United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-90/092
June 1990
&EPA
Superfund
Record of Decision
Hranica Landfill, PA
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50272.101
REPORT DOCUMENTATION 1'. REPORTNO.
PAGE EPA/ROD/R03-90/092
2.
3. RecIpient'. ACC888Ion No.
4. Tille end SubUIIe
SUPERFUND RECORD OF DECISION
HranicA Landfill, PA
First Remedial Action
7. Author(.)
'.
5. Report D8te
06/29/90
6.'
8. Pltrformlng Org8lllZlltion Rept. No.
g. Pltrformlng Org.lnlZllUon Name .nd Addreea
10. ProjectlT.8klWcrl UnI1 No.
U. ContnIct(C) Dr Grent(G) No.
(C)
12. ~Drlng Org8lllz8tlon Name end Addre..
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
(G)
13. Type of RepcII16 PetlDd Co-.d
Agency
800/000
14.
15. Supplement8ry Nelle.
16. Abelr.ct (Umlt: 200 word.)
The lS-acre Hranica Landfill site is an inactive landfill 21 miles north of Pittsburgh,
in Butler County, Pennsylvania. The site is in a rural agricultural setting with 4,000
people residing within a two-mile radius of the site. Between 1966 and 1974, both
municipal and industrial wastes were accepted on site including paint and solvent
wastes, plating wastes, metal sludge, and waste oils. The wastes were incinerated
nd/or stored onsite in surface impoundments until 1981. Liquid wastes were then
directly discharged into surface impoundments causing ground, surface, and soil cover
contamination. The surface impoundments were subsequently abandoned and the wastes
were then openly burned. The residual ash from the incineration process was stored
onsite in unprotected piles. Numerous drums of unprocessed wastes were also staged
onsite without further treatment. In 1983, removal activities were performed which
included removing and disposing of more than 19,000 drums and 4,000 cubic yards of
contaminated soil; incinerating oil and paint sludge and consolidating the incinerator
ash onsite; and capping the site. Although the removal action reduced the extent of
the contamination, further site studies revealed elevated levels of contamination in
the ash pit area, the landfill, and the
(See Attached Page)
17. Document Anely8l. L De.crlptono
Record of Decision - Hranica Landfill, PA
First Remedial Action
Contaminated Media: soil
Key Contaminants: metals (lead)
b. IdenUfier8lOpen-Ended T erma
Co COSio 11 ReIcIIG,oup
18. Aveilebility Stetement
19. Security Claaa (Thle Report)
None
20. SecurIty Claaa (ThIs Page)
Nnnp-
21. No. of P.ges
61
,
22. PrIce
(See ANSl-Z39.1S)
See /MlTucllona on Rfllfflrae
(Forrn8fty NTI~)
Depal1m8nt 0' Commerce
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EPA/ROD/R03-90/092
Hranica Landfill, PA
~irst Remedial Action
Abstract (Continued)
former drum storage areas. This first operable unit Record of Decision addresses the
soil contamination in the ash pile area and other areas where the lead concentration
exceeds the background range. The primary contaminant of concern affecting the soil is
lead.
The selected remedial action for this site includes repairing the 29,000-square foo~ ash
pile cover, capping other areas where lead contamination exceeds 300 mg/kg; monitoring
ground water and surface water; implementing site access restrictions and institutional
controls including land and ground water use and deed restrictions; and performing a
ground water verification study to determine whether any ground water remediation is
necessary. The estimated present worth cost for this remedial action is $1,037,000,
which includes an annual O&M of $81,450.for.year 0-1 and $30,550 for years 2-30..
PERFORMANCE STANDARDS OR GOALS: By repairing the ash cover and capping the
lead-contaminated areas exceeding lead 300 mg/kg, the remedial action will reduce the
Hazard Index to below the target of 1.
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I
II
RECORD OF DECISION
TABLE OF CONTENTS
PAGE
SITE NAME, DESCRIPTION, AND LOCATION
1
A.
B.
C.
D.
E.
F.
site Name and Location
Site History and Enforcement Activities
Highlights of Community Participation
Scope and Role of Operable Units
site Characteristics
Nature and Extent of Contamination
1
1
3
4
4,
5
SUMMARY OF SITE RISKS
7
III DESCRIPTION OF ALTERNATIVES
IV
V
VI
18
COMPARATIVE ANALYSIS OF ALTERNATIVES
24
DESCRIPTION OF THE SELECTED REMEDY
30
STATUTORY DETERMINATIONS
32
VII RESPONSIVENESS SUMMARY
35
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SUMMARY OF REMEDIAL ALTERNATIVE
SELECTION FOR THE HRANICA LANDFILL SITE
I.
SITE NAME, DESCRIPTION AND LOCATION
A.
site Name and Location
The Hranica Landfill site comprises 15 acres, and is located
approximately 21 miles north of Pittsburgh and just south of the
village of Sarver on Ekastown Road, Buffalo Township, Butler
County, Pennsylvania (Figure 1). The Site was used as a
landfill, drum disposal, and incineration facility.
The site is surrounded by orchards, corn fields, and woodeq
areas. Buffalo Township covers 23.9 square miles and has a
population of approximately 6,600 people. It is estimated that
1,000 people reside within a one-mile radius of the Site, and
4,000 people reside within a two-mile radius. The nearest
offsite, private drinking well is approximately 2,000 feet trom
the site boundary.
B.
site Historv and Enforcement Activities
Between 1966 and 1974, Joseph and William Hranica owned and
operated the facility, which accepted both municipal and
industrial wastes. Initially, the wastes were treated by a
combination of incineration and surface impoundment storage.
Incineration of waste was halted at the request of the Butler
County Health Department in April, 1981. Subsequently, William
Hranica disposed of the liquid waste by direct discharge into
surface impoundments with resultant ground surface and soil cover
infiltration. After five weeks of surface impoundment practices,
contamination was detected in a spring on an adjacent property by
the property owner, John Obringer. The surface impoundments were
abandoned, and the wastes were openly burned in large metal vats.
The residual ash from the incineration was stored in unprotected
piles on the Site, and several drums of unprocessed waste were
staged without further treatment. -
In April 1981, site investigations were performed by a Field
Investigation Team under contract to the u.S. Environmental
Protection Agency (EPA). The results of surface water samples,
including spring discharges and landfill seepage, collected
during the investigation indicated the need for further study. A
Preliminary Investigation at the site conducted by PPG
Industries, Inc. (PPG) confirmed the presence of contamination.
The Site Investigation report indicated that the facility
received paint and solvent wastes from the PPG plant in
Springdale, Pennsylvania, and from the PPG Research and
Development Center in Allison Park, Pennsylvania. The Hranica
facility also received plating wastes, metal sludges, and waste
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FIGURE 1
Taken
TT s xand Cumsville. PA
U.5.G.S. 7.5 Min. Quadransles.
' >G«**' ^-y~^\
4"S^-'/^fe^'
SITE_ACCESS ROAD
it ACCESS ROAD I,
(HRANICADR.) |j
»#
>- V--''-i
- ' )»,- J I'
x~^""i< a
SCALE
I" = 2000'
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3
oils from the Aluminum Company of America (ALCOA) 'facility in
Logans Ferry, Pennsylvania.
The Hranica Site was listed on the EPA's National Priorities
List (NPL) on September 8, 1983. After the Site's inclusion on
the NPL, PPG and ALCOA contracted D'Appolonia Waste Management
Services, Inc. to perform removal activities at the Site. The
removal activities were financed by ALCOA and PPG, and were done
according to a Consent Agreement with PADER. These activities
were 'performed during 1983 and 1984 and involved the removal and
ultimate disposal of more than 19,000 drums and 4,000 cubic yards
of visibly contaminated soil. Three large tanks containing oils
and paint sludges were also emptied, and their contents were.
incinerated at an offsite disposal facility. The incinerator ash
was then consolidated into a 2.5-acre area located at the
southern portion of the site. After these activities were
completed, the site was capped with natural clay, graded, and
revegetated to prevent or minimize infiltration, storm runoff,
and erosion.
Following the co~pletion of these removal activities,
additional testing of the ground water and surface water was
performed by Earth Science Consultants (ESC). The collected data
were summarized by International Technology Corporation (IT) in a
Comprehensive Site Investigation Report, dated January 30, 1987,
revised July 27, 1987. The results of this investigation
indicated contamination was still present at the-'. Site.
Therefore, EPA and PPG entered into a Consent Order on March 13,
1987 requiring that PPG conduct a Comprehensive site
Investigation (deemed to be equivalent to a Remedial
Investigation (RI», an Endangerment Assessment, and a
Feasibility Study for the Site.
On September 10, 1987, PPG contracted Dunn Geoscience
Corporation (DUNN) to prepare a Phase II Comprehensive Site
Investigation (RI) and Endangerment Assessment (EA). An SI/EA
Report was submitted to EPA and PADER in September of 1989.
Based on comments received from EPA and PADER, the SI Report was
revised two separate times and was resubmitted January 15, 1990,
and April 10, 1990. A new EA Report, dated January 1990 was
submitted to EPA and PADER by IT. The EA Report was revised in
accordance with comments received from EPA and PADER and was
resubmitted in April 1990. Finally, a Feasibility Study (FS)
Report, dated February 1990, was submitted to the EPA and PADER
by Remcor, Inc., on behalf of PPG. The FS Report was revised in
accordance with comments received from the EPA and PADER, and it
was resubmitted in May 1990. The RI and FS reports are
considered final once the ROD is signed.
C.
Hiahliahts of Communitv particication
The RI/FS, proposed Plan, and background documentation for
the Hranica Landfill Site were released to the public in May
1990. These documents were made available to the public in the
local information and administrative record repository at the
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
site:
,
Hranica Landfill Site, Buffalo Township, Pennsylvania
Statement of Basis and Purpose
This decision document presents the selected remedial action
for the Hranica Landfill site (the "Site") in Buffalo Township,
Pennsylvania, developed and chosen in accordance with the
Comprehensive Environmental Respc~. " Compensation, and Liability
Act (CERCLA) of 1980, as amended r~ the Superfund Amendments and
Reauthorization Act (SARA) of 1986, and to the extent
practicable, the National Oil and Hazardous Substances
Contingency Plan (NCP), 55 Fed. Reg. 8666-8865 (March 8, 1990)
(to be codified at 40 C.F.R. Part 300). This decision is based
on the Administrative Record for this Site.
The Commonwealth of Pennsylvania, Department of
Environmental Resources has concurred with the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to the public health,
welfare, or the environment.
Description of the Remedv
The primary objective of the selected remedy is to prevent
risk to pUblic health and to the environment through dermal
contact or ingestion of contaminated soils. The selected remedy
addresses the principal threats to human health presently posed
by the Site. Institutional controls will profiibit future
development and potable use of onsite ground water, and use of
the Site in a manner that may permit contact with the
contaminated soils. A fence will be constructed around the
perimeter of the site to prevent unauthorized access. Ground
water and surface water will be monitored on a continuing basis
to determine if any contamination has migrated from the Site, and
to assess any variations in water quality. Repairs will be made
to those portions of the ash pile cap that were disturbed
subsequent to placement of the original cap in 1984. Other areas
of the Site where the levels of lead exceed 300 parts per million
will also be capped with clay.
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2
The cap repair consists of the following major components:
.
Grading and compaction of the existing ground surface.
Placement and compaction of a two-foot thick clay cover.
.
,
.
Dust control during grading and cover placement.
Revegetation of the cover.
.
Long-term monitoring of the cover for erosion and
settlement damage.
A ground water verification study will also be conducted
as part of the selected remedy to determine if any remediation
of the onsite and offsite ground water is required. A
subsequent and final ROD will be prepared that will address
any further remediation that may be required at this Site.
.
Declaration
The selected remedy is protective of human health and the
environment, complies with State and Federal environmental laws
that are applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions to the maximum extent practicable for this Site.
However, treatment as an element of the remedy for the Site was
found to be impracticable: therefore, this remedy does not
satisfy the statutory preference for treatment as a principal
element. .
Because the remedy will result in hazardous substances
remaining onsite above health-based levels, a review will be
conducted no less often than five years after commencement of
remedial action to ensure that the remedy continues to provide
adequate protection of public health and the environment.
~~C/L
~:B. Erickson
~egional Administrator
I
I
,(');1'ft~
v ,
Date
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-1
Buffalo Township Municipal Building, Buffalo Township,
pennsylvania. The notice of availability for these documents was
published in both the Valley Dispatch News and the Butler Eaale
on May 19, 1990. A public comment period was held from May 19,
1990, through June 18, 1990. Additionally, a public meeting was
held at 7:00 P.M. on June 7, 1990, at the Buffalo Township
Municipal Building. At this meeting, representatives from EPA
and PADER answered questions about the Hranica Landfill Site and
the remedial alternatives under consideration. No written
comments were received during the public comment period. The
Responsiveness Summary (page 35) is based on oral comments
received during the public meeting. The above actions satisfy
the requirements of Section 113(k) and 117 of CERCLA, 42 U.S.C.
Sections 9613(k) and 9617. -
D.
Scope and Role of Operable Units
The Hranica Landfill Site has been divided into two operable
units.
-c
1.
Operable unit #1
Operable Unit #1 (OU1) consists of the soils located in the
ash pile area and other areas of the site where the concentration
of lead in the surface soils exceeds 300 parts per million (ppm).
The Site-specific background lead level range is from 9-299 ppm.
OUl consists of the soils where the lead concentration is above
the background range.
The soil areas, defined by Operable Unit #1, pose a threat
to human health and the environment because of the risks
associated with dermal contact or ingestion of these soils. The
purpose of the response authorized by this ROD is to prevent
incidental dermal contact with or ingestion of contaminated
soils.
2.
Operable unit #2
Operable unit #2 (OU2) consists of the onsite and offsite
ground water. A ground water verification study will be
conducted to determine if any remediation of this operable unit
is required. A subsequent ROD will be written that will address
any further remediation that may be required at this Site.
E.
site Characteristics
The 1990 population for Buffalo Township is estimated to be
6,600. The township occupies 23.9 square miles, of which 25% is
under agricultural use. Corn fields border the site to the
north, west, and east, and orchards border the Site to the south.
The Site sits at the end of an east-to-northeast-trending ravine.
A small unnamed tributary of Little Bull Creek discharges
intermittently onsite through this ravine. The flow through the
ravine originates from surface runoff and infiltration/seeps from
the Site. A sub-basin drainage divide is marked by a flat
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I:
;
hilltop'which encircles the ravine except on the northeast. To
the west of the Site, an unnamed tributary of McDowell Run flows
south through a narrow, steep valley. There are no
environmentally-sensitive areas, such as wetlands or parks, in
the immediate vicinity of the Site. Similarly, there are no
endangered species or critical habitats located near this Site.
Ground water flows through the site through three aquifers
contained in three different geological units: (1) The shallow
Morgantown Sandstone aquifer is 15 to 60 feet thick throughout
the site. The shallow aquifer appears to be a perched system
with, limited recharge and storage capacity. The aquifer
discharges through seeps and springs, and because of its low
productivity, it is unlikely to ever be used as a residential
water supply. (2) The Birmingham Shale/Pittsburgh Red Beds
layer is a semi-confined, water-bearing unit at a depth of 70
feet, which flows to the east toward Little Bull Creek, Bull
Creek, and the Allegheny River. This aquifer is also considered
unproductive, and therefore is not likely as a water supply
source. (3) The Saltsburg/Buffalo Sandstone is an apparently
confined aquifer at a depth of 180 feet. The aquifer flows to
the southeast, discharging to the Allegheny River, and provides
ground water to offsite residential wells that are not served by
local water authorities. Although this lower aquifer has not
been classified, it appears to have Class II characteristics,
which means that it could potentially be used as a water supply.
F.
Nature and Extent of contamination
Previous removal activities at the Hranica Landfill Site
resulted in the removal of 19,000 drums and 4,000 cubic yards of
contaminated soils. These actions reduced the extent of
contamination, however, further studies revealed that elevated
levels of organic and inorganic contaminants are still present on
the site. The primary contaminants of concern include: lead,
chromium, cadmium, and polychlorinated biphenyls (PCBs). The
source(s) of contamination have been identified as the ash pit,
landfill, and drum storage area (Figure 2). The volume of
contaminated soil has been estimated to be 219,000 cubic feet
(8,100 cubic yards).
Ground water analyses revealed volatile organic compounds at
elevated levels in the shallow, perched aquifer below the ash pit
area (MW-3S). The compounds included toluene, ethylbenzene,
total xylenes, and 4-methyl-2-pentanone. However, this water
system is not used as a water supply source. Onsite wells in the
deeper aquifers indicate minimal contamination. None of the
ground water samples taken from domestic wells exhibited elevated
levels of site-related compounds. In addition, there is minimal
degradation of the surface water quality in the site area. Based
on available information, it is believed that offsite contaminant
migration in the deep and intermediate aquifer has not occurred
to any significant extent.
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6
. The ground- water verification 'study, which will be done as
part of the remedial design for Operable Unit 11, will, also add
to, and may confirm, the information already accumulated during
the RI/FS about the ground and surface water ,contamination in and
around the site.
o
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7.
II.. SuMMARY Of SITE RISKS
A.
Potential contaminants of Concern
Ground water, surface water, soil gas, surface soil, and
sediments were identified as the media at the site to which human
populations may be exposed. Each of these media were analyzed
for various organic and inorganic constituents. The results of
these analyses were evaluated with respect to toxicity, measured
concentrations, frequency of detection, and potential human
exposure to determine the potential contaminants of concern
(PCOCs) for each media. The following PCOCs were identified for
each media:
Ground Water
Oraanics
Benzene
4-Methyl-2-Pentanone
2-Butanone
Acetone
Naphthalene
soil
oraanics
Toluene
Xylenes (total)
Tetrachloroethylene
Trichloroethylene
1,1,1-Trichloroethane
Naphthalene
Bis (2-ethylhexyl) phthalate
Polychlorinated biphenyls
soil Gas
oraanics
Benzene
Toluene
Xylenes (total)
Inoraanics
Cadmium
Chromium
Lead
Beryllium
Nickel
Inoraanics
Antimony
Arsenic
Barium
Cadmium
Chromium
Lead
Manganese
Mercury
Nickel
Selenium
Zinc
Cyanide
Human exposure to surface water and sediments is not
anticipated, therefore, no PCOCs were identified for these media.
The risk assessment did not take the shallow or intermediate
aquifers into consideration because neither aquifer serves as a
drinking water supply, and future use of the aquifers is
considered ~nlikely because of their low productivity. The
concentrations of the PCOCs used for the risk assessment are
presented in Table 1. The figures are from the Endangerment
Assessment which was produced by IT under a contract from PPG.
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t1
TABLE 1
RISK ASSESSMENT INPUT DATA BY MEDIA, HRANlCA LANDFILL
CONSTITUENT CONCENTRATION
Ground water (mg/l) .
Acetone 0.269
Benzene 0.0155
2-Butanone (MER) 0.0320
4-Methyl-2-Pentanone (MIBK) . 0.0825
Naphthalene 0.0724
Cadmium 0.0217
Bervllium 0.0224
Chromium 0.0998
Lead 0.0658
Nickel 0.245
Soil (Ash Pit Area; mg/kg)b
Antimony 15.24
Arsenic 6.14
Barium 3,035
Cadmium 328.6
Chromium 268.5
Lead 5,398
Man2anese 520.7
Mercury 2.50
Nickel 29.57
Selenium 107.1
Zinc 2,839
Cyanide 2.62
Toluene 0.0096
Xylene. 0.173
Tetrachloroethylene 0.0211
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t";.
TA!LE 1
RISK ASSESSMENT INPUT DATA BY MEDIA, HRANICA LANDFILL (contlnued)
CONSTITUENT CONCENTRATION
Soil (Ash Pit Area; mgj1cg)b (continued)
Trichloroethylene 0.0044
1 l.l-Trichloroethane 0.0061
Na~hthalene 11. 82
Bls(2-ethylhexyl)~hthalate 3.247
PCB (1245/1260) 10.96
SolI (Non-ash Pit Area, mg,lkg)C
... .-. i
Antimony 6.78
Arsenic 6.94
Barium 185.2
Cadmlwa 19.12
Chromium 59.60
Lead 629.7
ManJtanese 759.0
Mercury 1.68
Nickel 23.63
SeleniWl 1. 70
Zinc 591.0
Cyanide 1.26
Toluene 0.0087
Xylene 0.021
Tetrachloroethylene 0.0025
Trichloroethylene 0.0035
1,1 I-Trichloroethane 0.0050
NaDhthalene 0.134
Bi8(2.ethylhexyl)~hthal.te 0.59
PCB (1254/1260) 1.57
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1~
TABLE 1
RISK ASSESSMENT INPUT DATA BY MEDIA, HRANICA LANDFILL (continued)
CONSTI'roENT CONCENTRATION
SoU Gas (ug/l)d
Benzene 1. 81
Toluene 115.5
Xylene (total) 3,637
~round water Wells lD, 2D, 3D, and 4D (duplicates included).
bSoil Borings B5, B9, B1l, and B17 (most surficial sample only -
o to 3.0 feet; duplicates included)
CSoil Borings B2 to 84, B6, B10, B13 to B16, B18 (moat 8urficial
sample only - 0 to 3.0 feet).
dSoil-gas probe samples 1 to 140 (duplicates included).
NOTE:
All concentrations represent 95 percent arithmetic upper
bound limit (data presented in Dunn Geoscience, 1989).
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~
B. . Exposure Assessment
The Hranica Landfill Site was evaluated with respect to
physical characteristics, current and future land use, and
exposed populations to identify potential exposure pathways.
following exposure pathways were identified:
The
Ground Water Pathway
- Water ingestion
- Inhalation of volatilized
- Dermal contact
constituents
Soil Pathwav
- Soil ingestion
- Soil inhalation
- Dermal contact
Soil Gas Pathwav
- Inhalation
Potentially exposed populations were identified and
evaluated to estimate daily intakes of chemicals from
environmental media for both onsite and offsite receptors. The
populations identified include: (1) an offsite child having an
average body weight of 34 kilograms (kg) and an exposure duration
of 18 years: (2) an offsite adult having an average body weight
of 70 kg and an exposure duration of 30 years: (3) an onsite
child having an average body weight of 34 kg and an exposure
duration of 6 years: and (4) an onsite adult having an average
body weight of 70 kg and an exposure duration of 70 years.
C.
Toxicity Assessment
The relationship between the extent of exposure to a
contaminant and the potential for adverse effects was evaluated
during the toxicity assessment process. Cancer potency factors
(CPFs) were identified for potential carcinogenic contaminants,
and reference doses (RfDs) were identified for chemicals
exhibiting noncarcinogenic effects. CPFs and RfDs used for the
toxicity assessment are presented in Table 2.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)-',
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
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.12
TABL! 2
CANCER POTENCY FACTORS AND REFERENCE DOSES
USED IN HRANICA SITE RISK CHARACTERIZATION
CONSTITUENTS (:PF [(mg!kit/day).1 J 8 RfD (mg!kg/day)b REFERENCE C
VOLATILES ORAL INHALATION ORAL INHALATION
(VOC)
Acetone 0.1 1
,
Tetrachloro- 0.051 0.0033 0.01 1
ethylene
Benzene 0.029 0.0292 1
Toluene 0.3 2.0 1
Xylene 2.0 0.3 1
4-Methyl-2- 0.05 0.02 1
Dentanone -=- _.. .
. - .".
2-Butanone 0.05 0.09 1
Trlchloro- 0.011 0.0172 1
ethYlene
1,1,1- 0.09 0.3 1
Trlchloro-
ethane
SEKIVOLATILES (SVOC)
Naphthalene 0.4 1
B18 12- 0.014 0.02 1
ethYLhexyl)
phthalate
PCBs
PCB-1254/1260 7.7 1
METALS -
Antimony 0.0004 1
Arsenic 0.175d 50 0.001 1
BarIum 0.05 0.0001 1
Be ry 111 WI! 8.4 0.005 1
Cadmium 6.1 0.0018 1
~admium 0.0005' 1
I Chromium 41 0.005 1
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l~
TABLE 2
CANCER POTENCY FACTORS AND llEFERENCE DOSES
USED IN HRANICA SITE llISK CHARACTERIZATION (continued)
CONSTITUENTS CPF [(mg!kg/day)"'). llfD (mg!kg/day)1I IlEFERENCE C
ORAL INHALATION ORAL INHALATION
METALS (continued)
Lead 0.00140 2
Manltanese 0.2 0.0003 1
Mercury 0.0003 1 .
Nickel 0.84 0.02 1
Selenium 0.003 0.001 1
Zinc 0.2 1
Cyanide 0.02 1
.CPF - Cancer Potency Factor for carcinogenic effects.
bRfD - Reference do.e for noncarcinogenic effect..
Clleference 1 - Health Effects Assess.ent Summary, U.S. EPA, 1989, 3rd Quarter.
Reference 2 - Derived fro. lifeti.e health advi.ory of 20 ug/day using body
weight - 14 kg (U.S. EPA Drinking Water Health Advi.ory, 1985).
GDerived fro. unit ri.k of 5 x 10~ u&ll U81ng body weight of 70 kg, ingestion
rate of 2 l/day, and benchmark cancer risk of 1 x 10~. A benchmark cancer
risk one order of aagnitude 1e.. conservative than 1 x 10~ i. appropriate for
oral exposure fro. ar.enic due to the uncertainties a..ociated with ingested
inorganic arsenic (IRIS, 1990; Section 1I.B).
-aepresents oral RfD for food for soil ingestion exposure pathway.
'Represents oral RfD for water for water ing.stion exposure pathway.
~e RfD for lead baa been aU8pended because it i. currently believed by the
u. S. EPA that for young children, no exposure to lead 18 acceptable.
Although cancer potency factor. are unavailable a. yet, lead i. considered to
be a Probable Human Carcinogen via the oral and inhalation routes.
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14
Reference doses (RfDs) have been developed by EPA for
indicating the-potential for adverse health effects from exposure
to chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from human.
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects on humans). These uncertainty factors
help, ensure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur.
Risk Characterization
Excess lifetime cancer risks for the Hranica Landfill Site
were determined by multiplying the daily intake of chemicals from
environmental media by the cancer potency factors. These risks
are probabilities expressed in scientific notation (i.e., 1E-6).
An excess lifetime cancer risk of 1E-6 indicates that an
individual has a one in a million chance of developing cancer as
a result of site-related exposure to a carcinogen over a 70-year
lifetime. The EPA recommended upper bound for lifetime cancer
risks is between 1E-4 and 1E-7, however, the point of departure,
as described in the NCP, is considered to be 1E-6. See 40 CFR
300.430.
The estimated excess lifetime cancer risks for each of the
exposure pathways are presented below:
Excosure to Ground Water
POPULATION INGESTION
Offsite Adult 4.1E-7
Offsite Child 2.5E-7
ROUTE OF
DERMAL CONTACT
3.3E-7
1.9E-7
EXPOSURE
INHALATION
1.7E-7
2.8E-7
Excosure to Ash Pile Area Soils
ROUTE OF EXPOSURE
POPULATION INGESTION/DERMAL CONTACT INHALATION
Adult Trespasser 9.8E-6 5.0E-10
Child Trespasser 7.3E-6 2.8E-10
Offsite Adult N/A 1.3E-7
Offsite Child N/A 2.2E-7
Excosures to Non-Ash Pile Area Soils
ROUTE
POPULATION INGESTION/DERMAL CONTACT
Adult Trespasser 1.5E-6
Child Trespasser 1.1E-6
Offsite Adult N/A
Offsite Child N/A
OF EXPOSURE
INHALATION
1.7E-10
9.5E-11
4.6E-8
7.6E-8
TOTAL
9.1E-7
7.3E-7
TOTAL
9.8E-6
7.3E-6
1.3E-7.
2.2E-7
TOTAL
1.5E-6
1.1E-6
4.6E-8
7.6E-8
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~
-
Excosures to Soil Gas
POPULATION
Adult Trespasser
Child Trespasser
Offsite Adult
Offsite Child
ROUTE
INHALATION
5.4E-10
3.0E-10
1.4E-7
2.4E-7
OF EXPOSURE
TOTAL
5.4E-10
3.0E-10
1.4E-7
2.4E-7
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard.
quotient (HQ) (i.e., the ratio of the estimated intake derived
from the contaminant concentration in a given medium to the
contaminant's reference dose). The HQs for all contaminants in a
medium are added to obtain the Hazard Index (HI). The HI
provides a reference point for gauging the significance of
multiple contaminant exposures within a single medium or across
media. A hazard index less than or equal to 1 indicates that
there is no significant risk of adverse health effects.
The HIs derived for each medium are summarized below:
Exposure to Ground Water
POPULATION
Offsite Adult
Offsite Child
INGESTION
2.8E-1
2.9E-1
ROUTE OF
DERMAL CONTACT
4.8E-02
4.7E-2
EXPOSURE
INHALATION
7.6E-4
2.1E-3
TOTAL
3.3E-1
3.4E-1
Excosure to Ash Pile Area Soils
POPULATION
TOTAL
Adult Trespasser
Child Trespasser
Offsite Adult
Offsite Child
ROUTE OF EXPOSURE
INGESTION/DERMAL CONTACT INHALATION
1.2
4.4
N/A
N/A
4.0E-4
1.lE-4
1.0E-1
2.9E-1
1.2
4.4
1.0E-1
2.9E-1
Excosure to Non-Ash Pile Area Soils
ROUTE
POPULATION INGESTION/DERMAL CONTACT
Adult Trespasser 1.4E-1
Child Trespasser 5.2E-1
Offsite Adult N/A
Offsite Child N/A
OF EXPOSURE
INHALATION
5.4E-5
1.5E-4
1.4E-2
3.9E-2
TOTAL
1.4E-1
5.2E-1
1.4E-2
3.9E-2
Excosure to Soil Gas
POPULATION
Adult Trespasser
Child Trespasser
Offsite Adult
Offsite Child
ROUTE
INHALATION
2.9E-4
8.0E-4
7.8E-2
2.2E-1
OF EXPOSURE
TOTAL
2.9E-4
8.0E-4
7.8E-2
2.2E-1
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:!. ...
The results of the estimated excess lifetime cancer risks
and noncarcinogenic hazard indices indicate the primary adverse
health risk posed by the Hranica Landfill site is due to
ingestion and dermal contact with the ash pile area soils for
either an adult or child trespasser. Risk estimates for offsite
exposure to ground water from the deep aquifer and exposures to
soil gas indicate acceptable risks to human health. Cancer risks
for exposure to the non-ash pile areas slightly exceed the target
risk of lE-6, but they are still within the EPA recommended
guidelines. Thus, it is the Hazard Index that justifies a .
remedial action at this Site, not the cancer risk.
Due to the possibility of exposure to multiple media, the
risk estimates have also been summed over the environmental
media. Two risk characteristics have been evaluated including
. exposure to all media except the non-ash pile area soils and
exposure to all media except the ash pile area soils. The
results of this evaluation, presented in Table 3, indicate that
the only significant health hazard posed by the Hranica Landfill
Site is due to exposure to the ash pile area soils.
Actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
selected in the ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
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17
~.
TABLE 3
StJMKARY OF RISK ESTIMATES FOR EXPOSURE TO ALL MEDIA
HRANICA SITE . .
BUFFALO TOWNSHIP. PENNSYLVANIA
VITH EXPOSURE TO ASH PIT AREA CONSTITUENTS.
POPULATION TOTAL LIFETIME CANCEl. RISK TOTAL
NONCARCINOGENIC
, HAZARD INDEX
Adult Trespasser 9.8 xlO. 1.2
Child Trespasser 7.3 x10. 4.4
Off-Site Adult 1.2 x 10. 0.51
Off-Site Child 1. 2 x 10. 0.85
WITH EXPOSURE TO NON-ASH PIT AREA CONSTITUENTS
#~ I
POPULATION TOTAL LIFETIME CANCER. RISK TOTAL
NONCARCINOGENIC
HAZARD INDEX
Adult Trespasser 1.5 x 10. 0.13
Child Trespasser 1. 1 x 10" 0.48
Off-Site Adult 1. 1 x 10" 0.42
Off-Site Child 1.0 x 10. 0.60
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18
;-..
III.
DESCRIPTION OF ALTERNATIVES
A number of remedial alternatives were developed in the FS
to significantly reduce the risk to public health and the
environment from incidental contact with or ingestion of the ash
pile area soil (OU1). The following sections briefly summarize
each of these alternatives. .
Alternative
1 - No Action
Evaluation of the No Action alternative is required by the
National Oil and Hazardous Substances Contingency Plan (NCP).
This alternative serves as a point of reference for comparing all
other alternatives. If other alternatives offer no substantial
advantages over the no action alternative, no action may be
considered appropriate. Total cost for this alternative is $0.
Alternative 2 - Monitorinq. Access Restrictions. and
Institutional Controls
This alternative includes an environmental monitoring
program, access restrictions, and provision of institutional
controls. The monitoring locations would include existing and
proposed monitoring wells, seeps and springs, and surface waters.
The data would aid in the evaluation of contaminant migration
from the Site and variations in water quality. The continued
monitoring program would also evaluate health risk variations of
downgradient receptors.
Institutional controls would prohibit future development and
potable use of onsite ground water and limit unauthorized access
to the Site. Institutional controls would include filing deed
restrictions to prohibit the following:
(1) Development of wells at the Site for use as drinking
water, bathing water, or other domestic uses that would
expose people or animals to the ground water.
(2) Excavation or drilling of any type which may disturb
areas of cover placement or reconstruction, with the
exception of any characterizations which may become
necessary.
(3) Use of the Site that may permit contact with soils
determined by the endangerment assessment to present a
potential unacceptable health risk.
(4) Use of the Site that would allow free public access.
A fence would be constructed around the property boundary to
provide a physical barrier to limit unauthorized access to the
site. The fence would be an eight-foot high chain linked fence,
topped with three strands of barbed wire. This would prevent
access to the ash piles and monitoring wells, preclude future
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12
r,;.~...
site disturbanges or waste dumping, and prevent access by game
animals. Several gates will allow authorized access to the Site.
The capital cost for this alternative is $269,000 and the net
present worth (NPW) cost would be $679,000, assuming 30 years of
operation and maintenance (O&M) at 5% interest.
Alternative 3A - Monitorina. Access Restrictions. Institutional
Controls. ReDairs to the Ash Pile Cover. and CaDDina other Areas
with Lead Contamination .
Alternative 3A includes the same monitoring, institutional
controls, and access restrictions as described in Alternative 2.
In addition, repairs would be made to the ash pile cover that was
disturbed subsequent to its initial placement in 1984, and other
select areas where the concentration of lead exceeds 300 ppm
would be capped. The cap would be constructed to meet the
minimum solid waste landfill closure criteria contained in 25 Pa.
Code Section 75.264 (0) and (v) regarding closure and post-
closure of hazardous waste landfills.
The repair of the cap would require the following:
(1) Grading and compaction of the existing ground surface.
(2) Placement and compaction of a two-foot thick clay cover.
(3) Temporary dust control during grading and cover
placement.
(4) Revegetation of the cover.
(5) Long-term monitoring of the cover for erosion and
settlement damage.
The capital cost for implementing Alternative 3A is
$519,000, and the NPW cost would be $ 1,037,000, assuming 30
years 0 & M at 5% interest.
Alternative 38 - Monitorina. Access Restrictions. Institutional
Controls. ReDairs to the Ash Pile Cover. CapDina other Areas with
Lead contamination. and Increasina the Thickness of the Ash Pile
Cover To Three Feet.
Alternative 3B includes all of the components of Alternative
3A with an additional one foot of clay added to the cap over the
entire ash pile. The additional cap thickness would be
implemented by the same procedure as described in Alternative 3A:
(1) Grading and compacting the existing ground surface.
(2) Placement and compaction of an additional one-foot clay
cover over the entire ash pile area.
(3) Temporary dust control during grading and cover
placement.
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2.0
-
(4) Revegetation of the cover.
(5) Long term monitoring of the cover for erosion or
settlement damage.
The capital cost for implementing 3B would be $668,000 and
the NPW cost would be $1,401,000, assuming 30 years 0 & M at 5%
interest.
Alternative 4 - Monitorinq. Access Restrictions. Institutional
Con~rols. Excavation. and Offsite Disposal of Soil/Waste. and
Cover .
Alternative 4 includes the same monitoring, access .
restrictions, and institutional controls as Alternative 2 with
the addition of excavation and offsite disposal of 9800 cubic
yards of soil/waste materials excavated from the ash pile area.
The excavation of the soil/waste materials would involve the
following: .
(1) Excavation and stockpiling of the top foot of the intact
cover from the ash pile area for use in the final cover.
(2) Excavation, removal, and offsite disposal of the second
foot of the cover over the ash pile area.
(3) Excavation and offsite disposal of ash and soils
contaminated by virtue of their being an admixture of
soil and ash.
(4) Grading and compacting the subgrade surface.
(5) Placement and compaction of a two-foot thick clay cover.
(6) Temporary dust control during grading and cover
placement.
(7) Revegetation of the cover.
(8) Long term monitoring of the cover for erosion or
settlement damage.
The capital cost for implementing Alternative 4 would be
$3,920,000, and the NPW cost would be $4,653,000, assuming 30
years 0 & M at 5% interest.
Alternative 5 - Monitorinq. Access Restrictions. Institutional
Controls. Excavation. and Onsite Disposal
Alternative 5 includes the same monitoring, access
restrictions, and institutional controls discussed in Alternative
2 along with the construction of an onsite landfill, placement of
9800 cubic yards of ash pile area soils in the landfill, closure
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~
of the landfill, and placement of four additional monitoring
wells clusters around the newly constructed landfill. .
The onsite landfill would be constructed in the ash pile
area. This would enable the landfill to be built on a relatively
flat portion of the Site and in an area that would provide an
impermeable barrier over the shallow ground water system. The
landfill would be constructed following PADER and EPA regulations
governing the construction of a hazardous waste landfill. In
addition, four additional monitoring well clusters would be
installed in the shallow and intermediate aquifers at the time of
construction of the landfill. This would provide background and
long term monitoring for the onsite landfill. Preparation,
construction, and disposal in the landfill would include the
following:
(1) Clearing the area.
(2) Excavation and stockpiling of the top foot of the intact
cover from the ash pile area for use in the final cover.
(3) Excavation and stockpiling the second foot of the cover
over the ash pile and the ash pile waste.
(4) Grading and compacting the subgrade surface.
(5) Use of erosion, sediment, and dust control during all
prepara~ion and waste handling activities.
(6) Construction of a liner over the existing subgrade
consisting of a 3-foot thick layer of compacted clay
(permeability of 1 x 10-7 cm/sec or less), a flexible
membrane liner (FML), a leachate collection zone
(permeability of 1 x 10-3 em/sec or greater), and a
geotextile layer.
(7) Placement and compaction of the ash pile soils in
horizontal layers to allow compaction and minimize long
term settlement of the cap.
(8) Placement of a clean soil cover during any interruptions
of work to prevent wind and water erosion.
(9) Construction of a cap having a minimum 5 percent grade
to a maximum 25 percent grade. The cover will consist
of 2-foot thick compacted clay layer (permeability of 1
x 10-7 em/see or less), a FML, a 12-inch thick horizontal
drainage layer, a geotextile layer, and a 2-foot thick
cover of soil seeded with permanent erosion resistant
vegetation.
Surface waters and leachate within the landfill would be
collected, pretreated, and discharged to the publicly owned
treatment works. A sewer line has been funded along Ekastown
Road. If the sewer is in place prior to completion of the
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~
remedial action, a tap-in would be requested. If no sewer were
available, the leachate would be pre-treated, if necessary, and
transported to the Fawn-Frazier publicly owned treatment works.
The capital cost to implement Alternative 5 would be $3,375,000,
and toe NPW cost would be $4,223,000, assuming 30 years 0 & M at
5% interest. - -
Alternative 6 - Monitorina. Access Restrictions. Institutional
Controls. Stabilization (Chemical and Physical}. and Cover
Alternative 6 includes the same monitoring, access
res~rictions, and institutional controls as Alternative 2 with
the addition of chemical and physical stabilization precesses.
total of 9800 cubic yards of soil will be excavated and then
stabilized. The stabilization process would include the
following procedures:
A
(l) The removal and stockpiling of 1 foot of soil from a 25-
foot wide strip across the width of the ash pile.
(2) The removal and stockpiling of the lower foot of the
soil cover and the ash from a 15-foot wide strip across
the width of the ash pile.
(3) Stabilization of the top foot of the natural soil
subgrade using an additive to reduce the solubility
(fixation) of lead and a cementing agent to bond the
soil mass into a cohesive structure.
(4) The removal of a one foot layer from the adjacent
portion of the ash pile and placement over the
stabilized subgrade.
(5) Stabilization and compaction of the material placed on
the subgrade using the fixation and cementing agents.
(6) continued removal of the ash pile soils in ll-foot lifts
until the subgrade is reached.
(7) As each foot of ash pile material is removed, it would
be placed on the previously placed materials,
stabilized, and compacted.
(8) When the subgrade is exposed, it would be stabilized so
that an adjacent section of the ash pile can be removed
and stabilized.
(9) The process would continue until all of the ash pile
soils, including the stockpile, have been stabilized and
compacted.
{lO)The final disposal area would be covered with two feet
of soil and revegetated.
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2_~
'The capita~ cost to implement Alternative 6 would be
$2,060,000, and the total NPW cost would be $2,793,000, assuming
30 years 0 & M at 5 % interest.
Alternative 7 - Monitorina. Access Restrictions. Institutional
Controls. Stabilization (Vitrification). and Cover
Alternative 7 includes the monitoring, access restrictions,
and institutional controls discussed in Alternative 2 with the
addition of in-situ vitrification of the ash pile area soils,
plac~ment of a 2-foot soil cover, and revegetation. A total of
9800 cubic yards of soil will vitrified in this manner.
The vitrification process would involve the following:
(1) Construction of a power line to the site.
(2) The removal and stockpiling of the top foot of soil from
a 30 by 60-foot area of the ash pile.
(3) Installation of four electrodes to a depth of 3 feet
below the ash pile on a 30 by 30-foot square grid
pattern in the cleared area.
(4) Vitrification of the grid for 150 to 500 hours. If
necessary, a layer of graphite would be placed across
the ground surface to initiate the vitrification.
(5) Placement of two additional electrodes to form a second
square grid followed by vitrification of the grid.
(6) Removal of the soil from a third grid, and placement
over the first grid when cool.
(7) The process would continue until the entire ash pile is
stabilized.
(8) Placement of an additional foot of soil over the one-
foot cover placed during the vitrification followed by
revegetation of the soil.
The capital cost to implement this Alternative would be
$10,349,000 and the total NPW cost would be $11,082,000, assuming
30 years 0 & M at 5% interest.
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IV
2..4
COMPARATIVE ANALYSIS OF ALTERNATIVES
EPA evaluated each of the remedial alternatives developed
for the Hranica Landfill Site with respect to nine specific
criteria. The following sections present a brief discussion of
each of the evaluation criteria and a comparative analysis of
each of the remedial alternatives based on the nine evaluation
criteria.
1)
Overall Protection of Human Health and the Environment
. .
This criterion addresses whether a remedial alternative will
adequately protect human health and the environment. The
evaluation criteria should consider: the reduction of risk; any
unacceptable impacts; control of hazards (i.e., toxicity,
mobility); and minimization of short-term impacts.
The primary human health risk associated with the Site is
from onsite dermal contact or incidental ingestion of the ash
pile soils. The excess lifetime cancer risk due to onsite
exposure to the ash pile soils has been estimated to be 9.8E-6,
which is lower than the EPA's recommended upper bound of 1E-4 to
justify a remedial action. However, as Table 3 indicates, the
Hazard Index for a trespasser (either adult or child) is above
the target goal of 1.0. Therefore, the primary goal of the
remedial alternatives is to eliminate or reduce the onsite
exposure to the ash pile soils, in order to reduce the Hazard
Index to below the target of one.
Alternatives 3A, 3B, 4, 5, 6, 7, and to a lesser extent 2,
will all reduce the risk of dermal contact or ingestion of the
ash pile soils. Alternative 4 will eliminate the source of
contamination, provide a permanent solution, and eliminate any
long-term adverse health effects associated with the Site.
Alternatives 6 and 7 will reduce the mobility and toxicity of the
contaminated soil, and will be more protective of human health
than Alternatives 3A, 3B, and 5 in the event of a failure of the
clay cap. Alternatives 4, 5, 6, and 7 will increase the
potential for short-term impacts on human health due to the
disturbance of the ash pile. Alternative 1 does not provide
adequate protection of human health and the environment.
2)
ComDliance with ARARs
This criterion addresses whether or not a remedy will meet
all of the applicable or relevant and appropriate requirements
established by State and Federal environmental laws and/or
provide grounds for invoking a waiver.
A comp~ete listing of all site-related action-, and
location-specific ARARs is presented in Table 4. All of the
alternatives will meet ARARs, and no waivers will be required.
The creation of an onsite landfill or closure of the existing
landfill would have to meet all applicable State and Federal
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25
TA8LE 4
LOCATION-SPECIFIC ARARs
Standard, Requirement,
Criteria, or Limitation Citation
So d Waste Management 25 PA Code
Act .," ',,~~.pter 75
,1\ '''t'.
: :~. I
ACTION-SPECIFIC ARARs
Landfill Closure 25 PA Regulations for Yes/No
and Post-Closure Sections landfill closure
75.264
RCRA Landfill Closure 40 C.F.R. RCRA regulations Yes/No
and Post-Closure Part 264 for landfill closure
and post-closure
Fugitive Dust 25 PA. Control of dust Yes/No
Emissions Code emissions
Section
123.1
Criteria for 40 C.F.R. Establishes criteria Yes/No
Classification of Solid Part 257 for solid waste
Waste Disposal Facilities disposal facilities
and Practices
Generation of Runoff 25 PA Code Water Quality Yes/No
Discharging to Surface Section 93 Criteria
Waters
Clean Water Act 33 U.S.C. Effluent Limitations Yes/No
Sections for Point Source
301 & 402 Discharges
Discussion
Alternative 5. Landfills
may not be permitted in
environmentally-sensitive
areas.
Alternatives
3A, 38, S, 6,
and 7.
Alternatives
3A, 38,5, 6,
and 7.
For Alternatives
involving a cap
(3A, 38, 5, 6, 7)
Alternative 3~, 3B
If runoff is generated,
measures will be taken
to meet these
requirements
Same as Above
-------
:andard, Requirement,
~iteria, or Limitation
~cup~tion Safety and
!al tAct
I azardous Materials
ransportation
egulations
azardous Materials
ransportation
egulations
tandards Applicable
o Generators of
I azardous Waste
I
I
I
I
i tandards Applicable
I 0 Transporters of
azardous Waste
Citation
29 U.S.C.
1910 ,
1926
29 C.F.R.
1910
-49 U.S.C.
1801-1813
49 C.F.R.
Part 107,
171-177
.
40 C.F.R.
Part 262
40 C.F.R.
Part 263
26
Table 4 (continued)
ACTION-SPECIFIC ARARS
Description
App1icab1e/
Relevant and
Appropriate
Yes/No
Regulates workers
health and safety
in industry and
construction.
Health and Safety
standards for
employes engaged
in hazardous waste
operations.
Yes/No
Regulates Trans-
portation of
hazardous materials.
Yes/No
Establishes stand-
ards for generators
of hazardous waste
No/Yes
Establishes standards
which apply to trans-
porters of hazardous
waste within u.s. if
the transportation
No/Yes
Comment
The requirements
of the Act apply
to all response
activities under
the NCP.
Applicable to all
response activities
Only Alternative 4
would involve
transporation of
hazardous materials.
Only Alternative 4
would involve offsite
transportation of
either soil or
source material for
treatment or. disposal.
Only Alternative 4
involves offsite
transportation of
soil or source
material for treat-
ment or disposal.
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").7
regulations' regarding closure and post-closure care of a
landfill. The occupational Health and Safety Act will be
applicable for the protection of worker safety during
implementation of any of the remedial alternatives. The
excavation and offsite disposal alternative would have to meet
Hazardous Materials Transportation regulations. Measures would
be taken to ensure that surface runoff from any of the capping
alternatives meets National Pollution Discharge Elimination
Systems (NPDES) limitations and Federally-approved State Water
Quality Regulations. See 33 U.S.C. Section 402; 40 C.F.R. Part
122 and 25 PA Code 93.
Lonq-Term Effectiveness and Permanence.
This criterion refers to -the ability of a remedy to maintain
reliable protection of human health and the environment over time
once the cleanup goals have been met.
The most effective long-term alternative is Alternative 4,
which provides a permanent solution by eliminating the source of
the contamination. Alternatives 6 and 7 provide a more permanent
solution than the remaining alternatives by reducing the mobility
and toxicity of the contaminant source. Alternatives 3A, 3B, and
5 may require future remediation if the clay cap fails.
Alternatives 1 and 2 do not offer an effective long-term
solution.
4)
Reduction of Toxicitv. Mobility. or Volume throuah Treatment
I'
This criterion addresses the
selecting a remedial alternative
toxicity, mobility, or volume of
treatment.
statutory preference for
that permanently reduces the
the hazardous waste through
Since the primary exposure pathway associated with the
Hranica Landfill Site is the onsite dermal contact or ingestion
of the ash pile soils, Alternatives 3A, 3B, 4, 5, 6, and 7 will
all reduce the mobility of the ash pile soils with respect to the
primary exposure pathway. Alternative 4, excavation with offsite
disposal, would result in the greatest reduction in the toxicity,
mobility and volume of the PCOCs by removing the source.
Alternative 7, vitrification, and Alternative 6, stabilization,
would reduce the toxicity and mobility of the waste to a greater
extent than Alternatives 3A and 3B, however, these alternatives
may increase the volume of the waste. Alternative 5 would limit
dermal contact with the ash pile soils and reduce mobility of the
PCOCs. Alternatives 3A and 3B would limit dermal contact with
the ash pile soils, however, the toxicity and volume of the waste
would not be reduced. Alternatives 1 and 2 would not reduce the
toxicity, mobility, or volume of the waste.
5)
Short-Term Effectiveness
This criterion refers to the length of time required to
achieve protection of human health and the environment, and to
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2~t
any adverse- impacts posed during the implementation of the
remedial alternative.
Alternative 3A would adequately protect human health and the
environment, and could be implemented in approximately 4 months.
This alternative is anticipated to have little or no short-term
effect on the surrounding community or the workers during the
construction phase. Alternatives 3B, 4, 5, 6, and 7 would be
less effective short-term, due to increased construction.
schedules. The disturbance of the ash pile soils may also result
in adverse short-term health impacts. Alternatives 1 and 2 do
not 'provide adequate short-term protection of human health and
the environment.
6)
Implementabilitv
This criterion describes the technical and administrative
feasibility of a remedial alternative, including the availability
of materials and services needed to implement the selected
solution.
All of the alternatives proposed for the Site can be
implemented. The vitrification and solidification alternatives
would be the most difficult to implement because treatability
tests would be required to determine the stability of the
material over time.
7)
Cost
This criterion addresses the capital cost for materials,
equipment, etc. and the 0 , M costs.
Assuming a net present worth (NPW) cost including 30 years
of 0 , M costs, Alternative 7, vitrification, would be the most
expensive alternative to implement with a NPW cost of
$11,082,000. Due to the relatively low risk to human health
posed by the Site, this cost can not be justified. Alternatives
3A and 3B are comparable with a cost of $1,037,000 and
$1,401,000, respectively. However, Alternative 3B does not offer
any significant advantages over Alternative 3A. Therefore,
Alternative 3A is the more cost effective of the two. The NPW
costs for Alternatives 4, 5, and 6 are $4,653,000, $4,223,000,
and $2,793,000, respectively.
EPA has selected Alternative 3A. It offers the most cost-
effective solution, while still providing adequate protection of
human health and the environment.
8)
State Acceptance
This criterion indicates whether, based on its review of the
Remedial Investigation (RI), Feasibility Study (FS), and the
Proposed Plan, the State concurs with, opposes, or has no comment
on the preferred alternative.
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29
. The'PADER has concurred with the selected remedy.
also raised the following concerns:
1. PADER requested that the clay cap, which will be
installed as part of the selected remedy, meet the standards
described in 25 Pa. Code section 75.264 (0) and (v). EPA will
ensure during the remedial design phase that the cap meets those
standards. .
They have
2. PADER also requested that fugitive dust emissions,
would be generated by earth-moving equipment during
implementation of the preferred alternative, be controlled
order to comply with 25 Pa Code Sections 123.1 and 123.2.
control is part of the selected remedy and will be done to
with these regulations. .
which
in
Dust
comply
3. PADER also suggested that the municipal portion of the
Site be closed according to the state municipal closure
regulations as part of this Superfund action (25 Pa. Code
sections 273.221, 273.322 and 273.334). The municipal portion of
the Site does not present a risk to human health or the
environment; remediation of this area is not part of the selected
remedy. Accordingly, this area cannot be closed according to
state regulations using Superfund monies. The closure of that
portion of the Site is not part of the selected remedy.
9)
Communitv AcceDtance
This criterion assesses the public comments received on the
RI, FS, and the Proposed Plan.
Community interest is low at this site. A public meeting
was held on June 7, 1990, at the Buffalo Township Municipal
Building. This meeting lasted approximately one hour, and the
members of the public in attendance were able to have all of
their questions about the Site answered. No written comments
were received during the public comment period.
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v.
39
DESCRIPTION OF THE SELECTED REMEDY
Based upon considerations of the requirements of CERCLA and
on the detailed evaluation of the alternatives, EPA has
determined that Alternative 3A - Monitoring, Institutional
Controls, Repairs to the Ash Pile Cover, and Capping Other Areas
with Lead Contamination is the most appropriate remedy for the
Hranica Site in Buffalo Township, Pennsylvania.
This alternative will include a monitoring program using
exi~ting and proposed monitoring locations, seeps and springs,
and surface waters. The data will assist in the evaluation of
contaminant migration from the Site and variations in water
quality. The continued monitoring program will also evaluate
health risk variations of downgradient receptors.
Institutional controls will prohibit future development and
p~table use of site ground water and limit unauthorized access to
the Site. Deed restrictions will be filed to prohibit the
following: development of onsite wells for drinking water,
bathing water, or other domestic uses: excavation or drilling
which may disturb covered or reconstructed areas, except when
future characterizations become necessary: and use of the site
that may permit contact with soils that may present a potential
health risk.
A fence will be constructed around the property boundary to
limit unauthorized access. The fence will be an eight-foot high,
chain linked fence, topped with three strands of barbed wire.
This would prevent access to the ash piles and monitoring wells,
preclude future site disturbances or waste dumping, and prevent
access by game animals. Several gates will allow authorized
access to the site.
Repairs will be made to a 29,000 square-foot area of the ash
pile cover that was disturbed subsequent to its initial placement
in 1984. In addition, other areas on the site where the lead
contamination exceeds 300 ppm will also be capped. The procedure
will consist of grading and compacting the existing ground .
surface, placement and compaction of a cover, temporary dust
control during grading and cover placement, revegetation of the
cover, and long-term monitoring of the cover for erosion and
settlement damage. The cap will be designed to meet state
regulations concerning closure and post-closure care of hazardous
waste landfills.
A ground water verification study will also be performed to
determine whether any remediation of ground water, both onsite or
offsite that is not being addressed in the selected remedy, is
required. A subsequent ROD will be written that will address any
further remediation that may be required at this Site.
The rationale for selection of this alternative is based on
four factors. First, the drums and contaminated soil removed in
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31
I .
in .1983~1984 g+eatly reduced the human cancer risk to an
estimated 9.8E-6. Because of this removal, the most contaminated
soils have already been disposed of offsite, and the health risk
is low. Second, the primary human health risk presented by the
site is to trespassers from incidental ingestion or dermal
contact with contaminated soil in the ash pile area, mainly due
to the elevated levels of lead. Third, the Hazard Index of the
onsite soils is greater than 1.0, so there is justification for a
remedial action to reduce the Hazard Index. Finally, the.
selected remedy offers the most cost-effective solution while
still providing adequate protection of human health and the
environment. . .
Cost Estimate for Alternative 3A
Capital Costs
Work Plan
General Site Work
Monitoring Well Installation
Sampling and Analysis
Institutional Controls
Deed Restrictions
Fencing 4500
Reconstruction of Disturbed
Cover and Covering of Other
Areas with Lead Contamination
Exceeding 300 ppm
ft @ $18.89/ft
$ 49,000
$ 136,000
$ 36,000
$ 77,000
$ 4,000
$ 85,000
35 @ $2,200
Total Capital Costs
s
$
132.000
519,000
ODeration and Maintenance Costs
Year 1
13 Quarterly Samples (TCL)
Sampling (2 Technicians)
Reporting
Maintenance
Years 2 throuah 30
13 Semiannual Samples
Sampling.
Reporting
Maintenance
(TCL Metals and VOC's)
$ 63,400
$ 2,350
$ 1,700
S. 14.000
$ 81,450
$ 12,500
$ 2,350
$ 1,700
S 14.000
$ 30,550
$ 518,000
$1,037,000
Total 0 & M Costs for Year 1
Total 0 & M Costs for Years 2 through 30
NPW of 0 & M Costs for 30 Years
(assuming 5% interest rate)
Total NPW of Alternative No. 3A
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32
VI.
STATUTORY_DETERMINATIONS
EPA's primary responsibility at Superfund sites is to
implement remedial actions that are protective of human health
and the environment. Section 121 of CERCLA also establishes
several other statutory requirements and preferences. The
selected remedy must be cost effective and utilize a permanent
solution to the maximum extent practicable. The selected.
remedial action must comply with all applicable or relevant and
appropriate requirements set forth by State and Federal .
environmental regulations, unless such requirements are waived in
accordance with CERCLA Section 121. Finally, EPA must consider
the statutory preference for remedial actions that permanently
reduce the toxicity, mobility, and volume of the site-related .
wastes. The following sections discuss how the selected remedy
meets the statutory requirements and preferences set forth by
Section 121 of CERCLA.
Protection of Human Health and the Environment
The risk assessment identified dermal contact or incidental
ingestion of the ash pile soils as the only significant exposure
pathway having an adverse effect on human health or the
environment. The selected remedy would protect human health and
the environment by eliminating direct contact with the ash pile
soils through access restrictions and placement of a two-foot
clay cap over the contaminated soils. Additionally,
implementation of this alternative is not anticipated to result
in any adverse short-term risks or cross-media impacts.
Comcliance With Acclicable or Relevant and Accrocriate
Reauirements
The selected remedial action will comply with all applicable
or ":elevant and appropriate location-, action-, and chemical-
specific requirements (ARARs). A complete listing of ARARs
developed during the comparative analysis of alternatives is
presented in Table 4, the ARARs specific to the selected remedy
are presented below.
.
Chemical-specific ARARs:
None
.
Location-specific ARARs:
None
.
Action-specific ARARs:
40 CFR Part 264 - RCRA Closure and
requirements are applicable when a
landfill is being capped.
25 PA Code 75.264 (0) and (v) - PADER Landfill
regulations are relevant and appropriate for
this remedy.
Post-Closure
hazardous waste
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33
25 PA Code 123.1 - PADER regulations regarding
control of dust emissions are applicable to this
remedy.
29 C.F.R. Parts 1910 and 1926, Occupational Health
and Safety Act requirements are applicable to all
response activities. .
Cost Effectiveness
The selected remedy is cost effective because it has been
determined to eliminate the primary exposure pathway; it is
protective of human health and the environment; and has excellent
short-term effectiveness proportional to its cost. The estimated
capital cost for this alternative is $519,000, with a net present
worth cost including 30 years of operation and maintenance of
$1,037,000. The selected remedy provides a level of protection
of human health comparable to that provided by the other
remedies, but at a significantly reduced cost. Although other
remedies may be more effective in the long-term, the Site-related
risks do not justify the additional capital expenditure.
Utilization of Permanent Solutions to the Maximum Extent
Practicable
EPA has determined that the selected remedy represents the
maximum extent to which permanent treatment technologies can be
utilized in a cost effective manner for the Hranica Landfill
Site. Of those alternatives that are protective of human health
and the environment and comply with ARARs, the EPA has determined
that the selected remedy provides the best balance in terms of
short-term effectiveness; implementability; cost; reduction in
toxicity, mobility, and volume; and long-term effectiveness.
The selected remedy does not offer as high a degree of long-
term effectiveness as the offsite disposal or stabilization
alternatives, however, it will significantly reduce the risks to
human health posed by the ash pile soils. The excess human
cancer risk at the Site has been estimated to be 9.8E-6, which is
lower than EPA's recommended upper bound of 1E-4 to 1E-7. Due to
the relatively low risk associated with the Site, EPA has
determined that the use of more costly treatment technologies at
the Hranica Landfill Site are not justifiable. Because all the
remedial alternatives, with the exception of Alternatives 1 and
2, offer a comparable level of protection of human health and the
environment, the EPA has selected Alternative 3A, which can be
implemented quickly; will have little or no adverse effects on
the surrounding community; and will cost considerably less than
the other alternatives.
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34
Preference for Treatment as a Princical Element
The statutory preference for remedial alternatives that
employ treatment as the principal element has been determined by
the EPA to be impracticable at the Hranica Landfill Site. Due to
the relatively low risk to human health, the unproductive nature
of the upper aquifers, and the nature and extent of
contamination, the EPA has determined that Alternative 3A,
including monitoring, access restrictions, institutional
controls, and repair of the ash pile cap, can be implemented more
quickly and cost effectively than the other alternatives while
still providing an adequate level of protection to human health
and the environment.
Documentation of Sianificant Chahaes
The preferred alternative originally selected in the
Proposed Plan is also the preferred alternative identified in the
ROD. There have been no significant changes made to the selected
remedy in the time period between the issuance of the
Proposed Plan on May 18, 1990 and the signing of the ROD
approximately six weeks later.
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35
RESPONSIVENESS SUHKARY
HRANICA LANDFILL SITE
BUFFALO TOWNSHIP
BUTLER COUNTY PENNSYLVANIA
JUNE 1990
This community relations responsiveness summary is divided into the
following sections:
Section A:
Section B:
section C:
Section D:
Overview - A discussion of the EPA' s preferred
remedial action alternative and public reaction to
this alternative.
Backqround of Communitv Involvement and Concerns -
A brief history of the community's interest in and
involvement with the Hranica Landfill Site,
including a discussion of concerns raised by
communi ty members and officials during remedial
planning activities.
SummarY of Public Comments Received Durinq the
Public Comment Period and Aqencv ResDonses - A
summary of comments followed by EPA responses.
Remaininq Concerns - A description of remaining
community concerns that should be considered as the
EPA and the Pennsylvania Department of Environment
Resources (PADER) conduct the Remedial Design and
Remedial Action at the Hranica Landfill Site.
In addition to sections A through D, a list of EPA community
relations activities conducted at the Hranica Landfill site is
included as Attachment A of this responsiveness summary.
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36
A.
OVERVIEW
The Remedial Investigation and Feasibility study (RIfFS) reports
and the Proposed Remedial Action Plan were released to the public
for review and comment on June 18, 1990. This marked the opening
of the public comment period on the alternatives detailed in the
Proposed Plan. EPA identified its preferred remedial alternative
in the public notice.
The preferred alternative was described in detail iri Section 3.3.3
of the FS report as Alternative 3A. As proposed, Alternative 3A
includes the construction of a fence limiting unauthorized access
to the Site: deed restrictions on the property to prevent
development of onsite water as a source of drinking water and
prevent drilling into the placement cover: establishment of a
monitoring program for wells, seeps and surface water; and the
placement and compaction of a two-foot clay cover on the areas
where the ash pile cover has been disturbed, or where surface soils
have levels of lead greater than background (300 parts per
million).
Comments received from the public suggest that the area residents
do not object to the preferred alternative. However, there is
continued concern that the preferred remedial action does not
address the possibility of contaminated ground water migrating
offsite. EPA has included monitoring of residential wells in the
ground water verification study to address this concern.
B.
BACKGROtJND OP COMMUNITY IHVOLVBHBNT AIf1) CONCERNS
The Hranica Landfill site history dates back to 1957. Between 1957
and 1960 the Hranica Landfill was used as a disposal area for
industrial wastes, and between 1960 and 1973 industrial waste was
burned at the Site.
Public attention was first focused on the site in the late 1~60's
when contamination of springs on an adjacent farm was attributed
to the disposal of waste liquids at the Hranica Landfill.
A preliminary assessment of the site by EPA was conducted in April,
1981 and the results of the Hazard Ranking system (RRS) ranked the
Hranica Landfill site for inclusion on the National Priorities
List.
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37
On May 9, 1983, local residents met with representatives of PADER,
PPG Industries, Inc., Alcoa, and D'Appolonia to discuss removal
actions planned for the site. In addition, an executive meeting
with municipal, county, state, and federal officials was conducted
by PADER to discuss the removal actions.
At a meeting held on December 17, 1984 between PADER and the
Buffalo Township Board of supervisors, the Township expressed the
need for an investigation of health related impacts, and a formal
request by the Township for a cancer study was made on December 27,
1984. In July, 1985, after analyzing cancer mortality data from
the Pennsylvania vital statistics system for Buffalo Township and
Bulter County, the Pennsylvania Department of Health concluded that
no substantial evidence of aberrant cancer mortality levels or
patterns were detected in the data and the data did not indicate
a need for further study or analysis.
Concerns expressed by the community during telephone interviews
conducted to prepare the Community Relations Plan in 1988 included
the following:
1.
Ground water and subsurface water contamination was
present at the Hranica Landfill site and needed to be
addressed.
2.
Potential carcinogenic effects of the site may lead to
health problems for long-term residents of the area.
3.
The results of surface water sampling
conflicting and citizens are puzzled.
have
been
4.
Lack of knowledge of the Superfund process and the long
schedule for implementing the necessary investigations
and subsequent remedial actions to correct the problem.
Public comments received at the public meeting held on June 7,
1990, on the remedial alternatives detailed in the FS focused on
ground water contamination, individual contact with contaminated
soil onsite and definition of organic and inorganic compounds.
C.
SUMMARY OP PUBLIC COMMENTS
1. One commentor questioned whether the preferred al terna ti ve
includes a deed restriction and, if so, what the deed restriction
encompasses.
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EPA Response:
38
The preferred alternative includes a deed
restriction prohibiting any construction on the Site
that would damage the landfill cap. This includes
construction of any buildings or wells.
2. One commentor asked the significance of dichloroethylene,
trichloroethylene, dichloropropane and benzene in the ground water
and offsite surface water.
EPA Response:
All of the chemicals listed are organic chemicals,
meaning they contain carbon in their structure.
Trichloroethylene and benzene are considered
hazardous if a person is exposed to them. In order
for these chemicals to be hazardous to human health,
however, a pathway must exist for human
contact/exposure.
The ground water containing those chemicals was from
the onsite monitoring wells. Local people do not
drink that water, nor are they exposed to it. Based
on ground water modeling studies, there is no
indication that those chemicals will migrate from
the Site in concentrations significant enough to
adversely impact residents.
The surface water associated with the Site is a few
intermittent tributaries, with which humans or
aquatic life are unlikely to come in contact.
3. A commentor asked if those chemicals were found in residential
wells.
EPA Response:
EPA did sample residential wells. Laboratory
problems, however, caused EPA to disregard the
samples. Although testing indicated that no
contamination exists, EPA chose to perform modeling
assessments. Those assessments were based on the
concentration of contaminants on the Site, or in
ground water on the site. The results did not
predict significant contamination at nearby homes.
At least one more round of residential sampling will
be included in future ground water testing to verify
the modeling results.
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1
I
39
4.
One commentor questioned how long water testing will continue
EPA ReSDonse:.
Operation and maintenance (0 & M) for the Hranica
Site is scheduled for 30 years. EPA' s water
sampling will continue to ensure that contamination
in ground water wells is not increasing, and to
monitor improvement. .
5. One commentor asked if the EPA sampled water at the Obringer
spring on a neighboring farm.. .
EPA ResDonse:
The Obringer spring was sampled. At one time " the
spring on that farm was contaminated, but it no
longer is.
6. A commentor questioned how the EPA could be sure that the
Obringer spring would not be contaminated again, years from now.
EPA ReSDonse:
EPA has removed the source of the contamination, the
drums of hazardous wastes.
7 . One commentor indicated concern for a deep crevice in the
bedrock at the Hranica Site that may have led to contamination of
the Obringer property.
EPA ReSDonse:
EPA was unable to locate the crevice. The ground
water studies performed included a fracture trace
analysis to identify fractures and resultant
contamination. Thus far, no significant offsite
contamination has been detected, but further studies
will continue.
8 . A commentor asked what the cost of 0 & M will be and suggested
that the money would be better spent extending the city's water
lines to serve the Hranica area residents.
EPA ReSDonse:
Many people living around the site do not use ground
water as their water supply. Those people are
supplied with public water. The area beyond the
site that is not on public water is in the opposite
direction of the ground water flow. It is unlikely
that this water is contaminated.
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40
9. A commentor asked in what way the EPA will prevent human
exposure to the contaminated soil, and what area of the site would
be capped.
EPA Response:
...
The cap currently covering the site is two feet
thick. Parts of the cap have been disturbed and
those exposed soils which show contamination will
be re-capped. Approximately 1-2 acres of the site
in total will be re-capped. Further sampling will
ensure that no contaminated soil will be left
uncovered, and the site will be fenced off to
discourage trespassing.
10. A commentor asked what remedial activity had taken place on
wooded areas of the property.
EPA Response:
All hazardous waste was removed from that area of
the Site. A few cars remain there, as well, as a
5,000 gallon tank. The tank does not, however,
contain any hazardous waste.
D.
REMAINING CONCERNS
The one issue or concern expressed during the public comment period
that EPA was not able to address by the preferred remedial action
is the concern that cleanup of ground water contamination will not
be included in the remedy. Citizens are concerned that
contaminated ground water will migrate offsite and area residents
will be exposed to contaminated ground water.
EPA does propose well monitoring to detect migration of
contaminants and a water verification study to confirm results of
the feasibility study.
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. 0
41
ATTACHMENT A
community Relations Activities Conducted
at the Branica Landfill site
o
A public meeting to discuss removal actions scheduled to take
place at the site in July was held in May 1983.
, Community interviews were held and a Community Relations Plan
was formulated in November 1986.
o
o
A press release announced a public meeting and the Consent
Order to conduct the Remedial Investigation/Feasibility Study
(RI/FS) in March 1987.
An informational public meeting to discuss the Consent Order
to conduct the RI/FS was held on March 13, 1987.
o
A public notice in two local newspapers announced the
availability of the RI/FS reports and the Proposed Remedial
Action Plan at the local information repository on May 18,
1990. It also announced the opening of the comment period on
the alternatives detailed in the Proposed Plan and the public
meeting scheduled for June 7, 1990.
A fact sheet summarizing the Proposed Plan and EPA's preferred
alternative was made available to the public in June 1990.
o
o
A public meeting to receive comments on the alternatives
detailed in the Proposed Plan was held on June 7, 1990.
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"
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
June 29, 1990
717-787-5028
Mr. Edwin B. Erickson
Regional Administrator
US,EPA, Region III
841 Chestnut Building
Philadelphia, PA 19107
Re:
Hranica Superfund Site
Record of Decision (ROD) Concurrence
Dear Mr. Erickson:
The Record of Decision (as received June 14, 1990 and
revised June 29, 1990) for the Hranica site, has been reviewed by
the Department. It is my understanding that this Record of
Decision will be submitted to you for your approval.
The proposed remedy for this operable unit, as
revised on June 29, 1990, would include:
I
1. Install a cap over the ash pile and associated areas
where lead contamination exceeds a concentration of
300 ppm. The cap would meet the closure
requirements of Pennsylvania's hazardous waste
regulations (25 PA Code Section 75.264).
2. Conduct a groundwater verification study to
determine whether any groundwater or source
remediation is required. The determination
whether any further remediation is required
addressed as a separate operable unit in a
subsequent ROD.
3. Implement institutional controls to prohibit contact
with any contaminated soils and prohibit use and
development of contaminated groundwater.
control
of
will be
I hereby concur with the EPA's proposed remedy, with the
following conditions:
*
EPA will assure that the Department is provided an
opportunity to fully participate in any negotiations
with responsible parties.
*
The Department will be given the opportunity to concur
Wi~l decisions related to the design of the remedial
ac~. .on, to assure compliance with DER design specific
AIU .s.
-------
Mr. Edwin B. Erickson
Regional Administrator
- 2 -
June 29, 1989
*
The-Department's position is that its design standards
are ARARs pursuant to SARA Section 121, and we will
reserve our right to enforce those design standards.
The Department will reserve our right and responsibility
to take independent enforcement actions pursuant to
state and federal law.
*
*
This concurrence with the selected remedial action is
not intended to provide any assurances pursuant to SARA
Section 104(c)(3).
If you have any questions regarding this matter please
do not hesitate to contact me.
SinCerelY~
~Clel1an ~
Deputy Secretary
Environmental Protection
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