hammermill waste
injection program.
In Hammermill's most sophisticated reservoir modeling and the modeling
of all other investigators on both sides of the argument, it was noted that
the Hammermill injection program could have substantlally r.aised the formation
pressure at the Beach No.7 well. Hammermill's reservoir modeling includes
both the artesian flow argument and the pressure drive argument in the same
document. The most provable conclusion is that, at a minimum, the Hammermill
injection program forced a naturally occurring fluid that was near the surface
from the Beach No.7 well.
ENFORCEMENT STATUS
At the present time Hammermill is the only was:e generator who could he
linked to the site as a potentially responsible party. However, the injection
of pulping wastes has not been conclusively linked to the discharge at the
Beach No.7 well. Hammermill has argued that this discharge is exempted by
CERCLA from being considered as a release and consequently for inclusion on
the NPL because the discharge was a natural fluid. In addition, even if the
fluid is identified as Hammermill's, Hammermill has argued that it might again
be exempted under CERCLA since it was from a State permitted disposal operation.
-------
-8-
ALTERNATIVE EVALUATION
The major objectives of any remedial actions to be taken at the Presque
Isle Superfund Site 1nclud~ (1) prevent/minimize direct human exposure to
gaseous and liquid wastes from uncontrolled discharges, and (2) prevent/mini-
mize potential contamination of surface and ground water by pressure flow
through fractures, gas and oil wells, or other pathways.
Based on the above objectives, several source control and mitigation
control technologies were screened to provide a limited number of technologies
applicable for remedial actions at the site. Some of these technologies were
removed from fu~tther consideration based on site-specific information and
other comparative criteria. These other criteria include:
o - Technical per~ormance/reliability-
o
Constructibility
o
Health and environmental impacts
o
Institutional consideration
Each technology was evaluated not only in terms of theorectica1 feasi-
bility, but also in terms of whether the technology is applicable to the site
specific conditions. The candirl~te technologies that were dismissed from
retention are presented below w; ~h the justification for elimination.
Technology
Reason(s) tor Elimination
Removing Hammermill
deep~ell injected wast
from Bass Island Format-m
Not implementable. Wastes have
probably migrated from the poiat
of injection through fractures
and are therefore unrecoverable.
Identifying, investigatjag
and plugging (if required)
all abandoned oil and gas
wells in Erie County.
High cost; not effective since
many of these well locations are
unknown. Also, the number of wells
involved are in the thousands.
The technologies that have been retained for further analysis can be
grouped into the following four alternatives:
o
Depressurize Bass 151 --J Formation
o
Installation of Monit.-.~ing wells in Bass Island Formation to Determine
Seepage Origin
o
Installation of Monitoring Wells in Bass Island Formation to Predict
the Potential Migration Pathway of Hammermil1's Injected Waste
o
No Action
-------
- 9 -
To analyze these alternatives, an evaluation was conducted that considered
the new requirements of the Superfund Amendments and Reauthorization Act of 1986
(SARA) and the current version of the National Contingency Plan (NCP) (50 Fed.
Reg. 47912, November 20, 1985). Three broad categories were used for the ----
evaluation: effectiveness, implementability, and cost. Within these categories
there are seven facuors that consider the short-term and long-term effectts of
each alternative (see Table 2).
Alternative 1. - Depressurize Bass Island Formation
This alternative would be a very difficult undertaking. The effectiveness
of this action would be limited because, based on calculations, pressures in the
Bass Island Formation at the Hammermill injection site have probably returned
to natural conditions (i.e. no unusual pressures to be released). There would
be environmental and public health risks associated with drilling such wells
because sulfur water could be encountered, H2S gas could build up to significant
levels while the well. was capped be~een tests and releases to the air, ground
water, surface water and soil could occur.
To drill such a well would cost $150,000 each and depressurizing the
formation would require a facility to treat the formation fluids that flow
back. Such a facility would have to be immense in order to treat the 1.1
billion gallons of injected pulping liquors. It would have to operate for many
years, especially considering that the pulping liquor may have been diluted 10
to 200 times by the normal formation fluids. Additionally, the natural formation
fluids in the underlying Lockport Formation are just as hazardous (see Table 3)
and present few problems to experienced oil and gas well drillers. Thus far,
the only receptors that have been identified as at risk since the plugging of
the Beach No.7 well are the ones near the oil and gas well drilling rigs that
are actively drilling through the Bass Island Formation.
Alternative 2. - Installation of Monitoring Wells in the Bass Island Formation
To attemptt to conclusively define the source of the Presque Isle discharge,
drilling an unestimated number of wells into the Bass Island Formation. would be
involved. Each well would cost approximately $150,000. If cores of the
formation were collected, the cost per well would inc~ease by at least $50,000.
It is unclear whether any additional data obtained from these wells would
provide conclusive information regarding the source of the Presque Isle
discharge. Furthermore, there would be environmental and public health risks
associated with drilling such wells because sulfur water could be encountered,
HZS gas could build up to significant levels while the wells were capped
between tests, and releases of this gas and formation fluids to the air,
ground water, surface water, and soil could occur.
Alternative 3. - Installation of Monitoring Wells in the Bass Island Formation
to Predict the Potential Migration Pathway of Hammermill's Injected Waste
Installation of monitorin~ wells in the Bass Island Formation near the
three Hammermill injection wells and subsequent monitoring would potentially
provide information on the potentiometric surface of the Bass Island Formation
and possibly be used to predict the potential migration pathway of Hammermill's
injected waste. This would be an expensive undertaking since a minimum of
-------
EVALUATION FACTORS FOR REMEDY SELECTION
EffECTIVENESS IMPLEMENT ABILITY COST
Reduction 01
Toxicity,
MobHity, Technical Administrative
Protectiveness or Vo1Jms Feasibility FeaslJility Allailabilit Remedy
" y
SHORT-TERM
RedlJction of
existing risks
Compll"nce with
ARMs
Ability to construct
technology
S~rt-term reliability
0' technQlogy
t---i
~
b:I
r-<
tr1
Con1pliance with
other criteria,
advisories. and
. guidances
Protection of
Community during
r,,,,edla! actions
CompUance with
60me actlon-
specific AAARa
N
TIme !,Jntil protec-
tion Is achieved
LONG-TERM
R~Lictlon 01
tutur..rlsks
LOI)Q-term
;ell~lIity
~pllaoc..
"Mtt ARAR'
Permanent and
significant r$duc-
tlon of toxicity,
. mobility Of volume
Ea!!. of undertaking
..dditlo.ud ref'f1~laJ ,.
ac:tlon. ~ necessary
Ai>!!1ty to monllor
'ffeetlv,-ne,. 9' '.
rem"""" .'
:.:.,~'.
I '
[
. .. .
Pi"V8r1tlon
0' Ntur.
8~~~';' ~ .
. i!,,~~,~.
P9.~~~t~na~
11'""""",,,
I..'<'~:'
I~'..'<.:.'..'.'
". '" .
AbllliUio Perform. .
:: q ":JUon: d 'aln~ ..
op!f~q: AA tn. ..'
t.i1~~ funC1lon. :.
Ability to obtaJo
approvals f,om 9ther
ageocl~ul
lkellhood 9f favo(~
able c:ommu"ity ..
response .
Coordination with
olher 8ge~I8..
Compllanc8 With
some 1o<:8tlon-
$~Io A~~ :
AvaDabiJity of treal-
menta storage. ~od
disposaf services
and .capaclty
. .
Avalabllity 0'
neceS8~ry equip-
ment and
speclalist$
Development and
c:onsiruction costs
Operating costs
for implementing .
remedial action
Other capital and
short-term costs
until remedial
(ldlon is complete
Costs of opera-
tion and malnte-
n~e for as long
'8 necessary .
Costs 0' 5-yaar
. reviews
-------
COMPOSITIONS OF BRINES IN THE BASS ISLAND AND
LOCKPORT FORMATIONS AT THE PRESQUE ISLE BEACH NO.7 WELL
(Andrews-HML. 10/26/83)
D E V O. N I A N
STRATA
THICKNESS
(FEET)
. +
14 eo
REMARKS
FOf;MAiION
o VERl. YI NG SHAl.l.OW DEVONIAN SHAl.E
COMMERCIAl. GAS PRODUCTION' STRATA
rDS
( ~ 11)
'c 1
lQ/.1 )
pH
HZ S
(mQ l.l 5)
23 S
BA 55 IS l.A ND
60
PtnnDER 111
US G S 180
O'APPOLONIA 266 . 186 6.6
HYDROSTATIC PRESSURE: Fl.OW
AT SURFACE.
6.4
IS2
OBSERVED
SAl.INA
360
NO NATURAl. GAS PRODUCTION
TD9
19/.1 )
el
1 Q Ii)
pH
H2S
ImcJ/.I S)
l.OCKPORT
350
PtnnO!~
.U S Q S
O'APfIIOLONIA 208 132 ~.6 3 12
HfDRO,iATIC PRESSUREI FLOW OaSE~VED
AT SURFACE
~.8
9 41
MEDINA
UND£A 1.'1'1 NO COMMERCIAL GAS PRODUCTION STRAT
DEEP SUBSURFACE CONDITIONS AT PRESQUE ISLE BEACH NO.7 WELL
TABLE 3
-------
- 10 -
three points would be required to make any conclusions about hydrostatic level.
Ideally, many more than three points would be required for a true determi-
nation. Each well installation w~u1d cost a minimum of $150,000. The Hammer-
mill injection program has altered the normal hydrogeologic regime in the
Erie area and there is the possibility that the Bass Island Formations'
potentiometric surface could not be established to be representative of the
area affected.
In addition, there would be environmental and public health risk associated
with drilling such wells because sulfur water could be encountered, R2S gas could
build up to significant levels while the wells were capped between tests, and
releases of this gas and formation fluids to the air, ground water, surface water,
and soil could occur.
Alternative 4~ - No Action
The Bass Island Formation within the Beach No.7 well was permanently
plugged in 1982. Since that time, no discharge has been observed or reported
from that well or any other well in northern Erie County. Therefore, at the
present time, EPA 1n conjunction with PADER has determined that no further
remedial measures are appropriate. Based on remedial investigations performed
by both EPA and PADER which indicated that no significant contamination from
the Beach No.7 well discharge has been detected in the air, surface water,
ground water, or s01l, EPA in consultation with PADER, has determined that
the r~lease poses no significant threat to public health or the environment.
This determination has taken into consideration all applicable or relevant
and appropriate Federal and State environmental requirements.
The factors in this category do not require an implementability and cost
analysis since there are no implementation issues or costs associated with
taking no action.
Recommended Alternative
Section 121 of the Superfund Amendments and Reauthorization Act of 1986
(SARA) and the current version of the National Contingency Plan (NCP) (50
Fed. Reg. 47912, November 20, 1985) establish requirements relating to the
level-of cleanup for remedial actions under CERCLA. Applying the current
evaluation criteria in Table 2 to the four remaining remedial alternatives,
we recommend that Alternative 4 be implemented at the Presque Isle Superfund
Site.
The results of all studies conducted on the Presque Isle site to date
have been analyzed in the Remerlial Investigation/Feasibility Study (RI/FS)
report titled "Summary of Investigations and Recommendations for Further
Action" (Schoener-EPA, 10/85). Available chemical data provide ambiguous
informatIon about the source of the discharge and suggest that resolution of
these ambiguities at this time is impossible. Investigations, however, have
determined that the discharge at Presque Isle Beach No.7 well was an unusual
-------
- 11 -
event, and that the threat to the public was eliminated when the Bass Island
Formation within this well was permanently plugged in 1982. As a result, the
only known source of the seepage has been capped. Potential for direct exposure
has also been minimized by covering the past seepage with fresh sand and there
are no drinking water wells in use on the peninsula. No migration pathways
have been recognized and, based on current information, no significant contami-
nation is present at or adjacent to the Beach No.7 well.
Deletion of Presque Isle Site From NPL
"No action" sites are considered as completions once the determination is
made that no further remedial actions are necessary to be protective of public
health and the environment and the no-action ROD is approved. Once a site is
considered as a completion it becomes a candidate for deletion from the NPL.
deletion process. is separate from the ROD action and involves several steps
1ncludingpublic notices arid deletion docket preparation. .
The
Deletion of a site from the NPL does not preclude eligibility for subsequent
Fund-financed or PRP activities. Section 300.66(c)(8) of the NCP states that
Fund-financed responseacttions may be taken at sites that have been deleted
from the NPL i£ future conditions warrant such actions.
Recommendations Outside the Scope of the Presque Isle ROD
During the Presque Isle Site investigations, EPA and PADER became aware
that oil and gas well drillers in the Erie area generally believe that the
Bass Island Formation fluid is a clear brine. As a consequence the following
recommendations, if implemented, should minimize fu:-ther problems or releases
associated with natural formation brines:
1)
Local oil and gas drillers should
bearing brines are present in the
mations, and that a potential for
exiSlts, and
be notified that hydogen sulfide-
Bass Island and Lockport For-
release of hydrogen sulfide gas
2)
Future oil and gas wells drilled through the Bass Island and Lockport
Formations should be monitored for high pressures and the occurrence
of hydrogen sulfide releases to identify areas potentially requiring
more safety measures while drilling takes place.
Both of these recommendations should be implemented by the appropriate
State agency. EPA will notify the surrounding States and Canada, where the
Bass Island Formation is also present, of our recommendations. State programs
could be established to set up a monitoring program to expand these recommen-
dations.
The Pennsylvania Department of Environmental Resources has concluded that
because State law requires drillers to give 24-hour notice before drilling
begins and it was already the policy of the State Bureau of Oil and Gas Mead-
ville office to have the local oil and gas inspector present when the Bass
Island Formation is penetrated, it would not be necessary to incorporate these
provisions into PADER's oil and gas well drilling per~tting process.
PADER has a180 determined that monitoring future drilling with some sort
of hydrogen sulfide testing equipment would appropriately protect the surround-
ing population.
-------
~'r / ~ ,. e;.'" a~ J
~rtAl
I~
ai~
, ,
COMMONWEALTH OF 'PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Post Office Box 2063
HarrisbUrg" Pennsylvania 17120
PENNSYLVANIA
~
Deputy Secretary for
Environmental Protection
Mr. Thomas Volcaggio, Chief
Superfund Branch "
U.S. Environmental Protection Agency
Region III '
841 Chestnut Building
Philadelphia, PA 19107
Dear Mr. Voltaggio:
The draft Record of Decision for alternative remedial measures at the
Presque Isle Superfund Site has been reviewed by DER staff members. The
Department concurs with EPA's assessment of the selected remedy. No additional
remedial actions under CERCLA are required at the Presque Isle Site to protect
the public health. welfare and the environment.
I wish to thank you and your staff for your cooperation with the
Department during past work at this site. If you have any questions concerning
this matter. please do not hesitate to contact Mr. Mark Gorman or myself.
Sincerely.
'~~~ / II:/;' ,/",~ ,/ /~
, ,J' {#-,y/
-------
UNITED STATES ENV.IRONMENT AL PROTECTION AGENC'(
REGION III
841 Chestnut BUllolng
Philadelphia. P~nnsyl./dnla l'nnl
SUBJECT: Pre&que Isle ROD
FROM- Robert E. Greaves, ~
. Waste Management Br~ (3HW30)
0.:. r~: SEP 3 0 1987
TO:
Bruce Smith, Chief
Hazardous Waste Enforcement Branch
(3HW10)
The well at Beach No.7 was plugged with concrete in 1982.
Since
then, no significant contamination was found.
It is .suggested that
PA DER monitor for H2S at the well to ensure that the plugged
concrete does not shrink or crack.
The probable level of earthquake shaking in the area is above
that which would cause geologic deformation.
Therefore, in the
paragraph "Recommendations Outside the Scope of the Presque Isle
ROD", it should be added that PA DER should monitor HZS in the
nearby area after a notable earthquake occurs.
-------
PRESQUE ISLE SITE
SARA ADMINISTRATION RECORD *
----INDEX. OF DOCUMENTS
SITE IDENTIFICATION
1) Letter to Mr. Ed Shoener from Mr. Karl Niklas re: validity
of D'Appolonia report conclusions and inadequate methodology,
5/2/83.
2) Letter to Ms. Linda Boornazian from Mr. Bruce Pluta and Mr.
Donald Senovich re: recommenda~ions to u.S. EPA followinq a
quality assurance and toxicoloqical review, 5/2/83.
3) Report: Final Report of the site Inspection.of the Erie
County Wells Prepared under TDD No. F3-8212-12, 5/2/83.
4) Memorandum of call from Mr. Robie re:
functioninq, 4/25/83.
filters and equipment
5) Letter to Mr. Ed Shoener from Mr. D. Leonard Koederitz re:
deep well injection pressure, 4/21/83.' -
6) Letter to Mr. D.L. Koederitz from Mr. R. Zielinski re: map
transmittal, 4/18/83. Maps are attached to the letter.
7) Memorandum re: samplinq of waste fluid from four storage
tanks, 4/14/83.
8) Letter to Dr. Leonard Koederitz from Mr. John Walker re:
fracture trace map transmittal, 4/8/83.
9) Letter to Mr. Karl Niklas from Mr. Edward Shoener re: report
transmittal, 4/7/83.
10) Letter to Dr. Leonard Koederitz from Mr. Edward Shoener re:
report transmittal, 4/7/83.
11) Letter to Mr. Benton Wilmoth from Mr. Charles Robie re:
certificates of analysis on qas from school district well,
4/7/83. Map and certificates of analysis are attached to
the letter.
12) Memorandum to Mr. Andy McErlean from Mr. Ed Shoener re:
special analytical report, 4/6/83'. Letter regarding
D'Appolonia, and two letters regarding assistance request are
. attached to the memorandum.
*Administrative Record available 7/31/87.
1
-------
13) Letter to Hr. Russell Wyer from Mr. James Roqers re:
D'Appolonia's work at the site, 4/4/83.
e
14) Letter to Dr. Leonard Koederitz from Mr. Charles Kleeman re:
map ~ransmittal and the injection well discussion, 4/1/83. Maps
are attached to the letter.
15) Letter to Mr. James Roqers from Mr. Todd Gulick re:
Hammermill Paper ~ ~ Verstandiq, 3/29/83.
16) Memorandum to Mr. Charles Kleeman from Mr. Edward Shoener re:
review of Hammermill injection program, 3/28/83.
17) Memorandum to Mr. William Harmon from Mr. John Walker re:
disposal of fluids from Beach 7 well stored at well site,
3/25/83. .
18) Memorandum to Mr. Daniel Donnelly from Mr. Ed Shoener re:
site samples, 3/24/83.
19) Chronoloqy of events and documents relatinq to Beach No.
well, 3/23/83.
7
20) Biblioqraphy: Selected Publications for Bass Islands
Formation, 3/23/83.
21) Letter to Mr. David Buente from Mr. David Click re: USGS
document transmittal, 3/23/83.
22) Memorandum to file from Mr. Charles Kleeman re: Hammermill
injection well meeting, 3/21/83. Attached to the letter:
a) Record of communication regarding Memorial Technical
High School well:
b) memorandum regardinq special analysis:
c) memorandum regardinq project proposal:
d) project proposal:
e) letter regarding gas well discharge:
f) summary of analysis:
g) memorandum regarding field trip:
h) central laboratory information:
i) memorandum regardinq water quality:
j) memorandum regarding GC/MS scans:
k) letter regarding shallow ground water:
1) central lab log information:
m) letter regarding USGS proposal:
n) memorandum regarding water quality:
0) letter regarding tabulation:
p) tabulation:
q) letter regarding USGS budget:
2
-------
r) memorandum regarding meeting to discuss deep well
injection program:
s) meeting agenda:
t) meeting attendance she4t:
u) memorandum regarding deep well injection meeting:
v). letter regarding assistance from USGS;
w) letter regarding technical assistance to EPA:
x) memorandum regarding techncial assistance to EPA:
y) central lab log information;
z) memorandum regarding presentation of USGS work:
a') meeting attendance sheet:
bl) illustrations:
cl) memorandum regarding logging and sampling of Reukes'
gas well;
d') maps;
e') central. lab log information:
. f' f. memorandum regarding .transmission of report;
g') report: Impact of Fluids from Deep Formations on the
Shallow Ground-Water Systems ~ Erie, Pennsylvania;
hi) project proposal;
il) project proposal:
jl) memorandum regarding sampling for tannin and lignin;
kl) meeting attendance sheet:
1') memorandum regarding samples for tannin and lignin. .
23) Memorandum to Ms. Linda Young Boornazian from Mr. Edward
Shoener re: subcontract for special expertise, 3/14/83.
Curriculum Vitae is attached to the memorandum.
24) Letter to Mr. Truman Andrews from ::r. Edward Shoener re:
facility definition, 3/8/83.
25) Letter to. Mr. James Rogers, esquir~, from Ms. Heather Gray
re: Hammermill Paper Company, 3/8/83.
26) Letter to Mr. Ed Shoener from Mr. Leonard Koederitz re:
qualifications to provide subcontracted services, 3/7/83.
27) Letter to Ms. Heather Gray, esquire, from Mr. James Rogers
re: Hammermill Paper Company ~ Anne ~ Burford, 3/4/83.
28) Memorandum to Ms. Linda Young Boornazian from Mr. Edward
Shoener re: subcontract for special expertise, 3/4/83.
29) Memorandum to file from Mr. John Kalker re:
lignin in Bass Island fluids, 3/1/33.
tannin and
30) Report: Presque Isle state Park Gas Well Investigation, by
DIAppolonia, 3/83.
31) Letter to Mr. Ed Shoener from Mr. Truman O. Andrews re:
submittal of Hammermill's comments, 2/28/83.
3
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32) Letter to Mr. Russell Wyer from Mr. James Rogers re:
transmittal ot package of Hammermill comments, 2/25/83.
Comments in letter form are attached to the letter.
33) Letter to Mr. Vacys Savlys from Mr. Ed Shoener re: allocation
ot funds for contamination study, 2/22/83.
34) Record of communication to Mr. Truman Andrews from Mr. Ed
Shoener re: facility boundaries, 2/22/83.
35) Letter to Mr. Russell Syer from Mr. James Rogers re:
information in EPA's possession pertaining to the site,
2/22/83.
36) Memorandum to Mr. Ed Shoener from Mr. John Walker re: gas
well test, 2/18/83. Letter regarding uncovered well casing
is attached to the memorandum.
37) Mem~randum to the" PUbl'ic docket from Mr. Ed Shoener re:
meeting with Hammermill about proposed site listing, 2/8/83.
Press release is attached to the memorandum.
38) Letter to Mr. Russell Wyer from Mr. T.O. Andrews re: -
request by Hammermill for delay of comment period, 2/1/83. .
'-
39) Memorandum to Mr. Donald Zimmer from Mr. Russell Crawford
re: Bass Island brine and other data, 1/25/83.
40) Letter to Mr. John Walker from Mr. Kevin Carroll re: Bass
Island brine, 1/17/83. Memorandum regarding Bass Island
formation, meeting agenda, memorandum regarding inspection of
wells, and memorandum regarding proposal for deep well
disposal of produced brine are attached to the letter.
41) Meeting notes taken by Mr. Ed Shoener, 1/13/83.
42) Memorandum to Mr. Bruce Smith from Mr. Ed Shoener re: request
for TAT assistance, 1/12/83.
43) Letter to Mr. Ed Shoener from Mr. Garth Glenn re: transmittal
of calculation, 1/11/83. Calculations are attached to the
letter.
44) Memorandum to Mr. Bruce Smith from Mr. Ed Shoener re: request
for TAT assistance, 1/10/83.
45) Proposal: Correlation of the Chemical Composition of the
Shallow Ground Water with that of the Fluids from the Bass
Islands Formation in and near LakeErie, Fa., 1/83:--
4
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46) Memorandum to Mr. Ren Jen Sun from the District Chief, WRD, re:
transmission report, 12/28/82. Report: Impact of Fluids from
Deep Formation ~ ~ Shallow Ground-Water Systems ~ Erie,
Pennsylvania, is attached to the memorandum.
47) Record of communication to ~. Ed Shoener from Mr. John Walker
re: high school well, 12/24/82.
48) Record of communication to Mr. Ed Shoener from Mr. John Walker
re: the site, 12/23/82.
49) Report:
Beach 7 Well Testing and Plugging Project, 12/16/82.
50) Memorandum to the Record from Mr. J.D. Stoner re: logging and
sampling of Renkis' gas well, 12/16/82. Maps of sampling point.
are attached to the memorandum.
51) Letter to Mr. Rolland Hemmett from Mr. Vacys J. Saulys re:
Bass Islands Formation Integrity, 12/14/82.
52) Letter to Mr. H. Jack McCoy from Mr. Paul J. Horvatin re:
Groundwater Contamination Study in Erie, Pa., 12/7/82.
Bibliography of support documents is attached to the letter.
53) Report: ~ Full Field Investigation of Presque Isle ==
Interim Report with Sample Data, 12/6/82.
54) Memorandum: to Mr. Paul Horvatin from Mr. Robert J. Wellington
re: Suspect Plume, 12/6/82. Photograph and envelope are
attached to the memorandum.
55} Report: A Field Trip Report: Sampling and Plugging
Operations at Abandoned Gas Well, 12/6/82.
56) Memorandum to the Record from Mr. Henry J. McCoy re:
presentation of USGS work on Presque Isle to EPA, 12/2/82.
57} Memorandum to file TSU 16-17 from Mr. Paul Horvatin re: trip
report for 11/23/82 meeting on Erie, Pa., 12/3/82.
58) Letter to Dr. Richard Garness from Mr. Russell I. Sloboda re:
transmittal of lab data, 10/18/82. Summary of lab data is
attached to the letter.
59} Letter to the file from Joseph G. McGovern re: meetings to
decide the best utilization of costs for program, 10/14/82.
60} Handwritten notes, 10/12/82.
61) Letter to Mr. John Fryberger from Mr. Ken E. Davis re: Presque
Isle Beach No.7 gas well, 10/7/82. Diagrams are attached to
the letter.
5
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62) Memorandum to Mr. Clifford Risley from Mr. Anthony Kizlauskas
re: use ot a helicopter for lake sampling, 10/4/82.
63) Report: Plume Investigation Lake Erie, Pa.
Dollison, 10/82.
by Robert M.
64) Field notes, 9/82.
65) Memorandum to Mr. Ed Shoener from Dr. Richard Garnas re:
Comments on Proposal to Analyze Discharge from Presque Isle
wells, 9/27/82.
66) Letter to Mr. Ren Jen Sun from Mr. Robert H. Clemens re: A
request for assistance from USGS for enforcement support,
9/22/82. Memoranda regarding programs and plans are attached
to the letter.
67) Memorandum to Mr. Ed Shoener from Mr Alton Stone re: sampling
plan for Presque Isle full field invest-j;-gati-on-;-97Z178-2.
68) Memorandum to Mr. Dan Donnelly, Mr. John Austin and Mr. Joseph
slayton trom Mr. Russell Sloboda and Mr. Kenneth G. Symms re:
Analysis of Presque Isle brine, 9/10/82. Attachments A, _B, C
and article are attached to the memorandum.
69) Memorandum to u.s. EPA Central Regional Laboratory from Mr.
Russell Sloboda re: analysis of Presque Isle brine, 9/10/82.
Attachments A, B, C, and article are attached to memorandum.
70) Site Safety Plan, 9/7/82.
71) Tentative Dispos:~ion, 8/28/82.
72) Memorandum to Mr. Ren Jen Sun from the District Chief re:
technical assistance to EPA, 8/25/82.
73) Memorandum to the file from Mr. Paul Horvatin re:
8/24/82.
trip report,
74) Memorandum to Mr. Curtis Ross from Ms. Andrea Jirka re:
environmental survey, 8/12/82.
75) Memorandum to Mr. Kenneth Syms from Mr. Gary Hahn re: brine
chemical analysis considerations, 8/11/82.
76) Report: A Report on the conceptual Sampling Schedule and
Procedures for the Gas Well at Beach #7 , 8/6/82.
77) Memorandum to Mr. Stephen Wassersug from Ms. Madonna McGrath
re: technical assistance, 8/4/82.
6
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78) Memorandum to Mr. Edward Shoener from the Environmental
Photoqraphic Interpretation Center re: disposition of request
for technical support, 8/3/82. .
79) Memorandum to Mr. curtis Ross from Mr. Clifford Risley re:
analysis of water samples, 8/3/82.
80) Memorandum to addressees from Mr. Paul Horvatin re: field
study, 8/3/82. Sample parameters are attached to the
memorandum.
81) Memorandum to Mr. Stephen Wassersug from Ms. Madonna McGrath
re: technical assistance, 8/2/82. Technical Support Notice is
attached to the memorandum.
82) Memorandum to Mr. Dan Donnelly from Mr. Paul Horvatin re:
transmittal of reports, 7/24/82.
83) Memorandum to the file from Mr. Anthony Kizlauskas re: trip
report, 7/23/82.
84) Letter to gentlemen from Mr. J. Dixon Garley re: bids,
7/21/82. Bidding information is attached to the letter.
85) Memorandum to Mr. Russell Enos from Mr. Frank Quiros re:
technical support, 7/20/82.
86) Letter to Mr. Timothy Weston from Mr. Thomas Voltaggio re:
sampling procedures, 7/16/82.
87) Letter to Mr. Howard Wein from Mr. Lawrence Starfield re: fish
kill, 7/15/82. Hammermill memorandum and Department of Health
memorandum are attached to the letter.
88) Memorandum to Mr. Roger Anzollin from Mr. Benjamin Lacy re:
implementation LOE task order, 7/7/82. Scope of work, letter
regarding procurement request and letter regarding information
transmittal, memorandum regarding Hammermill Injection Well
meeting, and memorandum regarding confirmation of meeting are
attached to the memorandum. .
89) Memorandum to Mr. J. Roy Murphy from Mr. Stephen Wassersug re:
request for USGS assistance, 7/2/82. Letter regarding request
for assistance, letter regarding gas well discharge, memorandum
regarding water quality results, memorandum regarding general
organics and project proposal are attached to the memorandum.
90) Memorandum to Mr. Ed Shoener from Mr. John Walker re: updated
testing and plugging specification, 7/1/82. Specifications are
attached to the memorandum.
7
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91) Memorandum to Mr. Stephen Wassersug from Mr. Thomas VOltaggio
re: strateqy for site, 7/1/82. Memorandum and meeting agenda
are attached to the memorandum.
92) Memorandum to Mr. Ed Shoener from Mr. John Walker re: analys~.s
of gas from Beach 7 well, 6/30/82. Gas analysis is attached to
the memorandum.
93) Memorandum to the record from Mr. J.R. Ritter re:meeting on
Hammermill Deep Well Injection Program, 6/23/82.
94) Letter to Mr. Edward Shoener from Mr. David Richards re:
ground water quality analysis report, 6/21/82. Tabulation is
attached to the letter.
95) Memorandum. to the tile trom Mr. Edward Shoener re: meeting for
furtherinvestiqation of site, 6/21/82.
96) Memorandum to Mr. Greene Jones from Mr. Robert Blanco re:
contamination of the Bass Island aquifier, 6/14/82.
97) Memorandum to addressees from Mr. Edward Shoener re: meeting
scheduled to discuss Hammermill's deep well injection pr~ram,
6/14/82. Agenda is attached to memorandum.
98) Letter to Mr. William Harmon from Mr. Edward Shoener re:
transmittal of comments on proposed RFP, 6/7/82. Comments and
memorandums are attached to the letter.
99) Memorandum to Ms. Linda Boornazian from Mr. Frank Quirus re:
review of RFP for plugging Presque Isle Beach gas well,
5/24/82. Comments are attached to the memorandum.
100) Memorandum to Mr. Sheldon Novick from Mr. Joseph Armao re:
information transmittal, 5/13/82. Routing and transmittal slip
is attached to the memorandum. Routing and transmittal slip,
memorandum regarding potential subsurface water contamination,
memorandum regarding filed trip, letter regarding request for
assistance, and news item are attached to the memorandum.
101) Letter to Mr. Leonard Koederitz from Mr. Charles Kleeman re:
transmittal of information regarding pressure decline
calculations, 4/30/82. Memorandum is attached to the letter.
102) Memorandum to Mr. R. Timothy Weston from Mr. Carlyle Westlund
re: plugging and sampling abandoned gas well, 4/26/82.
103) Memorandum to Mr. Ed Shoener from Mr. Charles Kleeman re:
pressure decline calculations, 4/15/82.
104) Report:
! Site Inspection of Presque Isle, 3/23/82.
8
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105) Biblioqraphy, qenerated 3/5/82.
106) Record of communication to Ray [illeqible] from Mr. Ed Shoener
re: hiqh school well samplinq, 1/3/82.
107) Letter to Mr. R. Timothy Weston from Dr. R.W. Brown re:
chemical analysis, 8/25/81.
108) Letter to Ms. Elissa Parker from Mr. Donald D. Davis re:
trees, 8/17/81.
109) Memorandum to Mr. William Forrey from Mr. William Harmon re:
abandoned qas well, 8/11/81.
110) Memorandum to Ms. Elissa Parker from Mr. James Nichols re:
tree mortality at Presque Isle state park, 8/10/81.
111) Memorandum to Mr. Robert Kinqman from the Minerals Section,
Bureau of Forestry re: efforts to secure a rotary rig
contractor, 4/6/81. Chronoloqical summary is attached to the
memorandum. .
112) Letter to Mr. Peter Duncan from Mr. R.W. Brown re: technlcal
data pertaining to the mill process at Hammermill, 3/26/81.
Letter dated 2/26/81, letter dated 11/14/80, conference
documentation, meeting documentation, Filtration of Spent
Pulping Liquor for Deep Well Injection, and journal article
are attached to the letter.
113) Erie County Health Department Home Well Survey, 1981.
114) Local climatological data--annual summary with comparative
data, 1981 .
115) Memorandum to Mr. Carlyle Westlund from Mr. Arthur Socolow
re: inspection of wells in vicinity of Presque Isle problem
well, 12/18/80. Analysis of well data is attached to
memorandum.
116) Inspection reports, 10/11/80-10/1/80.
111) Memorandum to Elissa Parker from Mr. Kenneth G. Young re:
review of Hammermill files to identify characteristics of
waste streams, 7/25/80. Analytical laboratories report
attached.
their
118) Report: Potential Hazardous Waste Site Identification and
Preliminary Assessment, 1/11/80. ---- ---
119) Memorandum to District Chief, Harrisburq, Pa. from Assistant
Chief, Doraville, Ga. re: water quality--presque Isle Beach
sample, 7/3/80.
9
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120) Letter to Mr. John T. Walker from Mr. John W. Carroll re:
review of BWOM files for 1962-1972, 7/3/80.
121) Letter to Mr. James B. Synder from M.N. Bhatla re: cleanup of
contaminated soil adjacent to old gas well at Beach #7, 7/1/80.
Maps and sample data are attached.
122) Memorandum to Mr. John T. Walker from Mr. carlyle Westlund re:
fluid analyses from Beach #7 well, 7/1/80.
123) Memorandum to Mr. Robert Allen from Mr. Paul Laskow re:
Presque Isle-Well Inspection Hazard Waste Site Enforcement,
6/20/80.
124) Report: Potential Hazardous Waste Site Identification and
Preliminary Assessment, 6/12/80.
125) Memorandum to J.T. Walker from Mr. vince White re: transmittal
of lab data, 5/23/80. Lab data attached to the letter.
126) Memorandum to Mr. John T. Walker from Mr. William Harmon re:
Weston Consultants recommendations on closing Beach #7,
5/14/80. -
127) Memorandum to Mr. James D. Lesher from Mr. John T. Walker re~
results of Weston's preliminary investigation of Beach #7 wel~
problems, 5/14/80.
128) Memorandum to Mr. James Lesher from Mr. John T. Walker re:
toxic wastes from Beach #7 well on Presque Isle, 5/6/80.
129) Letter to Mr. T.O. Andrews from Mr. Kenneth G. Young re:
transmittal of report and summary of analyses, 4/26/80.
130) Letter to Mr. William C. Forrey from Mr. John T. Walker re:
results of laboratory analysis of fluids flowing from unplugged
well at Beach 17, 4/1/80. Data and index attached to the
letter.
131) Memorandum to Mr. John T. Walker from Mr. William Forrey re:
agenda for meeting with BWOM, 3/19/80.
132) Memorandum to Carlyle Westlund from Mr. Michael Arnold re:
toxicity review--compounds found in fluid from well at Beach
#7, 12/6/79.
133) Memorandum to Mr. John T. Walker from Mr. William C. Forrey
re: more pollutants found in sulphur water flowing froim old
unplugged well at Beach #7, 11/27/79.
10
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134) Memorandum to regional huydrologist from subdistrict chief re:
Atlanta Central Lab--special analysis, 11/8/79. Additional
memorandums and lab information attached.
135) Memorandum to the record from Mr. David B. Richards re: visit
to Presque Isle, 11/1/79.
136) Chronoloqy of events and documents relating to Beach #7 well,
Presque Isle state Park, Pa., 10/79.
137) Memorandum to E. Fund from Mr. John T. Walker re: newspaper
articles on old unplugged well and new well, 9/19/79.
138) Letter to Mr. Kenneth Young from T.O. Andrews re: transmittal
of Evaluation of the Potential for Pulp Liquor Miqration ~
Seepaqe from ~ Presque !!.!.! state Park Gas Well, 7/19/79.
139) Handwritten notes on calculated bottom hole injection
pressures, 6/1/79. Article on calculation of friction and
treating pressures in pipe is attached.
140) Memorandum to Carlyle
papermaking chemicals
old well at Beach #7,
included.
W. Westlund from Mr. John T. Walker re:
and wastes in sulphur water flowing from
5/10/79. Attachments 1 through 8 are"
141) Data rock formations, 5/2/79.
attached to the letter.
Inspection reports are
142) Memorandum to Mr. Eugene Frund from Mr. John T. Walker re:
meeting with Hammermill Paper Company, 4/23/79. Data
information attached.
143) Memorandum to Mr. Eugene Frund from Mr. John T. Walker re:
recently acquired data and conclusions on source ot foul-
smelling fluid flowing from old gas well at Beach #7, 4/12/79.
144) Memorandum to Mr. John T. Walker from Mr. Robert G. Piotrowski
re: corrected well location, 3/1/79. Maps are attached to
the memorandum.
145) Memorandum to Mr. John T. Walker from Mr. Eugene Frund re:
foul-smelling seep at Beach #7, 1/19/79. Attachments 1 through
3 area attached to the memorandum.
146) Commonwealth of Pennsylvania Department of Environmental
Resources bidder's contract compliance instruction sheet,
12/13/77.
147) Task report, 10/24/72.
11
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148) Memorandum to carlyle W. Westlund from Mr. Robert W.
Stallbaum re: industrial wastes Hammermill, 9/8/72.
149) Letter to Mr. T.O. Andrews from Carlyle W. Westlund re: well
history data and plugging procedures, 8/8/72.
150) Letter to Mr. Carlyle W. Westlund from Hammermill Paper
Company re: history of wells and planned plugging procedures,
6/28/72. .
151) Letter to Mr. Carlyle Westlund from Mr. T.O. Andrews re:
requested information, 4/11/72.
152) Letter to Hammermill Paper Company from Commonwealth of
Pennsylvania re: I.W. permit no. 368I006, 7/7/70.
153) Letter to Hammermill Paper Company from Commonwealth of
Pennsylvania re: I.W. permit no. 36515, 1/7/70.
154) Letter to Hammermill Paper Company from Commonwealth of
Pennsylvania re: I.W. permit no. 368I006, 2/25/69.
155) Letter to Hammermill Paper Company from Commonwealth of -
Pennsylvania re: I.W. permit no. 36515, 2/25/69.
156) Letter to Hammermill Paper Company from Commonwealth of
Pennsylvania re: I.W. permit no. 3681008, 7/11/68.
157) Commonwealth of Pennsylvania Industrial Wastes permit no.
3333681008, 7/11/68.
158) Fact sheet:
7/2/68.
Industrial Wastes Hammermill Paper Company,
159) Oath of publication of notice, 6/14/68.
160) Application for treatment or discharge of industrial wastes,
5/24/68.
161) Application tor treatment or discharge of industrial wastes,
5/17/68.
162) Hammermill survey, 12/26/66.
163) Letter to Mr. Larry Miller from Mr. R.W. Brown re: sampling,
12/9/66. Excerpt from "Deep Well Disposal of Spent Hardwood
Pulping Liquor," by R.W. Brown and C.W. Spaulding, is attached
to the letter.
164) Report:
Well Report at Hammermill '1 Disposal !!!!, 8/23/63,
12
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165) Letter to Mr. Clayton Schulze from unknown re: deep well
disposal, 7/12/63. Report entitled Proposed Disposal of
Pulpin~ Wastes into Hammermill N0.1 Deep !!!!, and letter
reqard1nq deep well injection are attached to the letter.
166) Deleqation brietinq (undated).
167) List of pollutants from paper mill effluents (undated).
168) Report: Hammermill #1 Rate of Increase of Injection Front for
Equi-Distant Periphery (undated).
169) Flammability/reactivity and toxicity/carcinoqenity fact sheet
(undated).
170) Memorandum to Mr. Paul Horvatin from Mr. Roqer Claff re: lab
reports (undated).
171) Letter to oil and gas operators in northern Erie County from
Mr. John Ifft re: applications for drillinq permits (undated).
172) Application for Pre-Qualification of Compliance with the
Contract Compliance Requlations (undated).
173) Maps depictinq Presque site and surroundinq areas (undated).
174) Well monitoring notes taken by Mr. Ed Shoener (undated).
175) Letter to Mr. Ed Shoener from Mr. Art (illegible) re:
transmittal of well reports (undated).
176) Record of communication to Mr. Ed Shoener from Mr. John Walker
re: loq of pluqqinq (undated).
177) Technical specification for pluqqing well on Beach 7 (undated)
13
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REMEDIAL RESPONSE PLANNING
1) Report: Records Compilation Presque Isle State Park, Erie
PA, submitted by Versar Inc., 8/3/87.----
2) Report: Draft report Document List for Presque Isle Record
compiltion, Presque Isle State Park, prepared by Versar Inc.,
6/16/87.
3) Memorandum to regional adminstrators of EPA Regi~ns III and
VI from Mr. J. Winston Porter re: Twelfth Remedy Delegation
Report--Part One, 5/26/87.
4) Letter to Ms. Linda Boornazian from Mr. Harry P. Butler re:
trip report, 1/30/87. Trip report is attached to the letter.
5) Letter to Ms. Linda Boornazian from Mr. Harry P. Butler re:
health and safety plan, 12/5/86. Health and safety plan is
is attached to the letter.
6) Letter to Ms. Patricia Tan from Mr. Mark E. Gorman re:
comments on the October 1985 EPA report Summary of
Investigations and Recommendations for Further Action,
9/5/86.
7) Letter to Kathy from Pat re:
Millcreek Township, 6/13/86.
hydrogen sulfide gas release in
8) Note to Mr. Ed Shoener from Mr. Jim Rogers re: verification
that Mr. Rogers was informed that Mr. Shoener is project
officer, 4/17/86.
9) Letter report to Mr. Truman o. Andrews from Mr. John c. wright,
Jr. re: technical review of the October 1985 EPA report,
Summary of Investigations and Recommendations for Further
Action, 12/20/85.
10) Letter to Mr. Truman Andrews from Mr. Ed Shoener re: review of
report entitled Summary of Investigations and Recommendations
for Further Action, 10/24/85. Report is attached to the letter.
11) Memorandum to Mr. Roland Schrecongost from Mr. Jack Stanton re:
correspondence concerning Presque Isle NPL site, 6/28/85.
12) Letter to Ms. Heather Gray and Mr. Ed Shoener from Mr. Lawrence
E. Starfield re: submission of a final technical report
regarding the Presque Isle site, 3/8/85.
13) Letter to Mr. Truman o. Andrews from Mr. John C. Wright, Jr.
re: results of monitoring drilling activities at the East High
School gas well, 3/7/85.
14
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14) Letter to Ms. Heather Gray and Mr. Edward Shoener re:
submission of a final Presque Isle site report, 3/85.
report is attached to the letter.
15) Letter to Mr. Edward Shoener from Mr. Lawrence E. Starfield re:
contents of a pulping liquor sample at Presque Isle, 1/9/85.
the
Final
16) Memorandum to Mr. Edward Shoener from Mr. David B. Richards re:
laboratory analysis of an East High School gas well sample,
1/4/85.
17) Report: status of Investigations and Recommendations for
Further Action, by Edward Shoener, 12/84.
18) Memorandum to Mr. Rob Clemans from Mr. Edward-Shoener re: USGS
investigations, 11/16/84. Letter containing a cost analysis is
attached to the memorandum.
19) Letter to Mr. Lawrence Starfield from Mr. Edward Shoener re:
enclosed report and computer printouts, 10/26/84.
20) Briefing document, 10/17/84.
21) Letter to Mr. Edward Shoener from Mr. David E. Click re: a
memorandum to the record, 9/28/84. Memorandum is attached
to the letter.
22) Let~er to Ms. Heather Gray from Mr. James A. Rogers re:
contents of original injected pulping liquor, 9/12/84.
23) Report:
Evaluation of Neutrace/I Pulping Liquor, 8/31/84.
24) Memorandum to Mr. Edward Shoener from Mr. Bruce Molholt re:
toxicology of pollutants in seepage at Presque Isle, 7/11/84.
25) Letter to Mr. Edward Shoener from Mr. Arthur W. Hounslow re:
investigation on the possibility of any reactions between the
injection liquor and the formation water, 6/30/84.
26) Memorandum to Mr. Edward Shoener from Mr. Bruce Molholt re:
toxicology assessment, 6/29/84.
27) Letter to Mr. Ed Shoener from Ms. Gillian Cooper-Driver and John
Wilson re: technical assay for lignins and associated
phenolics, 6/14/84.
28) Report:
6/84.
Technical Assay for Lignins and Associated Phenolics,
29) Letter to Mr. Edward Shoener from Mr. Leonard F. Koederitz re:
simulations of the Presque Isle well employing a thickness of 75
15
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feet at Hammermill and Presque Isle, 5/11/84.
attached to the letter.
Simulations are
30) Letter to Mr. Ed Shoener from Mr. J. Russell McGregor, Jr. re:
the ground water in the Erie, Pennsylvania area, 5/7/84.
Letters and attachments from Weston Consultants to DER dated
7/1/80 are attached to the letter.
31) Memorandum to regional adminstrators, Regions I-X from Mr. Lee
M. Thomas re: interim procedures for selecting sites from the
national priorities list, 4/27/84.
32) Letter to Mr. Ed Shoener from Mr. Garry G. Ehrlich, Ph.D. re:
injection of waste sulfite pUlping liquors, 3/16/84.
33) Letter to Mr. Ed Shoener from Ms. Gillian cooper-Driver re:
transmittal of investigative report, 2/23/84. Report is
attached to the letter.
34) Letter to Mr. Ed Shoener trom Mr. Arthur W. Hounslow re:
method ot analysis, 2/11/84.
35) Memorandum to the record trom Mr. Jack Felbinger re: synopsis
of USGS participation in well sampling, 1/19/84. Tables are
attached to the memorandum.
36) Letter to Mr. Thomas Eichler from Mr. Richard Brown re:
meeting, 1/16/84.
site
37) Letter to Mr. Ed Shoener from Mr. Garth Glenn re: transmittal
of report, 1/11/84. Related memorandum and report are attached
to the letter.
38) Letter to Ms. Heather Gray from Mr. John Wright re:
transmitted, 1/11/84.
report
39) Memorandum to Mr. Stephen Wassersug from Mr. Edward Shoener re:
expert review of the Presque Isle project, 1/11/84.
40) Letter to Mr. Lawrence Starfield from Mr. Ed Shoener re:
transmittal of technical documents, 12/29/83. Analytical
report is attached to the letter.
41) Memorandum to the file from Mr. Ed Shoener re:
of plant chemistry and phenols, 12/19/83.
42) Letter to Mr. Stanley Laskowski from Mr. T.O. Andrews re:
meeting between U.s. EPA and Hammermill, 12/12/83.
technical assay
43) Letter to Mr. Thomas Eichler from Mr. Richard Brown re:
listing, 12/6/83.
NPL
16
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44) Letter to Mr. Donald Senovich from Mr. Edward Shoener re:
Angerman Associates proposal, 11/4/83.
45) Letter to Ms. Heather Gray from Mr. James Rogers re:
monitoring well, 10/20/83.
proposed
46) Letter to Mr. Don Senovichfrom Mr. Thomas Angerman re:
subcontract agreement, 10/16/83. Qualifications, consulting
agreement, exhibit A and exhibit B are attached to the letter.
47) Letter to Mr. Ed Shoener from Ms. Gillian Cooper-Driver re:
transmittal of report, 10/19/83. Technical Assay of Plant
Chemistry and Phenols is attached to the letter.
48) Letter to Mr. Sheldon Novick from Mr. Carroll Wills reo:
results of analytical support tor the Wayne School
investigation, 10/18/83. Results are attached to the letter.
49) Letter to Mr. Edward Shoener from Mr. David Richards re:
technical data, 10/12/83.
50) Letter to Mr. Lawrence Starfield from Ms. Heather Gray r~:
Dr. Brown's analysis of spent NSSC pulping liquor, 10/12/83-.
51) Letter to Mr. Edward Shoener from Mr. David Richard re: core
permeability versus in situ drill stem testing permeability,
10/12/83. Ferron sandstone fact sheet, RGE graph, and ground
water system report are attached to the letter.
52) Letter to Ms. Heather Gray from Mr. Lawrence Starfield re:
transmittal of Dr. Brown's memorandum, 10/4/83.
53) Fact sheet re: deep subsurface conditions at Presque Isle
No.7 well, 9/22/83.
54) Memorandum to Mr. Howard Wein from Mr. John Walker re:
Street well, 9/16/83.
55) Letter to Mr. Edward Shoener from Mr. David Richards re: Wayne
School District well, 9/16/83. Tables, tabulation, chain of
custody record, maps, letter of transmittal, Weston letter,
fluid analysis summary, and organic analyses are attached to
the letter.
Wayne
56) Letter to Mr. David Click from Mr. Edward Shoener re:
of gas well, 9/14/83.
drilling
57) Letter to Mr. Ed Shoener
subcontracting, 9/7/83.
Review of the August 15,
the letter.
from Mr. Garth Glenn re: NVS
Letter report entitled Technical
1983 Penn DER Report is attached to
17
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58) Letter to Mr. David Noble from Mr. Bruce Laswell re:
estimates for long-term remedial measures, 9/2/83.
59) Record of phone conversation to Tom Heckran from Ms. Heather
Gray re: drilling program, 8/31/82.
cost
60) Record of phone conversation to Mr. Jim Rogers from Ms. Heather
Gray re: Hammermill's reluctance to drill wells, 8/29/83.
61) Record of phone conversation to Mr. Chuck Robie from Ms.
Heather Gray re: drilling, 8/25/83.
62) Record of communication to Mr. Ed Shoener from Mr. Jim Rogers
re: drilling at WaYne Street and Vincent High School, 8/24/83.
63) Letter to Mr. Edward Shoener and Mr. John Walker from Mr. John
Wright re: transmittal of testing and sampling plan, 8/22/83.
Testing and sampling plan is attached to the letter.
64) Letter to Ms. Heather Gray and Mr. Howard Wein trom Mr.
Lawrence Startield re: sampling at Erie School District wells,
8/19/83.
65) Letter to Ms. Heather Gray and Mr. Howard wein from Mr.
Lawrence Starfield re: gas well in the school district,
8/15/83.
66) Report: Beach 2 Well Problem: Presque Isle State Park and
Its Connection with Hammermill's Waste Injection Wells, by
Mr. John T. Walker, 8/15/83.
67) Letter to Heather Gray and Howard Wein from Lawrence E.
Starfield re: drilling specifications and matters relating to
a sampling operation, 8/15/83.
68) Memorandum to Kathryn Hodgkiss from Ed Shoener re: sole source
contract for well drilling on Hammermill Paper Company,
8/11/83.
69) Busan analysis proposal, 8/4/83.
70) Letter to Mr. Edward Shoener and Mr. Howard J. Wein from Mr.
James A. Rogers and Mr. Lawrence E. Starfield re: a request
for Hammermill to summarize its position regarding the
drilling of a monitoring well on its property, 8/3/83.
71) Letter to Mr. Ed Shoener from Mr. Gary W. Wojcik re: an
extension at the submission date' for the Presque Isle site
dratt remedial action master plan, 8/2/83.
18
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72) Letter to Mr. Ed. Shoener form Mr. Howard J. Wein re:
transmittal of copies of permits for wells, 8/1/83.
Copies are attached to the letter.
73) Record of communication to Mr. Ed. Shoener rom Wein, Roger and
Starfield re: Presque Isle/Hammermill, 7/5/83.
74) Letter to Ms. Wendy Gordon from Mr. Edward Shoener re:
transmittal of requested materials, 6/30/83.
75) Letter to Mr. Edward Shoener rom Mr. Leonard Koederitz re:
pressure flow at Presque Isle well, 6/30/83.
76) Letter to Mr. Russel H. Wyer from Mr. James A. Rogers re:
Proposed National Priorities List, 6/27/83.
77) Letter from Mr. Truman o. Andrews from Mr. John C. Wright, Jr.
re: transmittal of technical evaluations, 6/24/83.
78) Letter to Mr. Edward Shoener from Mr. James A. Rogers re:
listing of documents supplied to Ms. Marsh of ABC, 6/2~/83
a
79) Letter to Mr. Russel H. Wyer from Mr. James A. Rogers re:
Proposed National Priorities List, 6/21/83.
80) Letter from Mr. Truman O. Andrews from Mr. John C. Wright, Jr.
re: a technical review of EPA documents on Presque Isle well
project, 6/20/83. Listed attachments are attached to the
letter.
81) Memorandum to Linda Young Boornazian from Mr. Eeward Shoener
re: subcontract for well drilling for the Presque Isle site,
6/13/83. Recommended specifications are attached to the
memorandum.
82) Letter to Mr. Russel H. Wyer form Mr. James A. Rogers re:
Proposed National Priorites List, 6/10/83.
83) Letter to Mr. Truman o. Andrews form Mr. John C. Wright, Jr.
re: technical review of EPA documents released May 19, 1983,
6/8/83.
84) Letter to Dr. Edward Shoener form Mr. Karl J. Niklas re: the
Monsanto Research Corp. 's analysis of the Beach #7, Presque
Isle fluid, 6/8/83.
85) Letter to DR. Edward Shoener form Mr. Karl Niklas re:
qualifications of Dr. Gillian Cooper-Davis, 6/8/83.
86) Letter to Mr. Edward Shoener form Mr. Leonard Koederitz re:
permeability variations studied at Presque Isle well, 6/3/83.
19
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87) Quality assurance work plan for Presque Isle, Pennsylvania
Remedial Action Master Plan,5/31/83.
88) Memorandum to Mr. Edward Shoener forn Mr. Charles Kleeman re:
review of Hammermill injection proam under proposed EPA UIe
requlations, 5/26/83.
89) Letter from Mr. Truman O. Andrews from Mr. John C. Wright, Jr.
re: technical review of EPA documents released APRIL 23, 1983,
5/25/83.
90) Letter from Mr. Ed Shoener from Mr. Kevin G. Carroll re:
(Bass Island) brine, 5/25/83.
91) Letter to Mr. Wassersug from Hammermill Paper Company re: a
request that Hammermill Paper Company drill a well in order to
provide EPA with a sample of injection waste, 5/4/83.
Akron
92) Letter to Mr. Todd E. Gulick from Mr. James A. Rogers re:
Hammermill Paper Company ~ Ruckelshaus Civil Action,
No. 830575, 5/24/83.
93) Letter to Mr. Ed Shoener from Mr. Leonard Koederitz re:
pressure analysis for the Presque Isle study, 5/23/83.
Data are attached to the letter.
the
94) Memorandum to Mr. Ed Shoener from Mr. Daniel K. Donnelly re:
Presque Isle samples, 5/19/83.
95) Letter to Mr. Kevin G. Carroll from Mr. Ed Shoener re: Bass
Island (Akron) brine, 5/18/83. Well reports are attached to
the letter.
96) Record of phone conversation to Ms. Heather Gray from Mr. Jim
Rogers re: Hammermill-Presque Isle, 5/16/83.
97) Memorandum to Mr. Ed Shoener from Mr. John T. Walker re:
acetate-formate ratio in Bass Islan 5/9/83. Article on "The
Chemistry of Cellulose and Wood" is attached to the memorandum.
98) Letter to Dr. Richard Brown from Mr. Stephen Wassersug re:
request for HJammermill to drill a monitoring well, 5/8/83.
Recommended specifications are attached to the letter.
a
99) Handwritten notes of Presque Isle, 5/5/83.
100) Biographical data on Leonard F. Koederitz (undated).
20
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COMMUNITY INVOLVEMENT
1)
Report:
12/86.
Community Relations Plan Presque Isle Site,
2)
Report: The Pesque Isle Superfund Site, by Mr. T.O.
Andrews, 10/26/85.
3)
Letter of transmittal to Mr. Jeff Dunckel from Mr.
Kenneth Miller, 8/10/83.
Letter to Mr. Dale,Willats from Mr. Robert J. Wellington
re: level of barium in the drinking water, 7/18/83.
Chemical samples are attached to the letter.
4)
5)
Letter to Ms. Fabienne Marsh from Mr. Ed Shoener re:
different opinions about the Presque Isle site, 7/31/83.
Press release and letter about proposed listing of
Presque Isle to the National Priorities list are attached
to the letter.
6)
Letter to Mr. Roy Ragar From Mr. Ed Shoener re: trans-
, mittal of sample results, 7/12/83. Copy of letter sent
to Mr. John Johnson and Mr. Robert Hermann.
7)
Letter to Mr. R.P. Overdoff from Ed Shoener re: samples
collected from wells, 7/12/83. Copy of the letter sent
to Mr. Albert Dean, Mr. Kenneth Evans, Mr. Arthur Beatty,
Mr. Elmer Brown, Mr. Dale Willats, Ms. Dorothy Gehrlein,
and Mr. James O'Hara.
8)
Fact sheet regarding status at Presque Isle site, July
1983 .
9)
Letter to Mr. James A. Rogers from Mr. Ed Shoener re:
response to a Freedom of Information Act request,
6/28/83.
10) Report: Summary of Comments and Responses on the Scoring
of the Hazardous Ranking syst~ April 1983.
21
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~ SUMMARY
1) Memorandum to Mr. Russell Sloboda from Ms. Linda R.
Krokenberqer re: sample numbers 847C-7 through 847C-13, and
847C-1 through 847C-5, 11/22/83.
2) Memorandum to Mr. Ed Shoener from Mr. John T. Walker re: lab
analyses of Beach Well Seven and the Bass Island formation,
4/7/83. Lab ID numbers 2320909, 2320910, 2348006, 2348003,
4-11110, 4-111101, 8232825, 4-101881, 4-101880, 4-102882,
4-102382, 4-102383, 4-102388, 4-102384, 4-102784, 4~102987,
4-110490, 8233058, 4-110589, 4-110927, 8232626, 4-110928,
8232627, 4-111102, 8232826, 4-111103 are attached to the
letter. .
3) Memorandum to Mr. Sheldon Novick from Ms. Carroll Wills re:
results of analytical support for the Presque Isle
investiqation, 2/22/83. Groundwater analysis briefing, sample
numbers 3-13558, 3-13754, 3-13778, 3-13806, 3-13849, 3-13871,
3-13883, 3-13759, 3-13788, 3-13822, 3-19119, 3-19120, 3~13759,
3-19115 throuqh 3-19118 b, 3-19119 through 3-19122 c,
Tables 1-5, and Figures A-L are attached to the letter.
4) Letter to Mr. Donald J. Zimmer from Mr. Russell L. Crawford rL.
sample analysis, 1/28/83. Sample numbers 2611014, 2611015,
2611013, and 2611016 are attached to the letter.
5) Memorandum to Mr. Ed Shoener from Mr. Daniel K. Donnelly re:
enclosed data reports, 1/20/83. Information on sample numbers
821112-77-80, 821214-03,04 are attached to the memorandum.
6) Memorandum to Mr. Daniel K. Donnelly from Mr. Rick Dreisch, re:
Presque'Isle samples, 1/18/83. Information on sample numbers
821112-77-80, 821214-03,04 are attached to the memorandum.
7) Memorandum to Mr. D.E. Erdman trom Mr. Earl Anthony re:
quality sample tor tannin and liqnin, 1/18/83.
water
8) Letter to Mr. Ed Shoener from Mr. Garth Glenn re: attachments
of rough calculations of H2S concentrations, 1/11/83.
9) Desk memorandum to Mr. Ed Shoener from Mr. J. Walker re:
attached samples numbers 161-256, 124-123, 312-159, 1/7/83.
10) Memorandum to Mr. Daniel K. Donnelly from Mr. John Austin, re:
GC/MS analysis of superfund samples 821101-01, 821112-77-78,
821214-03-04, 821108-38-39 from Presque Isle, 1/6/83.
Information on the above sample numbers is attached to the
memorandum.
22
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11) Memorandum to Mr. Ed Shoener from Mr. Daniel K. Donnelly re:
volatile and extractable organics data reports, 12/13/82.
Letters and sample data pertaining to sample numbers
821026-01-03, 821108-38,39 are attached to the memorandum.
12) Record of communication to Mr. Ed Shoener from Mr. Harry Madril
re: status of the M~S. well, 12/12/82.
13) Letter to Mr. Daniel K. Donnelly from Mr. John Austin re:
Superfund Presque Isle gas well Number Seven, 821019-01-02,
821010-01, 11/26/82. Sample data pertaining to above sample
are attached to the letter.
14) Letter to Mr. Daniel K.Donnelly from Mr. John Austin re:
GC/MS analysis of Superfund samples 821026-01-03, 11/24/82.
Information regarding above samples, quality control sheet,
letters, and sample data for sample numbers 821101-01,
821019-01-02 are attached to the letter.
15) Laboratory analytical data for lab ID 2348006, 11/12/82.
16) Laboratory analytical data for lab ID 2320909, 10/11/82.
17) Letter to Linda Boornazian from Daniel K. Donnelly re: Presque
Isle analytical results, 1/12/82. Letters to Mr. Daniel K.
Donnelly from Mr. John Austin regarding sample number 81120216,
18, 21 are attached to the letter.
o
18) Record of communication to Mr. Ed Shoener from Mr. Garth Glenn
re: H 2 S concentration, 1/3/82. Information from sample
numbers 312-159, 319-03666, 161-256, 193-02932, 124-123,
126-02548 is attached to the record of communication.
19) Memorandum from Mr. Rick Dreisch to Mr. Daniel K. Donnelly
re: Presque Isle Purgeable Organics Analysis by FSCC/GC/MS,
12/15/81. Results from sample numbers 811202-17, -19, -20,
-22 are attached to the memorandum.
20) Well record from Commonwealth of Pennsylvania, 10/80.
21) Notes from Mr. Ed Shoener regarding pollution at Presque
Isle site, 1977.
22) Formation data, 8/28/64.
23) Well record from Commonwealth of Pennsylvania, 3/28/63.
24) Memorandum to Hammermill Paper Company from Mr. T.J. Powers
re: Bass Island brine samples, 3/12/63.
25) Lab data report to Dowell, Incorporated, 3/6/63.
23
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26) Tulsa laboratory report, 2/28/63.
27) Lab data report to Dowell, Incorporated, 2/18/63.
28) Spinner supplementary report by Dowell Industrial Service,
2/18/63.
29) Letter to Mr. Gray from Mr. Robert Thompson re:
drilling, 12/28/56.
30) Well data sheet for city of Erie #1 Presque Isle gas well,
9/9/10.
gas
31) Hammermill Paper Company's waste disposal wells (undated).
32) Case summary quality control reports released by Linda R.
Kiokenberger (undated).
33) Plugqing ot qas well on Beach No.7 (undated).
24
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SITE SPECIFIC GUIDANCE DOCUMENTS
1) "The Lower Depths," by Michael Brown, The Amicus Journal,
winter 1986.
2) "Laws of Pennsylvania Bureau of Oil and Gas Management,"
1984.
3) "Geochemistry and Subsurface Characterization Related to
the Transport and Fate of Inorganic Contaminants," by
Arthur W. Hounslow, Environment and Solid Wastes, 7/83.
4) "Plume Investigation Lake Erie Pennsylvania," by Susan E.
Titus, . 5/82. .'
5) "Chemical Diversification and Evolution of Plants as Inferred
From paleobiochemical Studies," by Carl J. Niklas, 19~2.
6) "Ground-Water Geochemistry: Arsenic in Landfills," by Arthur
W. Hounslow, Ground Water, JUly-August 1980.
7) "Evidence for Lignin-Like Constituents in Early Silurian
(Llandoverian) Plant Fossils," by Karl J. Niklas, et aI,
Science, 7/18/1980.
8) "H2S Produces Kick Complications," by Neal Adams, 3/80.
9) "The State Water Plan: SL::Jbasin 15," Prepared by Office o,f
Resources Management, 12, ;9.
10) "Fracture-Controlled Production," Composition by John R.
Kostura, ~ al, 1977.
11) "Lithium in Clayey Rocks of Pennsylvania Age, Western
Pennsylvania," by Harry A. Tourtellot, Lithium Resources and
Requirements ~ ~ Year 2000, 12/76.
12) "Semi-Chemical Spent Liquor Treatment Methods," 4/16/68.
13) "Precambrian of Northwestern Pennsylvania," 1968.
14) "Subsurface Disposal of Liquid Wastes in ontario," by D.D.
McLean, 1968.
15) "Deep-Well Disposal of the Spent Hardwood Pulping Liquors,"
by R.W. Brown, at aI, 12/66.
16) "Subsurface Disposal of Acid Mine Water by Injection Wells",
by Robert Stefanko, et aI, 8/10/65.
25
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17) "Deep well Disposal of spent Pulping Liquors," by C.W.
spaldinq, et al, 5/65.
18) "spent Sulfite Liqour: The Pearl-Benson, or Nitroso,
Method for the Estimation of Spent Sulfite Liquor concen-
trations in Waters," by Vincent F. Fellicetta, et al,
6/63 .
19) "Pulping and Paper Chemistry and Chemical Technology,"
1960.
20) "The Geology of the oil Regions of Warren, Venango,
Clarion and Butler Counties," by John F.Caill, 1880.
21) "Uses of Ammonia and compounds in Papermakinq,"
(undated) .
22) "Evaluation of Geochemical Analysis of Well Water/Seepage
from the Presque Isle Superfund Site," by Karl J. Niklas
(undated) .
23) "Overburden Minerology as Related to Ground Water
Chemical Changes in Coal strip Mining," by A.W. Hounslow
et al, (undated).
24) "Handbook of Natural Gas Engineering," (undated).
26
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G£r-:EkAL GUIDANCE ro:tJ.'iE!~TS *
1) "Pr
-------
u.s. ENV:~ONMENTAL PROTECTION AGENCY
REGION III
PRE~I,J;';.';' ISLE SUPERFUND SITE
RESPONS I VENESS SUMMA..~'!
PUBL IC COfv1'.M;:NT PERIOD ON THE REMED r.:..=.. :NVEST IGAT:ON/
?EASIBIL:TY S~UDY 2E?C~T
AC'G:JS:' 12, 1987 t:::; SC:?TE~BC:~ 13, 1987
-------
TAB L :::
CON TEN T S
o F
Section
INTRODUCTION
1.0
BACKGROUND
.:l..
3.
Site History
'Community Relations
2.0
S~~Y OF PUBLIC COMMENTS
.:l..
3.
Comments on the Proposed Remedy
Other Questions and EPA Responses
Position on the remedial
alternative
Timeframe for public comments
on the RIfFS
Possible NPL deletion
Site status
APPEND IX .; - ?:esque
Isle Superfund Site Fact Sheet
APP~NDrx 3 - P~blic~eeti~g Attendees
~?P:::~D:X C - ?~blic Meeting 7ranscript
~?PENDrX J - ~rit~en Comments
Page
Number
i
1
.1
2
4:
4
4:
4
6
6
7
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INTRODUCTION
In acco~dance with the U.S. Environmental Protection'
Agency's Community Relations policy and guidance, the EPA
Region III Office held a public comment period to obtain
comments on the recommendations of the Remedial
Investigation/Feasibility Study (RI/FS) prepared for the
Presque Isle Superfund site in Erie County, Pennsylvania.
In conjunction with the comment period, a public meeting was
held at the West Lake Jr. High School Auditorium in
Mi llcreelt Townshi.p, Er ie County, Pennsylvani.a on August 13,
1987. Both the comment period and meetina ~:are announced by
public notices published in local Erie newspapers.
The following responsiveness summary was. prepared by
Booz, Allen & ~amilton, Inc., a subcontractor to Camp,
D~esser & McKee, Inc., under contract to Region III to
provide community relations support. The ~ite history
section of this summary is taken largely from a site fact
sheet that was developed as part of the Region's community
relations activities and was distributed at the public
meeting. The summary of public comments was developed from
written comments received by Patricia Tan during the public
comment pe~iod and oral statements made a~ the public
meeting. Comments and questions are organized by issue
area. This summary does not repeat the comments verbatim.
A verbatim t~anscript of the public mee:~~g proceeding was
prepar~c by a court reporter present at the meeting. The
::anscript is included as Appendix C. W(itten comments
received by ~PA will be placed in the public record.
.;
.
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1.0
BACKGROUND
A.
Site History
The Presque Isle site is located on a peninsula which is
known as the Presque Isle State Park near the City of Erie,
in Erie County, Pennsylvania. The site area includes an
abandoned gas well known as the Presque Isle Beach No.7
well and its surrounding, contaminated area. The
surrounding area is comprised of a portion of an underground
geologic formation which is known as the Bass Island
Formation. Property on which the Presque Isle Beach No.7
well is located is owned by the Commonwealth of
Pennsylvania. The main use of the areas adjacent to the
site is for recreation.
Presque Isle Beach No.7 well was drilled by the City of
Erie in 1910 for use by the City Waterworks. It extended
3,570 feet through the Bass Island Formation and into the
Medina Formation, an underground formation at a lower
depth. In the 1920s, the well was abandoned without
plugging and covered by a concrete road surface that was
later covered with sand. In 1976, after numerous complain~s
from park visitors abou~ a foul-smelling odor in the Beach
No.7 parking lot, the Erie County Health Department filed a
complaint with park officials. The Coun~y Health Department
noted a seep near Beach No.7 well that Nas discharging a
noxious, hydrogen sulfide-bearing, black liquid.
In March 1979, the Pennsylvania Depar:men: of
Environmen~al Resources (PADER) uncovered :he wel: to
inves~igate complaints that the oaors were getting Norse.
The well was identified as the source of the discharge and
was equipped with a bleed valve a~d pressure gauge to
control discharge. PADE~ permanently plugged t~e 3ass
Island Formatio~ Nit~in the well ~n October 1982.
Investigations co~ducted at that time determined that no
healt~ hazards Nere present as a result of the seepage that
had already taken place.
P.~ER contacted ~?A s ~egi~n ~r: office to assist i~
sampling during tie Ne~L ~i~qg:~g in :~e =~l: of 1982.
After subsequent ~!:'l:==r'_~en:al sa!'!!p::.r:~, :::e ?resqt:.e :s:e
s:te'Nas placed C:l ::?:'. ::; ~ja;::'G::a::' ?r:~J:':.-:.es :":..s: ()IP!:..) , a
. . f .. . . - . d .
~:st 0 nazarcous Nas:e s::es ;:ar;etec :~r act:cn un eJ:' :~e
Superfund program, ::l September 1383. ~1ascns cited Nere
concer~s t~at tie sa~e E:uic ~igh~ te seepi:lg =r8m 8~ter
abandoned gas wells, of similar age and cons~=ucticn, in the
area.
-1-
-------
Subsequent investigations have revealed that the
discharge released hydroge~ sulfide gas into the atmosphere
and other hazardous substances into the soil and shallow
ground water.. Both PADER and EPA have sought to define the
source of the discharge and the potential for similar
discharges in the Erie area. The central issue of their,
investigations has been whether the discharge is a natural
phenomenon or if it was relat:d to the deep-well injection
by the Hammermill Paper Company of approximately 1.1 billion
gallons of spent pulping liquor into the Bass Island
Formation between 1964 and 1972.
The results of all studjes conducted on the Presque Isle
site to date have been analyzed in the RI/FS Report titled
"Summary of. Investigations and Recommendations for Further
Action" (Schoener-EPA) publi~:~ed in October 1985. Available
chemical data provide ambiguous information about the source
of the discharge and suggest that resolution of these
ambiguities will be difficult. Investigations, however,
have determined that the discharge at Presque Isle Beach
No.7 well was an unusual event, and that the threat to the
public was eliminated when the Bass Island Formation within
the well was permanently plugged in 1982.
Based on these investigations, EPA and PADER are
proposing to adopt a minimum action approach, as outlined in
the RI/FS recommendations. The RI/FS Report recommended
that the minimum action approach consist of two actions:
1)
Notify local oil and gas drille~s that a hydrogen
sulfide-bearing brine is present in the Bass Island
Formation, and that drillers should be prepared to
seal wells in the formation if a hydrogen sulfide
release occurs
2)
Monitor oil and ga~ wells drilled through the Bass
Island Formation for high pressures and the
occurrence of hydrogen sulf ide (" b lack water") .
At the present time, EPA, in conjunction with PADER, has
determined that no further remedial measures are appropriate.
B.
Community Relations
In meeting its ;mblic outreach cesponsibilities under
the Superfund program, E?A initiat~d sevecal community
celations activities. A draft Conrounity Relations Plan was
prepared and issued in December 1984. EPA also established
information repositories for the site at: the Erie County
Public Library, Presque Isle Branch; the Erie County Health
Department; and the Presque Isle State Park Research
Library. Interes~ed persons can review reports and other
site information at these repositories.
-2-
-------
] --
A sit~fact sheet also was developed and distributed at
a public information meeting held to obtain public input on
the proposed remedy In Millcreek Township, Pennsylvania on
August 13, 1987. A copy is shown in Appendix A. A list of
attendees at, and a transcript of, the meeting are provided
in Appendices a and C, respectively... .
The public comment period ran from August 12, 1987,
through September 18, 1987.
-3-
-------
2.0
SUMMARY OF PUBLIC COMMENTS
A.
Comments on the Proposed Remedy
Public ccmments on the proposed remedy were taken during
the publi~ meeting as well as throughout the comment
period. Fourteen people attended the meeting and four
submi tted wr i ttQl.l comments. One respondent represented a
citizens' .group formed to address the local environmental
issues and one the local branch of a national environmental
group.
One local respondent. expressed support for the proposed
remedy, based on a review of the findings of the RI/FS
Report and the aba~ement of hazard at the site due to
plugging the well. Representatives of the Hammermill Pape~
Company also supported the proposed minimum action remedy
for the site because there has been no evidence to indicate
any recent seepage from the well, nor to show that the site
currently presents ~ hazard to public health or the
environment.
The local environmental group representative maintained
that the decision was premature, since there may not have
been sufficient studies to ascertain the extent of hazard
posed by the site now, and because a natural phenomenon such
as an earthquake could cause another seepage incident. He
requested an extension of the public comment period on the
remedy to allow his group to conduct independent studies of
the site and to review existing material contained in the
information repositories.
B.
Other Questions and EPA Responses
Following is a concise summary of specific questions and
comments raise~ by the public during the comment period.
They are grouped by topic.
Position on the Remedial Alternative
R.
A citizen asked who will be responsible for
monitoring the oil and gas well drillers, which
will be a part of the reccmmended remedy.
EPA stated t Lat that has not yet been decided, but
will be giv~1 further considerat:on as part of the
remedy.
Q.
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Q.
R.
The representative of the local environmental
organization asked whether oil and gas well
- drillers have been notified of the presence of
black water in the Bass Island Formation. He
stated that this recommendation was made in 1985.
and something should be done about it soon. .
cPA resDonded that this is a recommendation of the
RIfFS. -It has not yet been implemented, but that
the Agency is working toward that and will put this
action into effect after the remedy has been
selected.
Comment: The environmental representative responded that
so~eone must be made responsible for coordinating
chis action.
Comment:
Comment:
Comment:
Comment:
A private citizen expressed his support for the
recommended remedy, even though the site is located
in an environmentally sensitive area. He based
this opinion on the evidence presented in the RIfFS
Report that the hazard has been eliminated.
The environmental representative commented that he
was concerned that it was prema:ure to implement
the proposed remedy. He pointed out the fact that
a natural disaster, such as an ~arthquake, could
create new potential for contam:~ation, and was
concerned that EPA seemed to be rushing to
implement this action after a period of little
action.
A Hamme~mill representative stated that he also
supported this action. Evidence indicates that the
site does not currently pose a hazard and no recent
seepage has been detected there. A letter dated
August 28, 1987, f~~m Ha~mermill again reaffirmed
this position.
I:1 a ~e~':e: -=.ated 'se~':e:!'.te: L3, 1?87, ~ ~.:cal ji~h
schoo: :eacher a;;raved :~e ~!/?S ccnci~sic~. She
also ~gges':ed ;er:cdic ~oni':or:~g ~: Ne:ls, ~rour.d
water, and soi:s shG~~d :je si:e je removed :rom
the ~PL.
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Comment: A written comment from two private citizens urged
EPA to consider only a complete and final cleanup
of this site.
R. EPA feels that at the present time no further
response actions are necessary, based on remedial
investigations performed by both EPA and PADER.
Timeframe for Public Comment on the RI/FS
Comment: The representative of the local environment:a1 group
stated that the Erie County Environmental Coalition
is formally requesting an extension of the comment
period, due to the volume of the supporting
documentation. He stated that the group had
obtained people to do computer modeling for the
site and other studies, and had been unaware of
some of the site investigations and documentation.
The site is also the subject of a great deal of
interest in the scientific community and requires
more time for comment on the proposed actions.
R. EPA representatives suggested holding a meeting in
the Erie area or the Region III Office during the
comment period to provide interested groups an
opportunity to obtain site information. They
stated that they had a records compilation
completed to help the public review Presque Isle
documentation, and would investigate the
possibility of extending the public comment period
on the remedy for one week to ten days.
Comment: A representative of Hammermill registered a formal
objection to the request for additional time in the
comment period, since site records had beer, in
existence and open to the public for over seven
years.
Possible MPL Deletion.
Comment: A private citizen voiced his agreement with EPA's
recommendation to delete the site from the National
Priorities List, since there is r.o evidence of
recent leais at the site and it appears to present
no hazard.
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Comment:
R.
The representative of the local environmental group
stated that the 30-day review period is not enough
- time to look at deleting the ~ite. He pointed to
th~ Butler Tunnel site as an example of a site that
had been on the NPL, was deleted from the list,. and
was later out back on, and stated that there ii a
similar possibility at the Presque Isle site.
EPA replied that the Agency is not currently
looking at deleting the site from the NFL, and
explained that the public comment period on the
proposed action is separate from site deletion.
Site Status
Comment:
Q.
A private citizen stated that on a recent visit to
the site he had noticed that the pressure guage had
a reading of 25 psi, and asked whether this was due
to natural gas or hydrogen sulfide gas pressure.
EPA responded ~hat someone would check the gauage
reading as a result of the comment, but tha~ the
most recent reading noted was 0 [zero]. The
pressure existing currently in the Beach No.7 well
is a result of natural gas production, which is
metered by the State Park office.
R.
Q.
A residen~ asked who is now re~?onsible for
moni~ori~g che well for natural gas or hydrogen
sulfide si~ce on a recent visit ie had decected ~he
odor o£ ~ac~ral gas near the well.
R.
EPA explained chat the well is moni~ored on a
routine basis by PADER. No leaks have been found
at any time.
A cons~l:anc for Hamrner~ill who Mas present at the
well plugging operation sta~ed t~at t~e ~ell ~as
cemented uo to 900 feet, and all formations were
closed. ~;y ~eak =etectec ~c~ i~ the area is
probably d~e to ~atural gas.
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APPENDIX A
~ lJJ IP m:]I{ IF lJJ N rID IP JR (Q) CG JR A 00
IFACT ~IFJI&IELr
aEPA
Regi9n III
PRESQUE ISLE SITE
RECOMMENDATIONS OF THE REMEDIAL
INVESTIGA TION/FEASIBILITY STUDY
AUGUST 1987
INTRODUCTION
This fact sheet presents proposed actions that the U.S. Environmental Protection Agency
(EP A) and the Pennsylvania Department of Environmental Resources (P ADER) may take to
respond to releases from the Presque Isle hazardous waste site in Erie County, Pennsylvania.
EPA has prepared a Remedial Investigation/Feasibility Study (RIfFS) report to
evaluate: 1) the extent of the contamination problem at the site, 2) the potential risks to public
health and the environment. and 3) the steps to be taken to correct the problem. EPA is seeking
public comment on the remedy recommended by the RL'FS report prior to EP A and P ADER
decision-making.
Following a brief description of the site and itS history, the proposed remedy is described.
Finally, an explanation of future action <; :It the site is given. Words in the text that appear in bold
face are defined in the glossary at the e~d of this fact sheet. .
SITE DESCRIPTION AND HIST~) RY
The Presque Isle site is located, (\ a peninsula which is known as the Presque Isle State
Park near the City of Erie, in Erie Counry, Pennsylvania (see map on the following page). The
site area includes an abandoned gas well known as the Presque Isle Beach No.7 well and itS
surrounding, contaminated area. The surrounding area is comprised of a portion of an
underground geologic formation which is known as the Bass Island Formation. Property en
which the Presque Isle Beach No.7 well is located is owned by the Commonwealth of
Pennsylvania. The main use of the areas adjacent to the site is for recreation.
Presque Isle Beach No.7 well was drilled by the City of Erie in 1910 for use by the City
Waterworks. It extended 3,570 feet through the Bass Island Formation and into the Medina
Formation~ an underground formation at a lower depth. In the 1920s, the well was abandoned
without plugging and covered by a con;:rete road surface that was later covered with sand. In
1976, after numerous complaints frorr: park visitors about a foul-smelling odor in the Beach
No.7 parking lot, the Erie County Heal~h Department filed a complaint with park officials. The
County Health Department noted a seep near Beach No.7 well that was discharging a noxious,
hydrogen sulfide-bearing, black liquid.
In March 1979, PADER uncovered the well to investigate complaintS that the odors were
getting worse. The well was identified as the source of the discharge and was equipped with a
bleed valve arid pressure gauge to control discharge. P ADER permanently capped the well in
October 1982. Investigations conducted at that time determined that no health hazards were
present as a result of the seepage that had already taken place.
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PRESQUE ISLE
BEACH NO. 7
GAS WELL
LAKE ERIE
PRESQUE ISLE
. STATE PAflK
/ • . • s^ • • ... i. i..i.
« fl t^j-\\ t'»» " l-llt-t
' t :. >"" •* -•»
-X"*S.I --^ • • ^
Ruler encu
7.5* USGS Tipogiaphic maps, Ena South, Eou North and SwanviHa Quadrangles.
Pennsylvania, Dated 1957, PhoJomvised 1969 and 1975, Scale I* - 2000'.
Si Al I
2IMJI)
^(MM)
4'KK) I it I
MAP SHOWING LOCATION OF PRESQUE ISLE,
CITY OF ERIE. PENNSYLVANIA
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P ADER conta&:ted EP A's Region m office to assist in sampling and plugging the well
during the Fall of 1982. After subsequent environmental sampling, the Presque Isle site was
placed on EP A's National Priorities List (NPL), a list of hazardous waste sites target=d for
action under the Superfund program, in September 1.983. Reasons cited were concerns that the
same fluid might be seeping from other abandoned gas wells, of similar age and construction, in
the area.
Subsequent investigations have revealed that the discharge released hydrogen sulfide into
the atmosphere and other hazardous substances into the soil and shallow ground water. Both ,
P ADER and EP A have sought to defme the source of the discharge and the potential for similar
discharges in the Erie area. The central issue of their investigations has been whether the
discharge is a na~ phenomenon or if it was related to the deep-well injection by a private
company of approximately 1.1 billion gallons of spent pulping liquor into the Bass Island
Formation between 1964 and 1971.
THE PROPOSED REMEDY
The results of all studies conducted on the Presque Isle site to date have been analyzed in
the Remedial Investigationl Feasibility Study (RIfFS) report titled'''Summary of Investigations
and Recommendations for Further Action" (Schoener-EPA, 10/85). Available chemical data
provide ambiguous infonnation about the source of the discharge and suggest that resolution of
these ambiguities will be difficult. Investigations, however, have determined that the discharge
at Presque Isle Beach No.7 well was an unusual event, and that the threat to the public was
eliminated when the well was pennanently plugged in 1982. As a result, the only known source,
of the seepage has been capped. Potential for direct exposure has also been minimized by
covering the past seepage with fresh sand and there are no drinking water wells in use on the
peninsula. No migration pathways have been recognized.
Based on these investigations, EPA and PADER are proposing to adopt a minimum action
approach, as outlined in the RIfFS recommendations. The RI/FS report recommended that the
minimum action approach consist of two actions:
1)
Notify local oil and gas drillers that a hydrogen sulfide-bearing brine is present in
the Bass Island Formation, and that drillers should be prepared to seal wells in the
formation if a hydrogen sulfide release occurs
Monitor oil and gas wells drilled through the Bass Island Formation for higi:
pressures and the occurrence of hydrogen sulfide ("black water").
2)
The third finding of the report was that existing information does not warrant the costs and
en vironmental risks associated with a drilling program to define the origin of the discharge at
Beach No.7 well. This finding will be revisited if the monitoring of oil and gas wells, described
above, detectS a problem. Each action and the fmding is funher explained below.
The f~t component of the remedy is notification of oil and gas well drillers of the presence
of sulfur-laden black water in the Bass Island Formation and a requirement to seal the formation
if sulfur water is encountered. The action would be taken whenever a well is drilled through the
Bass Island Formation. The current information that oil and gas well drillers have is that the
Bass Island Formation is a clear brine, and, thus, does not pose a threat to the environment or
public health. Drillers must be made aware of potential problems and be prepared to take
corrective action if a seep problem occurs.
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The second component of the remedy is close monitoring of all oil and gas wells drilled in
northern Erie County for high pressure and/or black water in the Bass Island Formation. This
would provide additional information on whether there is a problem sufficient to warrant the
expenditUre of significant resources to conduct more in-depth investigations.
- The final component of the remedy is the froding that installation of monitoring wells in the
Bass Island Fonnation is not necessary. Other than the discharge from the Presque Isle well and
another incident, there have been no reported discharges. Any attempt to defme conclusively the-
source of the discharge would require drilling wells directly into the formation, at a cost of
approximately $150,000 to $200,00 for each well. There would also be risks associated with
drilling these wells because of the sulfur water encountered and the potential for significant
amounts of hydrogen sulfide gas to build up between testS and cause another release. The
possibility of drilling wells to monitor the Bass Island Formation will be re-examined if the
monitoring program proposed in the second component of this remedy identifies significant
problems.
OPPORTUNITIES FOR COMMENT ON THE PROPOSED REMEDY
Public comment on the proposed remedy will be accepted through September 11, 1987.
D-irect written comments, questions, and requests for infonnation to:
Patricia Tan, Enforcement
Project Officer
U.S. EPA, Region III
841 Chestnut Street
Philadelphia, P A 19107
(215) 597-3164
Ann Cardinal, Community
Relations Coordinator
U.S. EP A, Region ill
841 Chestnut Street
Phildelphia, PA 19107
(215) 597-9905.
Copies {)f the RIlFS report and other infonnation about the Presque Isle site are available
for review at ~::~ following locations:
Presque Isle S - .:te Park
Research LibLi)'
Peninsula Driv~
Erie, PA 16505
(814) 871-425 1
Erie County Health Department
606 w. Second Street
Erie, P A 16507
(814) 454-5811
Erie County Library
Presque Isle Branch
902 W. Erie Place
Erie, P A 16505
(814) 453-5763.
NEXT STEPS
Following the conclusion of the 30-day public comment period, a Responsiveness
Summary will be prepared which summarizes citizens' commentS on the proposed remedy and
EPA's responses. Thereafter, EPA and PADER will prepare a formal decision document that
summarizes the decision process and the selected remedy. This document will include the
Responsiveness Summary.
If the minimum action alternative is selected for the Presque Isle site, actions will be taken
to delete the Sl~-= from the NPL. In order to do so, there must first be a technical evaluation to
detennine that the Presque Isle site meetS the established deletion criteria. EP A, in consultation
with the State, must find, and the available data confum, that the site poses no threat to public
health or the environment. Deletion of the site from the NFL does not make the Presque Isle site
ineligible for later government-financed actions, if any measures are needed. EP A will re-
evaluate the site periodically to ensure that it continues to pose no threat to the public health or the
environment.
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GLOSSARY
Formation: The primary unit of fonnal mapping or description. Most fonnations possess cert:1in
distinctive, or combinations of distinctive, rock or sedimentary features.
National Priorities List fNPU: EP A's list of the top priority hazardous waste sites in ~e country
that are eligible to receive federal money for response under Superfund.
Remedial Investieation/Feasibi1i~ Study (RIIFS): The RIfFS is a two-part study which is
completed before the decision to undertake a cleanup action at a site is made. The fIrst part is the
Remedial Investigation (RI), which studies the nature and extent of the problem at a site. The
second part is the Feasibility Study (FS), which evaluates different methods of dealing with the
problem and selection of the preferred method which will effectively protect the public health and
the environment.
~: A spot where water or petroleum oozes from the earth, often fonning the source ~: '" small
trickling stream.
Superfund: The common name used for the Comprehensive Environmental Response,
Compensation, and Liability Act, also referred to as the Trust Fund. The Superfund program
was established to help pay for cleanup of hazardous waste sites and to take legal action to force
those responsible for the sites to clean them up.
";-5
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Pat Tan
Karen Wolper
Gregg Crystall
Debra Miller
Mark Gorman
Scott T. Lee
David D. Aurora
Dan Brocki
Bill Welch
Bill Kenedy
Rob E. Sidman
Stephen J. Cruise
James H. Speice
Truman O. Andrews
Timothy M. Yeager
John Wright, Jr.
Gene Giza
Greg Schrum
Carolyn Sturtwant
APPENDIX B
PRESQUE ISLE PUBLIC MEETING
WEST LAKE JR. HIGH SCHOOL
ERIE, PENNSYLVANIA
August 13, 1981 - 1:30 p.m.
0.5. EPA
0.5. EPA
0.5. EPA
U.S. EPA
PA DER
Private Citizen
3818 Blossom Terrace,
Private Citizen
Er ie, PA
16505
Erie County Environmental Coalition
Millcreek Township
Hammermill Paper Co.
Hammermill Paper Co.
Hammermill Paper Co.
IT Corporation
Presque Isle State Park
Harrisburg
Presque Isle Aucuboo Society
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APPENDIX C
PUBLIC MEETING TRANSCRIPT
1
1
COMMONWEALTH OF PENNSYLVANIA,
2
COUNTY OF ERIE.
3
- - -
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IN THE MATTER OF:
5
U. S. ENVIRONMENTAL PROTECTION AGENCY
PUBLIC MEETING REGARDING PRESQUE ISLE
BEACH NO.7, PRESQUE ISLE STATZ PARK.
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1
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Transcript of Public Meeting held at the West
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Lake 3unior High School, Millcreek Township Auditorium
4330 West Lake Road, Erie, Pennsylva~ia, commencing at
7:45 o'clock p.m. on Thursday, August 13, 1981.
- - -
SPEAKERS:
Debra Miller - Community Relations Coordinator -
EPA
Patricia Tan, Project Officer - EPA
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P-R-O-C-E-E-O-I-N-G-S
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MS. MILLER:
I want to welcome you all
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here and thank you for coming tonight for the Presque
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Isle public hearing.
My name 1S Debra Miller, I work
5
for the Environmental Protection Agency, and I'm a
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community relations coordinator.
I'd like to introduce Pat Tan, she's a
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project officer, and Mark Gorman is the site project
officer for the Pennsylvania Department of
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Environmental Resources.
Pat is going to give a
presentation.
If you haven't already signed in, there i8
a 8ignup sheet, if you would like to do that, we will
be compiling a mailing list for any future mailings.
It you want to fill that out when you leave, feel free
to do that.
There is also a fact sheet out there, we
are going to be following some of the information in
the fact sheet tonight, you ~1ght want to take that
home and look at it.
Also, it you haven't already seen the
report, there 1s a ~resque Isle Report, it's at three
repositories in the community, it's at the Presque
Isle Branch of the Erie Couty Libra -y, and at the
Research Library area at Presque Isle State Park, and
also at the County Health Department, each of those
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. locations has a rep~rt.
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If you feel there should be more out in
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the community, we can stick a few more out there.
I
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have one or two with me tonight if people want to come
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up and take a look at it.
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Basically the agenda for the meeting is
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just. to go over the proposed recommendation, and the'
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alternatives for the Presque Isle si.te.
Pat will be
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going into a little more detail about that.
Also, this i9 the beginning of the public
comment period, we want to urge everyone if you have
comments, to make them in writing, or tonight if you
want to give comments in person, we have a court
stenographer here, this will be part of the official
record.
If you want to give a comment, speak up as
much as you can, give your name beforehand so she can
take that down.
Okay, bas~cally I will introduce Pat,
she'll go through a short presentation and we'll open
it up for questions, so feel free to jump in after the
presentation.
This is Pat Tan.
MS. TAN:
The f.rst thing I'd like to do
15 to go through a brief background concerning the
site, summarize our conclusions related to the studies
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.that were performed ~y many, many people and agencies,
and then go through what our6recommendat10n is
2
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regarding the site and a little bit ot the rationale
behind that and give you how we will proceed with
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~
these recommendations and give you an idea of the
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status ot the site in the months to come.
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All of this information can be found in
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that tact sheet, and it you have any questions I will
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certainly be glad to answer them after I go through
all this intormation.
In the early '70's a toul smelling and
sulfur laden black liquid began discharging near Beach
Well No.7 at the Presque Isle State Park located in
Erie, Pennsylvania.
The source ~emained somewhat of a
mystery until 1979 when the Pennsylvania Department of
Environmental Resources unearthed the leaking
abandoned natu~al gas well that was a source of the
noxious seep.
The formation which produced the seeping
liquid was the upper Silurian Bass Island dolomite at
a depth of 1,521 feet to approximately 1,586 feet.
The discharge releaser hydrogen sulfide into the
atmosphere and other .1azardous substances into the
soil.
Early investigations conducted by the Erie
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.County Departm~nt ot Health 1n the early '70's by
PACER trom 1979 to '83, and by the U.5. EPA and PADEK
,
from '83 to the present, have sought to better define
the cause of the discharge and potential for similar
discharges to create environmental and public health
hazards 1n the Erie area.
The central issue in these investigations
has been whether the discharge was a natural phenomena
or whether it was related to the deep well injection
of approximately 1.1 billion gallons of spent pulping
liquor into the Bass Island formation during '64 to
'71.
These two alternative explanations tor the
seeping gas well were investigated by some of the most
sophisticated chemical testing and mathematical
simulations of the deep well injection system
currently available.
The State of Pennsylvania plugged the
seeping well in the Fall of '82.
PADER's
environmental consultant, Roy F. Weston, Inc.,
investigated Beach No.7 and determined that no health
hazards were present as a result of the seepage which
had alr~ady tak-n place.
Ch:t1n sand was brought in to cover the
area surrounding this plugged well.
Beach No.7 well'
site was placed on the National Priority List, or NPL,
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.in September 1983 because the U.S. EPA and the U.S.
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Geologic Survey were concerned that the same noxious
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fluid might also be see~ing from other abandoned gas
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wells of similar age and construction in the Erie
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area.
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The U.S. EPA Field Investigation Team
1 .
sampled domestic water wells in the Erie area near
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similar abandoned 011 and natural gas wells and
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determined that none of the water wells showed any
effects that would indicate that the nearby oil and
gas wells were leaking.
Other oil and gas wells in the Erie area
were sampled to determine whether the Bass Island
Formation fluid from these wells were chemically
similar to the fluid which had seeped from Beach Well
No.1.
Wells were sampled very near to the
un~erground injection wells and from a well located
far beyond the area where the spent pulping liquor
could be expected to have moved within the Bass Island
Formation.
Chemical testing was unable to positively
link the Jischarge with the injected spent pulping
11quor.
Driller's logs of 011 and natural gas wells
from large portions of Erie County indicate 204
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.o:currences ot black water, a Bass Island Formation
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fluid which naturally resembles the noxious fluid
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encountered at Beach No.7 well.
Additionally, the adjacent counties in New
5
York also have similar formation fluids in the Bass
Island Formation.
Mathematical simulations on computers ot
the deep well injection system's effect on the
tormation pressures ot the Bass Island dolomite were
also unable to positively link the deep well injection
system with the seeping beach No.7 natural gas well.
These simulations indicate that it would
be quite difficult for the chemical constituents of
the injected spent pulping ~iquor to have both
migrated approximately four miles from the injection
wells to Beach No.7 well and have maintained enough
pressure to cause the seepage tor ten years following
the sealing of the injection wells.
The simulations do suggest that the
injection liquor could not be expected to have moved
tar enough to explain the occurrences of black water
in the 204 wells in Erie County or other wells 1n New
Ycd(.
The chemical testing provided enough
information to establish that the fluid which was
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.formerly seeping trom Beach No.7 well was very
similar to the hazardous formation fluids which oil
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and gas drillers normally encounter in routine
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drilling in Erie County.
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Oil and gas drilling is regulated by
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PADER's Bureau ot Oil and Gas Management, and
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procedures for responding to problems associated with
hazardous tormation tluids are already 1n place.
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The only known problems associated with
hazardous flulds seep1ng from abandoned 011 and
natural gas wells in the Erie area was Beach No.7
well.
The health hazard trom this well was eliminated
when PADER plugged the well 1n '82.
Further attempts
to better define the source ot the seepage at that
well would involve drilling very expensive monitoring
wells which might not resolve the issue, and could
present an unnecessary environmental risk.
Based on the investigations that have been
outlined in the Remedial Investigation and Feasibility
Study report dated October, 1985 by Shoener, and on a
Records Compilation which was performed by Versar for
EPA and final this August, we have the following
recommendations to consider for this site.
The first one is notify 011 and gas well
drillers of the presence of sulfur laden black water
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in the Bass Island Formation and require the formation
to be sealed it the sultur water 1s encountered and
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found to pose a potential hazard.
This action should
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be taken whenever a well 1s drilled through the 8ass
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Island Formation.
It is reported that the general
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knowledge ot oil and gas well drillers is that the
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Bass Island Pormation 1s a 'clear brine.
Drillers
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should be aware ot the potential problems and be
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prepared to take corrective action if necessary.
The second recommendation is closely
monitor all oil and gas wells drilled 1n northern Erie
County for high pressures and/or black water 1n the
Bass Island Formation.
Additional information on th~ formation
would be very useful in determining if there is a
problem suff1cient enough to warrant the expenditure
of signif1cant government resources to conduct more
indepth investigations.
The third recommendation was the
installat10n of monitoring wells in the Bass Island
Formation 1s not necessary based on current
1nformation.
Other than the discharge from the
~resque Isle well and the blow-out at the Hammerml11
injection well, there have been no reported
discharges.
To attempt to conclusively define the
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~ource of the Presque Isle discharge would involve
2
drilling wells into the Bass Island Formation.
Each
3
well would cost approximately $150,000 including
4
analytical and other costs.
If cores of the formation
5
were collected, the cost per well would increase by at
6
least $50,000.
There would also be risks associated
1
with drilling such wells because the sulfur water
8
could be encountered and the hydrogen sulfide gas
9
could build up to significant level while the wells
were being capped between tests.
In the absence of further information
regarding the occurance of elevated pressures and
sulfur water in the Bass Island ~ormation, the costs
and risks associated with ~he installation of
monitoring wells is not warrant~d at this time.
The next steps which will occur regarding
this site are the following:
right now 1s the start
of the 30 day public comment period, a Responsiveness
Summary will be prepared which summarizes the
citizens' comments and other comments on the proposed
remedy which I've just outlined, and all of EPA's
responses to those comments.
Thereafter, EPA and
PACER will prepare a formal decision document that
summarizes the decision process and the selected
remedy.
This document will include the Responsiveness
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.SUllUDary.
2
If the minimum action alternative is
3
.
selected for the Presque Isle site, actions will be
4
taken to delete the site from the NPL.
In order to do
5
so, there must first be a technical evaluation to
6
determine that the Presque Isle site meets the
7
established criteria for deletion.
EPA, in
8
consultation with the State, must find, and the
9
available data confirm, that the site poses no threat
to the public health or the environment.
Deletion ot the site from the NPL does not
make the Presque Isle site ineligible for later
government-financed actions if any measures are
needed.
EPA will reevaluate the site periodically to
ensure that it continues to pose no threat to the
public health or environment.
The end.
It anyone has any c6mmen~s, Debbie and I
would certainly like to hear them and respond.
MS. MILLER:
It you do. please maybe stand
up, it you want to give your name, just state your
name before the question.
MR. t.EE:
My name 19 Scott t.ee, and I'm a
private citizen of Erie.
And I just have a couple
questions and then a couple comments at the end.
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1
I was out at the well today, and I was
2
just taking a look at it, and I notice that on the
3
well there is a pressure gauge.
And the pressure
4
gauge reads 25 psi, and while that isn't a great
~
A, is this natural gas, or is it a buildup
pressure.
6
of hydrogen sulfide?
The well was plugged, okay, but
7
there 1s ." pressure gauge on the well that says 2~
psi, 1s that just an error in the gauge, or is there
8
9
some pressure?
MS. TAN:
Which gauge was it?
Because I
looked at them, also, and I saw zero on them.
I'll
have to go back out and check.
MR. LEE:
The one on the ground says zero,
when you look at it, looking toward the Lake, the one
that's above the ground, it's a white gauge, it says
25 psi.
MS. TAN:
I w111 have to go out and check
again, but I thought I saw zero on those gauges.
MR. LEE:
Also, and this is interesting,
but when we were out there, I smelled natural gas as I
was standing right next to the well, so I don't know
where that's coming from, but I distinctly d1d smell
it, so it's my guess that the pressure build1ng up
inside this well 1s probably natural gas and not
hydrogen sulfide.
If that 1s the case, the well 1s
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1 leaking, somebody should take a look at It because I
2 did smell that.
3 MS. TAN: Okay.
4 MR. LEE: So that may be a recommendation.
5 Also, I read the feasibility study the
6 other day and I notice that originally when the EPA
7 heard there was a concentration of 22,000 parts per
8 million, that's lethal, and what I want to know is,
9 now they said the well wasn't capped it was pluged, if
10 they did cap the well.there would be a buildup of
11 pressure of the hydrogen sulfide assuming the stuff is
12 still underneath there, which I assume it is, is there
13 any — when the alternatives were being formulated for
14 the RI/FS, was there any consideration to monitor
15 pressure buildup of the hydrogen sulfide gas?
16 MS. TAN: For that particular well?
17 MR. LEE: Yes. Because originally that's
18 where the seep had occurred, and that's where the
19 concentration problem is.
20 MS. TAN: That well is monitored, and
21 people do go out and check that on a routine basis and
22 they have not found that there was any leaks. I
23 haven't. It certainly would be a very good
24 recommendation to put in there.
25 MR. LEE: Who is going to be responsible,
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1.
1
. in the alternatives that are discussed here, who is
going to be responsible for monitoring all the gas and
2
3
oil wells in Erie County, is that going to be the
4
State's responsibility?
5
MS. TAN:
I think that's something EPA and
6
the State still have .to work out how that's going to
7
be done, because certainly we want to be kept informed
8
of any of these problems because then we can
9
reconsider these sorts ot problems again.
MR. .tEE:
Because there 1s a lot ot wells
in th1s area and it's. a pretty big job.
MS. TAN:
The Bureau of Oil and Gas
Management are involved in that program and they
regulate 1t.
MR. tEE:
I think that's all the questions
I have.
I just want to put 1n a couple commen~s.
I'm familiar with E~A'9 procedures in hazardous waste
clean ups and things, and; realize the Presque Isle
site is ecologically sensitive and sensitive to a lot
of people 1n the Erie area, but I want to say that I
do agree with EPA's recom~~ndations, the site should
be deleted from the NPL S~perfund with the provision
that it can be rellsted, or emergency funding can take
place it there i9 another discharge.
There has been
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1 no discharge for quite a while, and it certainly is a
2 lot better than the days when Hammermill used to
3 inject the waste directly into the Lake. As long as
4 there is no other recurrences, and I know Presque Isle
5 is fairly large and it's hard to monitor things like
6 that, but I think that there is no reason to keep the
7 site on the NPL. And informing well drillers in the
a area is a good idea.
9 But the only recommendation that I would
10 have is, to first of all check the pressure at the
11 well, see if it's leaking, find out what the leaking-
12 is. I know it's natural gas. And if it's not coming
13 from the well, it's coming from somewhere, because I
14 did smell it, and that was unusual.
15 But those are the only recommendations I
16 have. And perhaps maybe include that before you write
17 the record on the decision per se.
18 T hanks.
19 MS. TAN: Thank you.
20 MR. WRIGHT: My name is Jack Wright,
21 I'm an employee of IP Corporation, we were retained by
22 Haramermill Paper Coppany.
23 . In respjnse to this gentleman's questions,
24 I would like to state that I was at the well plugging
25 operation involved in 1982, it was a five week effort.
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. We w.~~e there monitoring the efforts that the State
2
Was undertakIng.
T~e well was completely cleaned out
3
of all casing, it was cemented up to a level of about
4
-900 f&et.
The State had made a decision rather than
5
to cement the entire well shut, the natural Devonian
6
shell was producing quite a volume of natural gas, I
7
think the reading was about lq3 psi, so they cemented
up to a level of 9SS, capped the well for later
8
9
development as an energy source.
50 any readings you
would be looking at would only be natural gas from the
Devonian shells, and in tact if there was a gas leak,
probably the well related to that.
MS. TAN:
Thank you.
MR. WELCH:
My name ~illiam Welch, I
represent the Erie County Environmental Coalition.
We request an extension on the time for
comments.
We were notified on Monday, and I checked
with t~e library, and just not only are there
documents there, but there is supporting documents,
there is two boxes of supporting documents.
And you
probably realize that's a pretty short time to make
any kind of comments based on the fact there is a lot
of interest
n the scientific community about this
situation. and hazardous waste written by Dr. Samuel
Epstein, University of Illinois toxicologist, he wrote
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1 extensively about this situation. And the scientific
2 _ community is very much Interested in this. So we are
\
3 going to, under Amendment 3 for funding as a citizens
4 group to get outside evaluation, particularly in
5 computer monitoring. And also we have secured and
6 talked to some individuals who have worked not only in
7 this country, but one of them worked in Israel and
8 Japan and Korea in this type of situation. So we
9 would like to get an extension of at least a month's
10 time on this because there is no real rush on this
11 well.
12 Furthermore, we have some questions. Has
13 Mr. Mackie been replaced with the Pennsylvania
14 Department of Environmental Resources on the gas
15 division" I mean, has his Job been filled by someone
16 else? H
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.National Resources Defense Counsel in one of their
publications mentioned the fact if that ever happened
and whatever source, ",'e could have serious
consequences if this ever built up in areas.
2
3
.
.
5
My questions are really to 011 and gas.
6
I've been in contact with Mr. Shoener about this a.
7
long time because of the fact the situation exists
:;
wherever this stuff 1s, and no one really knows.
And
9
I think that since Mr. Shoener is leaving the agency,
and he was probably the most knowledgeable in this
area, they asked about two or three years ago for
monitoring reports and notification be given to oil
and gas drillers, and I've never seen any of those
notifications, if they were given to oil and gas
drillers at that time.
Mr. MackIe
I don't know.
isn't here to defend himself.
I've never seen them.
I wonder, Mark, if you could prov1de
those?
With Ken Young, did he ever get any of those,
have you ever seen them?
MR. GORMAN:
My understanding of
Mr. Shoenerls recommendations were that they were just
that, recommendations that are being proposed as the
'ecommended alternative a~ this time, so there hasn't
been a notification procedure put into place to date.
MS. TAN:
Those recommendations haven't
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1 • been finalized, that's what we are working towards
2 fight now by formulating them In a record of decision
3 which will bind every one towards Implementing those.
4 MR. WELCH: We are real concerned about
5 the fact that DER — I Just asked Mr. Giza if he
6 knows. Mr. Mack!e.died, and I don't know if anyone
7 else has taken his position.
8 MR. GORMAN: There are oil and gas
9 inspectors —
10 MR. WELCH: What's happened is, oil and
11 gas has subsided, the drilling has kind of, because of
12 the price of a barrel of oil, dropped. But If you
13- read the New York Times on Sunday you realize
14 Halliburton Company is a real good investment, and
15 they are a fracturing company. That there is some
16 investors saying now is the time to start getting into
17 oil and gas and start drilling.
18 There is some question in terms of Medina
19 formation in this area. I don't know how many more
20 leases are available, because they deal — it's called
21 Rose Run formation, there is some speculation there is
22 some gas in, that's a deeper formation. I think there
23 are some people — I know some drillers have interest
24 in exploring other formations, and I think that with
25 the situation being as it is right now, there isn't
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. much drilling.
I mean, there is some, but not to the
2
extent it was a couple years ago.
3
I think that the DER should put back' in
4
the position someone responsible for coordinating
5
this, other than Mark, because Mark works in a
6
different area, he doesn't work directly ln 011 and
7
gas, he works 1n the hazardous end of it. . The 011 and
gas, they can tell whi~e the drill is there --
9
9
MR. GORMAN:
If I could answer your
question. DER has an 011 and gas inspector assigned to
Erie County on a full time basis, he works out of the
Meadville office.
MR. WELCH:
The thing I just read in the
paper Chambersburg office, they put someone in there
from another county.
DER can do that.
It seems lIke
all the agencies that's supposed to be monitoring the
state are down in Meadville.
At one time we had air
quality up in Erie, but they moved that out, they
moved it into Meadville.
The most important thing in
terms of air quality and water quality, the county
deserves some treatment, getting somebody up here.
I
think the new administration i9 g01ng to do something,
get more people.
What we would like 1s an extension of
time.
I can't go in and spend days reading.
We want
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1
." to send it out.
The National Sierra Club is very
2
1nterested in it because ot the tact it's just
3
a unique situation. there is the scientitic community
4
just ot natural curiosity is interested because it's a
5
unique occurrence.
6
MS. TAN:
One thing I'd like to suggest,
7
that once allot the people who are involved get a
8
hold ot this material, in tact either we can come out
9
there or you can come down to our place in
Philadelphia. and we can talk.
I've seen a lot of --
MR. WELCH:
Well. some ot these people are
located out of the country that I'm going to send this
material to.
I'm going to have difticulty, they are
on sabbatical leave.
What I need is -- I've looked at
bibliographies, it's just a mess.
I haven't -- is it
Dr. Walker or Mr. Walker~ I read Mr. Shoener's
material, I haven't seen Mr. Walker's material.
The
thing is. I just didn't have time. because this
hearing. you just sent the information out last
Thursday to the library, and you had the hearing.
The
notification was just last week.
It's just short
notice to go through the supporting documents, and
that's what we would like to do.
Plus the fact we
don't want to do this hastily, because you remember
Butler tunnel down there they took it oft and delisted
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0" it and it came back on again.
We just don't want to
2
see a situation like that occur.
3
MS. TAN:
It was relisted, we have no
4
problem relisting things.
5
MR. WELCH:
Well, the question on our mind
6
is, is the source of this, whether it's a natural
7
source or whether it's a man made source, and that.' s a
8
real critical issue.
And I think in terms of gas
9
drillers, too, because they get blamed for a lot of
things.
This is something they have no responsibility
on yet, they are taking all the risk.
MS. MILLER:
Possibly we can have a small
meeting.
Are any of yo~r experts in the area?
MR. WELCH:
I just talked to one today, in
fact one used to work -- he worked for the EPA
identifying hazardous waste sites, another one is an
Israeli that works allover the world, and I have to
get in touch with him, he's on sabbatical, I don't
know where he Is right now because I tried to call
him, he'a a hydrogeologist and a chemist, so he's real
concerned.
Dr. Matterson's office at Case Western
University 1n Cleveland has done studies on effect of
methane reducing action on hazardous materials, and
this is quite Interesting because of the fact it
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. freezes up some of the heavy metals in water.
And up
2
in, I believe it was Madison, Ohio, there was a case
3
involving this.
We would like to know what effects
4
hydrogen sulfides gas on reducing some of these heavy
5
metals in formations Is, because there are presence of
6
materials there, but they are bound up.
But it you
1
free those gases in formations, what is that going to
9
do?
We would like to send this
We don't know.
9
information to those people.
MS. TAN:
Well certainly we are not
talking about deleting the site, we are not talking'
about making a decision at this point in time --
MR. WELCH:
We would like to make comments
before you do anything, so we have some expert opinion
and we know it's out there.
We have people that have
done this stuff. they are professionals in this field.
I'm no professional in this.
It's a very complicated
situation.
MS. TAN:
I agree.
MR. ANDREWS:
My name 1s Truman Andrews,
I'm,Manager of Environmental Affairs for Hammermill
Paper Company, and I would like to register for the
record my objection to the request for additional
time.
This issue has been a matter of record
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1 ever since It opened In 1979. It was opened by DER,
2 Snd their records are open to the public. Mr. Welch
3 knows where their records are. It's a matter of
4 record that EPA — every bit of the technical
5 information that has been developed over the nine
6 years that this issue has been before the public, the
7 EPA and OER records have been available to any of the
8 interested public.
9 I would object to any time extension. I
10 think it's time decisions were made and the issue
11 moves on.
12 Now, 30 days is an infinitesimal amount of
13 time compared to nine years. Mr. Welch knows exactly
14 where he can come. We open the doors. We have always
15 had our doors open to anybody who is interested in the
16 technical facts.' Mr. Welch is welcome to come £0
17 Hanunermlll tomorrow if he desires, we have all of the
18 documents, we'll keep Mr. Wright here and we'll keep
19 him at the service of Mr. Welch.
20 Mow, I think this is totally untimely and
21 it's inappropriate. But Mr. Welch has a right to
22 speak on a public fourm, but I would like to have my
23 objection registered, please. Thank you.
24 MS. MILLER: Thanks.
25 Are there any other questions from anyone?
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MR. tEE:
Scott. tee again.
2
This question is not directed to EPA, but
3
perhaps Mr. Giza can answer this.
When you run 'a
4
weekly -- when weekly bacteria coliform samples are
~
taken at the Lake, I'm wondering if they sample for
6
any organic or inorganic contents in the water also?
7
MR. GIZA:
It's just bacterial studies.
8
MR. LEE:
There.was an incident, I can't
9
remember,
it was in the '70's, I think, where some
black liquid was coming actually out of the take
offshore trom Hammermill, this Is by no means to
implicate anyone, because It could be natural also, it
was a190 like an 011 slick, although it wasn't oily,
of course. Thls 1s what I'm wondering, are there
any -- and this Is not the EPA, it's the Department of
Health, I guess -- are there any existing sampling
methods that if this occurrence ever hapgens again
would they be able to go out again and dEtermine what
thls stuff is?
Thls may have been -- they can't prove
that It was related to the site or anything like that,
and I was just wondering if there was anything
established in Erie County for this kine of samrllng?
MS. TAN:
I think the thought was t,at it
was probably the leaks from the sewer system.
Is it
inky?
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1 . MR. LEE: Yes.
2 MS. TAN: That's what —
3 MR. LEE: Prom what sources? Erie '
4 outfall?
5 MS. MILLER: Mr. Welch?
6 MR. WELCH: I would like to comment. We
7 didn't know any federal action was going to be taken.
8 I was under the opinion there was still monitoring
9 reports, and it would be premature for me to ask
10 Hammermi 11 or anyone, to ask anyone unless the final
11 conclusive is in. I had no Idea this computer
12 monitoring was done.
13 I've never seen a bibliography or typed
14 bibliography to this extent. This is the first to my
15 knowledge of any of this type of material being in
16 such a manner. We don't have time to go down t;
17 Philadelphia. We do go down to DER, we go through
18 some of the files, but in many cas?s this is in
19 different places. The thing is I've never seen it put
20 together all in one place. We didn't know there was
21 going to be any federal action. I was under the
22 opinion after talking to Mr. Shoener there was going
23 to be continued monitoring and other tes s in this
24 area, I had no idea this action was going to be taken.
25 The first I had was notice in the paper, and that was
026
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is
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1
. last week.
50 it seems to ~e that's the reason we are
2
aSking tor this extension, not because we didn't have
3
access, but. because ot the action by the tederal'
4
government in relationship to this situation.
S
MS. MILLER:
Would it help -- and I will
6
just throw this out as a comment, but maybe betore the
7
.end ot the comment period, which is September 11th.
8
maybe we can do another week on that or so, but maybe
9
.
we can have' another meeting either a smaller group
meeting or public --
MR. WELCH:
What we would like to do 1s .
under that Amendment 3 would like to bring some
experts in.
We would like to do so.
We have
internationally known experts that are hydrogeologists
and they are geologists and things, because I can't
ask them overnight to do som~thing like this because I
didn't know this action was going to be taken place.
We have so many other things.
As you know, there is
all kinds of actions and permits coming out. and we
don't have time just to concentrate on one Supertund.
As you know there is three of them in this county, and
additional ones down south 3nd all ~ver the place. and
all kinds of environmental situati.ns coming up
constantly.
We had no idea this notification was going
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1
to take place until recently, that's why we are
2
isking, so our experts can see that as well.
Their
3
,
experts have seen it tor a period of nine years, ours
4
haven't because we haven't had the time.
We don't
5
have the resources of International Paper to do a11
6
the the research they do.
We do have people committed
7
. scientifically to examine this.
8
MS. TAN:
Hopefully your experts and their
9
experts are our experts, because we have certainly had
many experts look at this material also.
And I think
we stated the RIfFS report was written by Ed Shoener,
and it was written in October of '8~.
I thought it would be a good idea to pull
all the records in the world from the ends of the
earth together and look at it one more time and
compile it all in one place, and that's we did.
MR. W!LCJf:
That's what I say, I've never
seen it assembled in that fashion.
That's the
difference.
And you can't expect three or four years
of their work to be examined in two weeks by people
who have no knowledge in terms -- I can't look at that
stuff.
We have to have our experts.
There 1s no way
they can look at it in that short of time.
And it's
being held 1n August, right when people are on
vacation, many of the professionals.
I've tried to
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-call on them, and I can't even get a hold of them. one
2
r. -- I don't know where he 1s. .
3
MS. MILLER:
What we can do possibly' when
4
we get back to the off1ce tomorrow 1s talk to the
5
different supervisors involved and request a week to
6
ten days extension.
7
MR. WELCH:
I don't think the~e is any
8
need tor any great movement because of the fact,
9
obviously, there is no proof that it's Hammermill, so
what should they worry about?
MR. ANDREWS:
Because, Bill, it cost us a
million dollars a~ this point in time to try and
defend ourself against the accusations, the guilty
before proven innocent.
And I want to continue my objection to any
further delay in EPA's proceeding on this particular
site.
MS. MILLER:
Any other questions?
(No response.)
MS. MILLER:
I guess 1f there are no more
questions, then, please, you know, wr1te your comments
down 1f you like, mal) them to E?A.
In fact, sheets
are in the back, our .ddresses are on them, .and we
really urge you to put everything in writing you like
and send it to us so we can put it into the official
C-29
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1 record for this decision.
2 ~ And thank very much for coming tonight, w«
3 appreciate your time.
4 - - -
5 (Thereupon, at 8:35 o'clock p.m. the
6 hearing was concluded.).
7 - - -
8
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APPENDIX D
WRITTEN COMMENTS
O-fJ;"'1l 114 1". ~,V) 9 -I> -1'7
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Mrs. Donna M. Stoczynski
453 2ast 23th Street
Erie, ?A. 16504
September 13, 19S7
Patricia Tan
U.S. 3?A - Hazardous Waste
Inforcment Branch
341 Chestnut Street
Philadelphia, PA. 19107
Dear .vs. Tan,
The ability to see into the future, where environmental
•problems are currently a threat, would be a gift that any
environmental administrator would gladly accept. This gift
was needed especially in reference to the permits that the
2J2R granted to Hamnermill Paper Company for the drilling of
deep injection wells to dispose of over 1.09 billion gallons
of neutral sulfite between 1964 and 1971. The company worked
within guidelines that were stipulated by the state at that
particular time. I question the DER's permission to drill wells
for the disposal of residual - not knowing the full ramifications
and environmental impact of injecting under such force in an area
that possesses formations that would fracture and seep into prox-
imal areas. The gas well at beach ;? 1 in all probability was
an outlet for some of the paper company's effluent - but
"probability" will not hold up in a court of law. Was the seepage
caused by natural phenomena or the deep injection of wastes by
Hammermill? Inquiries by public and private personnel have not
led to any conclusive evidence. How do you corroborate the presenc
of lignin as r _rt of well ,--: 7's discharge? Was it from a natural
petroleum sou- ce or pulp liquor?
Hammermill appears to have "Lady Luck" on it"s side this
time. The only known source of seepage has been capped at beach
no. 7. The ground water and soils in the area do not appear to
be under any immediate threat. I therefore approve the decision
of the Final Report. There are too many other sites on the NPL
D-2
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tbat need
[.:illcreek
'ce tested
:sle site
at~ention - in p~rticular the narper ~rive
Township. T;le \tIell, groundwater and soils
periodic~lly ~or a~y cont~mination and the
should be rST.oved from the N?~.
Site in
should
Presque
Sincerely,
;':rs. Donna 1<. 3toczynski, 3.3.; M.?~;'.
9'Jr-. oJ~,. -- /to ~~.
..'.fternote: I am an instructor in 1 Othgrs.d~ biology at
.:a thedrs.l ?rep:3.ratory ~cnool in :rie. I obtained my masters
from Gannon in 1986 i~ ;ublic administration. I researched many
environmental areas - in particular air pollution and toxic waste
issues. Ey tb.esis dealt \'lith the :!arper Drive 3i te in l'lillcreek.
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TOWNSHIP OF MIUCREEK
' "' 1 36O8 WEST 26TH STREET RQ BOX8268 l^uU^a^n5
TcPresgueisie |. KIE, PSNNSYLVANIA165O5-O268 George S. Pulakos
'*•'"' *'--r": TaH»HONE 814/833-1 111 ArthurF. Detisch
Geraia M. wolf. Secretarytfreosurer
Ooben J. Waytenick. PE.. Engineer
Charles K. Moflaft. Ibwnshio Solicitor
August 19, 1987
Ms. Patricia Tan
Enforcement Project Officer
U. S. EPA, Region III
8U1 Chestnut Street
Philadelphia, PA 19107
Dear Ms. Tan,
The Supervisors of Millcreek Township would like to review EPA Contract
Number 68-01-7331, Work Assessment Number 109. How do we get a copy
of said report?
Our personnel who attended the meeting last Thursday reported that there
is a problem within the Erie County Northern Region. The RI/FS Study
Report recommended two actions: (1) Notify local drilling companies of
presence of hydrogensulfide gas and (2) purchase sophisticated
hydrogensulfide testing equipment.
How does local government protect the clean air our residents need to
breathe? Who is the enforcement prime mover, EPA or Pennsylvania DER?
Millcreek Township needs your help in identifying enforcement personnel.
After review, Millcreek Township may have more questions on black water
and be more aware of potential problems on clean air quality control and
enforcement.
>/^ J
CSP/pv
eorge S. Pulakos
Supervisor
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HAMMERMILL PAPER COMPANY
A „. *«. -»a 1007 1540 Easr Lake Rood
August 28, 1987 . Erie, Pennsylvania 16533
814456-8811
CERTIFIED MAIL
RETURN RECEIPT REO.
Patricia Tan
Enforcement Project Officer
US EPA Region III
841 Chestnut Street
Philadelphia, PA 19107
Re: Presque Isle Site
Recommendations of the Remedial Investigation/
Feasibility Study - August, 1987
Dear Ms. Tan:
Hantmermill Paper Company herewith acknowledges receipt of the Final Report
- Records Compilation - Presque Isle State Park. Erie. PA submitted by Versar
Inc., Springfield, VA 22151 dated August 3, 1987.
As you are aware, we appeared at the public hearing held at Wast Lake Jr.
High School on the evening of August 13, 1987, at 7:30 PM and spoke favorably
on the proposed remedy as contained in the hearing information passout and in
the recommendations made by Versar Inc.
During the hearing we also spoke against any delays in the comment period
as requested by a specific individual. Our obligation is based on the eight
year period this issue has been before the public and the accessibility of the
EPA and DER files in addition to files in possession of Hammer-mill.
This letter herewith reaffirms these comments and further recommends that
the site be delisted as soon as possible. This recommendation concurs with
EPA Region III intent and with the recommendation of EPA's consultant.
D-5
;ne ?ccers incusmci cccers Ccrveffing Qisrnbuficn ^crest Products
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...ILL PAPER COMPANY
Patricia Tan
Enforcement Project Officer
August 23, 1987
Page 2
We have been in contact with IPSCO seeking information on the Presque Isle
well plugging certificates. Mr. Wright is handling this and I have asked thai
he contact you with the results of his effort.
We compliment you and your associates for a well run, orderly hearing.
Very truly yours,
HAMMERMILL PAPER COMPANY
~ F & . Ci—-*<^-<^tO
I. 0. Andrews
Manager, Environmental Affairs
TOA/nnm //194
cc: Mr. J. C. Wright, Jr. - International Technology Corp.
ic: Mr. J. R. Rogers - Skadden, Arps
Mr. D. Brocki
Mr. J. H. Speice
Mr. R. M. Ludwig
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