United Sates
Environments! Prueotefi
Agency
Office erf
Emergency and
Remedial Response
EPA/ROO/R03-90/090
June 1990
Superfund
Record of Decision;
Lond-Shope Landfill, PA
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50272.101
REPORT DOCUMENTATION 1'. REPORTNO. 12.
PAGE EPA/ROD/R03-90/090
:a. A8c:IpI8nI'o ~ No.
4. 111Ie and SubtItle
~TJPERFUNDRECORD OF DECISION
Jrd-Shope Landfill, PA
Firs~ Remedial Action - Final
7. AuIhor(o)
5. Report Data
06/29/90
..
a. fI8rformIng 0rpnba1I0n A8pt No.
8. fI8rformIng 0rpJniIaII0n ...... and ~
10. Protect'f alUWorII UnIt No.
11. ConIrac:l(C) or Gntnt(G) No.
(C)
(G)
12. Sp-..Ing OrpniDtlon ......I11III Add!-.
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
11. Typa of A8p0rt. PwIocI eo-.!
Agency
800/000
14.
15. SuppIamentary No...
1&. Aba1r8c:t (UmI1: 200 _Ida)
The 25-acre Lord-Shope Landfill site is an inactive hazardous waste landfill in Girard
Township, Erie County, northwestern Pennsylvania. The site consists of a 4-acre
landfill and adjacent areas of contaminated soil, surface water and ground water. The
surrounding area is primarily agricultural and residential, with two unnamed tributaries
of Elk Creek bordering the site to the north and west. From the mid-1950s to 1979,
tustrial wastes, including spent adhesives, degreasing solvents, acids, caustics, and
.ne drummed wastes were disposed of onsite from nearby facilities. During 1982 and
1983, responsible parties, under an agreement with the State, implemented a remedial
alternative, which included removing 81 exposed drums, capping the landfill, and
installing a low permeability ground water cutoff wall to reduce leachate production
from the landfill and to divert ground water flow around the site. Landfill leachate
has, however, resulted in VOC and inorganic ground water contamination both beneath and
to the north of the landfill, with a contaminant plume migrating towards the north.
Surface soil around the landfill has also been found to contain elevated levels of VOCs.
The primary contaminants of concern affecting the landfill material, surrounding soil,
and ground water are VOCs including benzene, PCE, and TCE; and metals including arsenic,
chromium, and lead.
(See Attached Sheet)
17. 00cum8nt An8JyaIa ... D8acripIaI8
Record of Decision - Lord-Shope Landfill, PA
First Remedial Action - Final
Contaminated Media: soil, gw
Key Con~aminants: VOCs (TCE, PCE, benzene); metals (arsenic, chromium, lead)
b. Id8n1I~End8cI T-
c. COSA 11 Fi8IdIGrcqt
'IIiI8bIIty SI-.nt
18. &8cwI1y au. (ThI8 Report)
None
2D. &8cwI1y au. (ThI8 Paga)
Non~
21. No. of Pag88
98
22. .....
(See ANSI-Z38.18)
SMIn8InM:II- on~-
(4-H)
(FormIIIy N1JS.8)
D8p8mI8I.t of eo-
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EPA/ROD/R03-90/090
Lord-Shope Landfill, PA
First Remedial Action - Final
:ract (Continued)
The selected remedial action for this site includes in-situ vapor stripping using vacuum
wells to volatize and remove VOCs from the landfill material and the surrounding soil;
collection and treatment of gas emissions generated by the vapor stripping process using
carbon filtration; ground water pumping and treatment including pretreatment for metal
removal, followed by air stripping, to halt plume migration, with final discharge of
treated ground water into the nearby surface tributaries; implementation of site access
restrictions and institutional controls including ground water use restrictions. The
estimated present worth cost for the remedial action is $5,760,000, which includes an
annual O&M cost of $420,000 for years 1 - 2, and $310,000 for years 3 - 50.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific soil criteria for the landfill
material and the surrounding 50il were not provided, but will be determined during the
remedial design and will be based on soil contaminant levels that will not significantly
impact the underlying ground water. Ground water cleanup goals will meet SDWA MCLs or
proposed MCLs (PMCLS), and a 10-4 excess cancer risk or a hazard index = 1. Target
ground water cleanup levels include PCE 5 ug/l (PMCL), TCE 5 ug/l (MCL), benzene 5 ug/l
(MCL), arsenic 20 ug/l (based on an excess cancer risk of 10-4), chromium 50 ug/l (MCL),
and lead 15 ug/l (risk-based calculation). Ground water goals will be revised to meet
background levels in accordance with State ARARs. Air emissions from the air stripping
of the ground water treatment system and the gas released from the in-situ vapor
stripping process will be treated to meet State. standards.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Lord-Shope Landfill Site
Girard Township, Erie County, Pennsylvania
STATEMENT OP PURPOSE
This decision document presents the selected remedial action
plan for the Lord-Shope Landfill Superfund Site (the Site)
developed in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980, as amended by
the Superfund Amendments and Reauthorization Act of 1986
(CERCLA), 42 U.S.C. Section 9601 et sea., and to the extent
practicable, the National Contingency Plan (NCP), 40 C.F.R. Part
300.
STATEMENT OF BASIS
This decision is based upon and documented in the contents
of the Administrative Record.
The attached index identifies the
items which comprise the Administrative Record.
The Commonwealth
of Pennsylvania has reviewed, commented upon, and concurred in
this Record of Decision.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine,
pursuant to Section 106 of CERCLA, 42 U.S.C. Section 9606, that
actual or threatened releases of hazardous substances from this
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. Site, as specified in Section VI, Summary of Site Risks, if not
addressed by implementing the response action selected in this
Record of Decision, may present an imminent and substantial
endangerment to the public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The rem~1ial action plan in this document is presented as
the permanen~ remedy for resolving the groundwater contamination
at the site and for reducing the source of contamination.
This
remedy is comprised of the following components:
1.
A groundwater extraction and treatment component to
quickly halt plume migration, with the long-term effect
of returning the groundwater to its most beneficial
use:
2.
The innovative technology of in situ vapor stripping
that uses vacuum wells to volatilize and remove
volatile organic compounds from the landfill materials
and surrounding soils: and
3 .
The additional protection pr~vided by institutional
controls to restrict the use of contaminated
groundwater and the installation of security fencing
around the property ~~ prevent direct human contac~
with contaminants at the site.
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STAT'C'l'ORY Dl5"r~HATYONS
Pursuant to duly delegated authority, I hereby determine
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 i. cost-effective as
set forth in section 121(d) of CERCLA, 42 C.S.C. Section 9621(d).
This remedy satisfies the statutory preference, a. set forth in
section 121(b) of CERCLA, 42 C.S.C. Section 9621(b), for remedial
actions in which treatment that reduces toxicity, mobility, or
volume is a principal element.
Finally, it i. determined that
this remedy utilize. permanent solutions and alternative
technologies to the maximum extent practicable.
Because this remedy will result in hazardous substances
remaining on-site, it will be reviewed within five year. after
the initiation of the remedial action in order to assure that
human health and the environment are adequately protected by the
.-
remedy.
Date
b ~'/f?J
,
G-
rickaon
Adainiatrator
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SECTION
I.
II.
III.
IV.
V.
IV.
VII.
VIII
TABLE OF CON'l'EN'l'S
FOR .
DECISION SUKKARY
PAGE
SITE NAME, LOCATION, AND DESCRIPTION
. . . . . . . . .
1
SITE HISTORY AND ENFORCEMENT ACTIVITIES ......
1
SITE CHARACTERISTICS .........................
3
SUMMARY OF SITE RISKS........................
8
SCOPE OF REMEDIAL ACTION ..................... 14
COMMUNITY RELATIONS HISTORY.................. 14
DOCUMENTATION OF SIGNIFICANT
CHANGES FROM PROPOSED PLAN ................... 15
DESCRIPTION OF ALTERNATIVES .................. 15
IX. COMPARATIVE ANALYSIS OF ALTERNATIVES ......... 22
X. SELECTED REMEDIAL ALTERNATIVE ................ 31
XI. STATUTORY DETERMINATIONS ..................... 32
APPENDIX
A.
RESPONSIVENESS SUMMARY
APPENDIX
B.
ADMINISTRATIVE RECORD INDEX
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RECORD OF DECISION
LORD-SHOPE LANDFILL SITE
DECISION SUMMARY
I.
SITE NAME. LOCATION. AND DESCRIPTION
The Lord-Shope Site ("the Site") is located west of Pieper
Road approximately 4500 feet south of the intersection of U.S.
Route 20 and Pieper Road in Girard Township, Erie County,
Pennsylvania, as shown in Figure 1. To the north of the site and
to the west of the Site are two unnamed tributaries of Elk Creek.
The Site consists of an inactive, hazardous waste landfill
covering approximately 4 acres, and the adjacent areas of
contaminated soil, surface water, and groundwater. The 25.2 acre
property containing the landfill is currently owned by the Lord
Corporation ("Lord") of Erie, Pennsylvania.
The landfill currently appears as a grass covered hill which
rises approximately twenty feet at its highest point. The
surrounding area is primarily rural agricultural with scattered
residential areas bordering the roads. The property is bounded
by two residences to the east located on Pieper Road, an apple
orchard and vinyard to the south, an evergreen nursery to the
west, and an overgrown corn field to the north. A golf course is
located to the north of the landfill property, adjacent to the
corn field. The only nearby residences are located along Pieper
Road to the east and along Route 20 to the north. The nearest
population center, Girard Borough, is located two miles to the
northeast.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
From the mid-1950s until 1979, industrial wastes: including
spent adhesives, degreasing solvents, cutting oils, acids and
caustics: along with miscellaneous paper, wood and rubber wastes,
were disposed of at the site. Some wastes were disposed of in
drums. The property was then owned by Mr. Melvin Shope, who was
at that time an employee of Lord. The wastes originated at
Lord's Erie (12th Street) and Saegertown plants.
In 1982, after Lord had conducted some preliminary site
studies, Lord, Mr. Shope, and the Pennsylvania Department of
Environmental Resources (DER) entered into a Consent Order
and Agreement that called for continued monitoring and the
implementation of a "remedial alternative" at the site. The
remedial alternative, implemented in 1982 and 1983, consisted of
the removal of approximately 81 exposed drums of waste,
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X
\ .X-T -
--*-i.-_^_
LEGEND:
BM 4 A BENTHOS SAMPLING LOCATIONS
SOURCE: ALBION (I9S9 . *EV. !»€»)
PA. 7.5* QUADRANGLE
2000
scale
2000
fe*t
MAP LOCATION
Site Location and
Surface Water Hydrology
SHORE'S LANDFILL SITE
LORD CORP.
GIRARD TWP. , PA.
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2
emplacement of a composite cap over the landfill, the
construction of a low permeability groundwater cutoff wall
upgradient (south) of the landfill, and the regrading and
revegetation of the Site. The construction of the cap included a
clay layer, a synthetic membrane, and a vegetative soil cover.
The objective of that remedial alternative was to reduce the
amount of contamination entering the groundwater by reducing
leachate production in the landfill and diverting groundwater
flow around the Site.
Under provisions of CERCLA, the Site was placed on the
National Priorities List (NPL) in September 1983. The
regulations enacted pursuant to CERCLA generally require that a
Remedial Investigation and Feasibility study (RIfFS) be conducted
at each NPL site. The purpose of an RI is to characterize
conditions at the site. The subsequent FS then develops,
screens, and analyzes a series of remedial alternatives which are
applicable to those site conditions and might be implemented at
the Site. The area studied in the Remedial Investigation for the
Lord-Shope Site included the landfill and plume area, the area
immediately surrounding the Site, the two tributaries and
drainage patterns that make up the surface hydrology and the
groundwater system below these areas (",study area"). .
In order to supplement the existing site information and to
meet the requirements of CERCLA, DER and the U.S. Environmental
Protection Agency (EPA) requested, in 1985, that Lord conduct a
"focused" RI to characterize groundwater conditions, and an FS at
the Site. In 1987, Lord's agreement to conduct the RIfFS was
embodied in a Consent Order signed by DER and Lord. The RI was
conducted and the RI report submitted by Lord's environmental
consultant, AWARE INC. FOllowing evaluation of that report, it
was decided that further investigations at the Site were
necessary. DER and EPA requested that a "Phase II" RI and FS be
conducted. This investigation was conducted for Lord by
ECKENFELDER INC. (formerly AWARE INC.) and the reports, after
being finalized, were placed in the information repositories
described in section VI, Communitv Relations Historv.
Due to the landfill's leachate generation, groundwater
beneath and north of the landfill contains several volatile
organic compounds (VOCs) and inorganic compounds indicative of
site-related contamination. Several areas around the landfill
perimeter are wet in certain seasons. These areas have been
designated "seep" areas. These seeps represent areas where the
groundwater level rises above the ground surface and have been
found to contain site-related VOCs. No flow from these areas has
been observed. Air quality studies, conducted after the cap and
cut-off wall construction was completed in 1983, have shown no
indications that the ambient air has been degraded by the
landfill or associated contaminants.
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3
Residences and businesses in the Site vicinity, including
those immediately adjacent to the landfill, rely on groundwater
(private wells) for their drinking water supplies. Past and
ongoing monitoring of private well water supplies indicates that
the Site has not affected area water supplies.
III.
SITE CHARACTERISTICS
A. Geoloaic Conditions
Typical geologic features in the vicinity of the Lord-Shope
Landfill Site are depicted in Figure 2. This figure depicts the
surficial glacial deposits as they have been reported by E.E.
Schooler, in General Geoloav ReDort 64 (1974). Of primary
interest are the Ashtabula and Girard end moraines and a beach
ridge formed along the shoreline of the last inundation of
glacial lake Maumee III. Generally, the site is underlain by a
thick series of glacial deposits. These deposits include at
least three laterally extensive glacio-lacustrine deposits
interbedded with intervening glacial tills. Minor amounts of
glaciofluvial deposits were observed at the surface. Bedrock was
not encountered in any of the borings conducted during the
Remedial Investigation.
B. Groundwater Conditions
Groundwater has been found to occur within three zones
beneath the Lord-Shope Landfill study area:
1.
2.
The first water bearing unit ("Water Table Zone")is
unconfined and ranges in depth from 15 to 30 feet below
the surface. This zone consists of the coarse-grained
Ashtabula Till and Maumee III C lacustrine deposits,
with lenses of fine grained materials. These shallow
materials are among the most permeable that occur at
the Site, with an estimated average hydraulic
conductivity of 6 x 10."cm/sec. The Water Table Zone
receives recharge predominantly through direct
infiltration of precipita~ion. Lateral flow in this
zone is primarily to the north and northwest.
The second water bearing unit ("Intermediate Zone")
occurs within the coarser grained deposits of the
Maumee III B and the coarse grained Ashtabula Till.
The geologic deposits comprising this zone have a
moderately low hydraulic conductivity of approximately
6 x 10.5 cm/sec. This zone is almost completely
confined by overlying materials except in some
important areas. The exceptions include two areas
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BEACH RIDGE DEPOSITS
GLACIAL MORAINE
SOURCE: I. ALBION (1959 , REV. 1969 j
PA. 7.5' QUADRANGLE
2-SCHOOLER (1974)
2000
scale
20OO
feet
MAP LOCATION
FIGURE 2.
REGIONAL SURFICIAL
GEOLOGIC MAP
S MO PC'S LANDFILL SITE
LORD CORP.
SIR ARC TWP. , PA.
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4
directly beneath the northeastern edge of the landfill
and in the area of the plume north of the landfill
where the Intermediate Zone is in hydraulic contact
with the Water Table Zone and has been shown to have a
higher hydraulic conductivity.. Lateral flow in this
zone is also to the north and northwest.
3.
The third water bearing unit ("Deep Zone") is located
within the coarser grained deposits of the Maumee III A
lacustrine deposits, ranging in depth from
approximately 75 to 105 feet below the ground surface.
This unit has a hydraulic conductivity estimated at
4 x 10.5 em/sec. The lateral flow in this zone is to
the southwest; radically different from the two zones
above it.
Zones of lower hydraulic conductivity, termed aquitards,
separate each of the water bearing zones. The "Upper Aquitard"
separates the Water Table Zone and the Intermediate Zone while
the "Lower Aquitard" separates the Intermediate Zone from the
Deep Zone.
Deeper groundwater bearing zones probably exist belo~ those
that were studied in the Remedial Investigation. These zones may
bE contained within deeper glacial deposits and/or bedrock that
u~~erlies the site. These zones were not part of the studies
performed at this Site as they would be beneath the .Deep Zone
which studies have shown to be unaffected by the Site.
C. Surface Water Conditions
Elk Creek Tributaries The land in the vicinity of the Site
is drained by two unnamed streams that ~~e tributaries of Elk
Creek. Elk Creek is a major stream tha~ drains directly into
Lake Erie, approximately 2 1/2 miles to the north. The larger of
the two unnamed streams, termed the Elk Cr~~~ Tributary,
originates approximately 2/3 miles southea~ ~f the Si~e and
flows around the south, west, and north sid~s of the Site. A
smaller stream, the ~nnamed Tributary, originating immediately
north of the Site, flows north to a point where it joins the Elk
Creek Tributary. The Elk Creek Tributary flows continuously
throughout the year in the vicinity of the Site. However, ~he
smaller Unnamed Tributary stream flows only seasonally, in
periods of wet weather, in the upper 1,000 ft of its length.
Neither of these streams flows directly on the Lord-Shope
Landfill Site.
site Drainaae Surface drainage of precipitation on the
landfill cap is now well controlled by drainage improvements
constructed as a part of the remedial action in 1982 and 1983.
Most run-off likely recharges the water table in this area.
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5
However, some of this flow also moves directly to a poorly
defined swale that flows in a northwesterly direction from the
site.
Several areas adjacent to the site are seasonally wet.
These are localized areas in which the shallow water table
intersects the ground surface in low-lying areas. These areas
have been designated "seeps".
D.
Nature and Extent of contamination
The nature and extent of site-related contamination around
the landfill has been evaluated by a number of investigations;
the most recent being the Phase II Remedial Investigation
concluded in 1989. The investigations identified the
contaminated or potentially contaminated media to be the landfill
materials, groundwater, subsurface soils, and, to a limited
extent, surficial soils. A summary of the mean contaminant
concentrations in the affected media is included as Table 1.
Groundwater Contamination A contaminant plume, consisting
primarily of volatile organic compounds, has been identified to
the north and northwest of the Site. The contamination appears
to be migrating primarily in the Intermediate Zone, but has also
been demonstrated in the Water Table Zone. In general, the plume
has migrated to the north and west approximately 150 to 600 feet,
however, in an area directly north of the landfill a "plume
extension" has migrated approximately 1400 feet in an area shown
to have a higher conductivity. The VOC contaminant plume for the
Intermediate Zone is indicated in Figure 3.
A group of halogenated and non-halogenated volatile organic
compounds has been identified by the CLP analytical protocols
that are at present employed to analyze the site groundwater
samples. This group includes primarily methyl isobutyl ketone
(MIBK), 4-methyl-2-pentanol, acetone, methyl ethyl ketone (MEK),
vinyl chloride, trans-1,2-dichloroethene, and terahydrofuran
(THF). In addition to each of these compounds, the GC analytical
methodology that was employed prior to 1988 had identified
significant concentrations of cyclohexanone, 2-butanol,
isopropanol, and tetrachloroethene. These compounds correspond
well to the types of wastes known to have been disposed in the
landfill. The various ketones are shown to be the predominant
organic constituents.
With several exceptions, semi-volatile constituents have not
been detected in groundwater samples collected from the Site.
The exceptions include low level detections of benzo (k)
fluoranthene and benzoic acid in several of the plume wells
located very close to the margin of the landfill. PCBs and
pesticides were not detected.
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TABLE 1.
SUMMARr or HETAtS COHC£HTRAiIONS
(ppb)
Hed lull Alu.lnull Arsenic Bartu. Cadlliu. ChrOlllu. Cob a It Copper Lead Hercur)' Nickel Zinc
Groundwat.er - Best Est.l.atea
LOCii li on 1I-]9B \1-28 11-20B 11-20B 11-39B 11-39B 11-]11 11-28 11-20B 1I-]9B 11-398
Hean 26,000 11.9 11,200 8. I 61 11 16 60 1.5 15 160
'alues 3,350 11.9 11,250 6 116 11 16 60 2.8 32 39
118,100 6,020 6 88 0.3 111 289
11,000 16.11
3,600 6.]
11,090 11.1
],530 10
3,860
Groundwat.er - U!'per Bound b
~alion II-IA II-IA 11-] 1f-3 11-7 lIT 11-7 lIT 11-3 11-5A 11-311T "-711T II-IA
Hean J7 ,000 II] 5,800 9 111 11 11,1100 100 1.5 129 5,500
Values 2",600 50 5,"10 5 III 71 2],]00 2]0 1.5 129 95)
8,610 35 6,"30 1] 1]0 112 8,980
78,200 5,110 111 211 3,180
6,350 1511 8,"10
5,770 160
Surrar.e Wat.er - Seeps
-rocat.lon NE Seep NE Seep NE Seep HE Seep NE Seep NE Seep HE Seep HE Seep
Hean 5,1100 20 290 HOc ]2 "0 ]2 50 12 "0 160
Values 129 II 218 32 32 50 0.] 250
15,100 29.6 329 2.3 213
280 2.3 2611 26
St",.. Sedl.ent.
LocaUon SW-5 511-5 511-6 511-1 511-5 511-11 511-1 511-5 311-] 511-1 511-1
Hean 9.3E.06 111 ,000 81,000 1,000 10,000 1 I ,ooa 23,000 17 ,000 110 19,000 111,000
'alues 1. 1£+01 1,100 55,000 1,600 6,500 6,600 20,1100 12,JOO 110 20,800 111,900
9.2E.06 20,800 l01,aOO 10,300 8,500 23,000 22,1100 20,000 90,000
I.OE.01 20,200 115,1>00 9,700 11,700 22,500 21,800 20,500 1111,200
6.7£+06 13,000 12,800 111,000 211,200 25,100 8,100 15,800 12,300
6,900 5",500 11,500 12,100
....
a"Croundwal"r - Best. Eslllllal,," Includ"s lhe .Ia la ror the well contalnlns the lIa-lllull conc~ntr..l1",HI ,}r a~ ::', par.,"" ter 1" the flroup or
.onllorlng wp.lls localed norlh or the Lord properly line.
b"Grnundw"I...r - :'"".r !\OllIlJ" Includes the dala ror lhe we II conla In Ing the lIalllllull concentr'lt1nns or each parallet.er oul or all or the
sit" ..nnllorlnR ~lls.
r. .. Indl<-al"" lhllt lh.. "","l1r.u"'r cOI1ll'0und was not de t.ec led In a,{ 'I'le (or the noted ..edlu...
-------
TAI~. L (continued)
SUMMARY Of' YOLATIL~ nR~ANIC CONCENTRATION':>
(Ppb)
---
1,1- Tf!tra Trans- 1,2- Hethyl "ethyl Tet,....
Chloro- Dlchloro- chloro- Dlchloro- Trlchloro- Vinyl Ethy 1 !sobuty I hydro- 11-8e th, 1-
Hedlu8 Benzene benzene ethane ethene Toluene ethene ethen!! :::'lorlde letone letone Acetone ru,...a 2-Pentanol
Groundwater - ge8t E8tlllate8
Locetlon II-JII II-J6B 11-20B 11-208 II-JII II-JII 11-2!J!. II-JII
Hean T NDc NO NO NO 1,200 NO 1,500 "0 1190 1,100 1110 510
'alues T 1,200 2,1100 1190 1,100 1110 1,000
1,900 28
200
Croundw8 te r - Upper Boundb
Location V-J5B V-J W-~VT V-J W-36B V-9WT W-2!J!I II-J II-J ':-J II-~A 11-]
Helin 12 " JII NO 21 1,200 56 1,500 7,1100 25,000 11,000 360 52,000
Yalue8 12 " JII 27 1,200 65 2,1100 7,1100 118,000 37,000 25' " ,000
.. 117 1,900 8,1100 930 116' " ,000
112,000 5,800 180,000
200 3,1100 960 6,900
Sur face Va te r - Seep8
Locallon SE-Seep SE-Seep NE-Seep
Helin NO NO NO NO NO 130 H 56 NO NO NO ~ ND
'alue8 130 JJ 56
Oownstreae Sed lment
LocattO;;---- SII-7 SII-5
Hean NO 18 NO NO NO ND NO NO NO "0 90 II:) HD
Va lues 18 90
Surrtc 1a I SoIls
-.r.ian 6.11 NO NO 180 " NO ND ND NO NO ND II!) HD
hi ue s 6.11 " 7.8
72 10
J2 15
620
9
."C.,..".,"' - .", E,""'" ,...",., 'h, ,.,. r.. th, .." "'h I.,.. lh, ... ,.". .~.....".,.. ,r ".h p",-,,, ,. th, ""p ,r _."",.. "'''.
located north of the Lord property Iloe.
-'C.,."",,", - "PP"' .,..d' '''''''' lh, ,.,. r,. lh, .." "...,.," lh, ....... ......,....,.. or mh p'"-,,, ,.. ,r ... ,r tho "" .~....,..
III!lh.
cONDo IO'licate" that the p.lrlleul.lr COl1lpouo,1 wa" n"t d'Hl!'cted In any 8al1lple for the noted lied lUll.
-------
Leading edge of
Contaminaticm Plume
\ 1 1 \ VI
Landfill Perimeter
• FIGURE 3.
LORD-SHOPE LANDFILL
MIGRATION PLUME FOR VOLATILE ORGANIC CONTAMINANTS
IN THE INTERMEDIATE GROUNDWATER ZONE
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6
The primary plume constituents at the Shope's site are
volatile organic compounds. However, a number of inorganic
compounds principally consisting of a group of metals and
chloride have been noted in wells installed in the plume.
statistically significant levels of metals have been detected in
the Water Table and Intermediate Zones including barium, cadmium,
chromium, cobalt, copper, mercury, and zinc. However, most of
these metals are restricted to the wells located close to the
landfill. Only barium exceeds its MCL for drinking water.
The Deep Zone has not shown evidence of any contamination.
Residential wells in the area have also not shown any evidence of
any contamination.
Surficial Soils Surficial soil contamination has been
identified in several areas around the landfill. Several of
these areas correspond to the seep areas in which contaminated
standing water has been observed. This is the case in areas
immediately northeast, north, and southwest of the
landfill. Laboratory analysis of samples taken immediately below
the surface indicate that surficial soil contamination is highly
localized and that it exists in low concentrations for volatile
organic compounds.
The most significant area of surficial soil contamination is
the landfill toe area. This area is located immediately
southeast of the site and is depicted in Figure 4. The highest
levels of total volatile organic compounds (TVOs) observed in
this area with a field photoionizer detector range up to 300 HNU
units. HNU units are an approximation of TVO levels and are
equal to parts per million (ppm) when measuring the compound to
which the meter was calibrated and an approximation of ppm when
measuring other organics. One possible explanation for
contamination in this area is spillage from trucks entering the
site at the time of landfill operation.
The volatile contaminants within the surficial soils have
been characterized. Tetrachloroethene has been shown to be the
most abundant constituent, with concentrations being detected in
12 samples at values up to 620 ppb. Toluene was detected in four
samples at concentrations ranging to 15 ppb. Ethyl benzene is
the only other compound found in more than one sample and was
detected in three samples at concentrations ranging up to 5.3
ppb. Benzene and methylene chloride were found in only one
sample each at concentrations of 6.4 and 8.0 ppb, respectively.
Deep Soils A deep soil study focused on the landfill
perimeter indicated that the most significant levels of
contamination in soils, at depths ranging from 6 to 68 inches,
occurred on the hill 70 ft southeast of the landfill. TVO levels
measured with the field photoionizer detector reached a maximum
of 580 HNU units at a depth of 13 ft. Below that depth,
-------
FIGURE 4.
Landfill Toe und
Crested Soil Areas
-------
7
contamination levels dropped to nearly non-detectable levels at a
depth of 30 ft. The magnitude and penetration of soil
contamination was not as extensive in the other borings.
The volatile constituents identified by the selected
laboratory analyses of the deep soils are very similar to those
for the surficial soils. Tetrachloroethene was found in a number
of deep samples at concentrations ranging up to 51.7 ppb.
Scattered low level detections of ethyl benzene, toluene, and
trichloroethene were also observed in these samples.
A second deep soil study was conducted above the plume
extension in the area north of the landfill. The soils were not
believed to be contaminated as a direct result of chemical
leakage or spillage as are the soils on the landfill perimeter.
Rather, the soil pores are believed to contain the contaminated
groundwater of the plume extension.
Contamination in the soil samples correspond to the
approximate location of the plume extension in the Water Table
Zone and Intermediate Zone as determined by monitoring well
sampling.
As with the surficial soils and the deep soils of the
landfill perimeter, contamination of the deep soils in the area
of the plume extension is highly localized and exists at
relatively low concentrations. Compounds detected in the
laboratory analyses of the soil samples, and their maximum
respective concentrations, were: acetone (1.7 ppm), methyl ethyl
ketone (0.3 ppm), vinyl chloride (0.3 ppm), 4-methyl-2-pentanol
(2.6 ppm), 1-butanol (0.4 ppm), tetrahydrofuran (0.3 ppm), methyl
isobutyl ketone (1.0 ppm), and methylene chloride (0.2 ppm).
other Environmental Media Several of the other
environmental media at or near the site have been sampled during
the RI project and during previous investigations. These media
include surface waters and sediments from the stream tributaries,
seep areas, drainage swales, standing water in low-lying areas,
and ambient air. The significant conclusions of the RI regarding
these other media are summarized below:
No indications of landfill-derived organic compounds
have been observed in sediments of the two small
streams in the vicinity of the site. There is some
evidence of elevated metals in the sediments of the
small stream located north of the landfill.
Small volumes of surface water containing volatile
organics have been identified in the seep areas
immediately adjacent to the site. However, no
observable flow emanates from these wet areas.
-------
8
The ambient air quality at and adjacent to the landfill
is not being affected by the site. All photoionizer
detector readings indicated non-detectable or
background levels of volatile organic compound&.
IV.
SUMMARY OF SITE RISKS
A Baseline Public Health Evaluation and a Biological
Evaluation were performed at the Lord Shope Landfill Site in
accordance with guidelines established by EPA for performance of
such evaluations at Superfund sites. Indicator compounds were
selected and associated risks were calculated for the different
affected media and potential exposure routes at the site. The
results of these studies were reported in detail in the Remedial
Investigation Report and are summarized here.
The following compounds were selected as indicator compounds
for the characterization of risk because of their presence in the
contaminated media at the site and because of their potential
chronic health affects:
Carcinoaenic ComDounds
Noncarcinoaenic Compounds
Acetone
Barium
Cadmium
1,2-trans-Dichloroethene
Lead
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethene
Tetrahydrofuran
Currently there is the possibility of human exposure through
accidental ingestion of water from the seeps C~ accidental
ingestio~ of contaminated soils or sediments at the Site.
Arsenic
Benzene
Lead
Tetrachloroethene
Tetrahydrofuran
Vinyl Chloride
Since the cap and vegetative cover were implemented in 1984,
there has been no detection of volatile organic compounds in the
breathing space. The highest detection of total volatile
organics in the air was 2 parts per million at ground level near
the northeast seep. Consequently, the air pathway of expo:'ure is
considered insignificant.
The greatest pote~tial risk from Site-related contaminants
is by the ingestion of contaminated groundwater. This exposure
route is currently incomplete as there are no drinking wat~r
wells currently drawing water from the contamination plume.
Under CERCLA, EPA must consider current and potential exposure
scenarios in determining the risks from exposure to the sites.
As is shown in Figures 5 and 6, although current land use in the
-------
A AGRICULTURAL
_.' R RESIDENTIAL
1 C COMMERCIAL
F FOREST
GC GOLF COURSE
SOURCE: ALBION (1999, REV. IMf)
PA. 7.3' QUADRANGLE
2000
LOCATION
FIGURE 5.
LAND USE MAP
SHOPE'S LANDFILL SITE
LORD CORP.
TWP., PA.
-------
6178
1
I AGRICULTURAL
R-l LOW DENSITY RESIDENTIAL
R-2 MEDIUM DENSITY RESIDENTIAL
R-3 HIGH DENSITY RESIDENTIAL
C-l HIGHWAY/PLAZA COMMERCIAL
FIGURE 6.
ZONING MAP
SOURCE: I.ALBION (I9S», REV. IMt)
. 7.3' QUADRANGLE
SHORE'S LANDFILL SITE
LORD CORP.
GIRARD TWP., PA.
2.GIRARD TOWNSHIP OFFICIAL
ZONING MAP, (12/3/79)
0 20OO
MAP LOCATION
-------
9
plume area north of the Site is golf course and forest, the area
is zoned high density residential and thus is a potential area
for residential development. In addition, a goal of the
Superfund program is to restore groundwater to its most
beneficial use whenever possible. Given the statutory and policy
goals of the Superfund program, EPA is considering the risks from
potential future use of the groundwater.
Tables 3 through 8 present the risks associated with
ingestion of water from the northeast seep, ingestion of
contaminated soil or stream sediments from the Site, and
ingestion of groundwater. .
The estimated carcinogenic risks for the groundwater,
surface water (seeps), and soil ingestion routes are presented in
Tables 3, 5, and 7. The carcinogenic risks reported are "excess
lifetime cancer risks", determined by multiplying the estimated
chronic daily intake level by the cancer potency factor. These
risks are probabilities that are generally expressed using
scientific notation (e.g. 1.0 x 10-6 or 1.OE-6). An excess
cancer risk of 1.OE-6 indicates that, as a plausible upper limit,
an individual has an additional one in one million chance of
developing cancer solely as a result of 70-year cumulative
exposure to a substance under specific exposure conditions. The
exposure conditions assumptions used for risk calculations at
this Site are summarized in Table 2. The term "upper limit"
reflects the conservative nature of the assumptions used in the
calculation of the potency factor.
The potential for adverse health effects resulting from
chronic exposure to noncarcinogenic compounds is estimated by
comparing an average daily intake to an acceptable level such as
a chronic reference dose (RfD). If the ratio exceeds one, there
is a potential health risk associated with exposure to that
particular compound. The ratios can be added together for
exposures to multiple compounds. This sum, known as the Chronic
Hazard Index, is not a mathematical prediction of the severity of
the tox~c effects; it is simply a numerical indicator of the
transition from acceptable to unacceptable levels. The
noncarcinogenic Chronic Hazard Index calculated for the Lord
Shope Landfill Site are presented in Tables 4, 6, and 8. EPA
considers that any Chronic Hazard Index exceeding one presents an
unacceptable risk to human health.
Inqestion of Groundwater
As shown in Tables 3 and 4, the potential risk associated
with the ingestion of groundwater is represented by an excess
cancer risk of l.OE-Ol and a chronic Hazard Index of 2.8E+Ol.
The potential risks from groundwater are calculated using the
"upper bound" concentrations. For the investigations at this
Site, upper bound is defined as the average concentration of the
-------
TABLE 2
ASSUMPTlOOS USED
TO ESTIMATE HUMAN Im'AKE FACl'ORS
FOR 'IRE £VAWATED Ex:roSURE PA'IHWAYS
Pathway
Average
Daily
Intake
Frequency
of
Intake
(days/year)
Duration
of
Intake
(years )
Average
Body
Weight
(kg)
Human
Intake
Factor
Groundwater
Ingestion 2 1/day 365 70 70 2.9£-02 1/kg/day
Surface water
Ingestion 1 1 / day 26 70 70 1.0£-03 1/kgiday
Sediment,' soil
Ingestion
(Child) 0.1 g/day 90 10 20 1.8E-07 kgikgiday
The human intake factor for each pathway is calculated by:
Average Daily Intake x (Frequency/365 days) x (Duration/70 years) IBody Weight
-------
TABLE 3
ESTIMATED 'RISKS FE01 PCfI'ENTIAL CARcINCX:;ENS
INGESI'IOO OF G~TER, UPPER BOUND COOCENTRATICNS
Indicator Chemical Concentration Chronic Daily Potency Factor £stimated
(carcinogen) in Groundwater Intake (CDI) (PF) Risk
(rrg/l) (rrg/kg/day) (rrg/kg/day)-l
Arsenic 0.043 1.2E-03 1. 75E+00 2.1E-03
Benzene 0.012 3.5E-04 2.9E-02 1.0E-05
Lead 0.1 2.9E-03 ND ND
Tetrachloroethene ND ND 5.1E-02 ND
Tetrahydrofuran 0.36 1.0E-02 ND ND
Vinyl Chloride 1.5 4.4E-02 2.3E+00 1.0E-01
Total Upper Bound Carcinogenic Risk 1.0E-01
The estimated carcinogenic risk is the sum of CDI x PF, where CDI = Chronic
Daily Intake = (the Concentration x the Human Intake Factor) and PF = Potency
Factor.
For the ingestion of groundwater, the Human Intake Factor = 0.029 l/kg/day.
Potency Factors obtained either from the EPA's Integrated Risk Information
Service (IRIS) database (June 1989) or fran the April 1989 Health Effects
Assessment Surmlary Tables (HEAST).
~ = Not Applicable.
available.
ND = Not Detected, Not Determined or not currently
-------
TABLE 4
ESTIMATED RISKS FRCM NOOCARCINse Chronic
(noncarcinogen) in Groundwater Intake (CDI ) ( RfD) Hazard Index
(rrg/1) (rtg/kg/day) (rrg/kg/day) HI = CDI/RiD
Acetone 11 3.2E-01 1.0E-01 3.2E+00
Bari\.un 5.8 1.7E-01 5.0E-02 3.4E+00
Cadmium 0.009 2.6E-04 5.0E-04 5.2E-01
1,2-trans-
dich1oroethene 1.2 3.5E-02 2.0E-02 1.8E+00
Lead 0.1 2.9E-03 ND ND
Methyl Ethyl Ketone 7.4 2.1E-01 5.0E-02 4.2E+00
Methyl Isobutyl
Ketone 25 7.3E-01 5.0E-02 1. 5E+01
Tetrachloroethene ND ND 1.0E-02 ND
Tetrahydrofuran 0.36 1.0E-02 ND ND
Total Upper Bound Chronic Hazard Index
2.8E+01
The estimated noncarcinogenic Chronic Hazard is the sum of CDI/RfD, where
CDI = Chronic Daily Intake = (the Concentration x the Human Intake Factor)
and RfD. = Reference D::>se (formerly termed the Acceptable Intake for Chronic
Exposure) .
For the ingestion of groundwater, the Human Intake Factor = 0.029 l/kg/day.
Reference Dose information obtained either from the EPA's Integrated Risk
Information Service (IRIS) database (June 1989) or f~ the April 1989 Healt.~
Effects Assessment Summary Tables (HEAST).
NA = ~t Applicable.
available.
ND = Not Detected, Not Determined or not currently
-------
TABLE 5
ESTIMATED RISKS Frow1 POTENTIAL CARCINCGENS
. INGESTIOO OF WATER FRG1 NORrnEAST SEEP
Indicator Chemical Concentration Chronic Daily Potency Factor Estimated
(carcinogen) in Seeps Intake (CDI) (PF) Risk
(~/l) (~!kg/day) (mJ!kg/day)-l
Arsenic 0.02 2.0E-OS 1.7SE+00 3.SE-05
Benzene ND ND 2.9E-02 ND
Lead 0.05 5.0E-05 ND NO
Tetrachloroethene ND ND 5.1E-02 NO
Tetrahydrofuran BMDL ND ND ND
Vinyl Chloride 0.056 5.6E-OS 2.3E+OO 1. 34E-04
Total Estimated Carcinogenic Risk 1.7E-04
The estimated carcinogenic risk is the sum of CDI x PF, where CDI = Chronic
Daily Intake = (the Concentration x the Human Intake Factor) and PF = Potency
Factor.
For the ingestion of surface water or seeps, the Human Intake Factor =,0.001
l/kg/ day. -
Potency Factors obtained either fram the EPA's Integrated Risk Information
Service (IRIS) database (June 1989) or from the April 1989 Health Effects
AsseSSI1V:mt Surrmary Tables (HEAST).
NA = Not Applicable. ND = Not t:etected, Not Determined or not currently
available. BMDL = Below Minimum Detection Limit; this indicates that the
compound was present, but at a concentration below the limit for accurate
or precise quantitation.
-------
TABLE 6
ESTIMATED RISKS FRG1 NONCARCINCX:;ENS
. INGESTION OF WATER FRCM 'DRI'HEAsT SEEP
Indicator Chemical Concentration Chronic Daily Reference D:>se Chronic
(noncarc~nogen) in Seeps Intake (CDI) ( RfD) Hazard Index
(ag/l ) (ag/kg/day) (ag/kg/day) HI = CDI/RfD
Acetone ND ND l.OE-Ol ND
Barium 0.29 2.9E-os 5.0E-02 s.SE-03
Cadmium ND ND 5.0E-04 ND
1,2-trans-
dichloroethene 0.13 1.3E-04 2.0E-02 6.5E-03
Lead 0.05 5.0E-05 ND ND
Methyl Ethyl Ketone ND ND 5.0E-02 ND
Methyl ";;obutyl
Keto ie ND ND 5.0E-02 ND
Tetrachloroethene ND ND 1.0E-02 ND
Tetrahydrofuran BMDL ND ~"D ND
Total Estimated Chronic Hazard Index
1. 2E-0 2
The estimated noncarcinogenic Chronic Hazard is the sum of CDI/RfD, where
CDI = Chronic Daily Intake = (the Concentration x the Human Intake Factor)
and RfD = Reference Dose (formerly termed the Acceptable Intake for Chronic
Exposure) .
for the ingestion of surface water or seeps, the Human Intake Factor = 0.001
l/kg/day.
Reference Dose information obtained either from the EPA's Integrated Risk
Information SeIVice (IRIS) da~ (June 1989) or from the April 1989 Health
Effects Assessment Surrmary Tables (HFAST).
~ = Not Applicable.
available.
ND = Not Detected, Not Determined or not currently
-------
TABLE 7
ESTIMATED RISKS Fro-t POTENTIAL CARCINCGENS
INGESTION OF SEDIMENTS OR SOlIE (CHILD)
Indicator Chemical Concentration Chronic Daily Potency Factor Estimated
(carcinogen) in Sample Intake (CDI) (PF) Risk
(m;/l) (m;/kg/day) (m;/kg/day)-1
Arsenic 14 1. 6E-08 1.75E+00 4.4E-06
Benzene 0.0064 1.2E-09 2.9E-02 3.SE-ll
Lead 17 3.1E-06 ND ND
Tetrachloroethene 0.18 3.2E-08 5.1E-02 1.6E-09
Tetrahydrofuran ND ND ND ND
Vinyl Chloride ND ND 2.3E+00 ND
Total Estimated Carcinogenic Risk 4.4E-06
The estimated carcinogenic risk is the sum of CDI x PF, where CDI = Chronic
Daily Intake = (the Concentration x the Human Intake Factor) and PF = Poten~j
Factor.
For the ingestion of soil, the Human Intake Factor = 1.87 x10-7 kg/kg/day.
Potency Factors obtained either from the EPA's Integrated Risk Information
Service (IRIS) database (June 1989) or fran the April 1989 Health Effects
Assessment SUImIarY Tables (HEAST).
NA = ~ot Applicable.
available.
ND = Not Detected, Not Determined or not currently
-------
TABLE 8
ESTIMATED RISKS FR:M NOOCARClNOOENS
INGESTICN OF SEDIMENTS OR SOILS (CHILD)
Indicator Chemical Concentration Chronic Daily Reference D::>se Chronic
(noncarcinogen) in Sanp1e Intake (CDI) ( RiD) Hazard Index
(m;/l) (ng/kg/day) (ng/kg/day) HI = CDI/RfD
Acetone 0.09 1.6E-08 1.0E-01 1.6E-07
Barium 81 1.5E-05 5.0E-02 2.9E-04
Cadmium 1.6 2.9E-07 5.0E-04 5.8E-04
l,2-trans-
dichloroethene ND ND 2.0E-02 ND
Lead 17 3.1E-06 ND ND
Methyl Ethyl Ketone ND ND 5.0E-02 ND
Methyl Isobutyl
Ketone ND ND 5.0E-02 ND
Tetrachloroethen; 0.18 3.2E-08 1.0E-02 3.2E-06
Tetrahydrofuran ND ND ND ND
Total Estimated Chronic Hazard Index
8."':;-04
The estimated noncarcinogenic Chronic Hazard is the sum of CDI/RfD, where
CDI = Chronic Daily Intake = (the Concentration x the Human Intake Factor)
and RfD = Reference LOse (forrrerly termed the Acceptable Intake for Chronic
Exposure) .
For the ingestion of soil, the Human Intake Factor = 1.87 xll;7 kg/kg/day.
Reference r:.ose infonnation obtained either from the EPA' s Integrated Risk
Infonnation Service (IRIS) database (June 1989) or frc:m the April 1989 Health
Effects Assessment Summary Tables (BEAST).
NA = ~t Applicable.
available.
ND = Not Detected, Not Determined or not currently
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10
well having the highest concentrations for each of the indicator
compounds. Typically these are the wells located closest to the
landfill perimeter which exhibit a higher degree of contamination
than those located further downgradient in the plume. The
exposure assumptions used in calculating the risks from
groundwater ingestion represent the daily consumption of two
liters of water over a seventy year lifetime.
The cancer risk is driven by the presence of vinyl chloride
while the noncarcinogenic risk is dominated by the presence of
methyl isobutyl ketone and methyl ethyl ketone. As shown in the
tables, other compounds are also in the unacceptable risk range.
This pathway is currently incomplete as there are no
drinking water wells drawing from the contaminated groundwater
plume and, therefore, no one currently drinking this water. At
present, however, the plume is located under land that has the
potential for residential development and if left untreated, the
plume migration could impact the wells of the residences on u.s.
Route 20 to the north.
Inqestion of Water from Seeps
As shown in Tables 5 and 6, the risks presented by ingestion
of the water contained in the seeps are represented by an excess
cancer risk of 1.7E-04 and a noncarcinogenic chronic Hazard Index
of 1.2E-02. These numbers are based largely on the. presence of
the carcinogens arsenic and vinyl chloride and the noncarcinogens
barium and 1,2-trans-dichloroethene in the northeast seep. These
numbers are estimated using the conservative assumptions of
consumption of a liter of water twenty-six times a year over a
seventy year lifetime. Although the numbers indicate an
unacceptable cancer risk for these exposure conditions, it is
highly unlikely that accidental ingestion of seep water would
proceed at that rate. .
-:
Inqestion of Soils or Sediments
The risks involved with the ingestion of contaminated Site
soils or sediments are represented by an excess cancer risk of
4.4E-06 and a noncarcinogenic chronic Hazard Index of 8.7E-04 as
presented in Tables 7 and 8. The concentrations used in the
calculation of these values are a combination of the
concentrations found in both the on-site soils and the downstream
sediments of the Elk Creek Tributary and the Unnamed tributary.
The assumptions used in the risk calculations for soil or
sediment represent a childs accidental ingestion of 0.1 gram per
day of soil ninety times a year over a ten year span. Even using
these conservative assumptions the risk estimates fall within the
acceptable ranges.
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11
EXDosure bv Air:
Inhalation of Volatiles EvaDoratina from SeeDS
During the RI an air survey of the site using a
pilotoionization detector found no measurable concentrations of
volatile organics in the breathing zone at any location.
Concentrations as high as 2 ppm were found near ground level
primarily at the northeast seep. Analyses of water samples from
the northeast and other seeps show total concentrations of
volatile organics (TVO) as high as 700 ppb with an average of
about 30 ppb. Analyses for individual compounds show vinyl
chloride, 1-2-trans-dichloroethene, and trichloroethene at levels
from 33 to 130 ppb. Volatilization of the organic compounds in
the seep waters is the apparent source of the organics in the
air.
The seeps are unlikely to cause significant risks to human
health given the inaccessibility of the seeps and the consequent
low probability of chronic exposure. The only area chronic
exposure to volatile organics from the seeps could occur is at
the nearby residences, about 1,000 ft away from the northeast
seep. In order to estimate the potential risks in this area, the
rate of volatilization of organic compounds from the northFcst
seep and the concentration in air downwind from the northe~s~
seep have been estimated.
The rate at which volatile organic compounds eyaporate from
the seep can be estimated by:
Q=KAC
where:
Q = the flux from the liquid surface, gls
K = the overall mass transfer coefficient, mls
A = the area of the seep, m2
C = the concentration in the seep, g/m3
For very volatile organics, such as benzene and vinyl chloride,
and moderate wind sfeeds, the overall mass transfer coefficient,
K, is about 4 x 10. m/s. This corresponds to a half-life of
around 7 hours for a - '~ry sh2,llow seep. In other wore.:, half the
volatile organics wou..i evaporate in the first seven hours.
Since water in the seeps is probably replaced more slowly than
this, it is unlikely that a higher mass transfer rate could be
sustained. The area of the northeast seep (the only seep on site
which is permanently wet) was liberally estimated to be about 350
square meters. The high TVO re~jing c~ 700 ppb was used as the
concentration in the water. With the: -~ values, the maximum rate
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12
of volatilization from the northeast seep was estimated as 0.001
g/S.
The concentration in air downwind from the seep
estimated using a simple Gaussian plume model. At a
ground directly downwind from a ground level source,
concentration of contaminant in the air is given by:
can be
point on the
the
Q
c
=
17" OY CTz U
where:
C = the concentration, 91m3
Q = the emission rate from the seep, g/s
oy = the lateral dispersion, m
CTz = the vertical dispersion, m
U = the wind speed, mls
The model assumes a steady source, and is only valid for
distances at least 100 m from the source. The dispersion
coefficients depend on the distance from the source. For a 300 m
distance, 0y and 01 can be estimated to be 27 m and 12 m,
respectively. For an emission rate if 0.001 g/s and a wind speed
of 3.5 ml.s, the resulting concentration 300 m from the seep is
2.8 x 10"7 g/m3 or 0.3 ug/m3. This analysis is expected to be
conservative since it used a very high concentration of 700 ppb
for volatile organics in the seeps.
Making the very conservative assumption that all the
emission is vinyl chloride, the risk from inhalation can be
estimated using the methodology in SPHEM (EPA, 1986) by
multiplyipg the air concentration by the average daily intake of
air (20 m/day), dividing by the average weight of an adult (70
kg) and multiplying by the potency factor for inhalation of vinyl
chloride (0.025 (mg/kg/ dal)"'. The resulting potential cancer
risk estimate is 2.0 x 10" , which is within the acceptable
range.
Environmental ImDact of the Lord-ScoDe Landfill
Two Biological Investigations were conducted at the Lord-
Shope Landfill and surrounding area during the course of the
Remedial Investigation to evaluate the environmental impact
caused by the Site. The full results of these investigations are
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13
included as a separate volume in the Remedial Investigation
Report.
Sampling was conducted near the site and in the area of the
two tributaries of Elk Creek to assess any impacts of the
landfill on the benthic fauna. The sampling was conducted at the
eight stations shown in Figure 1. Stations BM2 and BM' were not
sampled in the most recent investigation, conducted in 1989. The
tributaries are believed to receive groundwater and surface water
discharge from the areas connected with the Site.
The investigations conducted at the observation stations
included classification of .streambed substrates, measurement of
community structure including the calculation of a number of
diversity indices, and the calculation of the Hilsenhoff Biotic
Index as a measure of water quality, as well as a statistical
comparison of the stations to determine the existence of local
effects. A wetlands evaluation was also conducted.
Results of these studies of the aquatic biota indicate that,
overall, the water quality is fair to excellent with a good
number of species and numbers of individual organisms. According
to the Hilsenhoff Index (1987) the following water quality
conditions were found during the most recent investigation:
Station
Location
Water Ouality
Condition
Comments
BM1
Downstream of
Landfill
Good
stream bottom stable
BM3
Control
Very Good
stream bottom stable
BM3A
Control
Good
stream bottom stable
BM4
Above Potential
Influence of land-
fill
Fairly Poor
stream affected by
agricultural runoff
BM5
0.4 miles up-
st:r~am of Highway
20
Fair
stream bank
physically denuded
BM6
At Highway 20 .
Fairly Poor
station impacted by
local activities ~n-
related to landf.-l
In the process of collecting benthic samples numerous
fathead minnows were observed and released. This was the only
fish species observed with the exception of two small bluegills
noted at station BM6.
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14
There are no presently recognized wetlands in the vicinity
of the unnamed tributary to the north of the landfill. There are
some areas upstream of the Elk Creek tributary, to the south of
the Site, that include some hardwood swamp environment. These
areas are not on the National Wetlands Inventory and are upstream
and considered to be outside the influence of the site or planned
Site activities.
There are no special or endangered species at the Site or in
the area of the Elk Creek drainage basin. There is no evidence
of impacts to biota in either tributary from activities at the
landfill.
Actual or threatened releases of hazardous substances from
this Site, if not, addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial endangerment to the public health, welfare, or the
environment.
V.
SCOPE OF THIS REMEDIAL ACTION
The remedial response action that is detailed in this Record
of Decision is a final action that addresses both the source of
contamination and the migrating plume of contaminated
groundwater. This is described in section X, Selected Remedial
Alternative.
VI.
COMMUNITY RELATIONS SUMMARY
In accordance with sections 113 and 117 of CERCLA, 42 u.s.c.
Sections 9613 and 9617, EPA, in conjunction with the Pennsylvania
Department of Environmental Resources, issued a proposed plan to
present the preferred remedial alternative. The proposed plan
and the RIjFS reports were made available to the public in the
copies of the administrative record maintained at the EPA Region
III offices and at the information repositories listed below:
Girard Township Municipal Building
10140 West Ridge Road, U.S. Route 20
Girard, Pennsylvania 16417
The Willcox Library
8 Main Street West
Girard, Pennsylvania
16417
EPA then instituted a public comment period from March 26, 1990
to April 25, 1990 for the purpose of soliciting public
participation in the decision process. As part of the public
comment period, a public meeting was held to present information
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15
and to accept oral and written comments and to answer questions
regarding the site and the remedial alternatives. A transcript
of the meeting was maintained in accordance with Section
1l7(a) (2) of ~ERCLA, 42 U.S.C. Section 9617(a) (2). Responses to
the oral and written comments received during the public comment
period are included in the attached Responsiveness Summary.
An announcement of
and the availability of
Feasibility reports was
1990.
the pUblic meeting, the comment period,
the Remedial Investigation and
published in the Erie Times March 23,
All documents supporting the remedy selection decisions
contained in this Record of Decision are included in the
Administrative Record for this site and can be reviewed at the
information repositories.
VII.
DOCUMENTATION OF SIGNIFICANT CHANGES FROM PROPOSED PLAN
The Proposed Plan for the Lord-Shope Landfill site was
released for comment in March 1990. The Proposed Plan described
the alternatives studied in detail in the Feasibility Study and
identified Alternative 3 as the Preferred Alternative. EPA
reviewed all written and verbal comments submitted during the
comment period and a- the public meeting. Upon review of these
comments, it was det~rmined that no significant changes to the
remedy, as presented in the Proposed Plan, were necessary.
The institutional contr::s described in Alternative 2, and
consequently included in Alternative 3, were nc~ originally
presented as part of the proposed plan but are ~ncluded in this
Record of Dec~sion as a logical and expecte~ extension of the
proposed alternative as discussed in the proposed plan and at the
pUblic meeting.
VIII.
DESCRIPTION OF ALTERNATIVES
The remedial objectives of the Feasibility Study performed
at this Site were to identify alternatives to address contaminant
source control and contaminated groundwater re-~diation.
Contaminant source control is expected to red~~e the rate of
release of contaminants into the water-bearing zones, and
contaminated ground~~~~r remediation will minimize potential
exposure of grot: "::iwc. '; ,-:' con,::, ~.inants to ~:.e public and the
environment and ;'Iake :uture '"all We:::: ": supplies available.
The Superfund Law requires that each alternative proposed to
address contamination at a hazardous waste site be protective of
human health and the environment, cost effective, and in
accordance with statutory requirements.
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16
Permanent solutions to contamination are to be achieved
whenever possible. In addition, emphasis is placed on treating
wastes on-site, wherever possible; to reduce the toxicity,
mobility, or volume of Site related contaminants, and on applying
alternative or innovative treatment technologies.
Technologies to implement these objectives which would meet
the requirements of pUblic health and environmental standards,
and other applicable or relevant and appropriate requirements
were evaluated. These technologies were also evaluated against
operational, institutional, cost and other factors affecting
implemntation. The technologies evaluated in the
Feasibility Study were combined into remedial alternatives to
address the Site.
The alternatives evaluated in the FS Report are summarized
below. The costs reported for implementing each alternative
represent both the preliminary estimates of initial capital
outlay and the estimates of continuing operation and maintenance.
Costs are reported as present worth figures calculated with a
discount rate of 10%. Costs of the alternatives are compared in
Table 9.
Alternative 1:
No Action
This alternative is included in the FS Report for comparison
with the other alternatives under investigation. It would only
be selected if the Site posed little or no risk to the public
health or the environment. Under this alternative, no
additional measures would be undertaken to remedy contaminant
sources or their migration pathways, and risks from the site
would remain and potentially increase with time. Because
hazardous materials would remain on the Site, five year
effectiveness reviews would be conducted.
Except for the costs involved with the five year review, no
capital or operation and maintenance (O&M) costs would be
incurred for this alternative, and no time expended beyond the
costs and time presently expended to maintain the existing
landfill cap and groundwater monitoring.
Source control and Miqration Control bv
Groundwater Extraction and Treatment
Alternative 2:
This alternative involves the extraction and treatment of
groundwater in the areas directly adjacent to the perimeter of
the landfill and to the north of the landfill. The extraction
and treatment would be implemented to halt the addition of new
contamination to the groundwater plume and to remove the
contaminants currently contained in the migrating plume. The
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TABLE 9.
COST ANAUSIS SUHI-IARY
--- - --
Allernative 1
Allernall ve 2
AlternaU ve ]
Alternalive 1111
Alternative qu
Costs
1989 Dollars
No Action
Source Control and
tIIgraUon Control by
Groundwater Extraction,
Groundwater Tr"eatment,
and Dlschar8e to
Surface Water
Source Control by
In Silu Vapor
Stripping; Source
and Migration Control
by Groundwater
Extraction,
Croundwater Treatment,
and Discharge to
Surface Water
Source Control by
Excavation, On Site
Incineration; Source
and !Ugralion Control
by Groundwater
Extracllon,
Croundw~ter Treatment,
and Discharge to
Surface Wilter
Source Control by
Excdvatlon, orr Site
lncinerallon;
Source and Higr~llon
Contro I by GrouruJwa ter
E_traction,
Groundwater" Trealment,
and DI sclla ",:e to
Surface Waler
Present Worth
1,9'10.,000 2,500,000 211,160,000" 180,OOO,OOOb
o ]10,000 1120,000 5,760,000 11/)'>,000
o ]10,000 1120,000 5,760,000 1165,000
'0 JIO,OOO ]10,000 5,760,000 1165,000
o 310,000 310,000 5,760,000 3 10 ,000
o 310,000 ]10,000 5,760,000 )10,000
o ]10,000 310,000 5,7fJO,OOO )10,000
o ]10,000 310,000 ]10,000 )10,000
o 5,010,000 5,760,000 50,9'10,000 183,1160,000
Cap ita I
O&t1
rear 1
rear 2
rear]
Year II
Year ')
rear 6
Year 1 - 50
aHajor cost Items; excavation, construction and operation of on slle Incinerator, completed within 6 yr.
bMajor cost Items; excavation, transportation and off site Incineration, completed within 21 yr.
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17
extracted groundwater would be pumped to an on-site groundwater
treatment system. At a minimum, this system would provide
pretreatment for the removal of iron and other metals, which is
necessary for the effective operation of the treatment system and
for achieving discharge standards, and air stripping for the
removal of volatile organic compounds. In the detailed design of
the groundwater treatment system other components may be added,
as necessary, to achieve the discharge standards. The treated
groundwater would be discharged to the unnamed tributary of Elk
Creek, subject to National Pollution Discharge Elimination System
(NPDES) permit regulations.
with the exception of air and water vapor, the emissions of
the stack gas will consist of volatile organic compounds. These
emissions will meet permit regulations for atmospheric emissions
in accordance with the Pennsylvania Air Pollution Control Act, 25
Pa. Code Section 127.1 requiring that emissions be the minimum
attainable through the use of best available technology. .
Cleanup goals for the groundwater were developed using
existing or proposed Maximum contaminant Levels (MCLs). Where no
MCL was available or where the other factors set forth in Section
300.430(e) (2) (i) of the NCP so require, health-based risk levels
were used in setting the cleanup goals for the groundwater at
this Site. As a result of this analysis, the cleanup. goals,
shown in Table 10, were set to levels representing 10-4 excess
cancer risks or hazard indices not exceeding 1.0 for each
contaminant determined to be present in groundwater in
concentrations above the appropriate MCL or health-based risk
level. Further, as part of this Alternative, background
concentrations of each contaminant will be determined through
groundwater monitoring. To the extent that the concentration of
any contaminant exceeds the background concentration, the cleanup
level will be modified to or set at the background concentration
unless attainment of background is determined to be infeasible or
is otherwise waived under section 121(d) (4) of CERCLA, 42 U.S.C.
Section 9621(d) (4).
A further component of this alternative is the
implementation of institutional controls to restrict the
permitting and construction of groundwater wells in the area of
the contaminated groundwater plume. This would prevent ingestion
by humans and interference with the efficiency of the groundwater
extraction system. These institutional controls would remain in
effect until all groundwater cleanup levels are achieved in the
current plume area and back to the perimeter of the landfill
("area of attainment").
This alternative also includes the installation of a
security fence around the property to prevent human contact with
the seeps and contaminated soils and to protect the treatment
system and equipment.
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TABLE 10
GR:XJNrWATER CLEANUP I..f.VEL GOALS
FOR THE LORD-SHOPE 4A.NDFILL SITE
Parameter Concentration Cleanup Level
(ug/l ) Basis
Acetone 3,500 Risk Based Calculationa
Arsenic 2 Risk Based Calculationb
Barium 1,000 MCL
Benzene 5 MCL
1,2-trans-dichloroethene 100 Proposed MCLc
Lead 15 Risk Based Calculationd
Methyl Ethyl Ketone 1,750 Risk Based Ca1culationa
Methyl Isobutyl Ketone 1.750 Risk Based Calculationa
Tetrachloroethene 5 Proposed MC:"~)
Trichloroethene 5 MCL
Vinyl Chloride 2 MCLe
aThe risk .:.ased calculations perforned for the indicated noncarcinogenic
c~~unds are calculated by carparing chronic human intake to Reference IX:>se
inf::=mation obtained eit&"ler friln the EPA' s Integrated Risk Information Service
(IRIS) data~se (June 1969) )r fran the April 1989 Health Effects Assessrrent
Surtrnary Tables (HFAST). The: ratio of these values is not to exceed 1.0.
brhe risk based calculation perforned for arsenic is predicated on an excess
cancer risk of 10-4.
cproposed in Federal Pegister, May 22, 1989.
dThe risk based level for: .:id is based on stt:c'ies that indicate drinking
water levels of 15 ppb an:: lower correlate to blood lead levels below the
concern level of 10 ug/dl.
~isk based calculations perforned on the MCL for vinyl chloride show an
excess cancer risk of 1.4 x 10-4. This limit is based on the limit of detecticr.
for this coopound and is considered to be protective.
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18
During the RI a three dimensional groundwater flow model was
used to describe and predict the characteristics of the ground
water system at the Site. Results of this effort indicate that
the plume migration would be halted within two months of
implementation of this alternative. The estimated time period
required for the remediation of the established groundwater plume
to the determined cleanup levels is approximately fifty years.
Potentially, continued leaching of contaminants from the landfill
materials would indefinitely extend the time required for
extraction and treatment of groundwater at the perimeter of the
landfill. The estimated cost of this alternative is 5 million
dollars.
Alternative 3:
Source Control bv In Situ VaDor StriDDina with
Groundwater Extraction and Treatment
This alternative includes the remedial activities described
in Alternative 2 (groundwater extraction and treatment, security
fencing, and institutional controls) plus additional source
control by in situ vapor stripping of the landfill and
surrounding soils (i.e., the soils contained in the landfill toe
area and the crested soil area shown in Figure 4).
In accordance with SARA's preference for remedies that
address the source of contamination and that utilize treatment to
reduce the toxicity, mobility, or volume of hazardous substances,
the in situ vapor stripping component of this alternative will
remove and treat volatile and semi-volatile organics from the
vadose zones of the landfill and surrounding contaminated s~ils.
Additionally, in situ vapor stripping is expected to reduce ~he
duration of the groundwater extraction and treatment needed to
attain the cleanup levels.
In situ vapor stripping is a process in which air is
introduced through vent pipes, passes through the media and is
withdrawn through vapor extraction wells. As the air passes
through the media, the volatile organics absorbed onto the soil
or other materials are partitioned into the air stream ("off
gas") and removed as the air is extracted. This air stream is
then collected and treated for contaminant removal by carbon
filtration or other appropriate process to be determined in the
detailed design.
The total emissions from the air stripper of the groundwater
treatment system described in Alternative 2 and the off gas from
the in situ vapor stripping process will be treated to conform to
the substantive requirements of the Pennsylvania Air Pollution
Control Act as set forth in 25 Pa. Code Section 127.1.
The cleanup criteria for soils in the landfill toe area and
the crested soil area will be determined during design by
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19
considering t~",8 characteristics of the soils and associated
contaminants ~nd then deriving specific levels of contaminants in
the soils that would not be expected to exert a significant
impact on the underlying grouJldwater. If that evaluation
indicates that the source has not been sUfficiently reduced, then
further remedial action will be implemented at the site.
Due to the heterogeneous nature of the landfill materials
it is impossible to generate a single set of characteristic
values that would be representative over the areal extent of the
landfill. Further, efforts to collect samples of the landfill
material for the generation of values to characterize subsections
of the landfill could not be substantiated as being
representative over a significant area. Therefore, the
traditional methods for determining the completeness of the
treatment and the effective end point are not applicable.
Meaningful target goals for final contaminant concentrations in
the landfill materials would be both difficult to establish and
subsequently verify. Additionally, the sample cores necessary
for intermediate and final analyses represent numerous additional
events where the integrity of the existing landfill cap would be
breached. Consequently, the end point for the in situ vapor
stripping phase of this alternative will be determined based on
performance criteria for this technology.
Indicator compounds for evaluation will be chosen according
to their presence and prevalence in the initial off 'gas,
toxicity, and physical characteristics which would affect
stripping rates. It is estimated that five volatile organic
indicators would be selected, along with carbon dioxide as an
indicator of the breakdown of any heavier, nonvolatile organics
due to biodegradation' enhanced by increased air flow.
The system would operate until nondetect levels or no
significant removal levels of the determined indicator compounds
have been demonstrated for three consecutive months and
subsequent spike values reveal nondetect or no significant
removal levels.
"Spike" values refer to the initial concentr::ltions displayed
in off gas when the sys:9.m is either started up initially or when
the system is "pulsed" (restarted after being shut off for a
period to allow the system to reequilibrate).
The "no significant removal" levels will be determined based
on ev~luation of concentrations of constituents in the off gas
and ~~~tistical analysis of mass of constituents extracted per
unit ~ime, rate of decline of mass extraction, and spike
concentrations.
At the completion of the in situ vapor stripping phase, the
effectiveness of the treatment will be evaluated with respect to
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20
the levels of contaminants remaining in the landfill materials
and surrounding soils and the continued impact of these media to
the groundwater.
. To be considered in the implementation of an in situ vapor
stripping system at the Lord-Shope Landfill are the existing cap
and high natural water table. These physical characteristics
will effectively act as boundaries to airflow and can be used,
with strategic placement of air vents and extraction wells, to
increase the overall efficiency of the system. The estimated
total cost of this alternative is 6 million dollars with
estimated time requirements of two years for completion of the in
situ vapor stripping phase and 50 years the groundwater
treatment.
Alternative 4A:
Source Control bv Excavation and On-site
Incineration of Landfill Materials with
Groundwater Extraction and Treatment
This alternative includes the remedial activities described
in Alternative 2 (groundwater extraction and treatment and
security fencing) plus additional source control by excavation of
the landfill materials and surrounding contaminated soils for
subsequent incineration in a facility that would be constructed
on the Site.
Excavation of the landfill would involve removal of the
engineered cap as excavation proceeded. On the north, west, and
east sides of the landfill, the excavation would be extended
beyond the delineated fill area an additional 10 ft horizontally
and 10 ft vertically to ensure that the areas of the highest
organic chemical concentrations are removed. The southern side
of the landfill, which is protected by an upgradient cutoff wall,
would be excavated to the cutoff wall only and not beyond.
..., .
For the on-site incineration option, approximately 144 tons
per day of soil will be excavated. Approximately 270,000 tons of
excavated materials will require incineration. This material
will be loaded into the incinerator facility each operating day.
Because of the depth to the water table, excavation dewatering
will be required for the excavation of approximately 10 ft of
soils beneath the landfill. The collected groundwater would
require treatment prior to disposal. Runon/runoff controls would
have to be installed to ensure that surface water would not be
contaminated by stormwater runoff from the landfill during
excavation. A stormwater collection system would need to be
installed for this source control option. Since the excavation
is into a landfill which held chemical wastes, the excavation
contractor crew and others would be required to work safety gear,
approved for the site conditions.
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21
Typical equipment for the landfill excavation operation
would include the use of a single, track-mounted, 3 cubic yard
front-end loader and a 15 cubic yard, triaxle dump truck or
equivalent equipment. The loader would load the dump ~ruck
approximately ten trips a day from the excavation area to the
inc~~erator building. site excavation for this remedial
alt,,=native would take approximately 5.5 years.
On-site Incineration involves the use of a service company
which would provide and operate a complete soil incineration
system on a contract basis. The incineration system would be
transported to the site and erected near the landfill. The
service company would provide the incineration equipment, civil
construction work, operating staff, environmental permitting
assistance, and the environmental monitoring and reporting
required by regulatory agencies.
This alternative considers the operation of a 6 ton per hour
rotary kiln unit which would burn soil 24 hours per day, 48 weeks
per year on a 7 day per week basis. This is the largest mobile
rotary kiln incinerator which is available. In this fashion,
approximately 48,400 tons per year of contaminated soil can be
incinerated. At this rate, approximately 5.6 years will be
required to incinerate all of the contaminated material planned
for excavatior:.
It is anticipated that the ash will comprise 40 percent of
the total volume to be excavated and will result in disposal
requirements for approximately 108,000 tons of kiln residue.
There are three hazardous waste landfills within 115 miles of the
Lord-Shope landfill which are suitable for disposal of solidified
kiln ash.
As described above the excavation and incineration phase of
this alternative would take an estimated 5.6 years, with 50 years
for the groundwater treatment. The total estimated cost of this
alterna~ive is 51 million dollars.
Alternative 4B:
Source Control bv Excavation and Off-site
Incineration of Landfill Materials and
Contaminated Soils with Groundwater
Extraction and Treatment
The source control by excavation, and source and migration
contr~l by groundwater extraction, groundwater treatment, and
discharge to surface water elements are identical to those
discussed in earlier sections. The difference in this
alternative is that after excavation of the fill area and soil,
the excavated materials would be transported off site for
incineration at a commercial hazardous waste incineration
facility.
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22
Commercial incineration capacity for contaminated waste
soils is currently limited in this country. There are only three
operating hazardous waste incinerators within a 500 mile radius
of the Shope site which can incinerate contaminated solid
materials.
The three facilities do not currently have sufficient
capacities to individually handle the volume of waste from the
Lord-Shope Landfill, therefore the excavated materials would have
to be distributed among different facilities according to
availability. For off-site incineration, excavation would
genera~e approximately 400 cu yd/day. Approximately 18 to 20
covered dump trailers (22 cu yd capacity) would be loaded for
shipment each working day. The Site would require a dump truck
loading and decontamination station and the implementation of
storm water runon/runoff controls for prevention of surface water
contamination.
The excavation and shipment phase of this alternative would
take approximately 2.4 years, with 50 years for groundwater
treatment. The total estimated cost for this alternative is 183
million dollars.
IX. COMPARATIVE ANALYSIS OF ALTERNATIVES
Each of the five remedial alternatives has been evaluated
with respect to the nine evaluation criteria in the NCP, 40
C.F.R. Part 300.430(e) (9). These nine criteria can be
categorized into three groups: threshold criteria, primary
balancing criteria, and modifying criteria.
Threshold Criteria
1-
2.
Overall Protection of Human Health and the Environment
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
primarv Balancina Criteria
3.
Reduction of Toxicity, MObility, or Volume through
Treatment
Implementability
Short-term Effectiveness
Long-term Effectiveness
Cost
4.
5.
6.
7.
Modifvina Criteria
8.
9.
Community Acceptance
State Acceptance
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23
These evaluation criteria relate directly to requirements in
section 121 of CERCLA, 42 U.S.C. section 9621, which measure the
overall feasibility and acceptability of the alternatives.
Threshold criteria must be satisfied in order for an alternat~ve
to be eligible for selection. Primary balancing criteria are
used to evaluate the performance of each of the alternatives
relative to the others. State and community acceptance are the
modifying criteria formally taken into account after public
comment is received on the Proposed Plan. The evaluations are as
follows:
1.
Overall Protection of Human Health and the Environment
A primary requirement of CERCLA is that the selected
remedial alternative be protective of human health and the
environment. A remedy is protective if it reduces current
potential risks to acceptable levels under the established
range posed by each exposure pathway at the Site.
Alternative 1 does not reduce risk to human health from
future use of groundwater or from direct contact with or
ingestion of contaminated soils.
and
risk
All of the other considered alternatives provide overall
protection of human health and the environment through
institutional controls on use of currently contaminated
groundwater and through groundwater extraction and treatment for
the long term reduction in groundwater contamination. The small
risk posed by direct contact/ingestion will effectively be
eliminated by the construction and maintenance of fencing
included in these alternatives.
2.
Comoliance with Aoolicable or Relevant and Aoorooriate
Reauirements (ARARs)
This section presents a summary of the five alternatives'
compliance with ARARs. Under section 121(d) of CERCLA, 42 U.S.C.
Section 9621(d), and EPA guidance, remedial actions at CERCLA
sites must attain legally applicable or relevant and appropriate
federal and promulgated state environmental standards,
requirements, criteria, and limitations (which are collec~ively
referred to as "ARARs"), unless such ARARs may be waived under
CERCLA Section 121(d) (4), 42 U.S.C Section 9621(d) (4).
Applicable requirements are those substantive environmental
standards, requirements, criteria, or limitations promulgated
under federal or state law that are legally applicable to the
remedial action to be implemented at the Site. Relevant and
appropriate requirements are those substantive environmental
protection requirements, criteria, or limitations promulgated
under federal or state law which, while not being directly
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24
applicable to the remedial action, do address problems or
situations sufficiently similar to those encountered at the Site
such that their use is well suited to the Site. ARARs may relate
to the substances addressed by the remedial action (chemical-
specific), to the location of the Site (location-specific), or to
the manner in which the remedial action is implemented (action-
specific). .
Alternative 1 allows a 1 in 10 cancer risk for potential
future ingestion of groundwater, and fails to meet most of the
chemical-specific ARARs (as set forth in Section XI of this ROD)
for this Site. All of the other alternatives are designed to
meet chemical-specific ARARs to the extent feasible. There are
no location-specific ARARs for this site. Alternatives 2 through
4B achieve compliance with a number of action-specific ARARs
including RCRA land disposal and treatment, storage and disposal
requirements, NPDES requirements, and air emissions ARARs.
Alternative 4A would have RCRA incineration construction and
operation requirements as an additional ARAR.
3.
Lona-Term Effectiveness and Permanence
Long-term effectiveness and permanence addresses the long-
term protection of human health and the environment once the
remedial action goals have been achieved. This comparison
focuses on the residual risk that will remain after completion of
the remedial action and the adequacy and reliability of controls
used to manage the untreated waste and treatment residuals.
There is virtually no residual risk associated with direct
contact with soil or soil ingestion for any of the alternatives
as long as the landfill cap is maintained and in the case of
Alternatives 2, 3, and 4A and B, the site remains fenced.
Fencing the site will eliminate potential exposure to
contaminated soils in the seep areas, the landfill toe area, the
crested soil area at the southeast corner of the landfill and
other small areas of contaminated surficial soils.
In terms of groundwater ingestion for future users,
Alternative 1 does not alleviate the potential long-term cancer
risk for users downgradient of the landfill. For Alternatives 2
through 4B, any potential residual risk is eliminated using
source control, plume extraction and groundwater treatment
technologies. Alternatives 3, 4A, and 4B provide reduc~ion in
the source of contamination and consequently reduction in the
risk of continuing release to the groundwater.
Due to the existing landfill cap, cut-off wall, and
vegetative soil cover, the adequacy and reliability of all the
described alternatives is sufficient to minimize leachate
generation and prevent direct exposure to soils. Alternative 1
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25
does not address the existing groundwater contamination and
therefore does not have adequate controls to reduce the potential
for expo:ure. The adequacy and reliability of controls for
groundwa~er recovery and treatment for Alternatives 2 through 4B
are the same ani are adequate and reliable. Additionally, early
monitoring wells which are part of the groundwater extraction and
treatment system of Alternatives 2 through 4B provide backup
performance monitoring by showing any continued migration of the
plume. The Alternative 3 source control technology, vapor
stripping, is a relatively new technology, but one which has been
demonstrated as being effective in removing VOCs from soils.
Field scale tests will be conducted to verify the effectiveness
of vapor stripping on the landfill materials. The controls and
monitoring technology for in situ vapor stripping are well
established and reliable.
Alter"atives 4A and 4B both feature excavation of the
landfill a:~d incineration of excavated materials as source
control measures. While removal of the landfill and contaminated
materials and treatment by incineration does provide a good long-
term solution for site remediation, the short-term implications
of excavation into the landfill and the transportation of
contaminated materials off ~ ~e for disposal are significant as
de~-=ibed below. For all of ~he five remedial action
alt ~natives, a 5 yea- review is needed to assure long-term
eff~ctiveness and pe~ anence, and the protection of human health.
4.
Reduction of Toxicitv. Mobilitv. or Volume throuah Treatment
This evaluation criteria addresses the degree to which a
~echnolc'gy or remedial alternative reduces toxicity, mobility, or
!olume of hazardous substance at the site. Section 121(b) of
=ERCLA, 42 U.S.C. Section 9621(b), establishes a preference for
rem~
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26
landfill and its immediate area. The extracted chemicals are
expected to be absorbed onto carbon and later incinerated during
regeneration or treated in a biodegradation process. The
statutory preference for treatment technologies which reduce
toxicity is thus met. Both Alternative 4A and 4B will reduce the
volume and toxicity of contaminated materials through
incineration.
Alternative 1 provides no irreversible treatment as no
treatment technologies are employed. In Alternatives 2 through
4B, groundwater constituents are treated by air stripping which
renders VOC constituents subject to photodegradation, other forms
of trans-formation, and dilution. In Alternative 3, the VOCs
which are absorbed onto carbon used in the in situ vapor
stripping system, will be irreversibly destroyed by
incineration/carbon regeneration of landfill and surrounding
area materials provides irreversible treatment. In the
incineration alternatives, 4A and 4B, the source of contaminants
will be irreversibly destroyed.
Alternative 1 does not provide any treatment and therefore,
there are no residuals remaining. In Alternative 2 through 4B,
the groundwater treatment system will produce an iron sludge
which is not expected to exhibit any hazardous or toxic,
characteristics or have any constituent concentration levels that
would render the materials hazardous or otherwise subject to land
disposal restrictions. In Alternative 3, the vapor phase carbon
adsorption system will produce spent carbon which will be
regenerated for reuse. In Alternatives 4A and 4B, incinerator
ash is generated which will be land disposed. This ash is not
expected to exhibit any hazardous or toxic characteristics or
have any constituent concentration levels that would render the
materials hazardous.
Alternative 1 does not address the statutory preference for
treatment of site contaminants. Alternatives 2 through 4B all
satisfy the CERCLA statutory preference for treatment, as opposed
to land disposal without treatment or abandonment in place
without treatment.
5.
Short-Term Effectiveness
Short-term effectiveness addresses the period of time needed
to achieve protection of human health and the environment and
any adverse impacts that may be posed during the construction and
operation period of the remedial alternative until cleanup goals
are achieved.
Alternative 1 does not present any short-term risk to the
community but does present a long-term cancer risk by exposure to
and ingestion of soils. Alternatives 2 and 3 do not present any
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27
substantive risk to the community. Potential releases of
contaminants to the air from the installation and operation of
vapor wells or the air stripping tower can be easily controlled.
Excavation and operation of an on site incinerator in Alternative
4A will present short-term risk to the community of releases to
the air and runoff to surface water during the operating period
of 5 to 6 yr. There would be a significant increase in risk to
the community in Alternative 4B resulting from the excavation as
in Alternative 4A, along with the increase in traffic caused by
the 18 to 20 dump trailer loads leaving the site on a daily
basis.
There wc~ld be no significant risk to workers resulting from
the implementation of Alternative 1. For all of the other
alternatives, there would be minor risks to workers with respect
to activities involving well installation, construction of the
groundwater treatment facility, and other related construction.
There would be significantly increased risks for workers at the
site in Alternatives 4A and 4B resulting from excavation of the
landfill. A sUbstantially increased risk of worker exposure to
air releases due to this activity would be expected. In
addition, Alternative 4B would result in an increased risk for
truck driver safety while hauling loads to distant incineration
facilities.
In terms of environmental impacts, there would be no
significant risk should Alternative 1 be implemented. For
Alternatives 2 and 3 there are no significant detrimental
environmental impacts. All air emissions, surface water
discharge and disposal of residuals would be conducted in
compliance with ARARs. For Alternative 4A, there would be
increased local pollutant loadings to the atmosphere from on site
incinerator. For Alternative 4B, there would be increased local
pollutant loadings to the atmosphere at off site incinerator
locations and there would be an increased chance of a release to
the environment caused by a hauling accident which could result
in d~~pi~g contaminated materials onto land or water.
In Alternative 1, at least 100 years is the estimate for
natural attenuation and disseminat:~n of groundwater constituents
to reach MCL levels. For Alternat~ves 2 through 4B, design and
construction of the groundwater treatment system could be
completed within 18 months of EPA ~pproval. Source and migration
controls would be effective with~n two months of start up thus
preventing the continuing movement of the contamination plume
towards currently used water supplies. This component of the
remedial alternative should b~ completed within 50 years of
implementation. Site design ~~d construction for the in situ
vapor stripping phase of Alternative 3 could be completed within
18 months of agency approval. Completion of this component of
this remedial action should be completed within 50 years. Site
design and construction of the on site incinerator facility for
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28
Alternative 4A should be completed within 24 months of approval.
Source excavation and incineration should be completed within 5-6
years of startup. The design and construction of the excavation
and truck loading areas for the excavation and shipment to off-
site incinerator should be completed within 6 months of approval.
Source removal could be completed within 2-3 years of startup.
6.
ImDlementability
This evaluation criteria addresses the difficulties and
unknowns associated with implementing technologies, the ability
and time necessary to obtain required permits and approvals, the
availability of services and materials, and the reliability and
effectiveness of monit~ring.
For Alternative 1, there is no action or construction to be
implemented. The groundwater recovery and treatment facilities
for Alternatives 2 through 4B would be relatively easy to
construct and operate. The groundwater treatment system requires
some operator attention. In Alternatives 3, the in situ vapor
stripping system would be relatively easy to construct and
operate. Because it is an innovative technology, field scale
testing will be used to verify its amenability to treating the
wastes at the Site. In Alternative 4A, the construction and
permitting of the hazardous waste incinerator is considered to be
moderately difficult and excavation of the landfill is considered
to be difficult. Construction and operation of the ash landfill
is considered to be relatively simple and easy to implement. In
Alternative 4B, the construction of the excavation/loading area
for excavated materials would be simple to construct and operate.
However, excavation of the landfill is considered to be
difficult.
For all of the remedial alternatives, the ability to monitor
effectiveness of each remedy exists. Over 90 groundwater
monitoring wells are currently installed at the site and nearby.
For all Alternatives, groundwater monitoring plus the use of the
early warning wells will give notice of failure of the action
well before significant risk of exposure for downgradient
groundwater users can occur. For Alternatives 2 through 4B
routine sampling and analysis of groundwater treatment system
discharges would allow monitoring of ARAR compliance. For
Alternative 4A, continuous and automated sampling and monitoring
of stack emissions would give the ability to monitor ARAR
compliance for air emissions.
Groundwater monitoring and reporting to PADER does not
require any approvals from regulatory agencies for Alternative 1.
Also, minimal coordination for reporting of the data is needed.
Obtaining the required RCRA, NPDES, air emissions and other
permits and approvals should not be difficult to obtain for
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29
Alternatives 2 and 3. P~rmits and approvals necessary for
excavation and shipping of hazardous wastes for Alternative 45
are expected to be more difficult. Alternative 4A requires the
acquisition of permits and approvals identical to the excavation
requirements of Alternative 4B with the added requirement of
obtaining permits and approvals for the construction of a
landfill and a hazardous waste incinerator. Permits for these
types of operations are difficult to obtain.
In terms of the availability of services and capacities,
Alternative 2 requires few services and its implementation will
not affect any commercially available capacities. For
Alternatives 2 and 3, services and capacities needed for
implementation are readily available. In addition to those
services needed for the implementation of either Alternative 2 or
3, Alternative 4A has the added need for incinerator construction
and site operating services, which are available. For .
Alternative 4B, most of the services and capacities needed for
the implementation of this remedial alternative are available.
However, off site incineration capacity is extremely limited and
future capacity is uncertain and may not be available.
For all of the alternatives, equipment, specialists and
materials are readily available. The availability of remedial
technologies is not applicable to Alternative 1. The specified
technologies needed are available for all of the remaining
alternatives. Alternative 2 requires groundwa~er treatmen~ pilot
testing. Alternative 3 requires in situ vapor extraction and
groundwater treatment pilot testing. Alternative 4A and 4B
incinerator technologies are readily available, but groundwater
treatment technology requires pilot testing.
Costs
7.
CERCLA requires selection of a cost-effective remedy that
protects human health and the environment and meets the other
requirements of the statute. The capital and annual operation
and maintenance (O&M) costs for these alternatives on a present
worth basis vary significantly. Cost estimates have been
developed for direct and indirect capital costs and O&M costs.
The present worth of each alternative haE been calculated for
comparative purposes. Direct capital costs include the
following:
Remedial action construction
Equipment
Buildings and services
Waste disposal costs
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30
Indirect capital costs include:
Engineering expenses
Environmental permit acquisition
Startup and shakedown
Contingency allowances
Annual O&M costs include the following:
Operating and maintenance labor and material costs
Maintenance materials and labor costs
Chemicals, energy, and fuel
Administrative costs and purchased services
Monitoring costs
Costs for periodic site review (every five years)
Insurance, taxes, and license costs
The remedial action alternative cost estimates have an accuracy
of +50 percent to -30 percent. For the purpose of the present
worth calculations, Alternative 1 has a performance period of 100
years and Alternatives 2, 3, 4A, and 4B can be completed in 50
years. Major capital expenditure items are completed in 5 1/2
years for Alternative 4A and 1 1/2 years for Alternative 4B. A
comparison of costs is presented in Table 9 and in the following
paragraph.
Alternative 1 involves no capital costs and no O&M. The
only cost for Alternative 1 is the cost associated with the five
year effectiveness reviews, which are necessary in all of the
evaluated alternatives. Alternatives 2 and 3 are comparable for
both capital and operating costs with Alternative 2 requiring
approximately $1,940,000 in capital cost compared to $2,500,000
for Alternative 3. The O&M cost for Alternative 2 is $310,000
per year compared to $420,000 per year for Alternative 3 in years
land 2, which then decreases to $310,000 per year. Alternative
4A is an order of magnitude higher than Alternatives 1, 2, and 3,
and Alternative 4B is two orders of magnitude higher than the
first three alternatives considered. Alternative 4A has an
estimated capital cost of $24,160,000 and a first year O&M cost
of $5,800,000. This O&M cost would drop to $310,00 in year 7 of
the remedial action, when the excavation and incineration of the
landfill is completed and the ash residue landfill is closed.
Alternative 4B has an estimated capital cost of $180,000,000,
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31
reflecting the
transportation
ma::.erial. The
$465,~00 which
action.
extremely high costs associated with off-site
and incineration of such a large volume of
first year O&M cost for this alternative is
drops to $310,000 in year 3 of the remedial
8.
state Accectance
The jCommonwealth of Pennsylvania has concurred with the
selection of Remedial Alternative 3, Source Control by In situ
Vapor stripping with Groundwater Extraction and Treatment, for
implementation at the Lord-Shope Landfill Superfund Site.
9.
Communitv Accectance
A public meeting on the Proposed Plan was held on April 3,
1990 in Girard, Pennsylvania. Comments received at that meeting
and during the Comment Period are discussed in the Responsiveness
Summary attached to this Record of Decision.
x.
SELECTED REMEDIAL ALTERNATIVE
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments, the
remedial alternative selected for implementation ("Selected
Remedy") at the Lord-Shope Landfill Superfund site is Alternative
3, Source Control by In situ Vapor stripping with Groundwater
Extraction and Treatment.
Goals
The primary goals of this 3elected Remedial Alternative are
to eliminate or reduce the ris~.s posed by potential ingestion of
contaminated groundwater and direct contact with the contaminated
soils associated with the Site. Additional goals are to meet the
statutory preference for remedies that utilize permanent
solutions and alternative treatment technologies to the maximum
extent practicable, and that utilize treatment to .reduce the
mobility, toxicity or volume of the source of contamination.
Summary of Alternative
As discussed in Section VIII, Descriction of Alternat:~es,
this Selected Remedial Alternative includes in situ vapor
stripping of the landfill materials and surrounding contaminated
soils to reduce the volume of contaminants currently present in
the landfill materials and contaminated soils, a groundwater
extraction and treatment component to remediate the existing
contaminated groundwater plume to MCLs or health based levels,
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32
and the construction of a security fence surrounding portions of
the Site to limit access and virtually eliminate risk from direct
contact with or ingestion of contaminated soils.
Institutional controls will be implemented to restrict the
use of groundwater in the area of the contaminated migration
plume to provide protection from potential ingestion of
contaminated groundwater. Following cessation of the in situ
vapor stripping phase of this Selected Remedial Alternative, the
degree to which vapor stripping has reduced the toxicity,
mobility, or volume of the waste will be determined, after
opportunity for review and comment by PADER.
These measures will be taken to supplement the existing
remedial actions implemented in 1984 which include the composite
cap and revegetation which significantly.reduce percolation of
incipient precipitation thereby reducing that aspect of leachate
production, and the upgradient groundwater cut-off wall which
further reduces leachate produced by groundwater flow through the
landfill waste.
XI.
STATUTORY DETERMINATIONS
Under it's legal authorities, EPA's primary responsibility
at Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other.
statutory requirements and preferences. These specify that when
complete, the Selected Remedy implemented at this Site must
comply with applicable or relevant and appropriate environmental
standards established under federal and state environmental laws
unless a statutory waiver is justified. The Selected Remedy also
must be cost-e£fective and utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatment
as a principal element to permanently and significantly reduce
the volume, toxicity, or mobility of hazardous wastes. The
following sections discuss how the Selected Remedy meets these
statutory requirements.
Protection of Human Health and the Environment
The Selected Remedial Alternative protects human health and
the environment in the long term by using groundwater extraction
and treatment to halt the migration of the existing contamination
plume and to reduce the contamination in the groundwater to
acceptable levels as determined by the MCLs or health based
cleanup criteria. The current excess cancer risks associated
with ingestion of contaminated groundwater are 1.OE-l.
Implementation of the Selected Remedial Alternative is expected
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33
to reduce this risk to 1.4E-4 and is expected to lower the
noncarcinogenic risks to acceptable levels. Institutional
controls to restrict the use of groundwater until cleanup levels
ar3 att~ined will eliminate the short-term potential risk from
this route of exposure. The remedy also provides protection from
direct contact with contaminated soils by the installation of
security fencing.
The potential for continuing contamination of the
groundwater will be significantly reduced by in situ vapor
stripping of the landfill materials and surrounding soils in
conjunction with the existing landfill cap and groundwater cut-
off wall. By reducing the contamination in the surrounding soils
in situ vapor stripping will also greatly reduce the risk of
direct contact.
There are no short-term risks associated with the Selected
Remedy that cannot be readily controlled. In addition no adverse
cross media impacts are ex?ected to result from implementation of
the Selected Remedy.
Comcliance with Acclicable or Relevant and ~ccrocriate
Reauirements
The Selected Remedy of groundwater extraction
and in situ vacuum extraction will comply wit:: all
relevant and appropriate chemical-, location-, and
specific ARARs. Those ARARs are as follows:
1. Chemical-Scecific ARARs
and treatment
applicable or
actior,-
Relevant and appropriate Maxim~~ contaminant
Levels (MCLs) promulgated Under the Safe Drinking
Water Act, 42 U.S.C. i 300f to 300j-26, and set
forth at 40 C.F.R. is 141.11(b) and 141.61(a) and
proposed MCLs set forth in 54 Fed. Reg. 22062 (May
22, 1989) are:
a.
Substance
Ben=.:ne
Chlorobenzene
Tetrachloroethene
Toulene
Trans-1,2 dichloroethylene
Trichloroethene
Vinyl Chloride
Arsenic
Barium
Cadmium
Chromium
Lead
MCL/rProcosed HCLl
5 ppb
[100 ppb]
(5 ppb]
[2000 ppb]
[100 ppb]
5 ppb
2 ppb
50 ppb
1000 ppb
10 ppb
50 ppb
50 ppb
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b.
c.
34
The Pennsylvania ARAR for groundwater for
hazardous substances is that all groundwater must
be remediated to "background" quality as specified
by 25 Pa. Code section 75.264(n). The
Commonwealth of Pennsylvania also maintains that
the requirement to remediate to background is also
found in other legal authorities. As described in
Section VIII of this ROD, groundwater monitoring
to determine the background concentrations of the
contaminants will be part of the remedial
alternative. Such background levels shall be
attained as part of the remedial alternative,
unless it is demonstrated that attaining such
levels is infeasible or otherwise waivable under
CERCLA Section 121(d), 42 U.S.C. Section 9621(d).
The National Emissions Standards for Hazardous Air
Pollutants (NESHAPs) set forth at 40 C.F.R. ~
61.63 and promulgated under the Clean Air Act, 42
U.S.C. ~ 7401, contain an emission standard for
vinyl chloride plants which is relevant and
appropriate to the air stripping and in situ vapor
stripping treatment. The vinyl chloride emission
standard is 10 ppm (average for 3-hour period) .
2. Location-Specific ARARs
No location-specific' ARARs with respect to this site
have been identified.
3. Action-Specific ARARs
a.
b.
c.
25 Pa. Code Sections 123.1 and 123.2 are
applicable to the remedial alternative, and
require that dusts generated by earthmoving
activities be controlled with water or other
appropriate dust suppressants.
To the extent that new point source air emissions
result from the implementation of the remedial
alternative, 25 Pa. Code Section 127.12(a) (5) will
apply, requiring that emissions be reduced to the
minimum obtainable levels through the use of best
available technology (BAT), as defined in 25 Pa.
Code section 121.1.
Treatment and discharge of contaminated
groundwater to an unnamed tributary of Elk Creek
will cause the requirements of Pennsylvania's
NPDES program to apply. Those requirements, as
set forth in 25 Pa. Code sections 93.1 through
93.8, include permitting, design, discharge, and
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d.
e.
f.
g.
35
monitoring requirements which will be met in
implementing the remedial alternative.
25 Pa. Code sections 102.11 through 102.24 contain
relevant and appropriate standards requiring the
development, implementaion, and maintenance of
erosion and sedimentation control measures and
facilities which effectively minimize accelerated
erosion and sedimentation.
25 Pa. Code Sections 105.291 through 105.314,
promulgated in part under the Pennsylvania Dam
Safety and Encroachments Act of 1978, set forth
applicable permitting and design requirements
relating to the groundwater treatment discharge
pipe/headwall construction.
25 Pa. Code Sections 264(0)(2),(10)-(14) and
264(v) (3) (xxvi) (F) (I), (IV) and (V) contain relevant
and appropriate requirements precluding any
breaches of the integrity of the existing landfill
cap except under certain circumstances, which
circumstances will be met by the remedial
alternative.Those provisions also will require
adequate repair of the landfill cap.
The groundwater treatment and in situ vapor
stripping treatment will be implemented
consistently with the requirements of 40 C.F.R.
Section 262 (regarding standards applicable to
generators) and the substantive requirements for
the treatment, storage and disposal of hazardous
wastes set fcrth in 40 C.F.R. sections 263
(regarding transporters of hazardous wastes) and
264 Subparts B-H (regarding general requirements
for TSD facilities).
Cost Effectiveness
The selected remedy is cost effective because it has been
determined to provide overall effectiveness proportional to its
costs in reducing risks associated with the Lord-Shope Landfill
site and meets the requirements of CERCLA. Compared to
Alternative 2, Groundwater Extraction and Treatment alone, the
selected alternati~e includes in situ vapor stripping to further
address the source and potentially reduce the time and continuing
costs necessary for extraction and treatment of groundwater.
When compared to the incineration alternatives, the selected
remedy achieves similar reductions in risk at a cost that is
estimated to be less than 15% of either Alternative 4A or 4B.
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36
Preference for Treatment as a PrinciDal Element
The selected remedy satisfies the statutory preference for
remedies that employ treatment as a principal element to
permanently reduce the toxicity, mobility, or volume of hazardous
substances. By treating the contaminated landfill materials,
surrounding soils, and groundwater, the selected remedy addresses
the principal threats posed by the Site through use of treatment
technologies.
utilization of Permanent Solutions and Alternative Treatment
Technoloaies to the Maximum Extent Practicable
EPA has determined that the selected remedy represents the
maximum extent to which permanent solutions and alternative
treatment technologies can be utilized while providing the best
balance among the other evaluation criteria. Of the alternatives
that are protective of human health and the environment, the
selected remedy provides the best balance in terms of long-term
and short-term effectiveness and permanence; cost;
implementability; reduction in toxicity, mobility, or volume of
hazardous substances through treatment; state and community
acceptance; and the statutory preference for treatment as a
principal element.
The selected remedy utilizes the innovative technology of in
situ vapor stripping to reduce the volume and toxicity of
hazardous substances in the landfill and surrounding soils and
the groundwater extraction and treatment technology will reduce
the volume and toxicity of hazardous substances in the
groundwater. Short-term, the risks posed by direct contact with
contaminated materials and the potential ingestion of groundwater
will be avoided through the installation of security fencing and
implementation of institutional controls on groundwater use.
Long-term, the groundwater extraction and treatment will return
the groundwater to levels that meet federal and state criteria.
The two treatment components of the selected remedy are easily
implemented and cost effective.
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APPENDIX A.
RESPONSI~~ESS SUMMARY
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RESPONSIVENESS SUMMARY
This community relations responsiveness summary is divided into the
following sections:
section I
Overview. A discussion of EPA's preferred remedial
alternative and the pUblic's response to this
alternative.
section II
Backqround of community Involvement and Concerns.
A discussion of the history of community interest
and concerns raised during remedial planning
activities at the Lord Shope Superfund site.
Summary of Major Comments Received During the Public
Comment Period and Agency Responses. A summary of
comments and responses categorized by topic.
Section III
I. OVERVIEW
EPA's preferred alternative, Alternative 3, outlined in the
Proposed Plan, involves an innovative technology called in situ
vapor stripping, along with groundwater extraction and treatment.
This alternative involves installing specially designed wells in
the Landfill and surrounding soils. These wells will apply a
vacuum to volatize and remove the volatile organic 90mpounds from
the Landfill material and surrounding soil. This alternative also
involves pumping extracted groundwater to an on-site groundwater
treatment system and discharging it to a tributary of Elk Creek.
This alternative also includes installation of a chain-link fence
around the perimeter of the Landfill to prevent human contact with
"seeps" and contaminated soil.
During the public comment period, the community, in general,
expressed concern about the in situ vapor str~pping alternative.
It is perceived by the community as a non-proven solution. Several
residents feel this alternative has been chosen because it is less
expensive than the incineration alternatives. Some residents
expressed support for an incineration alternative, feeling that it
would be a more effective way to assure complete removal of
contamination at the site. Residents feel strongly that making a
municipal water supply available would provide them a sense of
security and allay their fears that their wells will one day become
contaminated or go dry.
II. BACKGROUND OF COMMUNITY INVOLVEMENT AND CONCERNS
Community interest in the Lord Shope Landfill dates to 1979 when
well water samples were taken from the homes of seven property
owners living in the vicinity of the dump. Since that time,
communi ty concern and involvement have remained strong. A citizens
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group, Citizen's to Eliminate the Lord Shope Chemical Dump, was
formed in 1983 and has been particularly vocal in expressing the
concerns of the community to both the Pennsylvania Department of
Environmental Resources (PADER) and the EPA. PADER met with this
group in February 1984 to discuss the groundwater monitoring that
was beginning at the Site. In June of the same year, Lord
corporation conducted a Site tour with the media. PADER met with
the public again in 1985 to discuss the scope of work to be
performed at the Site and to announce the installation of an early
warning groundwater monitoring system. In September 1987, PADER
established an information repository in the Girard Township
Municipal Building and in October a second repository was
established at the wilcox PUblic Library.
Major concerns expressed during the remedial planning activities
at the Lord Shope Site focused on apparently inconsistent sampling
of residential wells, unavailability of sampling results, delays
in getting the site cleaned up, lack of PADER and EPA communication
with the community, and the refusal of authorities to provide a
municipal water source to the area. These concerns and how EPA and
PADER addressed them are described below.
III. SUMMARY OF MAJOR COMMENTS RECEIVED DURING THE COMMENT PERIOD
AND AGENCY RESPONSES
Comments raised during the Lord Shope Superfund Site public comment
period on the proposed plan are summarized below. The comment
period was held from March 26, 1990, to April 25, 1990. The
comments are categorized by relevant topics.
Remedial Alternative Preference
Each of the commentors on the Proposed Plan expressed a preference
for a specific alternative.
1.
PADER supports EPA' s choice of a preferred alternative for the
Lord Shope Superfund site; however, PADER would like EPA to
be more detailed and formalized regarding choosing a different
alternative should the proposed remedy fail to perform
adequately during the field tests.
EPA Response: EPA believes that it is premature to select a
second alternative for the following reasons.
First, EPA is confident that the implementation of the
selected remedy outlined in this Record of Decision will
achieve the goals of protection of human health and the
environment.
Second, the field tests for evaluation and design of the in
situ vapor stripping and groundwater treatment systems will
generate additional information on the wastes contained in the
Landfill. Any subsequent decision that the selected remedy
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is not ade~ate and the selection of an alternative remedy is
mandated w~ll rely, in part, on the information generated
during those field tests. If that becomes the case, an
amendment to this Record of Decision or a new Record of
Decision will be issued.
2.
Many area residents do not support EPA's choice of a preferred
alternative and instead feel that Alternative 4a or 4b would
be most effective in removing contamination. They asked what
the actual effectiveness level of incineration is versus that
of in situ vapor stripping. They feel that EPA is taking a
risk by using a new technology and would rather see a proven
remedy implemented at the site. They are concerned that if
the remedy does not work, they will have to wait another
twelve years to get the Site cleaned up. They feel that EPA
has chosen Alternative 3 because it is less expensive than
Alternatives 4a and 4b.
EPA Response: EPA understands the concern of area residents
about the use of an innovative technology for the remediation
of the Landfill and surrounding soils and the preference for
a proven technology such as incineration. EPA wants to
emphasize that the greatest risk from this site is from the
potential use of contaminated groundwater and that the
groundwater extraction and treatment component of the selected
remedy is a proven technology for the remediation of
groundwater. EPA believes th~t, although incineration would
be more effective at removing and destroying the contaminants
in the landfill materials, incineration would not be
significantly more effective at reducing the risks to human
health and the environment. EPA also believes that ei.::avation
and incineration would introduce short term risks of releases
to air or surface water.
EPA believes that the groundwater extraction and treatment to
halt migration and clean up the existing contaminated
groundwater plume, with in situ vapor stripping to reduce the
source of contamination, will work in combination with the
existing Landfill cap and groundwater cutoff wall as an
effective remediation appproach for the Site.
Selected remedies for Superfund Sites are, by statute,
required to be cost effective. However, this remedy was
selected by EPA because it is expected to provide protection
of human health and the environment without the short term
risks of air and surface releases and worker exposure
introduced by the excavation necessary for the implementation
of the incineration alternatives.
T: respond to the concern that if this selected remedy does
not prove effective residents will have to wait another twelve
years before any action is taken, EPA wants to assure
residents that the process will not have to start over. The
Remedial Investigation for this Site has been completed. The
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field tests for evaluation and design of the in situ vapor
stripping and groundwater treatment systems will generate
additional information on the wastes contained in the
Landfill. Any subsequent decision that the selected remedy
will not perform adequately and the selection of an alternate
remedy is mandated will rely on the information already
generated. If that becomes the case, an amendment to this
Record of Decision or a new Record of Decision will be issued
in a relatively short time.
Additionally, EPA believes that any remediation that would be
considered at this site would include groundwater extraction
and treatment (groundwater pump and treat); that component of
the remediation would continue to progress from the field
tests.
Technical Questions/concerns Regarding Remedial Alternatives
1.
Residents feel that the extent and direction of the
groundwater plume has not been accurately defined and that
perhaps the groundwater extraction and treatment portion of
the various alternatives will not be able to handle the extent
of contamination. Residents asked if additional studies
would be performed to further identify the extent of the
contamination plume.
EPA Response: The extent of the contaminated groundwater
plume has been extensively studied. The location of the
leading edge of the plume (the point at which contamination
becomes detectable) is estimated based upon analysis of
samples from monitoring wells already in place. The leading
edge of the plume is indicated in Attachment A (Figure 3 from
the Record of Decision). Currently there are monitoring wells
in place that have shown no detectable levels of contaminants.
This indicates that the leading edge of the plume has not
reached these wells. Additionally, there are early warning
wells placed between the plume and those residents that could
be affected. These wells also show no detectable levels of
contaminants.
2.
There are Site and residential well sampling programs
operating and the latest data from these programs will be used
in the design of the groundwater extraction and treatment
system to ensure that the entire plume is addressed.
Residents asked if either agency knew for certain what types
of chemicals were dumped into the Landfill and whether these
chemicals were still contained in drums.
EPA Response: Records indicate the waste materials dumped
into the Shope Landfill consisted mostly of waste rubber
scrap , demolition debris, pallets, and paper. However,
drummed chemical wastes consisting primarily of spent
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adhesives, waste paint, and paint sludges were also disposed
in the Landfill. These primarily contained non-halogenated
compounds including xylene, various ketones, toluene, naphtha,
and only small proportions of chlorinated compounds. Some
quantities of drummed wastes including chlorinated paint and
degreasing solvents, non-PCB cutting oils, and miscellaneous
acids and caustics were also deposited in the Landfill.
Widely accepted studies have shown that buried ferrous
containers, including steel drums, have corrosion rates that
can be predicted based upon the condition of the specific
subsurface environment. These corrosion conditions lead to
the deterioration of drums such that, at some point, liquids
would no longer be contained. Particularly Mughabghab and
Sullivan (1988) studied the corrosion of low carbon steel
containers as part of a u.s. Nuclear Regulatory Commission
funded study conducted by Brookhaven National Laboratory.
This study lead to a predictive equation for the corrosion of
drums for varying subsurface conditions.
Using these equations for the Lord-Shope Landfill conditions
indicate that, for the most conservative assumptions, drums
would be leaking from corrosion within nine years. Therefore,
it is fully expected that there are no significant amounts of
liquid chemical wastes contained in the drums buried at the
Lord Shope site. Furthermore, EPA believes that the present
condition of drums contained in the Landfill will not inhibit
the effectiveness of the processes described in the selected
remedy.
3.
A number of residents were concerned that the discharge of
water into a tributary of Elk Creek could disrupt aquatic life
in the creek. They wanted to know what the volume, quality
and temperature of discharge would be. They also asked if EPA
had to coordinate with other Federal and state agencies such
as the Bureau of Dams and waterways and the Fish Commission.
They wanted to know if there will be some kind of safeguard
built into the design in case the treatment plant can't keep
up with the volume of water being pumped, i.e., a holding
pond. .
EPA Response: The estimated discharge rate for treated
groundwater is approximately 80 ;allons per minute (gpm); but
for calculations a figure of 100 gpm was used. The mean flow
for the receiving stream immediately downstream of the
proposed discharge point has been calculated to be 942.5 gpm
and the mean flow at a point where the two tributaries combine
has been calculated to be 1525.9 gpm.
Therefore, the discharged treated water would make up
approximc-:ely 10% of the resultant flow of the receiving
stream .:,.:i approximately 6% of the flow of the combined
tributar _:::5. The physical and chemical characteristics of the
treated water would be subject to the permitting requ.irements
-------
of the National Pollution Discharge Elimination System
(NPDES). These requirements are based on an evaluation of
what the receiving stream can safely assimilate, taking into
consideration the stream's physical characteristics, water
quality, current and potential uses of the stream, and may
include modeling and continued monitoring where deemed
necessary to assure the stream quality. The Bureau of Water
Quality Management of the Pennsylvania Department of
Environmental Resources is responsible for setting the
requirements and issuing NPDES permits.
When setting NPDES requirements, the Bureau of Water Quality
Management considers the regulations and requirements of other
bureaus within PADER, including the Bureau of Dams and
Waterways, and other agencies such as the Fish Commission and
the Game Commission in order to assure that all pertinent
aspects of water quality are addressed. Specifically, the
Pennsylvania Fish Commission has already been in contact with
the Bureau of Water Quality Management concerning the status
of the Lord-Shope remediation.
..
The groundwater treatment system will be designed to handle
the combined flow of the extraction well pumps. Unlike sewage
treatment plants, stormwater is not added to the system and
will not cause overflow conditions. Additionally, the flow
from the wells can be adj usted as necessary if temporary
problems arise in the treatment system. The system will be
designed with the appropriate safeguards so that untreated
water will not be discharged.
4.
Residents wanted to know what type of monitoring of Elk Creek
will be done in the future if Alternative 3 is chosen.
EPA Response: Any stream monitoring requirements will be
determined in the process of meeting the NPDES permit
requirements for discharge of the treated groundwater. It is
expected that stream quality monitoring will be part of that
process.
5.
Residents were concerned that odors may be
chemicals are extracted from the ground water.
emitted when
EPA Response: The air emissions from the stripping tower and
from the in situ vapor stripping operations are subject to the
requirements of the Pennsylvania Air Pollution Control Act,
25 PA Code 127.1, which requires that emisssions be the
minimal attainable through the use of the best available
technology. Emissions of chemicals at these levels, subject
to further dilution in air, are not expected to display
detectable odors.
6.
One resident asked where the pumps for the groundwater pump
and treatment portion of the cleanup would be located. He
wanted to know if they would be above or below ground and how
-------
8.
7.
they would be maintained.
EPA Response: The pumps for the groundwater extraction and
treatment (pump and treat) component of the selected remedy
are expected to consist of well pumps, located in the wells,
and potentially, surface pumps to move the groundwater from
the well locations to the treatmeont facility. The exact
number and location of the pumps will be determined in the
detailed design of the treatment system. The system will be
designed to be accessible and easily maintained. The design
will consider the concerns of the nearby residents and
affected landowners and will be as unobtrusive as possible.
Residents wanted to know if there will be a building erected
on the site if Alternative 3 is chosen. In addition, they
were concerned about the fencing that would be erected around
the site. For asthetic purposes, they were concerned about
the appearance of the fence and also ~~estioned its purpose.
EPA Response: There will be a building to house some of the
equipment. This will be erected on the Landfill property.
The property will be surrounded by security fencing (expected
to be chain link fence). The purpose of the fencing will be
to protect the equipment and to further reduce the potential
for direct contact exposure to contaminants in the soil and
in the Landfill.
Tte residents of Pieper Road expressed strong concern that
when the groundwater extraction and treatment portion of the
remediation begins, they will lose the water supply to their
wells. They suggested connection with a municipal water
source as a way to prevent a loss of water supply to their
homes. One resident asked if EPA was going to test private
wells to find out which direction the water is coming from.
They are concerned that if their water supply is coming from
the underneath the Landfill, the groundwater pumping will,
cause their wells to go dry.
EPA response: Preliminary studies have indicated that a
series of well points and approximately five groundwater
extraction wells will be used to re::-~diate the currently
contaminated groundwater plume and prevent any further
contamination from leaving the area of the Landfill. These
studies have estimated that the total rate of flow that will
be extracted from these wells ~nd wellpoints would approach
100 gallons per minute. In the detailed design of the
extraction system, the radius of influence of the wells will
be limited to an area just outside the estimated perimeter of
the plume. This means that the pumping of groundwater will
be designed to have no significant influence or effect on the
groundwa~er flow or supply outside the perimeter of the
groundwater plume and will have no effect on 'ie water supply
in the existing residential wells in the are~.
The groundwater extraction and treatment component of this
-------
selected remedy will be designed to halt the spread of the
contamination plume, to draw the contamination away from the
perimeter to a central point for treatment and ultimately
eliminate the plume.
The residences are provided an added measure of safety by the
continued monitoring of early warning wells located between
the leading edge of the plume and the downgradient residences.
9.
A resident questioned the depth of the wells EPA plans to
install. She asked if the bottom of the wells would be above
or below the water table and what would happen if the water
table rose or fell dramatically.
EPA Response: Preliminary proposals presented in the
Feasibility Study indicate that vapor extraction wells in the
Landfill material will be installed to a depth approximately
five feet above the water table. Potential negative effects
of fluctuations of the water table on the equipment is not
expected to be significant due to the following factors:
o
The water table under the Landfill will be lowered
due to the combined effect of the groundwater cutoff
wall and the groundwater extraction and treatment
system.
o
The vapor extraction wells are generally designed
not as closed pipes with open ends, but as pipes
with perforations or slots in the walls of the
pipe's top allowing vapors to enter from the sides.
If the water table did rise to meet the bottom of
the well, the side openings would continue to be
functional. .
10.
Additionally, the falling water table under the Landfill due
to the groundwater extraction and treatment component of the
selected remedy will help to stabilize the water table to
prevent fluctuations and increase the effective area of the
in situ vapor stripping of the Landfill materials.
One resident asked if the possibility that the area is a
wetlands area would affect the choice of an alternative. He
wanted to know if EPA or PADER has determined if the area is
an actual wetlands environment.
EPA Response: If an area that contains a Superfund Site is
determined to be a wetland this would influence the choice of
a remedial alternative because potential impacts on the
wetland area would be considered.
EPA has determined that the Site is not located in a presently
recognized wetland. There are some areas south of the Site
which are considered to be hardwood swamp environments;
however these areas are outside of the influence of any past
-------
11.
12.
13.
14.
Landfill activity and the planned remedial activities.
Residents asked if there are other in situ vapor stripping
plants in operation currently and if the contractor chosen by
Lord Corporation to perform the process has a license to use
the technique.
EPA Response: There are in situ. vapor stripping systems
operating successfully worldwide. Included as Attachment B
is a letter sent in response to a request from one resident.
The letter names several Superfund and non-Superfund sites
where the technology is being used.
EPA has been assured that the contractor chosen by Lord
Corporation is not infringing on any patent with regard to
this technology.
One resident who owns property adjacent to the Landfill asked
what the potential for future development of his property
would be if EPA's preferred alternative is implemented.
EPA Response: The potential for development of the property
in question is limited by the institutional controls that will
be imposed on the groundwater usage for that area and by
whatever local permitting requirements are in effect for
development. EPA has been in contact with this landowner and
will continue this dialogue through the Remedial Design and
Remedial Action phases of this response as requested.
Residents wanted to know whether pr:'3te wells will continue
to be tested over the next fifty yea~~ while the ground water
is being treated.
EPA Response: A residential monitoring program will be
included as a component of the Remedial Design and Acti~~ as
part of the determination of the effectiveness of the remedy.
However, the duration of the program will be based on the
progress of the remediation, not on a predetermined time
period.
One resident asked if the six million dollar figure for the
cost of performing the in situ vapor stripping process is a
competitive bid.
EPA Response: EPA fully expects that Lord Corporation will
continue to participate in the cleanup of this Site and that
the Remedial Design and Remedial Action will be conducted by
Lord under EPA oversight. If this is the case, then Lord
corporation will agree to the implementation of the selected
remedy; the cost negotiated by Lord will have no bearing on
that agreement. If, however, Lord does not participate, EPA
will conduct the Remedial Design and Action using its
established contracting procedures which are competitive.
-------
community Relations Concerns
2.
3 .
1.
A representative of the citizens to Eliminate the Lord Shope
Chemical Dump organization stated that EPA credibility with
that organization is low. Instead of being contacted
personally, she was informed of the public meeting by a
television news broadcast. She expressed concern that "one
day trucks and people will just show up on site and residents
will not know what is going on." She asked if residents could
be kept updated during the design process so that they will
know what to expect.
EPA Response: The Community Relations Coordinator apologizes
for the way EPA informed citizens of the meeting. She had
intended resident's information letters to arrive before the
media received the press release. This problem will be
corrected for future meetings.
EPA will endeavor to keep citizens up to date during the
Remedial Design and Remedial Action phases at the Lord Shope
Landfill. Information will be distributed by fact sheets,
media coverage, public meetings, if necessary or requested,
and one-on-one discussions. citizens should also contact Amy
Burrage at EPA or Steve Curcio at the Pennsylvania Department
of Environmental Resources if they have any questions about
the Site. Both organizations would like to foster two-way,
effective communication with residents. Residents can support
this process by continuing to tell EPA their concerns and
needs.
Many residents expressed frustration over that fact that every
year there are new people from the state and Federal agencies.
They feel that each year they have to re-explain their
problems and they would like to have some familiar faces to
turn to.
EPA Response: EPA employees are also frustrated by the
turnover rate. EPA feels that some amount of reiteration will
always be necessary both within the agency and between the
agency and citizens. However, the agency will renew its
efforts to retain institutional knowledge of on-going citizen
interests.
The Committee to Eliminate the Lord "Shope Chemical Dump asked
if its organization could become a repository location since
the hours of the other two repositories are not convenient for
people who work during the day.
EPA Response: Any documents sent in the future to the two
established repositories, Willcox Library and the Girard
Township Supervisors, will also be sent to Ms. Ann Sawin,
citizen representative of the Committee to Eliminate the Lord
Shope Chemical Dump.
-------
Remaininq Concerns
1.
Residents wanted to know how long the Remedial Design process
will take and when they can expect actual cleanup at the site
to begin.
2.
EPA Response: Once the Record of Decision is issued,
negotiations leading to a Consent Decree with Lord Corporation
will be~in. After the Consent Decree is in place, the
Remedial Design will commence. The Remedial Action, which is
the actual field work, will proceed according to the schedules
developed in the design. Although EPA wishes to facilitate
the cleanup at this Site, this process can take as long as a
year following issuance of the Record of Decision. If a
Consent Decree with Lord Corporation can not be negotiated,
other mechanisms will be activated to implement the remedy
selected for this Site as quickly as possible.
Residents of Pieper Road have been under the impression that
their private wells are to be tested every six months and in
some cases it has been over ten months since the last round
of testing. They were concerned that their wells are not
being uniformly tested for certain contaminants. Also,
residents would like to receive results of tests without
having to call PADER to request the results.
EPA Response: The problems with the currently implemented
residential monitoring program have been caused. primarily by
miscommunication. When the monitoring program for the
selected remedy is designed, these communication problems will
be addressed and a consistent approach will be developed.
3 .
Early warning wells were installed on the easternmost part of
Lord's property. Residents wanted to know if they could be
notified when these wells are tested and what the results are.
EPA Response: This information will be provided to Ms. Ann
Saw:~, citizen representative of the Commit~ee to Eliminate
the.~ord Shope Chemical Dump.
-------
A'ITACHMENT A.
-------
.•• ''.-J~!
v// : '••
\y; - •
.' •'
• /~*
,s:
Leading edge of
Contamination Plume
\
Landfill Perimeter
' ' '•-'•> -\ I ' ." .''
4&:.';' ^•J-*^*^.,A; , ':
W. I/;, :,« v-v . ----«.v,.
f'
"1
\l
i
FIGURE 3.
LORD-SHOPE LANDFILL
MIGRATION PLUME FOR VOLATILE ORGANIC CCNTAMIv.-;~S
IN THE INTERMEDIATE GROUNDliATER ZONE
-------
ATTACHMENT B.
-------
.;,'0 174,...
;' A ~
\.'
+".( .."r:l
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
841 Chestnut BUlldtng
Philadelphia. Pennsylvania 19107
Mr. Rebert Elwinger,
Over Lake, Inc.
10601 Ridge Road
Girar:d, PA 16417
President
05/18/90
Dear Mr. Elwinger:
This letter is a partial response to your request for information
presented verbally at the public meeting on April 3, 1990 and in your
follow up writte~ comment dat: ~ April 23, 1990. At the public meeting,
one of your rec .=)tS was for Q list of sites where in situ vapor stripping
is currently be .g used.
The follow: 19 is a list of Superfuro remedial sites where in situ vapor
stripping has /:)( .n chosen as part of the remedial response:
Federal Fiscal
Year ~988 Site Nane State
Groveland Well MA
Keefe Envirormental NH
Bendix Flight Systens PA
Tyson's rurp PA
Airco KY
Goodrich, B.F. KY
South Valley ~
Hastings NE
Motorola A1.
Federal Fiscal
Year 1987 Seyncur IN
This is by no means a ~lete 1 isting, as I have not included the
remedial alternative selections fer fiscal year 1989. There has also
been wide usage of the technology on non-Superfund sites. Some of these
sites are listed below:
Upjohn Manufacturin:; Carpany, Barceloneta, Puerto Rico
Department of Energy, South Carolina . ...
Kinross Regional Correctional Facility, Saulte Saint Marie, HI
Sherwin Williams Paint Warehouse, Dayton, OH
Michigan Department of Transportation, Lansing HI
-------
-2-
. The above listings are just a few of the sites where in situ vapor
stripping has been used. These lists represent sore of the work done by
t~ ~ies, Terra Vac Corp. and MWRI, Inc. Both these ~nies hold
patents on sane aspects of the technology and they are only t~ of the
approximately 20 U.S. companies currently in
in this field.
In situ vapor stripping is being used internationally to remediate
volatile organic contamination. Specifically, I have enclosed a copy of
a presentation describing a site in Germany, similar to the I.crd-5hope
Landfill, where the technology has been used effectively.
The other concerns brought up at the public meeting are still being
addressed and you will be receiving further information as it is developed.
If you have any questions on the above or any other items, please call
me at (215)597-8309.
Very truly yours,
,/f t~ Y
'~~:I "..y. J -A-c..-'"'l
5ames J. Feeney (3~1 )
SE Pennsylvania Remedial Section
cc:
P. Anderson
A. Burrage
-------
AOOENIX.M
Partial Listing of the Superfund sites planning in situ vapor stripping
as part of the remedial response in federal fiscal year 1989
Federal Fiscal
Year 1989
Site Name
State
Midco I
Fairchild
(Mt. View/
Intel Raytheon)
IBM
Kellogg-Deering
, Union Carbide
Hastings
IN
CA
CA
cr
OH
NE
'.~ . ..,,~' ;: . .
.--... #, .,,":
-------
INTEGRATED SOIL-VAPOR/GROUNDWATER CLEANING SYSTEM
AT
SELECTED SITES IN WEST GERMANY
Authors
Karlheinz Bb'hm, Ph.D.
and
Gerrit Rost
Department of Environmental Engineering
Ed. Zublin AG
Albstadtweg 3
7000 Stuttgart 80
Federal Republic of Germany
and
Martin R. Griek
ZDI Construction Services
607 Herndon Pkwy.
Suite 100
Herndon, VA 22070
Presented at
The Second Forum on
Innovative Hazardous Waste Technologies:
Domestic and International
Philadelphia, Pennsylvania
May 15 - 17, 1990
-------
iNTEGRATED SOIL-VAPOR/GROUNDWATER CLEANING SYSTEM
1.
I NTRODUCT I ON
Ed. lUblin AG is an international civil engineering firm headQuartered in
Stuttgart, West Germany. It is represented in the U.S. by its operating
subsidiary, IDI Construction Services, Herndon,Virginia.
Ed. lUblin has provided the European and International markets with
construction related services for over 92 years. For the past decade their
DeDartment of Environmental Engineering has been involved in the treatment
and containment of hazardous material. These areas include:
Asbestos - removal and disposal
Hazardous waste site containment - HDPE lined slurry walls
Thermal incineration of contaminated soil with rotary kilns
Integrated soil-vapor/groundwater cleaning systems
Vacuum extraction of soil-vapor is not a uniQue process. It is, in fact, the
standard method in Europe today for cleaning up sites contaminated with
vec's. [Chlorinated Hydrocarbons (Solvents TCE-PCE-DCE) and Aromatics
(Petroleum Products - BTEX)] .
Combining a soil-vapor extraction and treatment system with a groundwater
treatment system for the remediation of a vec's contaminated site is a
sensible decision. The vadose zone ca:. be remediated by va:uum extraction
with relative ease and economy. This process removes the source of the
groundwater contamination. Thus the groundwater only needs to be cleaned of
residual contamination. Removal of the source pollution shortens the
duration of the treatment process since percolation of volatile substa~ces
through the soil horizons into the groundwater can take decades. The costs
and effectiveness of remediation can be vastly improved by using the combined
phase treatment process.
This paper presents two case studies utilizing lUblin's integrated treatment
process incorporating this procedure. Zublin has installed and operated
dozens of these systems during the past decade. With typical German
efficier:y, the company designed a highly flexible, efficient and functional
system to recover solvent contaminants and minimize discharge into t~e
biosphere.
II.
SCHERWIESEN SITE
This st~cy deals with a landfill, for industrial sludges, animal process;~g,
and household waste which had been operating since 1967. Following i:s
closure in 19BO, the landfill was excavated to a depth of three (3) feet and
capped w~th a one meter thick compacted clay seal.
Engineering studies performed in early 1984, showed that hydroxide sludges
and chlorinated hydrocarbons were present througnout the site and had started
to contaminate the groundwater. The contamination plume had exte~ded ove~
650 meters (2,100 feet from the site). At this point it had contaminated a
natural spring which was the primary drinking water source of a r~a~~y
village. Remediation of the site was ordered by the appropriate author:ies.
-------
In 1987 Zublin's Department. of Environmental Engineering was awarded the
project to extract and treat both the soil-vapor and the contaminated wate~
in the perched water table (source contaminants) as well as the contaminate~
spring water. Starting with commencement of the operation, a study was
conducted to record the effects of the treatment process. The data collected
during this study is presented herein. The plant is still in operation
today. Figure 1 is a schematic diagram of the treatment system. A site plan
of the project is shown in Figure 9.
I I I. TREATMENT PROCESS
A.
Soil-Vapor
Initially, ten (10) soil-vapor extraction wells were constructed with varying
depths of 13 to 17 feet at the points of highest contaminant concentrations
at the site. A set of vacuum pumps extracted 250 cubic meters per hour from
a five (5) well manifold with a negative pressure of approximately 200 mbar.
The manifold was shifted to different wellheads when the vapor concentration
decreased. The soil at the site is a heavy clay. Its zone of influence for
each sgil-vapor well was only 10 to 16 feet. With a permeability of the soil
of 10- cm/s, the need to drill additional wells was apparent. As a result,
in 1988, a year later, twenty (20) additional soil-vapor extraction wells
were installed.
The extracted soil-vapor passes through a water separator which removes the
water particles picked-up by the vacuum, along with the soil-vapor, from t~e
soil. The water from the separator, which may contain tra~e contaminants.
mixes with and is cleaned in the water treatment phase of tne system. ine
vapor, which has been heated by the energy produced by the vacuum pump, is
cooled prior to entering the activated carbon filter for maximum adsorption
by the carbon.
Two carbon filters are
either on stand-by or
reaching break-through,
continues uninterrupted
carbon filter material.
used: As one filters the influent air the other is
being regenerated. Prior to the on-line filter
the order is reversed. In this fashion the treatment
without the need to exchange and dispose of spent
During the regeneration process, steam desorbes the solvent from the
activated carbon. The contaminant laden steam is then conoe~sec.
S~bse~wentlYt the solvent and water are separated resulting in recovery of
t~e s:'vent. This solvent is 99% pure and can then be recycled or properly
d~spcsed. The contact water is fed bacK into the liQuid phase of the syste~
for cleaning. During the first year over 3.000 kg of solvent was recove~ed
at th1s site.
- 2 -
-------
Contaminant concentrations of the soil-vapor were reduced from 8,000 ppm to
between 30 - 50 ppm. Figure 3 shows the influent concentrations of the soil-
vapor. Air volume was measured with an integrated flywheel anemometer. The
total volume extracted and treated over this period of time exceeded 2.5
million cubic meters. This is graphically demonstrated in Figure 4. The air
discharge concentrations were well below the German standards of 100 ug/1.
Figures 5 and 6 show the air discharge concentrations and Quantity of air
treated. Figures 7 and 8 illustrate quantities of solvent recovered by the
plant.
As can be seen in looking at these curves there are instances of several
upward shifts. The primary cause for these shifts are two. The first is the
result of climatic conditions. As the clay dries, cracking occurs: These
cracks provide paths for the extraction of ambient air and lower the
concentration measured in the influent air stream. Further evidence of this
occurrence is the "decrease" in the negative pressure measured at the vacuum
pump.
The second reason for a shift is caused by interruption of the extraction
process at one or more of the wells. The phenomena of increased contaminant
concentration in the extracted soil-vapor after a shut-off well resumes
extraction is common. During this shut-off period the volatiles have a
chance to re-establish equilibrium in the "vacuumed" section of the soil.
That is, the volatiles inside the soil have a chance to diffuse into the
soil-air space. Consequently, concentrations following start-up are higher
than those recorded prior to shut down.
Other minor factors affecting the peaks are due to: shut downs of the plant
which occurred in December 1987, and June 1989 depicted on Figure 6; and,
precipitation - since a partial saturation of the vadose zone .impedes removal
of the VOC's. The important point of the graphs, however, is to note tne
trend of decreasing concentration in the contaminants.
B. Water
In order to expedite remediation of the site, a groundwater extraction and
treatment phase was implemented in conjunction with the soil-vapor treatment.
Five (5) of the original ten (10) wells were used to extract the perched
groundwater. A shallow ditch was constructed encompassing the site to
capture and treat the surface run-off.
The perched- water is part of the aquifer that feeds the spring. It is
greatly influenced by precipitation as shown in Figure 2. The perched water
with a flow rate of 200 liters per hour it is pumped into a storage tank.
From there it is fed through a sand filter into two activated carbon filters
operating in series. The initial concentration of the water measured at tne
plant was 23,500 ug/1 with point measurements at the monitoring well (P-12)
as high as 166,000 ug/1 of chlorinated hydrocarbons. Following treatment,
effluent concentrations of the discharged water were well within the German
drinking water standards of total CMC's less than 20 ug/1.
It should be noted that after constant and continuous remediation of 2-1/2
years, the contaminant concentration of the perched water was reduced to 1.9
mg/1.
- 3 -
-------
IV. ECONOMIC ANALYSIS
A cost analysis of the plant follows: Costs are in 1987 dollars at a
conversion ratio of 1.6 DM to $1.00 US.
Site Operations DM US
1. Soil-Vapor System
a. Installation 17.025 DM $10,6*0
b. Operation and Maintenance (12 mos.) 5.235 3,275
2. Solvent Recovery System
a. Installation 52.200 32,625
b. Operation and Maintenance (12 mos.) 18.070 11,295
3. GAC System
a. Installation 13.500 8,440
b. Operation and Maintenance (12 mos.) 2.160 1.350
Total 108.190 DM $67,625
Installation Costs
1. Site
a. Soil-Vapor System 17.025 DM $10,640
b. Solvent Recovery System 52.200 32,625
c. GAC System 13.500 8.44
* n
Total 82.725 DM $51,7:5
Operation and Maintenance
1. Site
a. Soil-Vapor 5.230 DM $ 3,270
b. Solvent Recovery 18.070 11,295
c. GAC 2.160 1.350
Total 25.460 DM $15,915
These Costs Include:
1. Site preparation for the plant
2. Mechanical and electrical installation charges
3. Labor, material and equipment
4. Operating supplies, utility costs, and maintenance
These Costs Exclude:
i. Well installation
2. Permitting costs
3. Replacement charges (depreciation)
4. Carbon replacement - liquid phase
5. Engineering charges for the sampling/testing study
- 4 -
-------
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...
APPENDIX B.
ArMINISTRATIVE RECORD INDEX
-------
LORD SHOPE LANDFILL
ADMINISTRATIVE RECORD FILE *
INDEX OF DOqlMENTS
I .
SITE IDENTIFICATION
1)
Report: Site Inspection of Lord Shope for the
Hazardous Site Control Division, u.S. EPA, prepared
by NUS Corporation, 6/21/84. P. 100001-100199.
*
Administrative Record File Available
4/12/90.
3/23/90, update
Note: Company or organizational affiliation is identified in
index only when it appears in file.
-------
II.
REMEDIAL ENFORCEMENT PLANNING
1)
. Letter to Mr. Eugene A. Miller, Lord Corporation,
from Mr. Mark E. Gorman, Pennsylvania Department of
Environmental Resources, re: Transmittal of the
Consent Order and Agreement, 11/12/87. P. 200001-
200022. The Consent Order and Agreement are
attached.
2)
Letter to Mr. Lawrence A. Demase, Esq., Rose,
Schmidt, Hasley & DiSalle, from Mr. Stephen R.
Wassersug, U.S. EPA, re: Review of proposed Consent
Agreement and Consent Order, 12/16/87. P. 200023-
200024.
3)
Lord-Shope Landfill Drum Disposal Summary,
summarized by Mr. J. Feeney, U.S. EPA, 8/89.
200025-200025.
P.
4 )
Sworn Statement of Melvin Shope, 4/12/84.
200026-200104.
P.
2
-------
III. fSMEDIAL RESPONSE PLANNING
11
Repc=t: Hydrogeologic Summary Report, Shope's
. Landfill, prepared by AWARE Incorporated, 9/85.
300001-300119.
P.
2)
Letter to Mr. Mark Gorman, Bureau of Waste
Management, from Mr. Eugene A. Miller, Lord
Corporation, re: Transmittal of the second draft of
the Feasibility Study Work Plan, 10/30/87. P.
300120-300147. A transmittal letter and revised
Work Plan for the Feasibility Study are attached.
3)
Desk Memorandum to Mr. Hector Abreu, U.S. EPA, from
Mr. Mark Gorman, Pennsylvania Department of
Environmental Resources, re: Transmittal of a
letter, regarding Feasibility Study Work Plan
Approval, 1/8/88. P. 300148-300150. The letter is
attached.
4)
Desk memorandum to Mr. Hector Abreu, U.S. EPA., from
Mr. Mark Gorman, Pennsylvania Department of
Environmental Resources, re: Phase II Remedial
Investigation Work Plan, 3/11/88. P. 300151-
300153. A letter, regarding the submittal of the
Work Plan by Lord Shope is attached.
~~~~~~Iga~~~p:l~ite:h~~:p;;e~e~~di~iRE
Incorporated, 4/88. P. 300154-300213.
5)
6)
Letter to Mr. Eugene A. Miller, Lord Corporation,
from Mr Mark E. Gorman, Pennsylvania Department of
Envi!':nmental Resources, re: Review of Phase II
Work -lan and revision of schedule, 6/21/88. P.
3002~~-300219. The Project Schedule is attached.
7 )
0.5. EPA Memorandum to File from Mr. Jim Feeney, re:
Documentation of comments on the RI/FS made by
Region III Bioassessrnent Work Group at September 13,
1989 meeting, 3/21/89. P. 300220-300221. A
memorandum notifying Federal Natural Resource
Trustees of upcoming RD/RA negotiations is attached.
Letter to Mr. Abraham Ferdas, U.S. EPA from ~=.
Stephen D. Von Allmen, Department of Health & -~man
Services, re: '!=ansmi ttal of completed Heal t:-
Assessments fo: Lord Shope Landfill, 4/10/89. P.
300222-300239. The Health Assessment is attached.
8)
3
-------
9)
10)
11)
12)
13)
14)
15)
16)
17)
18)
Letter to Ms. Alyce Fritz, NOAA CRC, from Mr. Jim
Feeney, U.S. EPA, re: Transmittal of the RI/FS
report, 7/21/89. P. 300240-300240.
Report: Feasibility Study, Shope's Landfill, Girard
Township, Pennsylvania, Volume I, prepared by
Eckenfelder Inc., 7/89. P. 300241-300473.
Report:. Feasibility Study, Shope's Landfill Girard
Township, Pennsylvania, Volume II-Appendices,
prepared by Eckenfelder Inc., 7/89. P. 300474-
300694.
Report: Phase II, Remedial Investigation Report,
Lord/Shope Site, Volume III-Appendices, prepared by
Eckenfelder Inc., 7/89. P. 300695-301155.
Report: Shope's Landfill, Remedial Investigation
~ort, Biological Investigatio~, prepared by
Eckenfelder Inc., 7/89. P. 301156-301209.
Report:
Phase II
prepared
301386.
Revised Baseline Public Health Evaluation,
Remedial Investigation, Lord/Shope Site,
by Eckenfelder Inc., 7/89. P. 301210-
U.S. EPA memorandum to Mr. Jim Feeney, from Mr.
Dominic C. DiGiulio, through Mr. Dick Scalf, re:
Review of Soil Vacuum Extraction Field Test at the
Lord-Shope Site, 9/20/89. P. 301387-301391.
. .
Report: Refined Groundwater Model Report,
Lord/Shope Site, prepared by Eckenfelder Inc.,
10/89. P. 301392-301440.
Letter to mr. Eugene A. Miller, Lord Corporation,
from mr. Donald J. Benczkowski, Pennsylvania
Department of Environmental Resources, re: Review
of the draft Remedial Investigation/Feasibility
Study Report, 12/5/89. P. 301441-301443.
Report: Feasibility Study, Shope's Landfill Gira=d
Township, Pennsylvania, Vol~, prepared by
Eckenfelder Inc., 7/89, Revised 1/90. P. 301444-
301675.
4
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19)
Report: Phase II, Remedial Investigation Report,
Lord/Shope Site, Volume I, prepared by Eckenfelder
Inc., 7/89 Revised 1/90. P. 301676-301913.
.:
5
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V.
L
COM~NITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/
I!-1.AGERY
1)
- Press Release, Pennsylvania Department of
Environmental Resources, re: Public comment
reg~rding the Remedial Investigation Report,
P. 500001-500002.
period,
9/9/87.
2)
Press Release, Pennsylvania Department of
Environmental Resources, re: Public Informational
Meeting, 11/29/87. P. 500003-500004.
3)
Fact Sheet and Public Inf9rmation Packet, re:
Public Meeting, Lord Shope Superfund Site, October
7, 1987, (undated). P. 500005-500024. The Fact
Sheet and Information Packet are attached.
4 )
Imagery: Shope's Landfill, Phase II, Remedial
Investigation Report, Volume II, Hydrogeologic Maps,
prepared by Eckenfelder Inc., 7/89. P. 500025-
500046.
5)
Press Release, Pennsylvania Department of
Environmental Resources, re: Recommendations
Available for Public Review, 8/4/89. P. 500047-
500047.
6)
Proposed Plan for the Remediation of the Lord-Shope
Superfund Site in Girard Township, Erie County,
Pennsylvania, (undated), (author unknown), P.
500048-500058.
6
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